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Home My WebLink About01-05881 ~ WASHINGTON MUTUAL HOME LOANS, INC, SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP, I IN lHE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs, ACTION OF MORTGAGE FORECLOSURE JANET A. V ANVOORHEES AND JEFFREY D, V ANVOORHEES Defendants .0/- 6ftl ~ TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and '!'il!Ag 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 liJI<, ~ase may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to yon. 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 TIlE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. J ~" ,1.\., J L,; CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300, \,; CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 1-'[1" >.,: f~j \!';"\ ;;"-Cj'~":!i![lj~" .. ~""""'~". I - '1 ~~~ WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE JANET A. V ANVOORHEES AND JEFFREY D. V ANVOORHEES, Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S,C, 1601 \",,'_/\( Si'( FL.!- The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed, Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid, If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. , ,"-\' J..,\ ,!':-:F, "", /, PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 171 02 (717) 234-4178 Attorney I.D,# 15700 Attorney for Plaintiff :"'F;;1~:r.'r,,,,,,o,, ,," ". ."- r -~, ",~ , ,~ WASHINGTON MUTUAL HOME LOANS, INC, SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW Q/-6~1 ACTION OF MORTGAGE FORECLOSURE JANET A. V ANVOORHEES AND JEFFREY D. V ANVOORHEES, Defendants COMPLAINT IN MORTGAGE FORECLOSURE .,,1. Plaintiff is WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY ':'\ ~ "'; MERGER TO FLEET MORTGAGE CORP" is a corporation whose address is P.O. BOX 1169, DEPT, 2665, MILWAUKEE, WISCONSIN 53201. f; , 2. Defendant, JANET A. V ANVOORHEES, is an adult individual whose last known address is 7005 i /\' SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, JEFFREY D, V ANVOORHEES, is an adult individual whose last known address is 7005 SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055. 3. 011 or about, June 23,2000, the said Defendants executed and delivered a Mortgage Note iIl the sum of $70,950.00 payable to GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P., which " , Note is attached hereto and marked Exhibit "A", ,,-\ 4, Contemporaneously with and at the time of the execution ofthe aforesaid Mortgage Note, iIl order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office ofthe within County and Commonwealth in Mortgage Book 1621, Page 581 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FLEET MORTGAGE CORP. and was recorded in the aforesaid County in Book 647, Page 809. 5. The land subject to the Mortgage is: 7005 SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto, ";_r-",,'-l-il'!*~~~ _ ~u" ,,~ , ~'-' " " "~ - k 6, The said Defendants are the real owners of the property. 7, The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on May 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $70,617.24 Interest at $18.13 per day From 04/0112001 To 1110112001 ( based on contract rate of 9.3 7 50%) $3,879.82 Accumulated Late Charges $0,00 Late Charges $26,29 From 05/01/2001 to 1110112001 $157,75 Escrow Deficit $371.86 Attorney's Fee at 5% of Principal Balance TOTAL $3,530.86 $78,557.53 **Together with interest at the per diem rate noted above after November 01,2001 and other charges and costs to date of Sheriff s Sale, 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 that are actually incurred by Plaintiff. 8, No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00, 10, Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. '.4'!'I"1r;1:.,:,'V"_"" ,"'_ '" "," H,_, " " ~ - ~ '. "I ~--.>"."". ~-~...... ~:. r~, 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No, 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 9,3750% ($18,13 per diem), together with other charges and costs including eScrow advances incidental thereto to date of Sheriff s Sale and for foreclosure and sale ofthe property within described, By: PURCELL, KRUG & HALLER Leon P, Haller, Esquire Attorney for Plaintiff LD, # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) ~~);d I' ''-''!'11': :nw~__,~, ~-."C"...._,' ~ .' '. .. "- ~, , ~T' - ~ -r r:'~_,~~~ ~,I "---...,. Frnc52392 (1696x2200x2 tiff) [13] MuItistate .' .-'... \. ~ ~ '"~I^'~'Al ,. . ,I" "'~ \Ht "'i ~ '\ " .. NOTE FHA-138047 ; - -- . - '; I ,~ , L/o I.t/IT957 ! FHA Case No. 441-62~187.8 .../-'" June 23 , 2000 [Date) 7006 SALEM PARK CIRCLE MECHANICSBURG, PA 17055 [l'roperty All_I 1. PARTIES "Borrower' means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P. and its successors and lI88igns, 1. BORROWEIVS PROMISE TO PAY; INTEREST In return for a loan received from Lender, BorroWClpromises to pay the principalswn of Seventy Thousand Nine Hundred Fifty and nO/100 Dollars (U.S. $ 70,950.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the dale of disbursement of the loan procee~ by Lender, at the rate of Nine and Three Eighths percent ( 9.376 %) per year until the full amoUJll of principal bas been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is securedby a mortgage, deed of trust or similar security inst:nunentthatis daledthe same date ....lbis Note and called the 'Security Instrument,' The Security Instrumentprotecls the LenderfrOJJ1losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) 11me Borrower sball make a payment of principal and interest to Lender on the first day of each month beginning on August ,2000. Any principal and interest rem";ni'1g on the first day of July 2030 , will be clue on that date, which is called the "Maturity Date." (B) Place Paymentshall be made at 600 OFFICE CENTER DRIVE, SUITE 325 FORT WASHINGTON, PA 18034 or at such. place as Lender may designate in writing by notice to Borrower. (C) Amouut Eachmonthly payment of principalandinterestwill be in the amountof U.s. $ 690.13 , This amO\mt will be part of a larger monthly payment req1lired by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment .41ustments If an allonge providing for payment adjustmentsis executed by Borrower togetherwith this Note, the covenants of the allonge shall be incorporatedinto and shall amendand supplementthe covenants of this Note as if the allonge were a part of this Note. [Check applli:able box] .. o Graduated Payment AllongU Growing Equity Allonge 0 Other [specify] 5. BORROWEIVS RIGHT TO PREPAY Borrower bas the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month, Lendersball acceptprepaymemon other days provided thatBorrowerpays interestou the amonntprepaidfor the remainderof the month to the estentrequiredby Lender and permittedby lCl!nlations of the Secretary, If Borrowermakes a partial prepayment, therewill be no cIlang<is in the due date or in the amountol the mODthly payment unless Lender agrees in writing to those changes. . ..- FJUMultlstateFlsed'RateNote...oo,S.' ~ -1ft (86011.0' CD VMPMORTGAOEFOAMS'(800)521"12,~' . Page 1 012 Inltl . I001R1oFnn . . f' 1~1~1111~ 1111//1111111111111111 tXHtSIT IlA~.1 "".~H'~' ;~, >r~ - '_0' I~~ I -,~" -~<< "~~...~.~~. ~ "" ~m_ ,~~~~ ~~-~ -- Fmc52392 (1696x2200x2 tiff) [14] FHA-138047 6. BORROWER'S FAILURE TO PAY (A) Late Cbarge for Overdue Payments If Lender has not received the full moothly paymentrequil'edby the Security Instrument, as descrihedin Paragraph 4(C) of this Note, by the end of fifteen calendar days after the paymellt is dne, Lender~y coI1ect a late charge in the amount of FOUR percent (4.000 %) Of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any mOnthly payment, thenLendermay, exeept as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full Of the principal balance remaining due and all accrued iuterest, Lender may choose not toexerclse this option Without waiving ~ rights in the event of any subsequent default. In many cirCllIll8tancesregulations issued by the Secretaty will limit Lender's iights to require immediatepaymellt in full in the case of payment defaults, This Note does, not authorizeaccelerationwhen I\Ot permittedlly HUDregulations, As used in this Note, "Secretary" mellll8 the Secretary of Housing and Urban Development or his or her designee, (C) Payment of Costs and Expenses If Lender has requiredimmediatepayment in full, as descn'bedabove, Lender may requireBorrowerto pay costs and expenses u>c1ud;"g reasonableand customary attorneys' fees for enforcing this Note to the extentnot prohibited by applicable law, Such fees and costs sha1l bear interest from the date of disbursement at the same rate as the principal of this Note, 70)'750' ~ 7. WAIVERS Borrower and any other person who has obligations W1der this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to requireLenderto demandpayment of amounts due. "Notice of dishonor" mellll8 the right to require Lender to give notice to other perSons that amounts clue have not been paid. 8. GMNG OF NOTICES Unless applicable law r"'luiresa different method, any notice thatmust be given to BorrowerW1der this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lenderunder this Note will be given by first' class mail to Lender at the address statedin Paragraph 4(B) or at a differellt address if Borrower is given a notice of that different address, 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is ful1y and personally obligated to keep all of the promises made in this Note, including the promise to pay the foil amount owed, Any person.who is a gnarantor, surety or endorser of this Note is also obligated to do these things, Any person who takes over these obligations, including the obligations of a gnarantor, surety or endorserof this Note, is also obligated to keep all of the promisesmadein this Note. Lendermay cnforceits rights underthis Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note, BY, SIGNING BEL00' Borrower accepts and agrees to the lermsand covenants rnnt.;n..tiin this Note, /7i1 I) V()hi.di~_~h"C ",l,),,"()~ ~ANVOORHEES I, -Bonowcr ET A VANVOORHEES - (Seal) ~Borrower (Seal) -Borrower (Seal) -Borrower (Seal) ,Bonowcr .. ~1R 188011.01 .. \IIlilhoul Recourse Fleet rtgageCorp. \ of' (Seal) , -Borrower fLEETMORTGAGE CORF'. 10 Ihe order of (Seal) Gat av Flllndlng Diversified Mortgage -Borrower Se cea, L.P. ' By 8 General pa~Undlng, Inc, Antho . Bruno Asst. ce President r.sy lvltlt:,6rElerQ1 (Seal) -Borrower 10D1R2,Fnn ,''jOf~, "T-"_ ,,"'3'>'~,~,:,__.^,~,,- ~,"- , ,~ -" , -~ . 1 ,~.^ ,~._,,._ - - Fmc52392 n,696x2200x2 tiff) [24] MAY-14'2001 12'21 FROM:8EINHAUR CURCILLO 717-651-9200 TO:C!15591E1221 P,010/014 EXHIBIT A 7005 Salem Park Circle Mechaniesburg, P A 17055 parcel No, 10-19-1606-096 : j~...: ALL THAT CBRTAIN piece 01 parcel of land situate in Hampden Township, Cumberland' County. Pennsylvania, more particularly bounde4 and described as follows, to wit: BEGINNING at a point on the line of adjolner between Lots 121 and 122 as shown on the hereinafter mentioned plan of lots, said point also being measure4 in a southerly direction a distance of 40 feet from the southern line of inlersection with a 10 feet wide cart path; thence by the ] Ine of adjoiner between Lots 121 and 122 aforesaid, Souib 22 degrees 29 minute!? 3S seconds West a distance of l00.0Jeet to a point; thence North 67 degrees 30 minutes 2S seconds West along common grounds now or formerly of The Homestead Group, Inc. a distance 'Of 20.0 feet to a po!!!t; thence North 22 degrees 29 minutes.35 seconds East along the line of adjolner between Lots 122 and 123 on Said plan a distance of 100.0 feet to a point; thence South 67 degrees 30 minutes 2S seconds East along other common grounds a distance of 20.0 fcetto a point, the place of BEGINNING. BEING Lot No. 122 on Plan of Salem Park Land Development, which Plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 25, Page 12. HAVING thereon erected a townhouse type dwelling known and numbered 700S Salem Park Circle. ~ BGod621raGf. 589 EXHibIT I~e/' "~Bf'~'--'''~_~.'.'; ,~'" ., ',e"__^, ~_ """'-:1 ,- ~~',< .~""'l'_ __ " " ,,-, VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR ,IN INTEREST BY MERGER TO LFEET MORTGAGE CORP. said facts Contained herein are made subject to the penalties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorities. Date: October 8, 2001 Leon P. Haller, Esquire ,;",>~"4'll"",' _~_,_,., .'''",-n---.'' 1-- ,,,' '7" " . " ,,~ ='-","'"" -", ~ ~. H~" -~ '. "~. "' ,-~~ ~, '<_."_ ~ r:. ~~ 't-' -g; t ';::::, ~ ,,,,", ~ .-- <J.1 ? '->J ~ ~ J ~ ~~, -f:;-- Cs-,) ~- , <:.^ ''''' ~-<;,' D -;-;-- --;--J.'," L7"1,'; C'. ::-c ,:.,) Ie- ':"J '-' ~""i ......-. r"~, ('-:,. " .-r, J I;.. JL.e~~,,_l$1)':!:~ JlW'~'If~!li'l~ii1r~~~.., '^" ~WtW"'-':'Y"I"'~''''''ii'.'~''''--<''':''~'';'''\i~~j'~'q~'~.~~~~~'fflij~~~'-l1'\!~ifi1ii",~~;~~"lli:'; ~ , SHERIFF'S RETURN - REGULAR CASE NO: 2001-05881 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS VANVOORHEES JANET A ET AL 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 VANVOORHEES JEFFREY D the DEFENDANT , at 1009:00 HOURS, on the 17th day of October ,2001 at 7005 SALEM PARK CIRCLE MECHANICSBURG, PA 17055 by handing to JEFFREY D VANVOORHEES a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6,00 7,15 ,00 10,00 ,00 23.15 ,~~~ R. Thomas Kline 11/07/2001 PURCELL KRUG HALLER Sworn and Subscribed to before me this /3 ~ day of By' 1l h . ~ AAIJHl 7ll. a/ltia-r- Deputy Sheriff ~~~<J~,/ ~/ A,D. ~tZ /?u;/,.,.~ thonotary , . '^';~-""""'... :r,~J.., _ ~__ 0, I ~"."~~,m~W'""""""","',,,,,..___,," ~~. - ~ , SHERIFF'S RETURN - OUT OF COUNTY C~SE NO: 2001-05881 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS VANVOORHEES JANET A ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: VANVOORHEES JANET A but was unable to locate Her in his bailiwick, He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On November 7th, 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York Co 18,00 9.00 10.00 30,35 ,00 67.35 11/07/2001 PURCELL KRUG So answe~~ ~- -' R, omas Kline Sheriff of Cumberland County HALLER Sworn and subscribed to before me this ""', /.3,,/' day of n,~"".I.J , d()fj/ A,D. C},.~ eo~;~~t~~~' '~~,,',q,=~IIIl',..,._ "'~,~ ,. , -, r~'~' --" l.; COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-%01 28 EAST MARKET ST" YORK, PA 17401 SHERIFF SERVICE . PROCESS RECEIPT and AFFIDAVIT OF RETURN ,. PLAINTIFF/SI Washington Mutual Hane Loans Inc. 4. TYPEOFWRITORCOMPLAINT 3. DEFENDANT/SI Notice and Canplainlm Janet A. Vanvoorhees et al Mortgage Foreclosure 5. NAME OF INDIVIDUAL. COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED, OR SOLD Janet A. Vanvoorhees 6. ADDRESS (STREET DR RFO WITH BOX NUMBER, APT, NO" CITY, BORO, lWP., STATE AND ZIP CODE) 923 Emanuel Road Lewisberry, PA 17339 7,INDICATESERVICE, QPERSONAL QPERSONINCHARGE xx.OEPUTIZE Cum~f'l~'L Q1STClASSMAlL QPOSlED QOTHER October 22 , 20Jl.!.... I, SHERIFF OF ~ COUNTY, PA, d hereby deputize the sheriff of York COUNTY to execute t ake return ccording to law, This deputization being made at the request and risk of the plaintiff, ~"'...... ~.c: SERVE .. AT { NOW 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: ADVANCE FEE PAID BY ATTY NOTE~ ONLY APPLICABLE ON WRIT OF EXECUTION: N~B. WAIVER OF WATCHMAN. Any deputy sheriff levying upon or attaching art1 property under wfthin writ may lea..e same without a watchman, in custOdy of whomever is found in possession. after notifying person of levy or attachment, without liability on the part of such deputy Of the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPj:~~ME and ADDRESS of ATIORNEY I ORIGINATOR and SIGNATURE Lt.'UN P. HALLER, ESQ. 1719 N. FRONT ST. HARRISBURG PA 7 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW (This area must be completed if notice is to be mailed). 10. TELEPHONE NUMBER 11. DATE FilED (717) 234-4178 10/11/01 ._01:''''. 15. Expiration/Hearing Date J. LUDWIG , 6. HOW SERVED: PERSONAL o RESIDENCE ( POSTED ( ) POE( ) SEE REMARKS BELOW 12 41. AFFIRMED and subscribed to before me this 42.dayof NOVEMBER ,200143, I'l "JAI. SEAl MELISSA J: $I:IAFF""'~1Io1Bry I'ilblc City 01 v. York n. fAI,' (~mi?-.!'lSl: .XI) A , ~,2002 2 y 44. Signature of Dep. Sheriff . Signature of York County Sheriff WILLIAM M. SEfi~ 11-2-01 49. DATE 51. DATE RECEIVED 1. VVHITE. Issuing AuthOrity 2. PINK ~ Attornev 3. CANARY - Sheriff's Office 4. BLUE - Sheriffs Office ~7"-'" '-~~_"~~'\''F~'='"Jo-'-''i''''''~'''=''"-'"''''''''''''''"''''.''''"''''''''''"''''''''~''''''--:'''''''""'_~"''l'~''''''Ift''1''nlJ"l '" __, ,",,,""=-''T''M'\'''''''''''''"~~''''''''''I"''l''''''''>'~=''''''ln,,,,,,,,o~''''''''=''''''''''''''''''~'''=''''''_'''~_''"''_'''_''''''''''~. . " --, "" "'1 COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 2B EAST MARKET ST, YORK, PA 17401 :;":" Washington l"JUtlJal Hane Loans , 3.' DEFENDANT/SI 1. PLAINTIFF/S~ 2, COURT NUMBER 1-5881 civil 4, Tf~'MlJI.08C~NT, cI, N=ce--:'B1Q re~~.lalnl'-,-n Janet A.=~anycorhees et al ~Drtgage Foree osure { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERlY TO BE LEVIED, ATTACHED, OR SOLD. Jan,;,t A. vanvoorhees 6. ADDRESS (STREET OR RFO WlTH BOX NUMBER. APT. NO" CITY. BORO, TWP" STATE AND ZIP CODE) 92.3, Ell1anuel, Road. ,Lewisberry. PA;i7339. '" 7, INDICATE SERVICE: '. a PERSONAL,. a PERsON IN CHARGE liiIDEPUTI~E O~tober .-;,2 York COUNTY to execute to law. This deputization being made at the request and risk of the plaintiff, Inc. SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN SERVE .. AT a POSTEP a OTHER NOW 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: "':,,.. \DVANCE PEE PAID BY ATl'Y NorE: O,NL Y APP-LlCABLE ON WRIT OF E)Q:CUTlON: N.S._ WAIVER.OF'WATCHMAN .,- Any deputy sheriff levying uppn or ~ng 'any -property'under within Writ may leave,same without a watchman, in custody of whomever is found-in possession, after notifying person of levy or attachment. without liability DfI,the part Qf'such deputy or the sheriff to, any-plaintiff. herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9, TYPf,B ~~. A?Jm,M{ ~-rw~:Y I .oRIGINATOR a~d S~!lNAlURE 10, TELEPHONE NUMBER 11. DATE FILED 1719 N. FRONT ST., HARRISBURG,PA 17102.'(7117)~ 234-417B 10/11/01 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW' (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SHERIFF 16. HOW SERVED: POSTED ( ) POE( ) 10/23/01 SHERIFf'S OFFICE Vf OTHER ( ) ,. SEE REMARKS BELOW ;.~ 13. I acknowledge receipt of the writ or complaint as indicated above. oJ ~ LUr)l;.AJIG 22, REMARKS: r.- ,,/ ,,'f 41.AFFIRMEDand5Ub~bed_to~etor~,~';'thi~<' 2 ,', \ _ , SOAN~,._.- 4Zdayof NO\lEMBt.R .'" ,20 Jl143, ,....--- 44, Sign~~:__y{/CkY"7/",-fto/}---,.- PRQTH~~~Y..46: Signature 01 York .,' _;' '. ' :"" "-. --~ .- -60u~,Sheriff-_ .'~ (, ,,-- --;f-r;~-t:.;,It.;' " ,;.~-./'-, _. . WILLIAM M. H'OSE,,/ (.-.2>;:;:::'l/~V'~-e.. ... ;."/ l:J' < ._," j ~~. tir //- 'F_ 48.. Signature of Foreign .-'~ /" i'j:....v~~.:.../:,1... _,,:tlj~'(-''''''''' ..&;,-,/ County Sheriff 50. i#lCKNOWLEDGE RECEIPT OF.THE,S IFF'S ETURN SI!lNATURE OF AUTHORIZED ISSUING AU-OJ;ORI 'AND TITLE 1 , :'''23. Advance Ceists :: 75 , 00 1 B. 00 ~ ''J4. foreign County Costs 32. Tot. Costs . Costs Due or Refund Check No. 44. 65 1'-t1~C) 40. Costs Due Of Refund 45. !;lATE! / J) J ~C-' , 47. DATE 11-2-01 49. DATE 51. DATE REC!;:IVED '" 1. vvHlTE - Issuing Authority 2. PINK - Attorney 3. CANARY. Sheriffs Office 4. !3LU~ - Sheriffs Office .....",: .~- I-- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WASHINGTON MUTUAL HOME LOANS, lNe. SUCCESSOR IN lNTEREST BY MERGER TO FLEET MORTGAGE CORP. vs, ACTION OF MORTGAGE FORECLOSURE .. JANET A. V ANVOORHEES AND JEFFREY D, V ANVOORHEES Defendants -A'O{-f'1Y[ ~ TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORM~TIQN OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 \y.ithin twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attomey 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 tl~ 9ase may proceed without you and a judgment may be entered against you by the Court without further notice for any money ~laim in the Complaint of 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, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TI!E OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. , , .,.' " " CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 717-249-3166 A VISa LE HAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CON1RA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARlO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISa. PARA DEFENDERSE ES NECESSARlO QUE USTED, 0 SU ABOGADO, I<I\!JISTRE CON LA CORTE EN FORMA ESCRlTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION G8l'lTRA LAS QUEJAS EN ESTA DEMANDA. ".. " RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P!:\ltTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARlO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. paR RAZON DE ESA DEClSION, ES POSSffiLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. ( \,0 SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE TRUE COPY FROM RECORD CARLISLE,PA 17013 In Testimony wner8Cf, I b8nI umo SI!t mv hano 717-249-3166 ,iidithe seal of CouC/U1lill8. Pi. nl' Ol. O(f I Lj ':. -"';"'",< 'L~~~, ,_~ ,;"'0_ _~"""""',~ """'"I - ~~~ ,~,-~ ~ ,"",,, ~.~ --. B WASHINGTON MUTUAL HOME LOANS, INC, SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP" Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE ~ JANETA,VANVOORHEESAND JEFFREY D, V ANVOORHEES, Defendants THE FOLLOWING NOTICE IS BEING PROVIDED,PURSUANT TO THE FAIRDEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 " ~ > \, ;'\ !' L ; The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose, The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed, Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is ; ,',' . valid, If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day ; ,; period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor, Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address ofthe original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff 1!:'V''-7>'F1W'l'i<'kmO -" ~,~ ~ -. ~ -" -, ~ . ~~- -- - - , HI - '''" . "'" WASHINGTON MUTUAL HOME LOANS, INC, SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP" Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW vs, ~TION OF MORTGAGE FORECLOSURE JANET A. V ANVOORHEES AND JEFFREY D. V ANVOORHEES, Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1, Plaintiff is WASHINGTON MUTUAL HOME LOANS, INe. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP" is a corporation whose address is P,O, BOX 1169, DEPT. 2665, MILWAUKEE, WISCONSIN 53201. r, 2, Defendant, JANET A. V ANVOORHEES, is an adult individual whose last lmown address is 7005 j.,\. SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055, Defendant, JEFFREY D, V ANVOORHEES, is an adult individual whose last lmown address is 7005 SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055. '., j" 3, On or about, June 23, 2000, the said Defendants executed and delivered a Mortgage Note in the sum of $70,950,00 payable to GATEWAY FUNDING DIVERSIFIED MORTGAGE SERVICES, L.P" which Note is attached hereto and marked Exhibit "A", 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1621, Page 581 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FLEET MORTGAGE CORP, and was recorded in the aforesaid County in Book 647, Page 809, 5. The land subject to the Mortgage is: 7005 SALEM PARK CIRCLE, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. -"c">";-"h~."_ ,,"" ,,0-. " ' f -'~<~~ -~""'~....., . "~- ~,~-,~~~ -.. . ""'-- 6. The said Defendants are the real owners of the property. 7, The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on May 01,2001 and all subsequent installments thereon, and the,following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $70,617,24 Interest at $18.13 per day From 04/01/2001 To 11/01/2001 (based on contract rate of 9.3750%) $3,879,82 Accumulated Late Charges $0,00 Late Charges $26,29 From 05/01/2001 to 11/01/2001 $157,75 Escrow Deficit $371.86 Attorney's Fee at 5% of Principal Balance TOTAL $3,530,86 . $78,557,53 **Together with interest at the per diem rate noted above after November 01, 2001 and other charges and costs to date of Sheriff s Sale. 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 that are actually incurred by Plaintiff, 8, No judgment has been entered upon said Mortgage in any jurisdiction, 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No, 6 of 1974 is not required in that the original principal balance exceeds $50,000,00, 10, Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended, -'~P;"fC~~~, . -'''",'"<}~.'" o~"1'F' ~c 0 , "~~~ -. ^ 11, The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions ofPeunsy1vania Act No, 91 of 1983, WHEREFORE, Plaintiff demands judgment in mortgage fareclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 9.3750% ($18.13 per diem), together with other charges and costs including escrOW advances incidental thereto to 'date of Sheriffs Sale and for foreclosure and sale ofthe property within described, By: PURCELL, KRUG & HALLER Leon P, Haller, Esquire Attorney for Plaintiff I,D, # 15700 1719 N, Front Street Harrisburg, P A 171 02 (717-234-4178) j , : i . : ~ ::;::d ( ,-,,(:: I:,'"-,~,,,,,,,,,-,~ "" ., ,e ,,"'''_ ,_ _ ~ ~. '" --I "'~<, -, ~ . ,.."".,.~-' ~- Fmc52392, (1696x2200x2 tiff) [13J Multistate " .':.", ~; ~ ('I':JI~I( ~,' 1\1 \'!'. * ~ ~ t\f-;t.~1 "- NOTE FHA-13B047 Jt> / J/ IT9'.s/ I PIfA ~ No. 441F~1B7.8 I .'./" ~ .- ,. . - - f I ,~, f . " I June 23. 2000 [Date) 7005 SALEM PARKCIRCLE MECHANICS BURG. PA 17055 [l'roperty Ad-J 1. PARTIES 'Borrower" means each person siguing at the eDd of this Note, and the person's successors .u assigns. 'Lender" means GATEWAY FUNDING DIVERSIFIED MORTGAGE$ERYICES, L.P. and its successors and assigm. 2. BORROWER'S PROMISE TO PAY; JNTEREST In returnfor a loan received from Lender, Borrowerpromises to pay the princlpalSUlll of 'Seventy Thousand Nine Hundred Fifty end nO/l00 Dollars (U,S, $ 70.~50.oo ), plus interest, to the order of Lender. Interest will belcharged on lInpaid principal, from the date of disbursement of the loan proce~ by Lender, at the rate of Nine and Three, EighthS percent ( 9.376 %) per year until the fo1l amount of principal has been paid. 3. PROMISE TO PAY sECURED Borrower's ~e to pay is securedby a mortgage, deed of trust or similar security iDstrumejltthatis datedthe same date as this Note and called the "Security Instrument," The Security Instrumentprotecls the Lenderfromilosses which might result if Borrower defaults under this Note, 4. MANNER OF PAYMENT (A) 'llme Borrower sIWl make a pa:yD1l>1lt of principal and interest to Lender on the first day of each month beginDing on August ,2000. Any priucipal and interest rem.nning on the first day of July 2030 , will be due on that date, which is called the "Matmity Date." (B) Place Paymentshall be madeat 500 OFFICE CENTER DRIVE, SUITE 325 FORT WASHINGTON. PA 19034 or at auch place as Lender may designate in writing by 1I0tice to Borrower. (C) AmOUllt EachmOl1th1y paymentof principal andinterestwil1 be in the llJIIOUIItof U.S. $ 590.13 , This amount \\IiIl be part of a larger!lIlOJIthIy payment required by the Security Instrument, that sbaJI be appIi<<I to principal, interest and other items in the order. described in the Security Instrwnent. (D) AIIoage' to this Nole for pa,...-lUlJllItme1lfs If 11I1 aIloIIge providiDg for pa:yD1l>1lt ~entsis cxecutedby Borrowectogetherwilh this Note, the covenants of the allonge shall be incotporatedinto and sIWl ameDdand aupplementthe COVC1lIl1lta of this Note as if the allonge were a part of this Note. [Check appliclible bOKJ . o Graduated Payment AlIOt1ge[] Growing Bquity ADonge 0 Other [specify] 5. BORROWER'S RlGllT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in JllITt, without clutrge or penalty, on the first day of any month, ~sIWl acceptprepaymentOll otfrer days provided thatBOttOWerJll4P intereston the amountprepaidfor. the ~emainderof the mot\th ~o the extent~by Lender and.perm;ttedby rl'f'I."1J1I8 of theSccr~, If Borrowexmakes a p~ prepayment. tberewil1 be 110 c:\umgtla m the due date or m the amounto the lIlOJIthIy pa)'Jlllilll unless Lender agrees in writillg to those changes. . _ FHA MuIlfstale PJxed'IIateNDte .10195. : ~ -1R (88011.01 . .. VMPMORTQAQEFORMS.C'OOJ&2'472~' . Poge 10f2 lnlll 101l1Rl.Frm .' . f' t:XHH3!T iIA!' :mnlllllll .' <';~'0WI';'~'~1l'i'L _ ,_ ~ ~ ..,..,..~ --' ,,---" - ~,,' ~...., -~-~~= Fmc52392 (1696xnOOx2 tiff) [14] , FHA-138047 6. BORROWER'S FAILURE TO PAY , (A) Late Charge for Overdue Payments . rf Lender has not received the full monthly payment required by the Security Inslrllln$t, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the p~yment is due, Lendermay coIIe<it a late charge in the amount of FOUR percent (4.000 %) of the oveJidue amount of each payment. (B) Defanlt rf Borrower defaults by failing to pay in full any monthlypa}'ll1ent, thenLendermay, ~t as limited by regulations of the Secretaryin the case of payment defaults, require immediate payment in full of the princip~ balance rP.l1lA;n;ng due and all a=ued interest. Lender may choose not to exercise this option without waiving its rights inl the event of any subsequent default. In many circumstancesreguIations issued by the Secretary will limit Lendl\r's rights to ~immediate payment in full in the case of payment defanlts. This Note does not authorize acce1erationwhenilOt permittedl>Y HUDregulations, As used in this Note, .Secretary" means the Secretary of Housing and Urban Development or his or her dbsignee. (C) Payment of Costs and Expenses rf I.enderhas requiredimmediatepaymentinful1, ,as described above, Lender, ma~~Borrowerto pay costs and expenses including reasonableand customary attorneys' fees forenforcini this Note to the DOt proIn'bited by applicable law, Such fees and costs shall bear interest from the date of disbursenient at the same rate as thelprincipal of this Note, 70) cr "SO " ~ 7. WAIVERS Borrower and any otlwr person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" meanstherigbt to requireLenderto w.mAn4paymentof amounts due. "Notice of dishonor" meansthe right to require Lender to give notice to otlwr persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requireia different method, any notice that must be given 10 Borrowerunderthis Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lenderunder this Note will be given by fu:st'class mail to Lender at the address slated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBUGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each personls fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amouutowed. Any person.who is a goarantor, surety or endorserof this Note is also obligated to do these things. Any person who takes over these obligllflO11", including the obllgations of a guarantor, surety or endorserof this Note, is also obligated to keep all of the promisesmadein this Note. LenderIDll)' enforceits rights underthis Note against each personindividual1y or against all signatories together..AIlJ OIW person sigoing this Note may be required to pay all of the amounts owed under this Note, BY S GNlNGBELO'~r Borroweraccepts and agrees to the terms and eovenants r.nnrninp.o;\in this Note. . VCMV( ~ (Seal) ~(J Ill.T It. \.)cu.J)~ Y VANVOORHEES ...Jlorrowor ET A VANVOORHEES .. (Seal) -Bonower (Seal) -Borrower (Seal) -Borrowe:r ~.1RI8eOll.01 .. Without RecoUlse Fleet rtgageCorp. \ ... (Seal) . -BoJ'[OWl:J' F1EErMORTGAGE CORP. 10 \he order of (Seal) Gat llY Funding Dlverslfuod Mortgage -Borrower &e ..... LP. . By General p~Undlng, Inc. . Bruno ce President (Seal) ..Jlorrowe;r f""rsy IV If.e. ~'Eler Q1 (Seal) -Borrowor 10D1R2.Frm -C-n-'r7-",o-.'fi~~" ,,,_, _, "c ~ ~'~" _" " 1 ,=~"~~", - "t- .,.,,,--,,,,,,, ,. , '" ~~,_ < -"-'~=,"_U_~!IIo"' Fmc52392 (1696x2200x2 tiff) [24] < MAY-14-20~1 12:21 FROM:BEINHAUR CURCILLO 717-651-9200 TD:2155910221 P,010/014 EXI-nBIT A 7005 Salem Plll'k Circle Mechanic~burg, PA 17055 l'arcel No', 10-1!l-1606,O96 :l'-l ALL THAT CERTAIN piece or parcel of land sllUlltc in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and describ,ed as follows, to wit: BEGINNING at a point on the line of adjoiner between Lots 121 and 122 as shown on the hereinafter menlioned plan of lots, said point also being measured in iil southerly directiOl! a distance of 40 feet from the southern line of inlersection wim a 10 feet wide ClI1t path; thence by the Jlne of adjoiner between Lots 121 and 122 aforesaid, South 22 degrees 29 minut~ 35 seconds West a distance of lOO.O.feet to a point; thence Nort1167 degrees 30 minutes 2S sc<:onds West along common grounds now or formedy of The Homestead Group, me. a distance 'Of 20.0 feet to a po!gl; thence North 22 degrees 29 minutes.35 seconds EastalODg the line of adjol.ner between Lots 122 and 123 on said plan a dislance of 100.0 feet to a point; thence South 67 degrees 30 minutes 2S seconds East along other common grounds a diSUll\c!l of 20.0 feet to a point, the place of BEGINNING. BErNG Lot No. 122 on Plan of Salem Park Land Development, which Plan is recorded in the Cumberland Counly Recorder of Deeds Office in Plan Book 25, Page 12. HAVING thereon erected a townhouse type dwelling known and numbered 700S Salem Park Circle. -- . ~ !lllod621P1lGL 589 EX\--! I 5lT '~6'1 11':\," "': ,<-'J,_'_,_':_ -<'O:F;<W,,",'-":"F'?'<"c<-, ',~ _, _, 0 _ _ 'C> , ';"'~'_""',""'~'):I ,_, " - ~,,__>" e, "" ""'"" . "' VERIFICATION ~ I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO LFEET MORTGAGE CORP. said facts Contained herein are made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn falsification to authorities. Date: October 8, 2001 Leon P. Haller, Esquire """'_;"''''''it{RW~:,=~ ~. .~ " - ," ~ ,~ ',," "'-~,~-~ ~ ~ ~ "~ ~ . r-~""""'"~"': , . >.!i" Hh,' ;1.:1 i i i ~! !: r-r' (" c ~" .'11, j \ DO .:_:i,1U tiffi!!WB_.....,.""," ~"'""!~,,(;:... L JI!ilL~.JiJ!m!!!i~~~"'f"i'Jl'N~'!'1:;~''\l.''P~,*,'Q!'''~~~~~'!:lt!T'''-''''"---,'i"'F'j" . __~.'O ,l $tf9llf7t ~~~w~ "j'" " '_ ',},,; ,F:' ','''~:5;-'''''''''-~'''--''''';~'''~''i'1'''f'''''''\I<:;cl~J-;<V,H'~I::jiW~<1'S~",~;;o;;')~-qI'-'0!I.r~~,*~F' WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP, IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA PLAINTIFF VS, NO. 01-5881 CIVIL TERM JANET A. VANVOORHEES AND JEFFREY D. VANVOORHEES DEFENDANTS CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Kindly Settle and Discontinue the above matter of record. PURCELL, KRUG & HALLER BY'~ Leon P. Haller ID #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 13. 2001 "''''",-i''''_)o'.~. ,'^",,,-,,". ,n"',:' -, ",~ ,w, ""1""'_ '_,"F" '''$--0" . , - M _",~ _" 0 .-. ,"" ~O.~~"_ ~ "X'" '".'~-~ ", __,,,,,O~",' _,_ <,.,,"_,_ "'~"_~ ., ." (") 0 c): c: -'n :;;: :z " -o'er.: C;J ~n rrlm .c ',---'- Z::c ZS; -:~j:<':; ~l ,~ '- ::~:(:_) ;<c,' -c; -'; " ~o ~;~~ 0 J>c: ':: '~ z 0 5J =< c -< <:' /\,S' S Ilfr~ml8'fI!'l-~~f'"'' ~1Nnll::r:1!fT1\1'3a~~p(~3!/f-~~""""?!""":rm"~!!fiF,,,p",~;1~F,,j'~"\f~1:',!<",,",*,f.;.~~~lW;!fi~~~-!ioo.u:~,,__,!J .-. "~~