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Home My WebLink About01-05743Spear & Hoffman, P.A. BY: BONNIE DAHL, ESQUIRE Attorney LD. No. 79294 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No. 5944629665 FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 PLAINTIFF, vs. LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DocKET No. OI -- .57Y3 ~~v ~ C~Tf2n-~ COMPLAINT -CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717) 249-3166 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted time veinte (20) dias de plazo a partir de la fecha de la demanda y la notification. Hate falta asentar una com..parencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandadas en contra de supersona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notification. Ademas, la Corte puede decidir a favor del demandato y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros dereches importantes para usted. LLEVE ESTA DEMANDA A UNABOGADOINMEDIATAMENTE, SINO T1ENE ABOGADO O SINO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DII2ECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIAL LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717)249-3166 Spear & Hoffman, P.A. BY: BONNIE DAHL, ESQUIIZE Attorney LD. No. 79294 1020 North Kings Highway, Suite 210 Cherry Hill, New Jersey 08034 (856) 755-1560, Attorney for Plaintiff, Loan No. FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 PLAINTIFF, vs. LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17.055 DEFENDANTS 5944629665 COURT OF COMMON PLEAS CUMBERLAND COUNTY /~. r ~7-' DOCKETNO. Ol - S7Y.3 l:tU~l. `~-t''"\. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is FANNIE MAE, with its principal place of business located at P.O. BOX 1093 NORTHRIDGE, CA 91323-1093. 2. The names and last lmown addresses of the Defendants are: LYNDA H. SUMMERS, 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055. 3. The iriterest of each individual Defendant is as mortgagor, real owner of the real property subject to the mortgage described below, or both. 4. On or about AUGUST 26, 1999, Mortgagors made, executed and delivered a Mortgage upon the premises hereinafter described to NORTH AMERICAN MORTGAGE COMPANY, which Mortgage is recorded as follows: Office of the Recorder of Deeds in and for CUMBERLAND COUNTY DATE OF MORTGAGE: AUGUST 26, 1999 DATE RECORDED: SEPTEMBER 14, 1999 BOOK: 1570. PAGE: 423 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. 1019(g). A true and correct copy of said Mortgage is attached hereto as Exhibit "A" and incorporated herein by reference. 5. On or about AUGUST 26, 1999, in consideration of their indebtedness to NORTH AMERICANMORTGAGECOMPANY, LYNDAH.SUMMERS made, executed and deliveredto NORTH AMERICAN MORTGAGE COMPANY their promissory Note in the original principal amount of $116,800.00. The Note is referenced herein only insofar as the terms of the Note are incorporated into the Mortgage. 6. Plaintiff is the legal holder of the Mortgage by virhre of being either the original Mortgagee, the legal successor in inter ;st to the original Mortgagee, or the present holder of the Mortgage by virtue of the following assignments: ASSIGNOR: NORTH AMERICAN MORTGAGE COMPANY ASSIGNEE: PNC MORTGAGE CORPORATION OF AMERICA DATE OF ASSIGNMENT: MAY 1, 2001 RECORDING DATE: MAY 1, 2001 BOOK: 673 PAGE: 582 7. The Mortgage is secured by property located at 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055, which is more particularly described in the legal description attached hereto as Exhibit "B" and incorporated herein by reference. 8. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, due OS/Ol/O1 and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become immediately due and payable forthwith together with late charges, escrow deficit (if any), and costs of collection including title search fees and reasonable attorney's fees. 9. The following amounts are due on the Mortgage: Principal Balance $115,466.95 8.52% interest from 04/01/01 to SEPTEMBER 25, 2001 at $26.95 per day $4,797.10 Accrued Late Charges $252.50 Other Fees $15.60 Attorney's Fees 2 829.50 TOTAL AMOUNT DUE $123,361.65 2 Interest continues to accrue at the per diem rate of $26.95 for every day after SEPTEMBER 25, 2001 that the debt remains unpaid. 10. During the course of this litigation costs may continue to accrue, including but not limited to escrow advances, late charges, attorney's fees, etc. 1 I. The original principal balance of the Mortgage is in excess of $50,000.00 and therefore, Notice of Intention to Foreclose Mortgage, pursuant to Act 6, 41 P.S. §403 is not applicable. 12. Pursuant to the notice provisions of Act 91, 35 P.S. §1680.403(c), notice was sent to Defendants, dated JULY 3, 2001. Defendants have failed to meet with the plaintiff or any of the consumer credit counseling agencies listed in the notice and/or have further failed to meet the time limitations specified in the notice and/or have been denied assistance from the Pennsylvania Housing Finance Agency. 13. Notice pursuant to the Fair Debt Collection Practices Act is attached as Exhibit "C". WHEREFORE, Plaintiff respectfully requests this Court to enter judgment IN REM in favor of Plaintiff and against the within named property of the Defendants in the amount set forth in paragraph 9, together with interest accruing after SEPTEMBER 25, 2001 to the date of Judgment, plus 6% legal rate of interest from date of Judgment to Final Sale, and Sheriff Sale costs, together with all costs of suit and any money hereafter expended by.the Plaintiff in payment of taxes, sewer and water rents, claims or charges for insurance or repairs and any and all other advances hereafter made by the Plaintiff as stated in paragraph 10, pursuant to the rights andprivileges granted under the terms ofthe subject mortgage, and for foreclosure and sale of the Mortgaged property. SPEAR & HOFFMAN, P.A. DATE: ~ D ~G~/ BONNIE DAHL, ESQUIRE 3 VERIFICATION I, BONNIE L. DAHL, verify that I am the attorney for the plaintiff in this action and that the foregoing Complaint in Mortgage Foreclosure is true and correct to the best of my knowledge, information and belief. I make this verification in lieu of FANNIE MAE, who is outside the jurisdiction of the court and its verification could not be obtained within the time allowed for filing this pleading. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. L (p DAT ~/ ~ ~v'~ BONNIE L. DAHL Attorney for Plaintiff 09!21/2001 14:36 2311505 PgGE 05 _... ~ LTn..' .. i I I Fmr..l. I.y vv~a FI I Sw..+P mom' ~ C.p.,, \..~„ 315 ~ N34dj3 CP.4.-./hD.ly-~ P /, roe,.::-:. r-.~.eR Nxlu~gewRDED whL ro: piCOiEC~: Uf G~ fiD5 x6gtx NI¢R ICPB MOgiDAx cgnpaxv pUl,eEi L4f9 CBUt~TYJ :. °. 80N 888091 ; ¢i9lU1M, DA Ba°1e-9081 Plw. Rev¢R w Bs6 '99 9EP 14 PPI i 39 Mrcel Numbe I _0°~ fBgm Ym~bp One Per YewntnB Dd\1- "°° MORTGAGE I ^' i fi60601s-668 Tfi1EAEGRTGA08('Eavrity lpuum6nt'IiB Aran on dU6msT le, I11/9 .iDY mnppgm ie LYND0. N. 9UAIEPB I (~BMrowm"). Thibdecuri\ylplNmMEle glvMb NpgTM PMER !DUI wgibNE COMPANY • • whkfi lBOYgwlud cad eEialinBVMer Nei6w9 of OELMdPf I read ahnrz I, Bddrmsie ]fiBa AIFN0.Y Oq IVl. BAxYA POBA. BP 86002 1'IalEU'). $nir~wm cam Lfilba she prlMpM Nm 0( ONE MJNOREO 91N1e[N TNOV9AN0 EIONT NDXOPFfi AN0 o0n00 iJnllen (Vb.E ~IIO,IDO.DO ). Titie debt uavldMUd by BOlrowre 9oudPUd Bhe omedero mthb5mwiry hutrumml (eNou'); which pNVibe IDf mOndlly pBYmMm, wish tb full dn[rry (tot pud urlim, dm and p6phl6w BEPTFk8E11 D I Z81a . Thi9 $ecurily InmNmMl TCYg01 lb I.Mdx. 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I. .'`v` a WIBNAT. yip~/yyHMV., rainy mm~a BIStlNN IMn Fm6oekrBb4VX6 rn~ /t•//drf(1{ g~' xP er m .. ~• .~.. ,. egdg157Ut~Et .428 yx goa+ vta 09/21/2001 14:38 2311505,_ ~ t _, .:«, • LEGAL DESCRIPTION - :t, ALL ehai wRaln Yie0e br pmeel of lead, vieuvpe SX Ch 4ewehip at oppm Ailm, Cwney a1 ilodhbrlabd aM 9esee OG vvnruylvema, pore clwlvsly Aemded abd deeophned m tollwu HHpiW3HB at ~~. poine w cha Xmcam lino Of appalPetllY Avawe a[ !lu swehern 31m et Lee Xe. li, sa sh0aa w ehe NrainafkXi mentioned 9 eE l.ota: cAmpe vlwp W eweham liAC et GO! m. ii Mrth 16 dapLeeD 16 minueeb Nee[ Cw tluvd[etl nmey 11101 Lent [e d petnc, ebmw Boeih a droa00e fi Xiweev xeb XERety IDD) Leec ee a pnfnc: Rmw aleeH;che XwrtACtb line e[ ine W. 36 w epid pl 6vueh a6 drocvve 16 edpukee Xmt Onc Xmyee nency 11101 Lpct to AppalaeAlm Pwnh : khemm almg the Nealew 11Y o4 Appalaveim Avewa 1roRh 13 droceee bd m1AU[ee e[ aieety (901 Stet !p !Fn plate bE BpD1%dIXX. Hp3pp Inc XD: 31. Plm of Sechlon i, Xc. oleo Neiphte: anid v1An bPim reawdvd Sn [he dtLlw pt Che Reaeedei of Gay in mB tai Cumbe[1' Cemcy fa DSm Hoek 11, pope 16, gAACXL Rb. D1•iB•i1g1-10 pD ppsAyY ADMRDB: SDi APPA4CNSAN AVppR, 1O11up1CDXHh i PA 31055 ' 88 PAGE 11 hggt~,57O6ax A29 tl9/21/2tl01 14:38 2311505 , PAGE 14 ~ . ._.. y,r'. _. LEGAT. DESCRIPT'!ON ~„ ... . ALL that oertain pd.ece er parcel of laLd, aieuate it County o£ Clvaherldad sad Heats of Peaneylvanla, moxtF doscrib¢d ae falloba: HBG1NNlm0 at a poinnt ea,eha me¢tern lice of Ayyalao4 of S,Ot No. 31, a6 ~6hama ail the-her¢inaftar mentlanek southern Sine cE Got No. i2 Nord. 75 degrees 16 mink £eet La a poiatj thence South l3 degrees 44 miautea~ thence along the morthexa line of Lot mo. 39 on saitl 8aat One 8undred 9meaty (],70) feet to Appalachian Ak lids of Agpnlachiaa Avenue North 13 degrees 94 mina! plaoa of lYE4i4ININC. 881NG Let No. 33, ;Plan o£ 8actign 2, Mt. Allen HeigY the O££iCe of the ;8ecorder of Deeds iq and for Cumb4 pegs 16. !~OVSSIS the-ROmgshiy of oyyer Allen, pnreiwlarly bouMep and as Avenue at the esuthern line Plea of Lots; thaace along the ea mast One 8uadred Tmeaty (320) 'ese 8laety (s0) feet to a point; Plan goukh 76 Qegreas 16 minutes nue~ thenco along the meatwn B Sast ninety (901 feet to Ehe a, said elan being recoxdefl in land Coaaty i6 Plan Hook 12, PAP.CM3L NO. 42-2H-2921-267 DACP8RT7f ADpaa55: E02 APPALaCgrAN AYBNC6, AIECmamIC9 ^It0, PA 1705$ Curnx~er a~Y^d, ~ 1 Certify this, 'o be recorded In Cumberl d County PA R order of Deeds NOTICE REQUIRED BY THE FAIIZ DEBT COLLECTION PRACTICES ACT (the Act) 15 U.S.C. SECTION 1601 AS AMENDED 1. This law firm may be deemed a "debt collector" under the Fair Debt Collection Practices Act. Any and all information obtained during the prosecution of this lawsuit maybe used for the purpose of collecting the debt. 2. The amount of the debt is stated in paragraph 9 of the Complaint. 3. The Plaintiff as named in the Complaint is the creditor to whom the debt is owed, or is servicing agent for the creditor to whom the debt is owed. The undersigned attorney represents the interests of the Plaintiff. 4. The debt described in the Complaint, evidenced by the copy of the mortgage note attached hereto, will be assumed to be valid by the creditor's law firm unless the debtor, within thirty (30) days after the receipt of this notice, disputes in writing the validity of the debt or some portion thereof. 5. If the debtor notifies the creditor's law firm in writing within thirty (30) days of the receipt of this notice that the debt or any portion thereof is disputed, the creditor's law firm will obtain a verification of the debt and a copy of the verification will be mailed to the debtor by the creditor's law firm. 6. If the creditor named as Plaintiff in the Complaint is not the original creditor, and if the debtor makes a written request to the creditor's law firm within the thirty (30) days from the receipt of this notice, the name and address of the original creditor will be mailed to the debtor by the creditor's law firm. 7. Written requests should be addressed to Spear & Hoffrnan, P.A„ 1020 North Kings Highway, Suite 210, Cherry Hill, NJ 08034. ~~ ~~ ~ w ~` ~t °~4 ~c ~~ c ~vl ~ ~~ ~~ t_ i ~_ J ~' 7 -i „~ ~~~, ~~ SPEAR & HOFFMAN, P.A. BY: BONNIE L. DAHL, ESQUIRE ATTORNEY LD. NO. 79294 1020 NORTH KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 FANNIE MAE PLAINTIFF, vs. LYNDA H. SLIMMERS DEFENDANT COURT OF COMMONI'LEAS CUMBERLAND COUNTY NO. 01-5743 CNIL TERM PRAECIPE TO WITHDRAW JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Kindly withdraw the judgment by default in the above captioned matter which was filed on NOVEMBER 20, 2001, as the Mortgagors have reinstated their mortgage. SPEAR AND HOFFMAN, P.A. i~~~ " BONNIE L. DAHL, ESQUIILE Attorney for Plaintiff ~ ~~ "; e,- --~ ~~ -~`; ~ ~: - t!+ A,- - T.. ' : _t C: _- .: __ T ~~-" r'~ ~' 4 SHERIFF'S RETURN - REGULAR CASE NO: 2001-05743 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FANNIE MAE VS SUMMERS LYNDA H SHANNON SUNDAY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SUMMERS LYNDA H DEFENDANT the at 2112:00 HOURS, on the 4th day of October 2001 at 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 by handing to LYNDA SUMMERS 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 6.50 Affidavit .00 Surcharge 10.00 .00 34.50 Sworn and Subscribed to before me this ~~ - day of ~e~Q,_.~,.. a c9v I A . /D~~ . ~.~q f ~ J~ JLO~ Prothonotary So Answers: e/ ~~~4 /~~~ R. Thomas Kline 10/05/2001 SPEAR & HOFFMAN ~ Deputy Sheriff SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIRE ATTORNEY LD. NO. 79294 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF LOAN# 5944629665 FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET 01-5743 CNIL TERM LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter Judgment IN REM in the amount of $124,574.40 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiff s Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffls damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $115,466.95 Interest at 8.52% from 04/01/01 to NOVEMBER 9, 2001 (223 days @ $26.95 per diem) $6,009.85 Accrued Late charges $252.50 Other Fees $15.60 Attorneys Fees $2,829.50 TOTAL AMOUNT DUE ~~ $124,574,40 BONNIE DAHL, ESQUIRE Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $124,574.40 ~~ o PRO PROTHY ~ ~° c ~ =, ~ -- -~; z' - ' _ ~~= ' _~ -- ~r' ~. ~ { ., ur~n~an.~n-! SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIItE ATTORNEY LD. NO. 79294 1020 NORTH KINGS HIGHWAY SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 FAX (856) 755-1570 ATTORNEY FOR PLAINTIFF FANNIE MAE ~ I COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY vs. LYNDA H. SUMMERS DEFENDANTS DOCKET NO.O1-5473 CERTIFICATION OF MAII,ING NOTICE PURSUANT TO RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to file a Praecipe for the Entry of Default Judgment was mailed to Defendant(s) and to his, her or their attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe for the Entry of Judgment. A true and eprrect copy of each Notice is attached hereto, sent as stated. SPEAR & HOFFMAN, P.A. Dated: 10/26/01 BY: --~~`%~~ ' BONNIE DAHL, ESQUIRE Attorney for Plaintiff SPEAR AND HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIRE ATTORNEY LD. NO. 79294 1020 NORTH KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW 7ERSEY 08034 (856)755-1560 FAX (856) 755-1570 ATTORNEY FOR PLAINTIFF, LOAN N0.: 5944629665 FANNIE MAE PLAII~TTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.O1-5743 LYNDA H. SUMMERS DEFENDANT(S) To: LYNDA H. SUMME1tS 502 APPALAGtFIIAN AVENUE MECHANICSBURG, PA 17055 Date of Notice: 10/26/01 NOTICE IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIItED OF YOU AV THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A NDGMENT MAYBE 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 HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717) 249-3166 ~~ ONNIE DAHL, ESQUIRE Attorney for Plaintiff THIS LAW FIRM MffY BE DEEMED A "DEBT COLLECTOR" UNDER THE FAIR DEBT COLLECTION PRACTICES ACT. ANY AND ALL INFORMATION OBTAINED Di1RING THE PROSECUTION OF TffiS LAWSUIT MAY BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIltE ATTORNEY LD. N0.79294 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HII,L, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DPJISION CUMBERLAND COUNTY NO.O1-5743 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 and that the last known address(es) of the judgment debtor (Defendant (s)) is (are): LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 SPEAR & HOFFM , P.A. BY: ~--~' ONNIE DAHL, ESQUII2E SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIRE ATTORNEY LD. N0.79294 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-]560 ATTORNEY FOR PLAINTIFF FANNIE MAE vs. PLAINTIFF, LYNDA H. SUMMERS DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO.O1-5743 CNIL TERM CERTIFICATE OF SERVICE We, Spear and Hoffman, P.A, Attorney for the Plaintiff, hereby certify that we have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Date mailed: _~~~v SPEAR & HOFFMAN, P.A. BY: ~~~ ONNIE DAHL, ESQUIRE _,~ _ SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIltE ATTORNEY LD. N0.79294 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUN I'Y DOCKET NO.Ol-5743 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE BONNIE DAHL, ESQUIRE, being duly sworn according to law, deposes and says that he is attorney for Plaintiff in the above-captioned matter, that he makes this Affidavit on Plaintiffs behalf, and that the statements in this Affidavit are true to the best of his knowledge, information and belief. Defendant, LYNDA H. SUMMERS, is over 21 years of age. Her last employment is unknown. Defendant is not in the military service of the United States as contemplated by the Soldiers' and Sailors' Civil Relief Act, as amended. This Affidavit is made in comtection with the judgment upon a note and mortgage secured upon the premises located at 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055. SWORN TO AND S'~S~CRI BEFORE ME THIS 1~3T"` DAY OF~ , 20 ~~ . of BY: ~/"~ ONNIE DAHL, ESQUIItE November 15, 2001 > ~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LAWRENCE E. WELKER Prothonotary TO: LYNDA H. SIIMIVIERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 FANNIE MAE PLAINTIFF, vs. LYNDA H. SiJMNIERS DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.Ol-5743 CNIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: X Judgment by Default Money Judgment Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BONNIE DAHL, ESOUIItE at this telephone number: (856) 755-1560 '6 ~_ Ji ~ ~` n , l - \ ~ ^ ~..i' J r a~ e ~, ' °w~ ~.m r~ ' c 4 i Z7Gr n„ . c~ - __ ~-; C f7 ^] f ~ 1. - 1 ~f ~ „ J"~ ~) ~_Y. i !._ :._? _ Q 7`1 _~ ~~~ ~` . .~eramenn~ - _- m~s~s ~naa~;wa,~evRm~mte~l~y~+~ad~aa~ua~im .fi..~,.~~a ~ ..•s 3r tips ~ =>°c n.=~^e 5a~A~al SPEAR & HOFFN,'AN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF LOAN# 5944629665 FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET 01-5743 CIVIL TERM LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Enter Judgment IN REM in the amount of $137,510.40 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiff's Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiff's damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid Interest at 8.52% from 04/01/01 to MARCH 4, 2003 (703 days @ $26.95 per diem) Late charges Other Fees Attorney's Fees (As stated in Complaint) TOTAL AMOUNT DUE $115,466.95 $18,945.85 $252.50 $15.60 $2,829.50 ~"~e-~~_1 \ - ~-~`-~~ $137.510.40 LAURENCE R. CHASHIN, ESQUIRE Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $137,510.40 lS/ ,/~' PRO PROTHY /.~~ ~. ~. ~,, c-~~ ... c,~ ~- ~ 1 ~,~, -. 8 - ~ .~ ~~: ~~ - o ~„ ~ -~ =-~ ~- ~ ~ ~. <~ :~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5743 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also duected to attach the property of the defendant(s) not levied upon in the possession of GARNISHEES} as follows: and to notify the garnishee(s) that: (a) att 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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atry's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothonotary (Seal) By: `~p~~, ~ ~ ~~ `~ ~ Deputy REQUESTING PARTY: Name Laurence R Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-755-1560 Supreme Court ID No. 77558 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR W RIT OF EXECUTION FANNIE MAE { ) Confessed Judgment ( ) Other vs. File No. 01-5743 CIVIL TERM LYNDA H. SUMMERS Amount Due $137.510.40 Interest $ 2,214.80 Atty's TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) 502 APPALACHIAN AVENUE. MECHANICSBURG, PA 17055 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. /~ /' DATE: March 4, 2003 Signature: ~ --~ __/ ~ - ~`~~- Print Name: LAURENCE R. CHASHEV, ESQUIRE Address: 1020 N. Kines Hiehwav, Suite 210 Chem Hill, N.J. 08034 Attorney for: FANNIE MAE `-e r_ u' ~ ^~ _:: 1. ~, -- -.~~ ==~ =~ ~ ~- ~ _a , L L~ u.~ :iL . `> > , o r , / o ~(\ xz~ ~ m~~ az ~z7~ c m ~xxx ~ ~ , ~r"xp ry a '0 ~ ~~aa "'x o~ ~cz ~,z o~y "p (~ A ~] -, r~ N 0 ;~ ~ P u ~ ` ~ ~~~ ~ ~ ~ ~, ®~~ o ~~ ~ ~~~ ~ .~ ~ b o ~. n ~ w O R, a ~ w n O y ~o ~~ O ~i y G~ °z ~~ ~3 ~~ d a x y ry ~z ~ x h7 n o ao ~ o ~ ~ z ~° W ~ ~S C r a ~ z° m zz ~r rm c~ a 0 9 IN THE UNITED STATES BANKRUP'T'CY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Lynda H. Summers Washington Mutual Bank, (n) MOVANT, vs. BKY CASE NO. 01-05871/RJW CHAPTER NO.: 13 Lynda H. Summers RESPONDENT(S)/DEBTOR(S) Charles J. Dehart,III, Trustee RESPONDENT/TRUSTEE 11 U.S.C. SECTION 362 ORDER MODIFYING §362 AUTOMATIC STAY AND NOW, this 9th day of August , 2002, at the MIDDLE District of Pennsylvania, upon failure of the Debtor to file an answer within the time allowed, appear or otherwise respond to the Motion of the above-named Movant for Relief fiom the Automatic Stay, and for good cause shown, it is: ORDERED AND DECREED that the Automatic Stay of all proceedings, as provided under §362 of the Bankruptcy Reform Act of 1978 (The Code) 11, U.S.C. §362 is modified to allow the above-named Movant, its successors or assigns to proceed with, or to resume proceedings iri mortgage foreclosure, including, but not limited to, Sheriffs or Marshal's Sale of 502 Appalachian Avenue, Mechanicsburg, PA 17055; and to take action, by suit or otherwise as pernvtted by Iaw, in its own name or the name of its assignee, to obtain possession of said premises. FURTHER, this order shall take effect immediately without regard to Bankruptcy Rule 4001(a)(1). /s! John J. Thomas UNITED STATES BANKRUPTCY JUDGE cc: Robert W. Cusick, Esquire SPEAR & HOFFMAN, P.A. 1020 North Kings Highway, Suite 210 Cherry Hill, NJ 08034 856-755-1560 1"ih ~~_~~. m a~ SPA ~ - ~ 20Q2 ...+!FY I _ `= ~ - = ?;~_: r~rfi`. - _; _ C" „f.:_ r,-:_. :. a ~ L.:: -i E - y f? =d ., <n .. .F$ ~ '^~1 ^~"a~115? ,~sef"A9,'$cssw. k~u+€£+~x~..rn aa~iep a sit-ys"^''~+`=~.n~. ixi~r.'~ r~a~3=,p.~e~~ i~..r SPEAR & HOFFMAN, P.A. BY: BONNIE DAHL, ESQUIRE ATTORNEY LD. NO. 79294 1020 NORTH KINGS HIGI-IWAY SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 FAX (8S6) 755-1570 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. Ol- 7~3 CERTIFICATION OF MAILING NOTICE PURSUANT TO RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to file a Praecipe for the Entry of Default Judgment was mailed to Defendant(s) and to his, her or their attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe for the Entry of Judgment. A true and egrrect copy of each Notice is attached hereto, sent as stated. SPEAR & HOFFMAN, P.A. Dated:l0/26/OI BY: /~~~~~ ~~-~ ' BONNIE DAHL, ESQUIlZE Attorney for Plaintiff ~~ ~_ =~~ _: .G. ~. ._.._ __~ ._ _,...~:. i_.J T~ 4 .. _~ ~ ` 1 ~ .._c. .' ~'} ~~ .. ~` ~~ tltp .... &~mrs~~rrswsa~°er~'Si'irtra _ B{u, ,. ~,av . .~ _-e-. rsrvi==.rs~, ~ '. ;=mixa+ _. xuaatire~rmarwnre~ SPEAR AND HOFFMAN; P.A. BY: BONNIE DAHL, ESC!1JIRE ATTORNEY LD. NO. 79294 1020 NORTH KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 FAX (856) 755-1570 ATTORNEY FOR PLAIN'I'iFF, LOAN N0.: 5944629665 FANNIE MAE PLAINT!FP, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. O 1-5743 LYNDA H. SUMMERS DEFENDANT(S) NOTICE To: LYNDA H. SUMMERS 502 APPALAGtHIAN AVENUE MECHANICSBUP.G, PA 17055 ~~. Date of Notice: 10/26/01' IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A NDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR,O'THER 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 HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17103 (717) 249-3166 ~~~ ONNIE DAHL, ESQUIRE Attorney for Plaintiff THIS LAW FIRM 1VIAY BE DEEMED A "DEBT COLLECTOR" UNDER THE FAIR DEBT COLLECTION PRACTICES ACT. ANY AND ALL INFORMATION OBTAINED DURING THE PROSECUTION OF THIS LAWSUIT MAY BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN THE TOWNSHIP OF UPPER ALLEN COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WESTERN LINE OF APPALACHIAN AVENUE AT THE SOUTHERN LINE OF LOT NO. 32, AS SHOWN ON THE HEREIN AFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF LOT NO. 32 NORTH 76 DEGREES 16 MINUTES WEST ONE HUNDRED TWENTY (120) FEET TO A POINT; THENCE SOUTH 13 DEGREES 44 MINUTES WEST NINETY (90) FEET TO A POINT; THENCE ALONG THE NORTHERN LINE OF LOT NO. 34 ON SAID PLAN SOUTH 76 DEGREES 16 MINUTES EAST ONE HUNDRED TWENTY (120) FEET TO APPALACHIAN AVENUE, THENCE ALONG THE WESTERN LINE OF APPALACHIAN AVENUE NORTH 13 DEGREES 44 MINUTES EAST NINETY (90) FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 33, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 12, PAGE 16: BEING THE SAly?E PREMISES WHICH LYNDA H. SUMMERS BY DEED DATED AUGUST 26, 1999 AND RECORDED SEPTEMBER 14, 1999 IN THE COUNTY OF CUMBERLAND AND STATE OF PENI<'SYLVANIA IN DEED BOOK 207 PAGE 738 CONVEYED UNTO LYNDA H. SUMMERS, MOT;TGAGOR HEREIN. PARCEL NO. 42 28-2421-267 PROPERTY ADL.RESS: 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055. _:, SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-5743 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: WASHINGTON MUTUAL BANK C/O FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 and that the last lmown address(es) of the judgment debtor (Defendant (s)) is (are): LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 SPEAR & HOFFMAN,//P.A. BY: _ C~-~-~~ LAU NCE R. CHASHIN, ESQUIRE ~, ~.: - C. ~.a -„ ~;a tf < G- ,, ~. _ _ f~ ~ mot, ~ .~ i: ~ C.. - ' J , . Jy /~ Spt _r SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE COURT OF COMMON PLEAS PLAINTIFP, CIVIL DIVISION vs. CUMBERLAND COUNTY LYNDA H. SUMMERS I NO. 01-5743 CIVIL TERM DEFENDANT(S) CERTIEICAfE OF SERVICE We, Spear and Hoffman, P.A., Attorney for the Plaintiff, hereby certify that we have served by fast class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Date mailed: Ja - S- 03 SPEAR & HOFFMAN, P.A. BY: ~ 0\ ~C LAURENCE R. CHASHIN, ESQUIRE L= ._ rn ~'~ -r7 ~: _' ~„ ~`%. (S. ~`~_ ~~~~ `F t J ~~ ~_ .. 1 ~ p-~ r. SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 01-5743 CIVIL TERM AFFIDAVIT OF NON-MILTTARY SERVICE LAURENCE R. CHASHIN, ESQUIRE, being duly sworn according to law, deposes and says that he is attorney for Plaintiff in the above-captio„ed matter, that he makes this Affidavit on Plaintiff's behalf, and that the statements in this Affidavit are true to the best of his knowledge, information and belief. Defendant, LYNDA H. SUMMERS, is over 21 years of age. His last employment is unknown. Defendant is not in the military service of the United States as contemplated by the Soldiers' and Sailors' Civil Relief Act, as amended. This Affidavit is made in connection with the judgment upon a note and mortgage secured upon the premises located at 502 APPALACHIAN AVFNUE, MECHANICSBURG, PA 170SS. SWORN TO AND SU` B~CRIBED BEFORE ME THIS ~' ~- DAY OF yYl CC)^e~l~ , 20 ~ . _, Mazch 4, 2003 BY: _ C /, A CE R. CHASHIN, ESQUIRE DONNA M. l.UPO Notary Public of New Jersey My Commission Expires February 22, 2005 f"~ : > 4- ..~.. `"11f=~ = ~_5 - _ ~ ;- -' _ _ ~~ L ° _ l.ry.' _ ~- ~i_ ~ ~ .I -_ -- ' _ it .~'' L .. J <r OFFICE OF TI-TR PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY r'r LAWRENCE E. WELKER Prothonotary TO: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. Oi-5743 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you aze hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: X Judgment by Default ^ Money Judgment ^ Judgment for Possession ^ Judgment on Award of Arbitration ^ Judgment on Verdict ^ Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY LAURENCE R. CHASHIN, ESQUIRE at this telephone number: (856) 755-1560 ~ ~. SPEAR & HOFFMAN, P.A. ~ BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE :: PI>AINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 01-5743 CIVIL TERM LYNDA H. SUMMERS DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 FANNIE MAE, Plaintiff in the above action, by its attorney, LAURENCE R. CHASHIN, 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 502 APPALACHIAN AVENUE, MECHANIC5BURG, PA 17055: 1. Name and address of Owner(s) or Reputed Owner(s): LYNDA H; SUMMERS 502 APPALACHIAN AVENUE MECHANI~SBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: UPPER ALLEN TOWNSHIP 4714 INDIAN TRAIL ROAD NORTHAMPTON, PA 18067 REF/i 200]-2657 Name and address of the last recorded holder of every mortgage of record: WASHINGTON MUTUAL BANK C/O FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 NORTH AMERICAN MORTGAGE COMPANY 3883 AIRWAY DRIVE SANTA ROSA, CA 95403 PNC MORTGAGE CORP. P.O. BOX 2026 FLINT, MI,48501-2026 ~ +fi ~ .. y 5. Name and address of every other person who has any record lien on the property: 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: DOMESTIC RELATIONS P.O. BOX 320 13 N. HANOVER ST. CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE -LIEN BUREAU OF COMPLIANCE DEPT. 280946 HARRISBURG, PA 17128-0946 ATTENTION: SUE BLOUGH CUMBERLAND COUNTY TAX CLAIM BUREAU 1COURTHOUSESQUARE --- CARLISLE, PA 17013 CAROLYN MCQUILLEN TAX COLLECTOR 1044 PINE ROAD CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX DIVISION DEPT. 280601 HARRISBURG, PA 17128-0601 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(S)/OCCUPANT(S) 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.Q.S. §4904 relating to unsworn falsification to authorities, SPEAR & HOFFMAN, P.A. LAURENCE R. CHASHIN, ESQUIRE Attorney for Plaintiff - c ~ ,;, -~ - _. rn=i. ~ - L ... .. G^.:_ ' -G .: ~~, > . _e~S,.s - ~ ~C O =.~ ~ - ` u ~ -~ SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. HINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 01-5743 CIVIL TERM CERTIFICATION LAURENCE R. CHASHIN, ESQUIRE, hereby verifies that she is the 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 Pa.C.S. section 4904 relating to unsworn falsification to authorities. =Y~ ~ . ~C LAURENCE R. CHASHIN, ESQUIRE Attorney for Plaintiff ~- ~- -~,t ~~~, ; z_ ~_ - ~;` <_ ~: t' - ~= , ~~. =~_: = -- C : _ _>- ~ ~3~ SPEAR & HOFFMAN, P.A. ~y BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS COURT OF COMMON, PLEAS CUMBERLAND COU>~JTY DOCKET NO.Ol-5743 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Your house (real estate) at: 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 is scheduled to be sold at Sheriff's Sale on JUNE 11, 2003 at: CUMBERLAND COUNTY COURTHOUSE 2ND FLOOR, COMMISSIONERS HEA1'tING ROOM 1COURTHOUSESQUARE CARLISLE, PA 17013-3387 at 10:00 a.m. to er..force the court judgment of $137,510.40 obtained by FANNIE MAE 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 to FANNIE MAE the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (856) 755-1560. 2. You may be able to stop the sale ley filing a petition asking the Court to strike or open the judgment, if the judgment was improperly enterer'. You may also ask the Court to postpone the sale for good cause. 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 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (717)240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717)240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. Ycru 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 JULY 11, 2003 This schedule will state who wilt be receiving the money. The money wlll 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. 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 COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17103 PURSUANT TO THE FAIIi DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TffiS LAW FIItM IS DEEMED TO'3E A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~. C? ~ r, .., t. ~: =' _ Z r_7 _ Cries- Gi__. r: _. '~ ( ~ ~..' - .1% ~ z. ~ £~ _. '~ ~ CTS SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY LD. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.O1-5743 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the Attorney oY record for the Plaintiff in this Action against Real Property and further certify this property is: [ ] FHA -Tenant Occupied or Vacant [ ] Commercial [ ] As a result of a Complaint in Ass~.rttpsit [ X ] That the Plaintiff has complied in all respects with Section 403 of the Mortgage assistance Act including but not limited to: (a) Service of notice on Defendant(s) (b) Expiration of 30 days since the service of notice (c) Defendant(s) failure to request or appear at meeting with Mortgagee or Consumer Credit Counseling Agency (d) Defendant(s) failure to file appli~dtion with Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff of CUMBERLAND County for any false statement given herein. LAURENCE R. CHASHIN, ESQUIRE Attorney for Plaintiff ~., ~_ c __~ -. -~;= ~~. G?. c~ \. 4' ~L~ _ ~. Y'~_.~ ~. ~ 1~. ~~~_ .~ C. CERTIFICATE TO THE SHERIFF SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE 1COURTHOUSESQUARE CARLISLE, PA 17013-3387 FANNIE MAE :COURT OF COMMON PLEAS vs. NO.Ol-5743 CIVIL TERM LYNDA H. SUMMERS I HEREBY CERTIFY THAT The judgment entered in the above matter is based on an action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. IL The defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by the Entireties C. Joint tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one defendant and either A or B above not applicable, state which defendants are residents of the Commonwealth of Pennsylvania. Residents: Name: LAURENCE R. CHASHIN. ESQUIRE Attorney LD. NoQ. 77558 Signature: ~~- /~ _ ~~~ Phone No. (8561755-1560 Address: 1020 N. Kings Highway. Suite 210 Cherry Hill. N.J. 08034 C ` . _,_ i Z l7° ;.-, i. i i %C t_._ L`i .. ~~~ {° =. -G f3~ -~ SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 NORTH KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 01-5743 CIVIL TERM PRAECIPE TO WITHDRAW JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Kindly withdraw the judgment by default in the above captioned matter which was filed on March 10, 2003. SPEAR AND HOFFMAN, P.A. LAUR NL'E R. CHASHIN, ESQUIRE Attorney for Plaintiff ~ ~ ~2 ~- ~ o ~ ~ G C: -: --~ ~' rid! c~ , a~: . ~__ ~r T c? ~~ ~~ r; _'~ -. ;?,,,, Mar 12 03 04:04p SpearaHoffman 18567551570 P•1 Law Offices Spear and Hoffman, P.a. March 12, 2003 SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE 1COURTHOUSESQUARE CAP.LISLE, PA 17013-3387 ATTN:JODY RE: FANNIE MAE vs. LYNDA H- SUMMERS Docket No. 01-5743 CIVIL TERM Sale Date: JUNE 11, 2003 OuT File WMS-P-273 Dear Sir/Madam: Wine C. Spear f1922-1976)- ' C'? r:a n c. c„ l - .y.i ,.• ri; ~ ~:_y v; ._ . ~_~ r-- : ~ =~ - <. rm ~ , c` ~ ~ r .. `=i _ a Kindly stay the sale scheduled for the above-referenced case due to the fact that Defendant LYNDA H. SUMMERS has satisfied her payments to ow clietit. No monies were received. In order for our firm to properly bill our client, please take the time to send us the refund of $1,500.00 and a copy of the writ- Please return the writ to the prothonotary. If you have any questions or concerns, please do not hesitate to contact the undersigned. Thank you for your anticipated cooperation and courtesy in this matter. Very truly yours, SPEAR AND HOFFMAN, P.A. C -~.~ Holly C. Koenig, Paralegal /hck VIA FACSIMILE TO 717-240-6397 {~l/1 ~ .Q.Q l~ ~ ~_~ ~ ~ ~r ~ ~~ NJ/PA: 1020 N. Kings Highway/ Suite 210/Cherry Hill, New Jersey 08034/(856) 755-1560/ Fax(856) 755- L570 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA). COUNTY OF CUMBERLAND) NO 01-5743 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also duected 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 duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R LONG Prothonota/r~y ~I ~o ~~ nn // (Seal) By: 7C.,P/L/,~nr ~- d.5e/X~ Deputy REQUESTING PARTY Name Laurence R. Chashin, Esq. Address: 1020 N. Dings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-755-1560 Supreme Court ID Nc. 77558 Real Estate Sale # 33 On March 12, 2003 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA known and numbered as 502 Appalachian Ave., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2003 By:~-1C~5M,(~q Real Estate Deputy .~ - e. n*a-m+mz~vy~"a~&0'+i ~xiF :-e F,p_' a ..~.,-..., .. ~ ;.~R.s t-s.e~i~r.- -;,'y,.3~t S~f S~.. '. WRIT OF EXECUTION and/or ATTACHMENT' COMMONWEALTH OF PENNSYLVANIA) NO 01-5743 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: ' To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (1) You are duected to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are duected to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's' Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothon ota r y (Seal) /~ ` ~ ~~ ~ ~ ~! By: 7C-yvv~~r.,r /~, ~21r12,~E~ '~ v Deputy / REQUESTING PARTY: Name Laurence R Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone:856-755-1560 Supreme Court ID No. 77558 TRIf~ a;~t~pY ~R~a~i1 RE~ClRD In Testimony v~hereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ..../.0...._. day of.._`dv(ac~i p ............. `~ . _ kt/s...... ~.. . Prothonotary .~ r, ~ ,., ,, i, i,~ ~ , -WRIT OFEXECUTION-and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COi1N'I'Y OF CUMBERLAND) NO 01-5743 Civil CNIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also duetted 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 duetted to notify him(her that hefshe has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothonotary (Seal) ~ ,,~ By: ~/~~d,~` /~. ~~~~ v Deputy REQUESTING PARTY: Name Laurence R. Chashin, Esq. Address: 1020 N. HIngs Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-755-1560 Supreme Court ID No. 77558 TRUE C:~PY F~~l~ RECORD In Testimony v.~hereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ..../..~........ day of._..d2?ac~~ ....... ~/ ....~~ Prothonotary u~_C I 1111,1{i 1 Il ~4 ~ I 1 ~ i 'ii I Iii ~ I: ~ I , I 1 ~~~ ~ 1 ~i I ~~ I~ ~ 11 ~ 1:: I I I I 1 I: ~ i ,. , {4t~i:j ~ ...~ I` ~p .3i I' t {3 ~ { lr~.' 1' ICI 11 ~ 1 I~ el 1 i~ . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-5743 Civil COUNTY OF CC1IvIBERLAND) CML ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lyuda H. Summers (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRH'TION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are dtrected to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$i37,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothonotary (Seal) By: 7~l~isLi,!„^ /~. ~°l~ Deputy REQUESTING PARTY: Name Laurence R. Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-755-1560 Supreme Court ID No. 77558 YRUE COPY F~;3sU R~~~RD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa, This ... ~~........ day of....~d~ac~~., p~~ ~p ~~' ~d/ Prothonotary i, i r' ~ ~, ~ I .. .~ ~~ l~i h li i it ~~ ~. u ~ ~.a ~ ~I ~ ~- ~ I i i ~~ ~ ~i i I ~ {i ~ ~ ~ i ~ `r-~l - ,I ~ a 14tIP ~ 'r 1 ~ li, <.. .. ~' . ~: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-5743 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers DESCRIPTION . (1) You are duected to levy upon the property of the defendant (s)and to sell SEE LEGAL (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amoun[ Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothonotary (Seal) ~ .,! By: ~~~.,~ /~. ~O ~ ~ Deputy REQUESTING PARTY: Name Laurence R. Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff Telephone: 856-755-1560 Supreme Court ID No. 77558 l'R~lE COPY ~~~3iy1 R~~~RD In Testimony ~Fritereof, I h;;re unto set my hand and the seal of said Court at Carlisle, Pa. This ..../D........ day of....`A?!/ac~` ,.........._.`~ .. ytGc,_.~_.. ~... Prothonotary - ~ ~' 17 i._ _. .. ' I;- i -a,~,~*.... Real Estate Sale # 33 On March 12, 2003 the sheriff levied upon the d.efendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA known and numbered as 502 Appalachian Ave., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2003 By. - Real Esta Deputy ~~ 3 tivu ~.Ra~+in.. .a..,,,a~~..x_. r,vr ~..~~-a~.~.;~srrssaeswam ,~.~*a'-~.: ,~ .-. <._ eaptet~~~r¢wSN4k _._...-" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5743 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (1) You aze duetted to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also duetted 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 duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs P1ain6ff Paid Date: March 10, 2003 CURTIS R. LONG Prothon~~(ota///ry~~~~~~ (Seal) By: ~~ /~'. ~ Deputy REQUESTING PARTY: Name Laurence R. Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, NJ 08034 Attorney for: Plaintiff TRUE COPY ~~~~M RECORD In Testimony ~rohereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ... %o........ day of....evlg-~ Telephone: 856-755-1560 Supreme Court ID No. 77558 Prothonotary '^s==« Real Estate Sale # 33 C-n March 12, 2003 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA known and numbered as 502 Appalachian Ave., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2003 By: Real Estate Deputy. ~'0~ WRIT OF EXECUTION and/or ATTACHMENT- COMMONWEALTH OF PENNSYLVAN'A) NO 01-5743 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Fannie Mae Plaintiff (s) From Lynda H. Summers (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You aze also duected to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to 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 of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) no[ levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$137,510.40 L.L.$.50 Interest $2,214.80 Atty's Comm % Due Prothy $1.00 Atty Paid $115.50 Other Costs Plaintiff Paid Date: March 10, 2003 CURTIS R. LONG Prothon ota ry (Seal) `` ~~ ~ .,.~ By: 7~Dr~Gi,t^ /~. `~o~ ~~_ Deputy REQUESTING PARTY: Name Laurence R. Chashin, Esq. Address: 1020 N. Kings Highway, Suite 210 Cherry Hill, N3 08034 Attorney for: Plaintiff Telephone:856-755-1560 Supreme Cour[ ID No. 77558 TR~J~ Ci~P1' In Testimony t~~hereof ~^~a~i1 R~~~RD I he , re unto set my hand and the seal of said Court at Carlisle, pa. This ..../..~.......- day of....`d~~~ P..v..........~~j,~y~.. Imo/ ., . ~..,, ~rCd/~YJ ~` Pr(((///ot°°°hllP"o~~~n..o"`tary~J J ,._ { i i'' I ~ ~ i; ~., .s few,»«~.,:..,,,~,~R Real Estate Sale # 33 (hi March 12, 2003 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA known and numbered as 502 Appalachian Ave., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2003 By Real Es e Deputy SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR 1 FANNIE MAE PI:AINTIFF, vs. LYNDA H. SUMMERS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 01-5743 CIVIL TERM DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 FANNIE MAE, Plaintiff in the above action, by its attorney, LAURENCE R. CHASHIN, 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 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055: Name and address of Owner(s) or Reputed Owner(s): LYNDA H; SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: UPPER ALLEN TOWNSHIP 4714 INDIAN TRAIL ROAD NORTHAMPTON, PA 18067 REFN 2001-2657 4. Name and address of the last recorded holder of every mortgage of record: WASHINGTON MUTUAL BANK C!O FANNIE MAE P.O. BOX 1093 NORTHRIDGE, CA 91328-1093 NORTH AMERICAN MORTGAGE COMPANY 3883 AIRWAY DRIVE SANTA ROSA, CA 95403 PNC MORTGAGE CORP. P.O. BOX 2026 FLINT, MI,48501-2026 Name and address of every other person who has any record lien on the property: 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: DOMESTIC RELATIONS P.O. BOX 320 13 N. HANOVER ST. CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE -LIEN BUREAU OF COMPLIANCE DEPT. 280946 HARRISBURG, PA 17128-0946 ATTENTION: SUE SLOUGH CUMBERLAND COUNTY TAX CLAIM BUREAU 1 COURTHOUSE SQUARE CARLISLE, PA 17013 CAROLYN MCQUILLEN TAX COLLECTOR 1044 PINE ROAD CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA INHERITANCE TAX DIVISION DEPT. 280601 HARRISBURG, PA 17128-0601 7. Name and address of every other person of whom the plaintiff has knowledge wh"o has any interest in the property which may be affected by the sale: TENANT(S)/OCCUPANT(S) 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.z/.S. §4904 relating to unsworn falsification to authorities. SPEAR & HOFFMAN, P.A. ~°~~ ~ c. LAURENCE R: CHASHIN, ESQUIRE Attorney for Plaintiff .:w,~,,A.a.~ . SPEAR & HOFFMAN, P.A. B!: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856)755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS ~oP~r COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.Oi-5743 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LYNDA H.. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Your house (real estate) at: 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 is scheduled to be sold at Sheriff's Sale on JUNE 11, 2003 at: CUMBERLAND COUNTY COURTHOUSE 2"'D FLOOR, COMMISSIONERS HEARING ROOM 1COURTHOUSESQUARE CARLISLE, PA 17013-3387 at 10:00 a.m. to enforce the court judgment of $137,510.40 obtained by FANNIE MAE 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 to FANNIE MAE the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due: To fmd out how much you must pay, you may call: (856) 755-1560. 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 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (717)240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717)240-6390. 4: If the amount"due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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. Yqu 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 JULY 11, 2003 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 afer 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 COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17103 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COp~ ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN THE TOWNSHIP OF UPPER ALL1;N COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WESTERN LINE OF APPALACHIAN AVENUE AT THE SOUTHERN LINE OF LOT NO. 32, AS SHOWN ON THE HEREIN AFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF LOT NO. 32 NORTH 76 DEGREES 16 MINUTES WEST ONE HUNDRED TWENTY-(120) FEET TO A POINT; THENCE SOUTH 13 DEGREES 44 MINUTES WEST NINETY (90) FEET TO A POINT; THENCE ALONG THE NORTHERN LINE OF LOT NO. 34 ON SAID PLAN SOUTH 76 DEGREES 16 MINUTES EAST ONE HUNDRED. TWENTY (120) FEET TO APPALACHIAN AVENUE, THENCE ALONG THE WESTERN LINE OF APPALACHIAN AVENUE NORTH 13 DEGREES 44 MINUTES EAST NINETY (90) FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 33, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 12, PAGE 16. BEING THE SAME PREMISES WHICH LYNDA H. SUMMERS BY DEED DATED AUGUST 26, 1999 AND RECORDED SEPTEMBER 14, 1999 IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA IN DEED BOOK 207 PAGE 738 CONVEYED UNTO LYNDA H. SUMMERS, MORTGAGOR HEREIN. PARCEL NO. 42 28-2421-267 PROPERTY ADDRESS: 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055. SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY LD. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. LYNDA H. SUMMERS DEFENDANTS ~~~ COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO,Ol-5743 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LYNDA H. SUMMERS 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 Your house (real estate) at: 502 APPALACHIAN AVENUE MECHANICSBURG, PA 17055 is scheduled to be sold at Sheriff's Sale on JUNE 11, 2003 at: CUMBERLAND COUNTY COURTHOUSE 2N° FLOOR, COMMISSIONERS HEARING ROOM 1COURTHOUSESQUARE CARLISLE, PA 17013-3387 at 10:00 a.m. to enforce the court judgment of $137,510.40 obtained by FANNIE MAE 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 to FANNIE MAE the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (856) 755-.1560. 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. 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 on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS BEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If she Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (717)240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717)240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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 JULY 11, 2003 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. 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 COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17103 PURSUANT TO THE FAIIt DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN THE TOWNSHIP OF UPPER ALLEN COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE WESTERN LINE OF APPALACHIAN AVENUE AT THE SOUTHERN LINT OF' LOT NO. 32, AS SHOWN ON THE HEREIN AFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SOUTHERN LINE OF LOT NO. 32 NORTH 76 DEGREES 16 MINUTES WEST ONE HUNDRED TWENTY (120) FEET TO A POINT; THENCE SOUTH 13 DEGREES 44 MINUTES WEST NINETY (90) FEET TO A POINT; THENCE ALONG THE NORTHERN LINE OF LOT NO. 34 ON SAID PLAN SOUTH 76 DEGREES 16 MINUTES EAST ONE HUNDRED. TWENTY (120) FEET TO APPALACHIAN AVENUE, THENCE ALONG THE WESTERN LINE OF APPALACHIAN AVENUE NORTH 13 DEGREES 44 MINUTES EAST NINETY (90) FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 33, PLAN OF SECTION 2, MT. ALLEN HEIGHTS, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BOOK 12, PAGE 16. BEING THE SAl~?E PREMISES WHICH LYNDA H. SUMMERS BY DEED DATED AUGUST 26, 1999 AND RECORDED SEPTEMBER 14, 1999 IN THE COUNTY OF CUMBERLAND AND STATE OF PENI<'SYLVANIA IN DEED BOOK 207 PAGE 738 CONVEYED UNTO LYNDA H. SUMMERS, MORTGAGOR HEREIN. PARCEL NO. 42 ~28-2421-267 PROPERTY ADI`~-RESS: 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055. SPEAR & HOFFMAN, P.A. BY: LAURENCE R. CHASHIN, ESQUIRE ATTORNEY I.D. NO. 77558 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 (856) 755-1560 ATTORNEY FOR PLAINTIFF FANNIE MAE PLAINTIFF, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 01-5743 CIVIL TERM LYNDA H. SUMMERS DEFENDANTS CERTIFICATION LAURENCE R. CHASHIN, ESQUIRE, hereby verifies that she is the 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 Pa.C.S. section 4904 relating to unsworn falsification to authorities. LAURENCE R. CHASHIN, ESQUIRE Attorney for Plaintiff i, CERTIFICATE TO THE SHERIFF SHERIFF'S OFFICE CUMBERLAND COUNTY_COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 FANNIE MAE :COURT OF COMMON PLEAS vs. NO.01-5743 CIVIL TERM LYNDA H. SUMMERS I HEREBY CERTIFY THAT The judgment entered in the above matter is based on an action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by the Entireties C. Joint tenants with right of survivorship D. A partnership E. Tenants in Common ~_ F. A corporation III. The defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one defendant and either A or B above not applicable, state which defendants are residents of the Commonwealth of Pennsylvania. Residents: Name: LAURENCE R. CHASHIN. ESOUIRF. Attorney I.D. NoQ. 77558 Signature: ~ /~- _ ~~-~~~ Phone No. (856) 755-1560 Address: 1020 N. Kings Hiehwav. Suite 210 Cherrv Hill, N.J. 08034 SPEAR & HOFFMAN, P.A. Attorneys at Law 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, NEW JERSEY 08034 Tel: (856) 755-1560 Fax: (856) 755-1570 March 4, 2003 OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY CUMBERLAND COUNTY COURTHOUSE ICOURTHOUSESQUARE CARLISLE, PA 17013-3387 ATTN: SHERIFF'S SALE DEPARTMENT RE: FANNIE MAE v. LYNDA H. SLMMERS Docket No. 01-5743 CIVIL TERM Our File No. WMS-P-273 Dear Sir/Madam: The Prothonotary shall have delivered the Writ of Execution for sale of Real Property to you together with the below listed documents for the JUNE 11.2003 sale date. Please advise if this property will not be scheduled for that date. In accordance with CUMBERLAND County's requirements for scheduling a Sheriff's sale, I enclose: X Sale deposit in the amount of $1,000.00; X Bankruptcy dismissal court order; X Property legal description; X Affidavit pursuant to Rule 3129.1; X Act 91 Affidavit; X Notices of Sale for each Defendant; X Certification as to the sale of real property; X Certificate to the sheriff; X Request for service of the notice of sale; X Request for posting, advertising, of the notice of sale. Please time stamp the enclosed "ATTORNEY COPY" of the 3129 Affidavit and return in the prepaid envelope provided. We will send notice of the sale to all known lien holders prior to the sale and will file a Certification. Thank you for your cooperation in this matter. Very truly yours,/~ _0~ _ ~~_~ LAURENCE R. CHASHIN, ESQUIRE LC/hck Enclosures 5 Law Offices Spear and ~~offman~ P.a. ORDER FOR SERVICE TO: SHERIFF OF CUMBERLAND COUNTY FROM: LAUREN~E R. CHASHIN, ESQ. ATTORN ~Y ID# 77558 SPEAR AND HOFFMAN, P.A. 1020 N. KINGS HIGHWAY, SUITE 210 CHERRY HILL, N.J. 08034 (856) 755;1560 (856) 755J1570 FAX FANNIE MAE PLAINTIFF Vs. LYNDA H. SUMMERS DEFENDANT SERVE: LYNDA H. SU1~iMERS March 4, 2003 Irvine C. Spear (1922-1976) DOCKET NO. 01-5743 CIVIL TERM WRIT OF EXECUTION SERVE AT: 502 APPALACHIAN AVENUE, MECHt1NICSBURG, PA 17055 PROPERTY ADDRESS: 502 APPALACHIAN AVENUE, MECHANICSBURG, PA 17055 INSTRUCTIONS FOR SERVICE: SERVICE ON ALL DEFhNDANTS X CERTIFIED MAIL _ _ ORDINARY MAIL COURT ORDER POST PROPERTY X _ DEPUTIZE COUNTY (WITHIN PA. ONLY) DEPOSIT$ REGISTERED MAIL _ (OUTSIDE OF THE UNITED STATES ONLY) PERSON IN CHARGE _. OTHER SPECIAL INSTRUCTIOEIS: PLEASE ATTEMPT SER@ICE THREE TIMES AND PLEASE POST THE PROPERTY ADDRESS. NJ/PA: 1020 N. Kings Highway/ Suite 210/ Cherry Hill, New Jersey 08034/ (856) 755-1560/ Fax (856) 755-1570 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANLA IN RE: Lynda Ii. Summers Washington Mutual Bank, (n) MOVANT, vs. Lynda H. Summers RESPONDENT(S)/DEBTOR(S) Charles J. Dehart,III, Trustee RESPONDENT/TRUSTEE BKY CASE NO. O1-05871/RJW CHAPTER NO.: 13 11 U.S.C. SECTION 362 ORDER MODIFYING §362 AUTOMATIC STAY AND NOW, this 9th day of August , 2002, at the MIDDLE District of Pennsylvania, upon failure of the Debtor to file an answer within the time allowed, appear or otherwise respond to the Motion of the above-named Movant for Relief from the Automatic Stay, and for good cause shown, it is: ORDERED AND DECREED that the Automatic Stay of all proceedings, as provided under §362 of the Bankruptcy Reform Actof 1978 (The Code) 11, U.S.C. §362 is modified to allow the above-named Movant, its successors or assigns to proceed with, or to resume proceedings in mortgage foreclosure, including, but not limited to, Sheriff's or Marshal's Sale of X02 Appalachian Avenue, Mechanicsbwg, PA 17055; and to take action, by suit or otherwise as permitted bylaw, in its own none or the nanie of its assignee, to obtain possession of said premises. FiJRTHER, this order shall take effect immediately without regard to Bankruptcy Rule 4001(a)(1). 1st 9oh~ J.'Elaomas UNITED STATES BANKRUPTCY JUDGE. cc: Robert W. Cusick, Esquire SPEAR & HOFFMAN, P.A. 1020 North Kings Highway, Suite 210 Cherry Hill, NJ 08034 856-755-1560 ~~ ug ~, ~~ ~,.