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Home My WebLink About99-03251{ 1 Iry MM' J •I? ?1 Qv?i) M ;? \ l ,r ?' FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 1215l 563-7000 FIRST UNION HOME EQUITY BANK, N.A. S/B/M TO FIRST UNION 11011E EQUITY CORPORATION 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607-5066 V. Plaintiff WILLIAM H. BROWN DEBORAH K. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. qq CUMBERLAND COUNTY CIVIL ACTION -.LA W MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. bltz?L 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 CUMBERLAND COUNTY PAR ASSOCIATION 2 LIBERTY AVFNUF. CARLISLE, PA 17013 (717) 249-3160 1. Plaintiff is FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607-5066 2. The name(s) and last known address(es) of the Defendant(s) are WILLIAM H. BROWN DEBORAH K. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/19/88 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 900, Page 659. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 9/5/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $15,521.39 Interest 1,373.97 8/5/98 through 5/1/99 (Per Diem $5.07) Attorney's Fees 800.00 Cumulative Late Charges 0.00 4/19/88 to 5/1/99 Cost of Suit and Title Search 550.00 Subtotal 18,245.36 Escrow Credit 0.00 Deficit 0.00 Subtotal 0.00 TOTAL $18,245.36 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A." 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "Bu. or (ii) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days. of receipt of this pleading, counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $18,245.36, together with interest from 5/1/99 at the rate of $5.07 per diem to the date of Judgment, and other costs and charges collect' le under the mortgage and for the foreclosure and sa a of I'Mhe mortgaged property. s ra c ma FRANK FED ERM N, ESQUIRE Attorney for Plaintiff First Union Mortgage Corporation ? Po OMce Box 900001 F e I ? o ? Raleigh, North Carolina 276769001 1100 Corporate Center Drive ti 1N Raleigh, North Carolina 276076066 WILLIAM H BROWN 45 CREEKSIDE DR ENOLA, PA 17025-2916 April 13, 1999 RE: FUMC Loan Number 0009793667 NOTICE OF INTENTION TO FORECLOSE First Union Mortgage Corporation is the holder of the mortgage on your property located at 45 CREEKSIDE DR, which mortgage is in SERIOUS DEFAULT because you have not made the current monthly payment of 274.72 for 09/05/1998 through 04105/1999. Late charges (and other charges) have also occurred in the amount of 0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is 2197.76. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, we will obtain and provide you with written verification thereof: otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, we will send you the name and address of the original creditor if different from above. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of 2197.76, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made in the form of certified check, cashiers check or money order, and made at First Union Mortgage Corporation, ATTN: Cash Processing, P.O. Box 900001, Raleigh, NC 27675-9000. If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly payments. If the full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If you cure the default before we begin legal proceedings against you. you will still have to pay the reasonable attorney's fees actually incurred up to 550.00. However. if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if thev are over $50.00. Any anomey s fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure this default within the THIRTY (30) DAY period, you will not be required to pay the attorneys fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN EXH1'31T A First Union Mortgage Corporation Post 0171ce Box 900001 Raisigh, North Carollna 27675,9001 UN toOCorpore Carolina 2760 66 ?0" 11 00 Raleigh, North Carolina Drive DEBORAH K BROWN 45 CREEKSIDE DR ENOLA, PA 17025-2916 April 13, 1999 RE: FUMC Loan Number 0009793667 NOTICE OF INTENTION TO FORECLOSE First Union Mortgage Corporation is the holder of the mortgage on your property located at 45 CREEKSIDE DR, which mortgage is in SERIOUS DEFAULT because you have not made the current monthly payment of 274.72 for 09/05/1998 through 04/05/1999. Late charges (and other charges) have also occurred in the amount of 0.00. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is 2197.76. You may dispute the validity of the debtor any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, we will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, we will send you the name and address of the original creditor if different from above. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of 2197.76, plus any additional monthly payments and late charges which may fall due during this period. Stich payment must be made in the form of certified check, cashier's check or money order, and made at First Union Mortgage Corporation, ATTN: Cash Processing, P.O. Box 900001, Raleigh, NC 27675-9000. If you do not cure this default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly payments. If the full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable anomey's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attomey's fees even if they are over 550.00. Any attomey's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure this default within the THIRTY (30) DAY period, you will not be required to pay the attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN EXHIBIT A THE FORECLOSURE PROCEEDINGS THE NON-EXISTANCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If yon have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total due, as well as the reasonable attorney's fees and cost incurred in connection with the foreclosure sale (and perfomt any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs Sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out any time exactly what the required payment will be by calling us at the following number: 1-800-654-1350. This payment must be in the form of certified check, cashier's check or money order and made payable to us at the address stated above. You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs Sale, a lawsuit could be started to evict you. You have additional rights to help protect your imerests in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOT14ER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU MAY HAVE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUfvISTANCE THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure this default, the mortgage will be restored to the same position as if no default has occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, V"&( 450fervlt David Smith Delinquency Control Mortgage Loan Servicing Group BLPA01 EXH?gtT A l?pN UN1 WILLIAM H BROWN First Union Mortgage Corporation Post Ofte Box 900001 Raleigh, North Carolina 27676,9001 1100 Corporate Center Drive Raleigh, North Carolina 276074066 45 CREEKSIDE DR ENOLA, PA 17025-2916 April 13, 1999 RE: FUMC Loan Number 0009793667 Property Address 45 CREEKSIDE DR ENOLA, PA 17025 From: First Union Mortgage Corporation, owner and holder or agent for owner and holder for the referenced Mortgagor (s). ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1-300.3422-397. La notificacion en adjunto es de sums inportancia, pues afecta su derecho a continuer viviendo en su casa. Si no cornprende el contenido esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al nurnero meniconado arriba. Puedes set elegible para un prestamo por el programs llamedo "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS You may be eligible for financial assistance that will prevent foreclosure on your mortgage if EXHIBIT B rigs UNION First Union Mortgage Corporation Post Me Box mool Raleigh, North Carolina 276769001 1100 Corporate Center Drive Raleigh, North Carolina 276075066 DEBORAH K BROWN 45 CREEK.SIDE DR ENOLA, PA 17025-2916 April 13, 1999 RE: FUMC Loan Number 0009793667 Property Address 45 CREEKSIDE DR ENOLA, PA 17025 From: First Union Mortgage Corporation, owner and holder or agent for owner and holder for the referenced Mortgagor (s). ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1-800-3422-397 La notification en adjunto es de suma inportancia, pues afecta su derecho a continuer viviendo en su casa. Si no corprende el contenido esta notification obtenga una traduccion immediatamente Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero meniconado arriba. Puedes ser elegible para un prestamo por el programa Ilamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS You may be eligible for financial assistance that will prevent foreclosure on your mongage if EXHIBIT B you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible far emergency temporary assistance if your default has been caused by circumstances beyond you control, you have a reasonable prospect of resuming you mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of you rights. Under the Act, you are entitled to a temporary stay of foreclosure of your mortgage for thirty days from the date of [his Notice. During that time you must arrange and attend a "face-to-fact" meeeti eting with a representative ol'the lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face to face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. Your mortgage holder is First Union Mortgage Corporation, 1100 Corporate Center Drive, Raleigh, NC 27607, telephone number I-800-654-1350. The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to face meeting. You should advise your lender immediately of your intentions. Your mortgage is in default because you failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is 2197.76. That sum includes the following: Total of 8 monthly payment(s) from 09/05/1998 to 04/05/1999 Late Charges 2197.76 0.00 Property inspections and NSF check charges, if any 0,00 Other charges accrued, if any 0.00 LESS: Suspense (unapplied funds): -0.00 TOTAL AMOUNT OF DELINQUENCY: 2197.76 Your mortgage is also in default for the following; reasons: N/A If you have tried and are unable to resolve this problem at or after your face to face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application fix assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency, Your applications must be filed or post marked, within thirty (30) days of your face-to face meeting. It is et tremelr impormnt that voa plc your application promptA, /f J»u do not do so, or iif rou do not jollou, the other times periods set /on7lr in tlu.v lerr •r. foreclosure mar proceed ggainst your home EXHIBIT B immediately It is extremely important that your application is accurate and complete ine everyrespect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision of your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or I-800-342-2397 (toll free number). Persons with impaired hearing can call 1-800-342-2397• In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called "Notice of Intention to Foreclose". You must read both notices, since they both explain your rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sent by Regular Mail, Certificate of Mailing (PS Form 3877) Sincerely, Z)44 a SMO/lt David Smith Delinquency Control Mortgage Loan Servicing Group BLPA02 i i sovall 5 PENNSYLVANIA HOUSING FI2MNCE AGMM= HOMEOWNER'S MMGHNCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES Aa era aauaiag Corporation 046 North Broad Street Philadelphia, PA 19130 (215) 765.1221 (215) 765-1427 (fax) Bucks, Chester., Delaware, Montgomery, Philadelphia Action Housing, Inc. Number Two Gateway center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 (412) 391-4512 (fax) Allegheny, Beaver, Butler, Payette, Greene, Washington, Westmoreland AN Credit Counseling Institute 175 Strafford Avenue, Suite 1 Wayne, PA 19087 (610) 971-2210 (610) 687-7860 (fax) Bucks, Cheater, Delaware, Montgomery, Philadelphia American Red Cross- Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 (717) 637-3294 (fax) Adams, York, Franklin Bedford-Fulton Housing Services R.D.81, Box 384 Everett, PA 15537 .(814) 623-9129 (814) 623-73.87 (fax) Bedford, Blair, Cambria, Fulton, Huntingdon, Somerset Blair County Baca Opportunity Council 2100 6th Avenue Altoona, PA. 16602 (814) 946-3651 (814) 946-5451 (fax) Adana Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 (814) 453-5749 (fax) Crawford, Erie, Warren Bucks County Housing Group, Inc. 140 S. Richardson. Avenue Langhorne. PA 19047 (215) 750-4310 (215) 750-4318 (fax) Bucks CCCS of Ventura Pennsylvania, Inc. 312 Chestnut Street Suite 227 Meadville, PA 16335 (814) 333-8570 Lawrence CCCS of Western Pennsylvania, Inc. Senior Activity Center 550 Main Street Johnstown, PA 15901 (814) 539-6335 Cambria, Somerset CCCS of Northeastern Pennsylvania 185 Elmira Street P.O. Box 218 Troy, PA 16947 (717) 297-2101 (717) 297-2799 (fax) Bradford,Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Northeastern Pennsylvania Human Services Building 541 Wyoming Avenue, Box 168 Scranton, PA 18501 (717) 342-1072 or 800-922-9537 (717)342-8040 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzerne, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. 1 North Gate Square P2 Garden Center Drive Greensburg, PA 15601 (412) 838-1290 Fayette, Greene, Indiana, Somerset, Washington, Westmo:eland CCCS of Delaware Valley 1515 Market Street Suite 1325 Philadelphia, PA 19107 (215) 563-5665 (215) 864-2666 (fax) Bucks, Chester, Delaware, Montgo, Philadelphia CCCS of Western Pennsylvania. Inc. 309 Smithfield St. Pittsburgh, PA 15222 (412) 471-7584 Allegheny CCCS of Northeastern Pennsylvania 17 Crofton Street Wellsboro, PA 16901 (717) 724-5252 (717) 724-5783 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of western Pennsylvania, Loo. 500-02 3rd Avenue P. 0. Box 278 Duncanoville, PA 16635 (814) 696.3546 Armstrong, Bedford, Blair, Cambria, Cameron, Centre, Clearfield, Huntingdon, Juniata, Mifflin, union CCCS of Northeastern Pennsylvania 31 W. Market Street Wilkes-Barre, PA 18702 (717) 821.0837 or 800-922-9537 (717) 821-1785 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzern*, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Northeastern Pennsylvania 9 South 7th street Stroudsburg, PA 18360 800-922-9537 (717) 420-8981 (fax) Bradford, Carbon,WOarce, Pike, Wayne CCCS of Western Pennsylvania, Inc. 675 Cherrytree Lane Uniontown, PA 15401 (412) 439-8939 Westmoreland CCCS of Western Pennsylvania, Ina. 50 E. Cherry Avenue Washington, Pa 15301 (412) 222.8292 Washington CCCS of Northeastern Pennsylvania German Street P.O. Box 389 Dushore, PA 18614 (717) 928-9668 (717) 928.8144 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. YMCA Building 339 N. Washington Street Butler, PA 16001 (412) 282.7812 Butler, Clarion, Jefferson, Mercer, Vansago acv 1/9 CCCS of Nester Pennsylvania, Inc. 2000 Linglescown Road Harrisburg, PA 17102 (717) 541.1757 (717) 731.9509 (fax) Adams, Cumberland Dauphin, Franklin, Perry Snyder, York CCCS of Nester Pennsylvania. Inc. 971 Third Street Beaver, PA 15009 (412) 774-0798 Beaver CCCS of Northeaster Pennsylvania 103 Warren street P.O. Box 709 Tuakhannock, PA 18657 (717) 836.6840 (717) 836.6332 Bradford, Sullivan. Susquehanna, Tioga Wayne, Wyoming CCCS of Northeaster Pennsylvania 931 Main Street Honesdale, PA 16431 (717) 253-4981 (717) 253-4817 (fax) Bradford, Sullivan Susquehanna, Tioga Wayne, Wyoming CCCS of Nester Pennsylvania, Inc. 912 South George Street York, PA 17403 (717) 846-4176 Fulton. Lancaster, York Franklin CCCS of Nester Pennsylvania, Inc. 1st Federal Plaza Suite 406 North Mill Street New Castle, PA 16101 (412) 652-8074 Lawrence Budget Counseling Center 247 North Fifth Street Reading. PA 19601 (510) 375-7866 (610) 376.6575 (fax) Berko, Chester, Montgomery, Schuylkill NCH-IBiT B CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 821-4011 or 800-220-2733 (717) or (8141 only (6101 821-0137 (fax) (610) 821-4010 (fax) Berko, Bucks, Carbon, Lancaster, Lehigh, Northampton, Schuylkill Commission on Economic Opportunity of Luzer- County 163 Amber Lane Wilkes-Barre, PA 18702 (717) 826-0510 or 800-822-0359 (717) 829 1665 ca: before fazing (717) 455-4994 (Hazeltor (717)455 $631 (fax) ca: before faxing (717) 836.409 (Tunkhannock) Carbon, Columbia Luzerne, Moaroe Schuylkill, Wynming Community AatLe Commission of the Capital Rsgioa 1514 Corry Street Harrisburg, PA 17104 (717) 232.9757 (717) 234.2227 (fax) Cumberland, Dauphin Franklin, Perry, Snyder Community Action Development Comm 701 Dekalb Street Norristown, PA 19401 (610) 277.6363 (610) 277.2123 (fax) Montgomery Community Development Corp. of Prankford Group Ministry 4620 OriSCOM Street Philadelphia, PA 19124 (215) 744.2990 (215) 744.2012 (fax) Rucks, Chester, Delaware Philadelphia Community Action Southwest 22 West High Street Waynesburg, PA 15370 (412) 852-2891 Allegheny, Fayette, Greens, Washington, Westmoreland Community Housing Counselor, Inc. P.O. Box 244 Kennett Square, PA 19348 (610) 444-3682 (610) 444-3178 (fax) Barks, Chester, Delaware, Lancaster, Montgomery Economic Opportunity Cabinet of Schuylkill County 225 N. Centre Street Pottsville, PA 17901 (717) 622-1995 (717) 622-0429 (fax) Barks, Carbon, Lebanon, Lehigh, Luzerns, Northumberland, Schuylkill Fayette Cc Commnnlty Action Agency, Inc. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 or 800.427-INPO (412) 437-4418 Fayette Financial Counseling Services of Franklin 31 west 3rd Street Waynesboro, PA 17268 (717) 762.3285 Adams, Cumberland, Fulton, Perry Financial services Unlimited 31 Watt 3rd Street Waynesboro, PA 17268 (717) 762-3285 Franklin Greater Erie Comaauaity Action Committee 18 Wait 9th Street Erie, PA 16SOI (814) 459-4581 (814) 456.0161 (fax) Crawford, Erie, Vanaago, warren Hispanic Amoco. of Contractors/Raterprlses 2921.27 North Sth Street Philadelphia, PA 19133 (215) 744-2990 (215) 744-2012 (fax) Ducks, Chester, Delaware Philadelphia Housing opportunities of Heaver County, Inc. 1501 3rd Street Beaver, PA 15009 (412) 720.7511 (412) 664-1590 (412) 728-7202 (Pax) 1412) 664-0873 (fax) Deaver, Butler, Lawrence Rousing Opportunities, Inc. 133 Seventh Street P.O. Box 9 MCHeeeport, PA 15132 (412) 664-1590 (412) 664-0873 (fax) Allegheny, Deaver, Butler, Washington, Westmoreland Housing Council of York 116 North George Street York, PA 17401 (717) 854-1541 (717) 845-7934 (fax) York Housing Association of Delaware valley 1500 walnut Street Suite 601 Philadelphia, PA 19102 (215) 545-6010 (215) 790-9132 (fax) Philadelphia Indiana County Community Action Program 827 Water Street, BOX 187 Indiana, PA 15701 (412) 465-2657 (412) 465-5118 (fax) Armstrong, Cambria, Clearfield, Indiana, Jefferson, Wastmcrelamd John F. Kennedy Canter, Inc. 2021 East lath Street Erie, PA 16510 (814) 898-0400 (814) 898-1243 (fax) Crawford, Elk, Erie, Jefferson, Mckoan, vanango Keystone Economic Development Corp. 1954 Mary Grace Lane Johnstown, PA 15901 (814) 535-6556 (814) 539-1688 (fax) Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland Lycoming-Ciintoncounties Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 (7171 322-2197 (fax) Centre, Clinton, Lycoming, Union Nadia Fellowship mouse 302 S. Jackson Street Media, PA 19061 (610) 565-0846 Chester, Delaware, XOutgomery, Philadelphia Nadia 7allowship Rouse 658 North watts Street Philadelphia, PA 19123 (215) 978-0224 (215) 765.7614 (fax) Philadelphia /ton-valley Unemployed Committee 120 S. 9th Avenue Homestead, PA 15120 (412) 462-9962 (412) 462.9964 (fax) Allegheny, Deaver, Butler, Fayette, Greene, Washington, Westmoreland Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 (814) 486-1161 (814) 486-0825 (fax) Cameron, Elk, McKean., Potter Philadelphia Council for Community Advancement 100 North 17th Street Suit 600 Philadelphia, PA 19103 (215) 567-7803 (215) 963-9941 (fax) Cheater, Delaware, Montgomery, Philadelphia Shenacgo Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Somerset, PA 15501 (014) 445-9628 (814) 443-3690 (tax) Bedford, Cambria, Fayette, Somerset, Westmoreland Tabor Community Services, Inc. 439 E. Xing Street Lancaster, PA 17602 (717) 397-5182 or 800-788-5062 (H.O. only) (717) 399-4127 (fax) Chester, Lancaster, Lebanon The Trebob Center of Northeastern PA 7 Lake Avenue, Box 339 Montrose, PA 18801 (717) 278-3338 or 600.982-404S (717) 278-1889 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming EXHIBIT A Urban La ague o Pittsburgh, You. Building For 6qua Opportunity One Smithfield Street Pittsburgh, PA 15222.222 (412) 227-4802 (412) 261-5207 (fax) Allegheny . Urban League e Metropolitan Rarrisburg 25 N. Front street Harrisburg, PA 17101 (717) 234-5925 (717) 234-9459 (Lax) Perry Urban League o Metropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234.5925 (717) 234-9459 Cumberland, Dauphin. Franklin, Snyder warren-Forrest Countie Economic Opportunit Council 204 Liberty Street P.O.. Box 547 Warren, PA 16365 (814) 726-2400 (814) 723.0510 (fax) Forest, Warren Weatherization Office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 Bedford, Blair, Fultor Runtingdon, Juniata Mifflin, Perry YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 (717) 731-9589 (fax) Cumberland, Franklin Perry Rev 1/9 87ZINNING at a stone, corner of lands formerly of John Fake; thence by the same, snuth 401 degrees east, seven (7) perches to a stone in the road; thence along said read by lands now or formerl.y of Tob 1i1as M^Itz and others, south 301 degrees west, twelve and one-halElje*ches to a atone by the side of the ruad•, thence by lends now or formerly of Jacob ,T.ekert across said -rnad, north 35 3/4 degrees west,* seven-tenths (.7) of 'a perch to a atone; thence along said road by Lands of same and Lands now or formerly of !%-vi '±ckert, south 54-? degrees west, 'ten (10) pcfches to a atone corner joining lands formerly of Sebastian Vckert'anlieire; thence by eame. north 22k degrees west, six and six-tenths (6.6) perches to a stone; thencd by the same, south 761 degrees west, three and five-tenths (3.5) perches to a stone in the road; thence along same by lands now or formerly of T,evi Fake, north 8 3/4 . degrees west, six and six-tenths (6.6) pez'ches to a atone; thence by lands formerly of John Fake, north 653 degrees east, twenty and nine-tenths (20.9) perches to the place of B--r INNING. CCrJTA7{41NC :;ne acre and eighty one, perches. RAVING thereon erected a dwelling known as No, 45 Creek- side Drive, ;:nola, Pa. Being the same premises which Harold F. Picking and Melvin C. Pinking, co-partners, trading and doing business as 11 & M Contract- ore, by their Deed dated November 15, 1965 and recorded in the Gffice for the }recording of Deeds in and for Cumberland County in Deed Book "D", Volume 21, Page 668, granted and conveyed unto Margaret I•:, Wittle. And the said Margaret 0, 1•littl.e, being seized in fee simple of the a- bove tract of land, died testate an September 21, 1983, her Last Will and Testament being probated in the Office for the Register of Will.e of Cumberland County as aforesaid, and Tettera Testamentary were is- sued to Jerome };, Wittle and Eugene L. Wittle, Grantors herein. The Title of which the said Margaret E. Wittle died seized was the legal title only, she having agreed to sell the aforesaid pre- mises to the said Grantees herein, which payments were completed on or about?April, 1983, but a Deed was never executed and delivered by the maid Margaret E. Wittle, due to her illness. DENNIS CHASTEN hereby states that he is ASSISTANT VICE-PRESIDENT of FIRST UNION MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: S ? 99 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION Plaintiff CIVIL DIVISION VS. No. 99-3251 CIVIL WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION, hereby verify that on AUGUST 4, 1999 AND NOVEMBER 1 1999, true and correct copies of the Notice of S'heriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on AUGUST 4, 1999 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. i RANK FEDER , ESQUIRE Attorney f r Plaintiff 4, 0. Date: November 8, 1999 FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION V9. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 99-3251 CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 45 CREEKSIDE DRIVE, ENOLA PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) WILLIAM H. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 DEBORAH K. BROWN, A/K/A 45 CREEKSIDE DRIVE DEBORAH KAY MILLER ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME GREENWOOD TRUST COMPANY HOLY SPIRIT HOSPITAL LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 3311 MILL MEADOW ROAD HILLIARD, OH 43026 NORTH 21ST STREET CAMP HILL, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET FINANCE AGENCY HARRISBURG. PA 17101 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) EAST PENNSBORO TOWNSHIP DOMESTIC RELATIONS OF CUMBERLAND COUNTY 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 8. 1999 -' A E / DATE F K F"LMERMO, ESQUIRE T.torney for /Plaintiff fpcelved From: •' " ' FRTIFRMAiQ pN-?A? 111 r ••. TWO PENN CENTER PLAZA, SUITE 900 IH .o One piece of Ordinary mail addrtased to: liQIY SPIRIT HnSarT_nr NORTH 21ST STREET y 6A#F-lrrr , ,,, Q - a; J. Lfe? PS Form 3817, Mar. 1989 ii i 0 0 a u x? N u d Qua a a°i u +7 a •o ?Fa n C Z h 7 'C O ----------------------- RETURN POSTMAAJyB?'9ATE,, STACTED VERY Q t 4L E PCCE Ir f,E PETUPN NECEIPT Q' ND FEES SENT TO: NOiFOflIN EflN TONGLAUIL L ru N E ru r1L4L11lii r• d((L I\i? L F F m ay l n r _::e jj_Vt r? 6tiU1•A F Pei lIJLS L L Ir i a [ PS FORM 3800 US Postal Service Receipt for `- Certified Mail O O 0 m Ill N m r` a REST C PET()" J*¦¦`) RESTRICTED DELrv[Pv uEfPPT [CPi,F'EC TEE. PLTUPN PCCEP' 6EnVICE rcuL reswcE a"D FECs SENT T0: " INOifoHIN mFNi `oN1L MAIL 4LZ:IilLtil A. JL\lii1.?? n/ m A Jit Vlttiri aril :u r..LA '? a, C}Ct.:tin:i.L'6 JluVa L.?ti LY.`L PrL 1/U-) t ASH OR DATE I o a O Ii-, V uu L 4 i PS FORM 3800 US Postal Service Kempt Tor < j Certified Mail c ?-- C> ?_ G. ?.i ??' CJ U I < ? •" ! ? ?? I (?l ` ? ?L? -_ It:'- ' .J,:. I ?? ?:•, `. L? i. i_/ % r ,r STATE OF PENNSYLVANIA, 1 COUNTY OF CUMBERLAND J ss. Robert P Ziegler h ------------------------------------------------------------------------------ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________ Rachael Leiby ---------------------------•-------------------------------------------------------- is the grantee the same having been sold to said grantee on the ---- 8th------------------------------------------- day of -------December----------------------- A. D., 19___99 --, under and by virtue of a writ -------------- ----------- Execution--------------------------issued onthe---- 5th -- - ------- -------------------------- day of _________A_u_gu_s_t ___________ A. D., 19___ 99 out of the Court of Comman Pleas of said County as of -------- Civil -------'-------°--------------------------------------------------Term, 19_99 --- Number---- 3251_____ at the suit of____ First_Unior._Hame E44ti_B?Dk_[q A_sJ¢LflL_t4_FLLzx Union Home Equity Corpf ---------°---------°------------- against--------- William ----------H-- Brown------- Deborah---------- K ---aka -----Deboral------a Kay Miller duly recorded in Sheriff's Deed Book No. ____216 Page ------------ ?5 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this __ 24n____ day of ..- -dam = --- A. D., 7 74 ------------- ?? ? eNtdCr Of Deeds fw4ba*a EOm the kgfbadt= 2112 First Union Home Equity Bank, NA In the Court of Common Pleas of S/B/M to First Union Equity Cumberland County, Pennsylvania Corporation No. 99-3251 Civil Term -vs- William H. Brown, Deborah K. Brown Aka Deborah Kay Miller Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on September 29, 1999 at 7:07 P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of William H. Brown and Deborah K. Brown aka Deborah K.Miller located at 45 Creekside Drive, Enola, Cumberland County, Pennsylvania according to law. Michael E. Barrick, Deputy Sheirff, who being duly sworn according to law, says on August 18, 1999 at 12:40 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: William Brown by making known unto William Beers III, Son at 45 Creekside Drive, Enola Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on August 18, 1999 at 12:40 o'clock P.M. EDST, he served a true copy of Real estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Deborah Brown aka Deborah Kay Miller, by making known unto William Beers III, Son at 45 Creekside Drive, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Christopher Evans Deputy Sheriff, who being duly sworn according to law, says on October 6, 1999 at 1:46 o'clock P.M. EDST, he served a copy of Real Estate Poster, in the above entitled upon one of the within named defendants to wit: William H. Brown by making known unto Deborah Brown, Wife at 218 Clay Street, Apt # 2, West Fairview, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Christopher Evans Deputy Sheriff who being duly sworn according to law, says on October 6, 1999 at 1:46 o'clock P.M. EDST, he served a true copy of Real Estate Poster in the above entitled action upon one of the within named defendants to wit: Deborah Brown aka Miller by making known unto Deborah Brown at 218 Clay Street Apt #, West Fairview, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: William H. Brown by first class mail to his last known address 218 Clay Street Apt # 2, West Fairview, Pennsylvania, This letter was mailed under the date of October 6, 1999 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action upon one of the within named defendants to wit: Deborah K. Brown by first class mail to her last known address 218 Clay Street, Apt # 2, West Fairview, Pennsylvania. This letter was mailed under the date of October 7, 1999 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on December 8, 19999 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 27,000.00 to Judy D. Leiby. It being the highest bid and best price received for tite same Judy D. Leiby of 54 Creekside Drive, Enola, Pennsylvania being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 28,200.56 it being costs, transfer taxes etc. Sheriff's Costs: Docketing 30 00 Poundage . 540.00 Advertising 15 00 Posting Bills . 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 29.76 Certified Mail 74 Levy 15.00 Surcharge 24.00 aw Journal L 271.25 Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Sworn and Subscribed To Before Me 333.38 23.63 25.00 26.50 $1,390.76 Pd By Judy Leiby 01/19/00 This a 8 Day of `l? 2000, A.D.? rotionotary So ansN'CCS: R. Thomas Kline, Sheriff By t Real estate Deputy D ? 3 t o Cle 1 7 36 7 /GCC.. `19Y9L Sale # 23 Schedule of Distribution Date filed January 6,2000 Writ No. 99-3251 Civil First Union Home Equity Bank, N.A. S/B/M to First Union Equity Corporation -vs- William H. Brown, Deborah K. Brown A/K/A Deborah Kay Miller 45 Creekside Drive Enola, PA Sale Date December 8, 1999 Bid Price $27,000.00 Buyer Judy D. Leiby Real Debt $ 18,661.10 Interest from 7/21/99 to 12/8/99 per diem $ 3.07 432.87 Atty Writ Costs 1 2 $ 19,215.89 Total Collected $ 28,200.56 DISTRIBUTION Sheriffs Costs 1,390.76 Legal Search 200.00 1999 County Township Taxes 69.39 1999-2000 School Taxes 250.80 Tax Claim Bureau 827.02 Sewer and Refuse East Pennsboro Twp 3,098.77 Transfer Taxes local 230.28 Transfer Taxes state 230.28 Credit Writ No. 99-3251 Civil with 19,215.89 Credit Judgement No 296 Civil 1993 with 207.37 $ 00,000.00 Refund to Attorney advance costs 1,000.00 So aaj-t9wf?i& as' %p R. Thomas Kline, Sheriff Real Estate Deputy TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO.23 Held Wednesday, December 8, 1999 Date: December 14, 1999 TAXES: Receipts for all taxes for the years 1996 to 1998 inclusive. Taxes for the current year 1999. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , , and recorded in Cumberland County Deed Book Page RECITAL: Being the same premises which Jerome E. Wittle and Eugene L. Wittle, Executors of the Last Will and Testament of Margaret E. Wittle by Deed dated January 25, 1985 and recorded February 21, 1985 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book "C", Volume 31, Page 947 granted and conveyed to William H. Brown and Deborah K. Brown, his wife. OTHER EXCEPTIONS: The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. Public and private rights in the roadbed of Creckside Drive. 6. Mortgage in the amount of $23,200.00 given by William H. Brown and Deborah K. Brown to First Union Home Equity Corporation dated April 19, 1988 and recorded April 20, 1988 in Cumberland County Mortgage Book 900, Page 659. Complaint in mortgage foreclosure fled by First Union Home Equity Bank as Plaintiff against William H. Brown and Deborah K. Brown as Defendants on May 28, 1999 in the Office of the Prothonotary to file Number 99-3251. Default Judgment in the amount of $18,661.10 entered August 5, 1999. Judgment in the amount of $3,360.51 entered by Greenwood Trust Company as Plaintiff against William H. Brown and Deborah K. Brown as Defendants in the Office of the Prothonotary of Cumberland County to File No. 296 Civil 1993. Writ of Revival filed December 2, 1997 to File No. 97-6642. Mortgage in the amount of $16,000.00 given by William H. Brown and Deborah K. Brown to Pennsylvania Housing Finance Agency dated July 22, 1994 and recorded August 15, 1994 in Cumberland County Mortgage Book 1228, Page 517. Judgment in the amount of $2,225.50 entered by Holy Spirit Hospital as Plaintiff against William Brown and Deborah K. Brown on March 11, 1994 in the Office of the Prothonotary of Cumberland County to File No. 94-130. 10. Municipal lien in the amount of $884.45 entered by East Pennsboro Township as Plaintiff against William H. Brown and Deborah K. Brown as defendants on June 23, 1997 in the Office of the Prothonotary of Cumberland County to 97-3354. 11. Municipal lien in the amount of $312.93 entered by East Pennsboro Township as Plaintiff against William H. Brown and Deborah K. Brown as defendants on October 14, 1998 in the Office of the Prothonotary of Cumberland County to File No. 98-5876. 12. Municipal lien in the amount of $1,072.61 entered by East Pennsboro Township as Plaintiff against William H. Brown and Deborah K. Brown as defendants on August 25, 1999 in the Office of the Prothonotary of Cumberland County to File No. 99-5176. 13. Municipal lien in the amount of $65.53 entered by East Pennsboro Township as Plaintiff against William H. Brown and Deborah K. Brown as Defendants on November 15, 1999 in the Office of the Prothonotary of Cumberland County to File No. 99-6894. 14. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau. The amount due as of the date of this report is $827.02. 15. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff's Sale. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not he valid or unfit countersigned by an authorized signato?, REAL ESTATE BALE NO. 23 Writ No. 99-325151 Ci i First Union Home Equity Bank N.A., S/B/M to First Union Home Equity Corporation vs. William H. Brown, Deborah K. Brown, a/k/a Deborah Kay Miller Atty.: Frank Federman ALL that certain piece of parcel of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded - and described as follows, to wit: BEGINNING at a stone, corner of lands formerly of John Fake thence by the same, south 40 1/2 degrees east, seven (7) perches to a stone in the road: thence along said road by lands now or formerly ofToblas Moltz and others, south 30 112 degrees west, twelve and one-half (12 1/2) perches to a stone by the side of the road; thence by lands now or for- merly of Jacob Eckert across said road (north 35 3/4 degrees west, seven-tenths (.7) of a perch to a stone): thence along said road by lands of same and lands now for- merly of Levi Eckert, south 54 1/2 degrees west, ten (10) perches to a stone comer joining lands formerly of Sebastian Eckerts Heirs; thence by same, north 22 1/2 degrees west. six and six-tenths (6.6) perches to a stone: thence by the same, south 76 1/4 degrees west, three and five tenths (3.5) perches to a stone in the - mad: thence along same by lands now or formerly of Levy Fake. north 8 3/4 degrees west, six and six- tenths (6.6) perches to a stone; thence by lands formerly of John Fake, north 65 1/2 degrees east. twenty and nine-tenths (20.9) perches to the place of BEGINNING. CONTAINING One acre and eighty one perches. HAVING thereon erected a dwell- Ing known as No. 45 Creekside Drive, Enola, PA. Tax Parcel #09-16.1051.040. TITLE TO SAID PREMISES IS VESTED IN William 11. Brown and Deborah K. Brown, his wife by Ex- ecutor's Deed from Jerome E. Wltile and Eugene 1. Wilde dated 1/25/85 recorded 2/21/85 in Deed Book 'C*, Volume 31 Page 947. 51,DOU.DO.Ad:aneeCossPaid REAL =STATE SALE NO 8/10/99 AM% Frank Federman Assessed Valuation 5 1520.00 WRIT IN 0. 99-3251 Civil First union Home Equity Bank, N.A. S/B/M to First union Equity Corporation VS William H. Brown, Deborah. K. Brown A/K/A Debra K Miller 45 Creekside Drive PEAT DEBT " Enola, PA 17025 INTEREST fr 7/21 to 12/8/99 3.07 per diem ATT• S FEES WT UT COSTS ATTF ESCROW LATE CHARGE SHERIFFS COSTS Dock--.tine Poundast Pos;inz Bills Adce-isine Ackowledo;np D,!e_ Auctioneer La-,v L ibrarv C o unr: Milea^, Ce:t Mail Le-,r, Postpone Sale Surcharge Legal Sear,:h La%%, Journal Patriot Share of Bills Distribution of Procee:5 Shd:,i' s De..4s ST.kN[PS Pa Transfer Tag TnT or Boro Transfer Ta>: TAYES 1999 County Township Taxes 1999-2000 School Taxes Tax Claim Bureau Sewer & Refuse $ 18,661.10 432.87 121.92 30.00 540.00 15.00 15.00 30.00 10.00 .50 1.00 29.76 .74 15.00 24.00 200.00 271.25 333.38 23.63 25.00 26.50 69.39 250.80 827.02 3,098.77 REAL ESTATE SALE No. 23 Writ No.99-MI CIVIITWM Final Union Homo E4uKy Bank N.A_SIBIMTc Fins Unloh Home Et;uityCorpporation I 1. we . W(1(IemH.Brow ,; Deborah K. Brown `r'' ARIA Deborah Key Miller.,. Ally: Frank Federman DESCRIPTION ALL that certain plow of parcel of lend anuate in the Township of East Pennaboro. perches to a stone Ins the road; thence of Tobias KOM end others, south 30.1/2 degrees twelve and oria- (12 1/2) ' Perches to stone by. the sift olnrhe road: Monica by lands now or formerly of Jacob : Eckert across said road, (north 35 314 degrees west, seven-tenths (1) of a perch to a stone: terlce along saki roads by - lands of same and lands now formerly Of Levi Ed-,ert, south 54 114 degrees west, ten (10) perches to a stone comer joining lands tonn6dy cif Subaslian Eckees Heirs; thanos sam 22 west. six and siK tenths (6 6) tpe chesegr foes stone; thence by the same, south 76.1/4 - degrees west, three and five tenths (3.5) patches to a stone In the road: thence along same by lards now or formerly of Levy Fake, north 6 314 degrees west, six Fmd six-tenths (6.6) perches to a stoma; thence formerly of John Fake. 'north 65y12 dedress east twenty and nkl Wft (20.9) perches to the plea of . BEGINNING. CONTAINING Ono acre and elghty-6m Perches. NHAVING thereon erected a dwelling wv as No. 45 CreeWde Dom, Enolk Tax Parcel #09.16.1051-040. TITLE TO SAID PREMISES IS VESTED IN WAxam H. Brown Ord Deborah K. Brown. firs wife by Essculork Dead farm Jerome E. Wens and Euaene 1. VA M dated 125M5 recorded 2121/W In Dead Book 'V. Volume 31 Pape 947. 4 I 1 , I ?r f i i? THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Commonwealth of Pennsylvania, County of Dauphin} as Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, In the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular dally and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd and 9th day(s) of November 1999. That neither he nor said Company is Interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of direc ors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said out of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. q 1Y L- PUBLICATION _ V U- I COPY Sworn to and subscribed efore me this 181h cIPjof S A L E #23 Terry L. Russ6lr, Notary Public NOTAf{Y Ir 13LIC Harrisburg, Dauphin County My Commission Expires June e, 2002 A1cm1br:,, Peru; o II quolu 1 esion expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 331.88 Probating same Notary Fee(s) $ 1.50 Total $ 333.38 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. THE PATRIOT NEWS CO. By .................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal i periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 22, 29, NOVEMBER 5, 1999 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALL NO. 23 I I? Writ No. 99.3251 Civil Ro r M. Morgenthal, Editor First Union Home Equity Batilt ? I N.A.. S/B/M to First Union Home SWORN TO AND SUBSCRIBED before me this ' Equity corporation . 5 day of _ NOVEMBER. 1999 VS. William H. Brown, Deborah K. Brown.a/k/a Deborah Kay Miller is Ally.: Frank Federman ALL that certain piece of parcel of L SEAL land situate in the Township of East LOJS E. SNYDER, Pennsboro, County of Cumberland Cadiela Eoro, Cum 11, Notary Public i and State of Pennsylvania, bounded my C"Mirdon Expire, March 5 h. PA I and described as follows, to wit: ?001 BEGINNING at a stone. corner of 1 lands formerly of John Fake thence i by the same, south 40 1/2 degrees cast, seven (7) perches to a stone in 1 the road: thence along said road by ; lands nowor fonuerly of'robias Moltz and others, south 30 1/2 degrees west. twelve and one-half (12 1/2) Perches to a stone by the side of file ' road: thence by lands now or, for- merly of Jacob Eckert across sald i road (north 35 3/4 degrees west, ',- seven-tenths (.7) of a perch to a stone): !hence along said road by lands of same and lands now for- . inerly of Levi Eckert, south 54 1 /2 degrees west, ten (10) perches to a stone corner joining lands formerly of Sebastian Eckcri's Heirs: thence by same, north 22 1 /2 degrees west. six and six-tenths (6.6) perches to a stone: thence by the same, south 76 1/4 degrees west. thrre and five tenUts (3.5) perches to a stone in the l J toad: f fence :long svnr by lands ` now or tin inei ly of lx%yv rake. north d 3/4 degrees wrsl, sm and six- tenths 143.431 nerches Io a stout-: thence by lands fbrmeily of John rake, north 135 1/2 degrees rant. twenty and nine tenth% (229) perxhcs to the place of BEGINNING. CONI AI N ING One acm and rlghty onr perrhes. J IAV9NCi thrreon erectnf a dwell. mg lowwit as No. 45 0wk1sldr Drue. Eawia.. PA. _ Tax Parcel *09.16.1051440. TITLE TO SAID PREMISES IS %TSI1:D IN Wilhain It. Liman and tkbnrAi K. Hnrwn. In% w•11c by Kx- etutor* Deed rrom.Jetonw E, Wlnle ltd Eueffw L Wilde dated 1125/83 RNeedcd 2121 /83 In Dttd Book 'C'. 14blume 31 PW 947. FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION VS. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER . CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION NO. 99-3251 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 lAffidavit No. 1) EQUITY CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 45 CREEKSIDE DRIVE. ENOLA, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s) : NAME WILLIAM H. BROWN DEBORAH K. BROWN, ALK/A DEBORAH KAY MILLER LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 45 CREEKSIDE DRIVE ENOLA, PA 17025 45 CREEKSIDE DRIVE ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real. property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) GREENWOOD TRUST COMPANY 3311 HILL MEADOW ROAD HILLIARD, OH 43026 4. Name and address of the last recorded holder of every mortgage of record: NAME PENNSYLVANIA HOUSING FINANCE AGENCY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 2101 NORTH FRONT STREET iMRRISBURG, PA 17101 5. ti NONE Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) EAST PENNSBORO TOWNSHIP 98 SOUTH ENOLA DRIVE ENOLA. PA 17025 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE. PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 21. 1999 ?i?tVtcY?G? DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FIRST UNION HOME EQUITY BANK, N.A., CUMBERLAND COUNTY S/B/M TO FIRST UNION HOME EQUITY CORPORATION COURT OF COMMON PLEAS V9. CIVIL DIVISION WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER NO. 99-3251 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY July 21, 1999 TO: WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER 45 CREEKSIDE DRIVE ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 45 CREEKSIDE DRIVE, ENOLA, PA 17025, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $18,661.10 obtained by FIRST UNION HOME EQUITY BANK. N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the MARCH 1. 2000 Sheriff's Sale. 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 cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. o You may need an attorney to assert your rights. The sc.-ner ybu 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 BIGHTS 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 {215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 „I r ALL that certain piece of parcel of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described as follows, to writ. BEGINNING at a stone, corner of lands formerly of John Fake thence by the same, south 40 1/2 degrees east, seve•1 (7) r=rches to a stone in the road; thence along said road by lands now or formerly of Tobias Moltz and others, south 30 1/2 degrees west, twelve and one-half (12 1/2) perches to a stone by the side of the road: thence by lands now or formerly of Jacob Eckert across said road (north 35 3/4 degrees west, seven-tenths (.7) of a perch to a stony) thence alone said road by lands of same and,lands now formerly of Levi Eckert, south 54 1/4 degrees west, ten (10) perches to a stone corner joining lands formerly of Sebastian Eckert's Heirs; thence by same, north 22 1/2 degrees west, six and six-tenths (6.6) perches to a stone; thence by the same, south 76 1/4 degrees west, three and five tenths (3.5) perches to a stone in the road; thence along same by lands now or formerly of Levy Fake, north 8 3/4 degrees west, six and six-tenths (6.6) perches to 'a stone; thence by lands formerly of John Fake, north 65 1/2 degrees east, twenty and nine-tenths (20.9) perches to the place of BEGINNING. CONTAINING One acre and eighty one perches. HAVING thereon erected a dwelling known as No.45 Creekside Drive, Enola, PA. Tax Parcel #09-16-1051-040 TITLE TO SAID PREMISES IS VESTED IN William H. Brown and Deborah K. Brown, his wife by Executor's Deed from Jerome E. Wittle and Eugene I Wittle dated 1/25/85 recorded 2/21/85 in Deed Book "C", Volume 31 Page 947. 1 -- WRIT OF EXECUTION and/or /ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. -99-3?51 CI TEg?I CIVIL ACTION - LAW LAW TO THE SHERIFF OF Cumberland COUNTY: i To satisfy the debt, interest and costs due First Union Home Equity Bank N.A. S/B/M to First i. Union Home Equity Corporation PLAINTIFF(S) .? from William H. Brown n°hnrah K Rrimm A4K4A Deborah Kay hill 45 Q ak a aive, Enola, Pa. 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell 45 Creekside Drive Enola Pa. 17025 (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/are 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 defenclant(s) notleviedupon an subjectto attachment isfound In the possession of anyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjolned as above stated. AmountDue? 18,661.10 Interest frcrn 7/2E12 to 771 per Diem Interest d3? 8? Atty's Comm % L.L. SO 50 $3.07 Due Prothy 1.00 Other Costs Atty Paid 121.92 Plaintiff Paid Date: Aurust 5, 1999 REQUESTING PARTY: Curtis R. Long _ Prothonotary, Civil Division by: Deputy Name Frank Federman Address't T Perin Center Plaza Attorney for: plaintiff Telephone: (am) 563-7000 Supreme Court ID No12248 11 Oil /4/ L ?J/. 4,996 thB 5110i""iii 1CP"16ii UnOn tile dafenclan,-, I111t; ist in the real property situated Ir, Curnberland County, Pa., knmv!i and ni,(il z;r6(i as: ?? ?D_ ,moo ?I r _ and more fully dv;l;riti.; in Exhibit ''A" filed wiatj this writ and by this reference incrri!cratvd Ilerci!l, VI NVAil SNN3d _f' 66I Wd OZ 9ttq J M r d?ii19"HS 3H1 ?C 3?Idl0 It SHERIFF'S RETURN - REGULAR CASE NO: 1999-03251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION HOME EQUITY BANK VS. BROWN WILLIAM H ET AL CHRISTOPHER EVANS Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon BROWN WILLIAM H the defendant, at 15:36 HOURS, on the 2nd day of June _ 1999 at 45 CREEKSIDE DRIVE ENOLA, CUMBERLAND County, Pennsylvania, by handing to WILLIAM BROWN a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers:ii Docketing 18.00 Service 9.92 P Affidavit .00 Surcharge 8.00 R - omas ine 5 ri $ _3 5 -FEDERMAN & PHELAN 06/03/1999 ( N? L 1. by l?1? ?1/ \??1ns e u y 5 eri sworn and subscribed o before me this 3,,,4 day of 19 4i,(, A.D. io- Ffbtaf- CASE NO: 1999-03251 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION HOME EQUITY BANK VS. BROWN WILLIAM H ET AL CHRISTOPHER EVANS Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon BROWN DEBORAH K the defendant, at 15:36 HOURS, on the 2nd day of June 3.999 at 45 CREEKSIDE DRIVE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to WILLIAM BROWN a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So aa. Docketing 6.00 e Service z-- Affidavit .00 `t Surcharge 8.00 R-Inomas Kline, S eri -06/03 1999 PHELAN by u y eri Sworn and subscribed to before me this J.,,( day of 19 99 A. D. Qw;L-= C, ;!h? r i a FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900, Two Penn Center Plaza (215) 563-7000 FIRST UNION HOME EQUITY BANK, NA S/B/M TO FIRST UNION HOME EQUITY CORPORATION 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607-5066 Vs. WILLIAM H. BROWN DEBORAH K. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-3251 CIVIL SUGGESTION OF RECORD CHANGE RE: DEFENDANT'S NAME TO THE PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief the Defendant's name was erroneously listed as: WILLIAM H. BROWN DEBORAH K. BROWN The correct name for the Defendant is: WILLIAM H. BROWN DEBORAH K. BROWN A/K/A DEBORAH KAY MILLER Kindly change the information on the docket. Date: July 12, 1999 ?,, /' ? 1,4,- Frank Federman Attorney for Plaintiff. ?> N CT C ? 1. CJ CL rJ iJ Fn cn :D rn V FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607-5066 Attorney for Plaintiff CUMBERLAND COUNTY . COURT OF COMMON PLEAS va. CIVIL DIVISION WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER , 45 CREEKSIDE DRIVE ENOLA, PA 17025 NO. 99-3251 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against WILLIAM H. BROWN AND DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 5/1/99 TO 7/21/99 TOTAL I hereby certify that (1) the Defendant(s) are as shown above, and in accordance with Rule 237.1, copy $18,245.36 $ 415.74 $18,661.10 addresses of the Plaintiff and d (2) that notice has been given attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: / 9 9 J PRO PROTHY FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION Plaintiff VS. WILLIAM H. BROWN DEBORAH K. BROWN Defendant(s) TO: WILLIAM H. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 DATE OF NOTICE: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS . CIVIL DIVISION CUMBERLAND COUNTY NO. 99-3251 CIVIL JUNE 23, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BAR ASSOCIATION Frank Federman, Esquire Attorney for Plaintiff . `FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 FIRST UNION HOME EQUITY BANK, N.A., S,/B/M TO FIRST UNION HOME EQUITY CORPORATION Plaintiff VS. WILLIAM H. BROWN DEBORAH K. BROWN Defendant(s) TO: DEBORAH K. BROWN 45 CREEKSIDE DRIVE ENOLA, PA 17025 DATE OF NOTICE: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-3251 CIVIL JUNE 23, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should lake this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman., Esquire Attorney foi Plaintiff C, a 3 Cr w 9 4 3 cn ?J r FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST UNION HOME EQUITY BANK, N.A., CUMBERLAND COUNTY S/B/M TO FIRST UNION HOME EQUITY CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION VS. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER NO. 99-3251 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, Co wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant WILLIAM H. BROWN is over 18 years of age and resides at 45 CREEKBIDE DRIVE, ENOLA, PA 17025. (c) that defendant DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER is over 18 years of age, and resides at 45 CREEKBIDE DRIVE, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. FNK FEDE AN, ESQUIRE Attorney for Plaintiff 1 ?J ' o PRAECIPE FOR WRTF OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION Plaintiff VS. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 99-3251 CIVIL C PRAMPE FOR WRIT OF EMCMON (MORTGAGE FORECf.OS M TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $18,661.10 Interest from 7/21/99 TO S 432.87 and Costs 12/8/99 (PER DIEM - $3.07) $19,093.97 TOTAL 22'%&'t FRANK FEDERMAN, ESQUIRE TWO PENN CEN'T'ER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. o a H W a 40 OD P. zOU ` °i oa. ri) E-4 14 0 Z o0 z tO o i m H I a H W 0 ~ 0 U to x w0 .4 > Pk > C 0 0 x o ? L) FU M O . a o 0 ? 7 z P 1 U? 0 H m w m W ? W H ? q :q. •• P4 O ? W W W Cf W O r7 w? IT4 F O O? wo W a b Pa O N O n a $4 n, a y W A a Q m A b H a W 14 9 R In m w N K' v M 4 ALL that certain piece of parcel of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described as follows, to writ: BEGINNING at a stone, corner of lands formerly of John Fake thence by the same, south 40 1/2 degrees east, seve•t (7) p-rches to a stone in the road; thence along said road by lands now or formerly of Tobias Moltz and others, south 30 1/2 degrees west, twelve and one-half (12 1/2) perches to a stone by the side of the road: thence by lands now or formerly of Jacob Eckert across said road (north 35 3/4 degrees west, seven-tenths (.7) of a perch to a stong) thence along said road by lands of same and. lands now formerly of Levi Eckert, south 54 1/4 degrees west, ten (10) perches to a stone corner joining lands formerly of Sebastian Eckert's Heirs; thence by same, north 22 1/2 degrees west, six and six-tenths (6.6) perches to a stone; thence by the same, south %6 1/4 degrees west, three and five tenths (3.5) perches to a stone in the road; thence along same by lands now or formerly of Levy Fake, north 8 3/=4 degrees west, six and six-tenths (6.6) perches to a stone; thence by lands formerly of John Fake, north 65 1/2 degrees east, twenty and nine-tenths (20.9) perches to the place of BEGINNING. CONTAINING One acre and eighty one perches. HAVING thereon erected a dwelling known as No.45 Creekside Drive, Enola, PA. Tax Parcel #09-16-1051-040 TITLE TO SAID PREMISES IS VESTED IN William H. Brown and Deborah K. Brown, his wife by Executor's Deed from Jerome E. Wittle and Eugene I Wittle dated 1/25/85 recorded 2121/85 in Deed Book "C", Volume 31 Page 947. f L; ? ? ? 1 A "1 ? 1T h ?` .? t r ?"? i' i=' '` -' ?,?-.' ..; !?_<.. r'r ?- C. ?i ? -? u.i r:.. ? _i ,:'. ?:a. ?? ? _ C' ci A M ?'1__ yy`` ?ll l FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 FIRST UNION HOME EQUITY BANK, N.A., s/B/M TO FIRST UNION HOME EQUITY CORPORATION V8. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION NO. 99-3251 CIVIL FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (XX) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDE N, ESQUIRE Attorney for Plaintiff ' 7 u'. %J FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION VS. WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER CUMBERLAND COUNTY . COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3251 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) FIRST UNION HOME EQUITY BANK, N.A., S/B/M TO FIRST UNION HOME EQUITY CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 45 CREEKSIDE DRIVE, ENOLA, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s) : NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER 45 CREEKSIDE DRIVE ENOLA, PA 17025 45 CREEKSIDE DRIVE ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) GREENWOOD TRUST COMPANY 3311 MILL HEADOW ROAD HILLIARD, OH 43026 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) PENNSYLVANIA HOUSING 2101 NORTH FRONT STREET FINANCE AGENCY HARRISBURG, PA 17101 5. NONE 6. NONE 7 Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME EAST PENNSBORO TOWNSHIP DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. %TUly 21, 1999 22??L - DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ?" r ) 1,',. C: ??- _ i ?' ??1. 7 i --? r ? L;r , L (' ti ?•. 1 _ ??l ('..? G, ' 1. 1 ? .? ?` ? FIRST UNION HOME EQUITY BANK, N.A., CUMBERLAND COUNTY S/B/M TO FIRST UNION HOME EQUITY CORPORATION COURT OF COMMON PLEAS Va. CIVIL DIVISION WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH RAY MILLER NO. 99-3251 CIVIL NOTICE OF SHERIFF'S 8 LE OF REAL PROPERTY July 21, 1999 TO: WILLIAM H. BROWN DEBORAH K. BROWN, A/K/A DEBORAH KAY MILLER 45 CREEKSIDE DRIVE ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 45 CREEKSIDE DRIVE, ENOLA. PA 17025, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8, .1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $10,661.10 obtained by FIRST UNION HOME EQUITY BANK, N.A., S!B/M TO FIRST UNION HOME EQUITY CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the MARCH 1, 2000 Sheriff's Sale. 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 cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE 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 (2151 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the Sheriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL that certain piece of parcel of land situate in the Township of East Pennsboro; County of Cumberland and State of Pennsylvania, bounded and described as follows, to writ: BEGINNING at a stone, corner of lands formerly of John Fake thence by the same, south 40 1/2 degrees east, seve•t (7) p-rches to a stone in the road; thence along said road by lands now or formerly of Tobias Moltz and others, south 30 1/2 degrees west, twelve and one-half (12 1/2) perches to a stone by the side of the road: thence by lands now or formerly of Jacob Eckert across said road (north 35 3/4 degrees west, seven-tenths (.7) of a perch to a stone) thence along said road by lands of same and, lands now formerly of Levi Eckert, south 54 1/4 degrees west, ten (10) perches to a stone corner joining lands formerly of Sebastian Eckert's Heirs; thence by same, north 22 1/2 degrees west, six and six-tenths (6.6) perches to a stone; thence by the same, south 76 1/4 degrees west, three and five tenths (3.5) perches to a stone in the road; thence along same by lands now or formerly of Levy Fake, north 8 3/4 degrees west, six and six-tenths (6.6) perches to a stone; thence by lands formerly of John Fake, north 65 1/2 degrees east, twenty and nine-tenths (20.9) perches to the place of BEGINNING. CONTAINING One acre and eighty one perches HAVING thereon erected a dwelling known as No.45 Creekside Drive, Enola, PA. Tax Parcel #09-16-1051-040 TITLE TO SAID PREMISES IS VESTED IN William H. Brown and Deborah K. Brown, his wife by Executor's Deed from Jerome E. Wittle and Eugene I Wittle dated 1/25/85 recorded 2/21/85 in Deed Book "C", Volume 31 Page 947. _, .. _. _ ;,?, y. r. -• ?:;;. C L)• .? ?. ? ?. ? ?? J ' ? -? ? i ii L' r .. ?. , f-? , f IJ l.?_ ti.. L.) C"'1 C?i ?--? l_? • ?