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Home My WebLink About99-03886 i 0 a Z 1-3 O h v 3 \ Ls 'L G b: 'o. O? a FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 Plaintiff V. THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 TERM NO. 9 L) - 3 Y N, Cc; u -re,- CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 ajudgment 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 2. The name(s) and last known address(es) of the Defendant(s) arc: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/26/95 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. 1284, Page 335. 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 9/1/98 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 mounts are due on the mortgage: Principal Balance $70,642.57 Interest 4,727.70 8/1/98 through 6/1/99 (Per Dienn $ 15.45) Attorney's Fees 3,532.00 Cumulative Late Charges 218.52 9/26/95 to 6/1/99 Cost of Suit and Title Search 550.00 Subtotal 79,670.79 Escrow Credit 0.00 Deficit 9.94 Subtotal 9.94 TOTAL $79,680.73 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 o(1983, has terminated because either: 6 J Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B'% 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 $79,680.73, together with interest from 6%1/99 at the rate of $15.45 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. & Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff L JUN 11 '99 12:23PM BRRRETT BURKE M L 23 P. 002751 Norwest Mortgage, Inc. Building 7 P.O. Box 1225 Charlotte. NC 28201-1225 November 2. 1998 Thomas W. Johnson, Jr. 2010955i002751?472 49 W. Keller S!. Me MeehA hanleaburg PA 17055 RE: Norwest Loan Number 2010955 Mortgagor(s): Thomas W. Johnson, Jr, Mortgaged Premises: 49 W. Keller St. Mechanicsburg, PA 17055 dGIICE_GE_ItlIEtlIIGtl_IC_t:OBECLGfiE_tlG8IG8GE DEAR BORROWERS: The mortgage held or serviced by NORWEST MORTGAGE, INC. therelnaf ter we, us. or ours) an your proper ?0 located at 49 N. Keller St., Mae hanlrsburg, PA, IS IN SERIOUS DEFAULT because you've not made the monthly payments since September 1, 1998 through today. Late charges and other charges have also accrued to this datc. The total amount now required to cure the default. or in other words, bring your loan current, Is calculated below. 3 Payments a 606.94 Totaling S 1,820.82 Total Accrued Unpaid Late Charges S 48.56 (Monthly Late Charge S 24.25) Suspense Balance 5 - S 0.00 Miscellaneous Fees S 15.00 Total Delinquency as of November 2. 1995 S 11884.38 Payments due within the nest 30 days Tataling $ 606.94 Total due to cure default and bring lo•n current as of December 2. 1998 52,991,32 Total due to cure default and bring loan current as of December 2, 1996 52.491.32 You may cure this default within THIRTY (30) Days of the Jate of this letter, by paying to r us the above amount of '61,864.38 plus any additional monthly Fa Monts and late charges which may fall due during this period. Such payment must be made elEher by cash, cashier's check, or ma ney order to Norwest Mortgage. Inc., P.O. Box 0057, Palat):te, IL 60055-0057, telephone d 1-300-766-0987. If you do not cure the default within THIRTY (30) days of the date of this letter, we intend to exercise our right to accelerate the n.ortgaga a Monts. This means that whatever Is owing on the ortginal amount borrowed .,Ill be conpsidered due immedlately and you may lose the chance to pay off the original mortgage In monthly Installments, Please see (ol(owing pages. EXHIBIT A r U N MH 23M .j JUN 11 '99 12:23PM BARRETT BURKr ® A 24 P,5/7 00275) ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE PERO THIS NOTICE. YOU MAY DE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. Date: November 2. 1996 Re: 2010955 To: Thomas N. Johnson, Jr. You may be eligible for financial assistance that will present foreclosure an your norl5gage if you eemfly with the provisions of the Homeowners' Emergancy Mortgage Assistance qef OF 1983 (the Act"). YOU may be eligible for emergency temporary assistance if your default has been Caused by circumstances beyond your control, you have a reasonable prospaet OF resuming ycur mortgage payments, and if you meet other ell9l Is Ilty requirements auto tished by :he ennsytvanla Housing Finance Agency. Please read all of this Notice, It contains an explanation of your rights. Under the Act, you are ant l l led to a temporary stay of Foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this 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 (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 p,-oceeding In the mortggage foreclosure ma take place for l61r ty 130) days after the Cats of this meeting. Tha name. address end to lop hone number of our represental days l after Is; Theresa Davenport NOewest Mortgage, Inc. Default Department-MS 125402 5024 Parkway Plaza Blvd., Bidg 7 Charlotte, North Carotlna 28217 Telephone No: 1-600-766-0987 The names and addresses of designated consumer credit counseling are shown on the attached sheet. It Is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your Intentions, Your mortgage Is in default because you have failed to pay promptly Installments of principal and Interest, as required, for a period of at least slaty (60) days, The total amount of the delinquency is $1,684.38. This sum Includes the following: mans hly payments of $1,620.82 through the current month, plus charges of $63.56. If you have tried and are unable to resolve this probl en) 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 for assistance may only be obtained from a consumer, credit counselingB agency. The consumer credit counseling agency wilt assist you in filling out your appllcatlon and will submit your complete application to the Pennsylvania Housing Finance Agency. Your appllcatlon must be ()lied or postmarked, within thirty (30) days of your face-to-face meeting. It Is extr emel,y Important that you fits your appllcatlon promptly If you do not do so. or if you do not follow the ether time periods sat forth in this letter, foreclosure may proceed against your home Immediately. Available funds for emergentg mortgage assistance are waryy {Imlted. They WILL be disbursed by the Agency under the eligibility criteria established by the Act. It Is extremelyy Important that your application is accurate and complete In every respect. The Pennsylvania Housing Finance Agency has sixkg (60) days to make a decision after It receives your appllcatlon. 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 notlfled d'rectly by the Agency of Its declsian on your application. The Pennsylvar.:a Housing Finance Agency Is located at 2101 North Front Street, Post Office Sax 8029. Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3000 or 1-800-342-2397 (to:l free numh or). Persons with Impair ad hearing can call 1-800-346-1869 Licit free .timber), In addition you may receive another notice from this lender under Act 6 of 1974. That notice Is called a -'No tlee of Intention to Foreclosure". You must read both notices, since l hey both explain rlghts lha! yyou now have under Pennsylvania Law. Hewover, if you choose to exerclse your rights des ,y bad In this netlce, you cannot be foreclosed upon while you are recefving that assistance. U K S N MD 24M TUN 11 199 12:23PM BARRETT BURKE P.6/7 002741 If Full payment of the amount of the default Is not made within THIRTY (30) ggDRYS, we also IFte thetomorrtgaget Isr foreclosed, tSourstart mortggagadupropertyr Witts bey soldmCyt aaShertff(s)tor ther e similar official(s) sale to pa•,l off the mart gaga debt. If you cure the default before we begin totgal proceedings agalnet you. you ul[ll still have to pay the roasonabl¦ tartedy( ag)ainsts you!! gout Willn curred, to pag the reasonawble aHwr. ttorney(s) feeslespie ncIf th% aare re over $50.00. Any attorney(9) fees will e added to hateuar ou Due the lender, which mayy also Include their reasonable costs. If you cure the defauylt within the THIRTY (30) DAY period you Witt not be required to pay 1 atf or nay(s) fgas. we may also sue you personally for the unpaid principal balance and all other sums due under fhe mortgage. IF you haue not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yew still have the rlg ht to cure the default and prevent the sale at any time up to one hour before the Sheriff(s) or other similar official(s) foreclosure sale. You ma do so by paying the total amount of the unpaid monthly payments plus any other charges then due, as wall as the reasonabla attorney(s) fees and costs connected with the foreclosure sale, and Perform any other reyuiremehks under the mortgage. It is estimated that the earliest date that such a Sheriff(s) or other similar official(s) sale could be held would be approximately six months from today. A notice of the date of the Shariff(s) or similar offlclaL(s) sale will be sent to you before the sale. Of course, the amount needed to cure the default Witt Increase the longer you watt. You may find out at time exactly what the required payment will be, by calling us at the Following number: 12900-766-0997• This payment must be made by cash, cashier's cheek, cartlf led check or money order and made payable to us at the address stated above. You should reaLlze that a Sheriff(s) or other similar official(s) sale mitt end your ounershlp of the mortgaged property and your rlgg ht to remain in It. If you cent lnue to live In the properlyy after the Sherlf F(s) or ether similar official(s) sale, a lawsuit could be started to evict you. You shall haue the right to assert in the (creel as ure precsedtngs, the nonexistence of a default or any other defense that you may have to accele.at l on or foreclosure. Sincerety, Theresa Davenport Norwest Mortgage Default Management Department Attachment: New Western Union Insert City Code NMS In ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pinnsyluanla's Homeowner's Cmargency Nort Aga Assistance Pro ram may be neeC more Informathan calfde he ePennsy Wanlaol eus ing FlnanestRgeney ha,Prog00m3N2'2397,i1 you La notlflcaclon an ad)unto as de suma Importancla, pugs afecta $u derecho a eontinuar ulvlande an su Casa. Si no comprende at contanldo de Oita not lflcacl on ebtenga una traducclon Immedlatamente llamanda esta agent la (Penns lwnla Housi Mg chance A ancy) sin car qos al numbre menclonada arrlba. Puedes ser eleglbYapars un prestamo par at pro rams llama40 Homeowner's Emorgeney Mortgagge Assistance prmgram•' el curl pug de satvar eu caia de +,told, del derec he a red I m I r su hlpoteca. pleele see following page. EXHIBIT g 1 l I ( _ A 24 _ If you cure this default, the mortgage Will be restored to the same position as If no default had occured, lieweu you are not entitled to this right to cure your default more than three times In any calendar year. The Fair Debt Collection Practices Act re quires us to notl/99 you that In the event your loan Is in qu de Fautt, Norwest Mortgage will attempt to collect ti: debt and any Information obtained Will be used for that purpose. PENNSYLVANIA EOIISING FINANCE AGENCY ROMEOWNSR'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGMHCIES A c u r a H o u s i n g Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765.1221 (215) 765.1427 (fax) Bueka, Chester, Delaware, Montgomery, Philadelphia Action Housing, Inc. Number TWO Gateway canter Bch Floor Pittsburgh, PA 15222 1412) 391.1956 1412) 391.4512 (tax) Allegheny, Beaver, Butler, Fayette, Greene, Washington, Westmoreland AM Credit Counseling institute 175 Stratford Avenue, Suite 1 Wayne, PA 19087 (610) 971-2210 (610) 687-7860 (fax) Bucks, Chaster, Delaware, Montgomery, Philadelphia American Red Cross- Hamover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637.3768 (717) 637-3294 (fax) Adams, York, Franklin Bedford-Fulton Housing Services A.D. P1, Box 384 Everett, PA 15537 (814) 623-9129 (814) 623.7187 (fax) Bedford, Blair, Cambria, Fulton, Huntingdon, Somerset Blair County soon Opportunity council 2100 6th Avenue Altoona, PA. 16602 (814) 946.3651 (814) 946.5451 (Lax) Adams Booker T. Washington center 1720 Holland Street Erie, PA 16503 (814) 453.5744 (814) 453.5749 (fax) Crawford, Eria, Warren Bucks County Housing Group, Inc. 140 E. Richardson Avenue Langhorne, PA 19047 (215) 750-4310 (215) 750-4318 (fax) Bucks Budget Counseling Center 247 North Fifth Street Reading. PA 19601 (6101 375-7866 (610) 376.6575 (fax) Barks, Cheater, Montgomery, Schuylkill CCCS of Western Pennsylvania, Inc. 312 Chestnut Street Suite 227 Meadville. PA 16335 (814) 333.8570 Lawrence CCCS of Western Pennsylvania, Inc. Senior Activity cancer 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, Tinge, Wayne, Wyoming CCCS of Northeastern Pennsylvania Human Semites Building 541 Wyoming Avenue, Box 168 Scranton, PA 18501 (717) 342-1072 or 800-922.9537 (717)342-8040 (fax) Bradford, Carbon, Columbia, Lackawanna, Luzerns, Lycoming, Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tinge, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. 1 North Cate Square p2 Garden Center Drive Greensburg, PA 15601 (412) 838-1290 Fayette, Greene, Indiana, Somerset, Washington, Westmoreland 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 Cra!ton Street Wellsboro, PA 16901 (717) 724-5252 (717) 724-5783 (fax) Bradford, Sullivan, Susquehanna, rings, Wayne, Wyoming CCCS of Western Pennsylvania, Inc. 500.02 3rd Avenue P. O. Box 278 Ouncansville, PA 16635 (814) 696.3546 Armstrong, Bedford, Blair, Cambria, Camsrnn, 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, Luzerns, 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,MOoros, Pike, Wayne CCCS of Western Pennsylvania, Inc. 675 Cherrytree Lane Uniontown, PA 15401 (412) 439-8939 Westmoreland CCCS of Western Pennsylvania, Inc. 58 E. Char-/ Avenue Washington. Pa 15301 (412) 222-8292 Washington CCCS of Northeastern Pennsylvania German Street P.O. Box 389 Dunhore, PA 18614 (717) 928-9668 (717) 929-8144 (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, venango CCCS of Lehigh Valley 3671 Crescent Court East Whitehall, PA 18052 (610) 821-4011 or 800-220-2733 (717) or (814) only (610) 821-0137 (fax) (610) 821-4010 (fax) Barks, Bucks, Carbon, Lancaster, Lehigh, Northampton, Schuylkill Haw 1/97 CCCS of Western Pennsylvania, Inn. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 (717) 731.9589 (fax) Adams, Cumberland. Dauphin, Franklin, Perry. Snyder, York CCCS of Western Pennsylvania, Inc. 971 Third Street Beaver. PA 15009 (412) 774.0798 Heaver CCCS of Northeaster- Pennsylvania 103 Warren Street P.O. Box 709 Tunkhannock, PA 18657 (717) 836-6840 (717) 836.6332 Bradford, Sullivan. Susquehanna, TLoga. Wayne, Wyoming CCCS of Northeaater- Pennsylvania 931 Main Street Honesdale, PA 18431 (717) 253.4981 (717) 253-4817 (fax) Bradford, Sullivan. Susquehanna, Tioga. Wayne, Wyoming CCCS of Wester- Pennsylvania, Inc. 912 South George Street York, PA 17403 (717) 846.4176 Fulton, Lancaster, York Franklin CCCS of Waster- Pennsylvania, Inc. Ist Federal Plaza Suite 406 North Mill Street New Castle. PA 16101 (412) 652-8074 Lawrence commission on Economics Opportunity of Luzern* County 163 Amber Lane Wilkes-Barre, PA 18702 (717) 8:6-0510 or 800.822.0359 (717) 829 1665 ca.. be!ore faxing (717) 45S-4994 (Hdrelton (717)455 5631 (fax) ca.: be-are taxing ( 7 1 7) 8 3 6- 4 0 9 (Tunkhannock) Carbon, Columbia. Luzerns, Monroe. Schuylkill, Wyoming Community Actio: Commission of the Capital Region 1514 Derr/ Street Harrisburg, PA 17104 (717) 232.9757 (717) 234.2227 (fax) Cumberland, Dauphin. Franklin, Perry, Snyder EXHIBIT B Community action Development Comm 701 Dekalb Street Morristown, PA 19401 (610) 277.6363 (6101 277.2123 (fax) Montgomery Coemoity Development Corp. of Frankferd Group Ministry 4620 Griscom Street Philadelphia, PA 19124 (215) 744-2990 (215) 744-2012 (fax) Bucks, Chester, Delaware Philadelphia Community Action southwest 22 West High Street Waynesburg. PA 15370 (412) 952.2891 Allegheny, Fayette, Greene, Washington, Westmoreland community sousing Counselor, Inc. P.O. Box 244 Kennett Square, PA 19348 (610) 444-3682 (610) 444-3170 (fax) B er ka, Chester, Delaware, Lancaster, Montgomery Economic Opportunity Cabinet of Schuylkill county 225 N. Centre Street Pottsville, PA 17901 (717) 622-1995 (717) 622-0429 (fax) Berke, Carbon, Lebanon, Lehigh, Luserne, Northumberland, Schuylkill Fayette Cc Community Action Agency, Inc. 137 North Beeson Avenue Uniontown, PA 15401 (412) 437-6050 or 800-427-INFO (412) 437-4418 Payette Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 1717) 762.3285 Adams, Cumberland, Fulton. Perry Financial Services Unlimited 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Franklin Greater Erie Community Action Committee 19 West 9th Street Erie, PA 16501 (814) 459.4581 (814) 456-0161 (fax) Crawford, Erie, Venaego, Warren Hispanic Assoc. of Contractors/Enterprises 2921.27 North 5th Street Philadelphia, PA 19133 (215) 744-2990 (215) 744.2012 (fax) Bucks, Chester, Delaware Philadelphia Housing Opportunities of Beaver County, Inc. 1501 3rd Street Beaver, PA 15009 (412) 728-7511 (412) 664-1590 (412) 728-7202 (fax) (412) 664-0873 (fax) Beaver, Butler, Lawrence sousing opportunities, Inc. 133 Seventh Street P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 (412) 664-0873 (fax) Allegheny, Beaver, 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, Westmoreland John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898.0400 (814) 898-1243 (fax) Crawford, Elk, Erie, Jefferson, Mckeaa, Venango Keystone Economic Development Corp. 1954 Mar/ Grace Lane Johnstown, PA 15901 (814) 535-6556 (814) 539.1688 (fax) Bedford, Blair, Cambria, Clearfield, Indiana, Somerset, Westmoreland Lyaoming-Clintoaccunties Commission for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, PA 17703 (717) 326.0587 (717) 322-2197 (fax) Centre, Clinton, Lycoming, Union Media Fellowship Roams 302 S. Jackson Street Media, PA 19061 (610) 565-0546 Cheater, Delaware, Montgomery, Philadelphia Nadia Fellowship House 658 North Watts Street Philadelphia. PA 19123 (215) 978-0224 (215) 765.7614 (fax) Philadelphia Non-Valley Unemployed Committee 120 E. 9th Avenue Homestead, PA 15120 (4121 462.9962 (412) 462-9964 (fax) Allegheny, Beaver, Butler, Payette, Greene, Washington, Westmoreland Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15934 (814) 486-1161 (814) 486.0825 (fax) Cameron, Elk, McKean, Patter Philadelphia Council for Community Advancement 100 North 17th Street Suit 600 Philadelphia, PA 19103 (2151 567-7803 (215) 963-9941 (fax) Cheater, Delaware, Montgomery, Philadelphia Shenango Valley Orb" League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 Crawford, Lawrence, Mercer Tableland Services, Inc. 131 North Center Avenue Somerset. PA 15501 (814) 445-9628 (814) 443.3690 (fax) Bedford, Cambria, Fayette, Somerset, Westmoreland Tabor Community Services, Inc. 439 E. King Street Lancaster, PA 17602 (711) 397.5182 or 800-788-5062 (H.O. only) (717) 399-4127 (fax) Chester, Lancaster, Lebanon The Trehab Center of Northeastern PA 7 Lake Avenue, Box 339 Montrose. PA 18801 (717) 278-3338 or 800-982-4045 (717) 278-1889 (fax) Bradford, Sullivan, Susquehanna, Tioga, Wayne, Wyoming EXHIBIT B Urban League of Pittsburgh, Inn. Building For Equal Opportunity One Smithfield Street Pittsburgh, PA 15222-2222 (412) 227-4802 (412) 261.5207 (fax) Allegheny Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, PA 17101 (717) 234.5925 (717) 234-9459 (fax) Ferry Urban League of Metropolitan Harrisburg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234.5925 (717) 234-9459 Cumberland, Dauphin. Franklin, Snyder Warren-Forrest Counties Economic Opportunity Council 204 Liberty Street P.O. Box 547 Warren, PA 16365 (814) 726.2400 (814) 723-0510 (fax) Forest, Warren Weatherisation Office 917 Mifflin Street Huntingdon, PA 16652 (814) 643-2343 Bedford, Blair, Fulton, Huntingdon, 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' ALL THAT CERTAIN lot of around situate an the South side of Went Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded 'and described as follows, to wit; BEGINNING at a point on said West Keller Street and at corner of lot of Harald Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot. South one hundred forty (140) feet, more or leas. to an Allay; thence alone said Alley, West twenty-six (26) feet to lot of Harold Wilbur sforesoid; thence along said lot. North one hundred forty (140) feet, more or less, to the Place of BEGINNING; and HAVING ERECTED THEREON a two and one-half story frame dwelling house numbered 49 West Keller Street, and ocher necessary buildings. BEING THE SAME PREMISES which Wilbur S. Arbegasc and Lattie E. Arbogast, husband end wife, by their Dead dated and recorded September 21. 1959 in the Office of the Recorder of Deader in and for Cumberland County in Dead Book K, Volume 19, Paso 197, granted and conveyed unto William E. Stone and Jaen L. Stone, husband and wife, Grantors heroin. PREMISES: 49 WEST KELLER STREET VERIFICATION TIMOTHY P. O'BRIEN hereby states that he is ASSISTANT VICE- PRESIDENT of NORWEST MORTGAGE, INC. 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 1S Pa. C.S. Sec. 4404 relating to unsworn falsification to authorities. 21-? - - TIMOTHY P. O'BRIEN; ASST. VICE PRESIDENT DATE: l0 2I ' `1 1 '1 J t? "X J (Y' ' 1 J J a ?n v 7• b L_J n? a ? ?a IRE a 6 FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (2151 563-7000 NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 NO. 99-3886 CIVIL TERM PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against THOMAS W. JOHNSON JR., 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 $79,680.73 Interest - 6/1/99 TO 8/13/99 $ 1.143.30 TOTAL $80,824.03 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ?.Ln? fc ")r;'0"A-, ?/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: /1 l w? p /S( & F L - rte t PRO PROTHY/,,?,? U m ?s L. = m m ?. FEDERMAN AND PHELAN 'Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 j (215) 563-7000 NORWEST MORTGAGE, INC. Plaintiff Vs. THOMAS W. JOHNSON, JR. Defendant(s) TO: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: JULY 23, 1999 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS . CIVIL DIVISION . CUMBERLAND COUNTY . NO. 1999-3886 CIVIL TERM 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ???? b? \ C: aC ?? \ ? ?I' ?3 ?_ n-J??>j+ 04 ?p ? ? wb ?-• ? Z J? M1 ?«: ? ?u ?? ? ? ? (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NORWEST MORTGAGE, INC. ) NO. 99-3886 CIVIL TERM Plaintiff VS. THOMAS W. JOHNSON, JR. ) Defendants Notice is given that a Judgment in the above-captioned matter has been entered against you on AUGUST 1999. By: DEPUTY If you have any questions concerning this matter, please contact: 2RL??K F DEN.- E OUI§- RE \__ _ Attorney for;Party Filing Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 **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.** FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 NORWEST MORTGAGE, INC. Vs. THOMAS W. JOHNSON, JR. ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 99-3886 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors, Civil Relief Act of Congress of 1940, as amended. (b) that defendant THOMAS W. JOHNSON, JR. is over 18 years of age and resides at 49 WEST KELLER STREET, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN`, ESQUIRE Attorney for Plaintiff W? CV3 s k . . M', _ cm ox 0 r PRAECIPE FOR WRIT OF EXECUnON - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 ,NORWEST MORTGAGE, INC. Plaintiff Vs. THOMAS W. JOHNSON, JR. Defendant(s) . COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PA NO. 99-3886 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION • (MOR7Y:ACF, FORECLOSURE) TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 8/13/99 TO 12/8/99 (PER DIEM - $13.29) -$-80,824.03 / $ 1.568 22 and Costs $82.392.25 Total FRANK FEDERMAN, ESQUIRE TWO PENN CENTE?t PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. 0 ro T CA H m E E a H H U co co co n m rn 0 z Q OQ h > Q .] ?z oz 00 92 OQ UV W ? F 5 z5 V U H W U E4 0 E m 3 0 z N z 0 F u .. z v W 0 V1 0 O h a LL m 3 O? N {y O a? E U W Q a ro U1 w Ln In a a a P° W U ri W W a a W oc E W mc m M m N m A a 9 N H m a m sa m N m N N m H ?o b I u FIR a ur. ?4 b? 'j, J o'er" cn DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at comer of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-six (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel /f 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29/95, in Deed Book 128, Page 1037. R lV ? ^` Y t2 ' cm ul Y lclrc% FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 NORWEST MORTGAGE, INC. VS. ATTORNEY FOR PLAINTIFF . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION THOMAS W. JOHNSON, JR. NO. 99-3886 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) 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 FEDERMAt? , ESQUIRE Attorney for Plaintiff ? WQ C7 ? vii C F aE d J? '> PLC = m a 15 rn NORWEST MORTGAGE, INC. VS. THOMAS W. JOHNSON, JR. CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION . NO. 99-3886 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No 1) NORWEST MORTGAGE INC. , 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 49 WEST KELLER STREET. MECHANICSBURG PA 17055 1. Name and address of Owner(s) or reputed owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) THOMAS W. JOHNSON JR. 49 WEST KELLER STREET MECHANICSBURG. PA 17055 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) NONE 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) NONE r 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 TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 49 WEST KELLER STREET MECHANICSBURG. PA 17055 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. August 13, 1999 ? n,x 2a we,0 A DATE FRANK FEDERMAN, ESQUIRE Attorney forjPlaintiff ? ¢? M _ ?? a. ?> ???,? 1 ? ? i i LL LIB ? _ = ? L? t CJ O? 1 NORWEST MORTGAGE, INC. Vs. THOMAS W. JOHNSON, JR. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3886 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY August 13, 1999 TO: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 **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 49 WEST KELLER STREET MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriff's Sale on DECEMBER S. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $80.824.03 obtained by NORWEST MORTGAGE. INC. (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 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 DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-six (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel# 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29/95, in Deed Book 1281 Page 1037. a ?-° ? ? r8 ? ? ? ? o. ?? z ?ti?? ? ? a ? ? ? Norwest Mortgage Inc. -vs- William W. Johnson, Jr. In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-3886 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 1149 Posting Bills 15.00 Advertising 15.00 Law Library .50 County 1.00 Mileage 12.40 Certified Mail 3.34 Levy 15.00 Postpone sale 20.00 Surcharge 16.00 Share of Bills 23.63 Law Journal 200.00 Patriot News 222.75 $ 586.11 Pd by atty 12-09-99 Sworn and Subscribed To Before Me This /5 L Day of ??- 1999, A.D. _ u 7k QQc - Pr th notary So answers: R. Thomas Kline, Sheriff By t??? Real Estate Deputy Cie Q010 Rt'e. R9ot. 3 1 NORWEST MORTGAGE, INC. VS. THOMAS W. JOHNSON, JR. . CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION NO. 99-3886 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) NORWEST MORTGAGE. INC. , 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 49 WEST KELLER STREET MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 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) NONE 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) NONE i 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) TENANT/OCCUPANT 49 WEST KELLER STREET MECHANICSBURG, PA 17055 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. August 13, 1999 An 4A DATE FRANK FEDERMAN, ESQUIRE Attorney for ./Plaintiff -P 4.. NORWEST MORTGAGE, INC. • CUMBERLAND COUNTY COURT OF COMMON PLEAS Vs. CIVIL DIVISION THOMAS W. JOHNSON, JR. • NO. 99-3886 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY August 13, 1999 TO: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 **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 49 WEST KELLER STREET MECHANICSBURG PA 17055, 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 580,824.03 obtained by NORWEST MORTGAGE INC. (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: 12151 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 (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 ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at comer of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-sic (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel# 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29/95, in Deed Book 128, Page 1037. WRIT OF EXECUTION and/or ATTACHMENT I COMMONWEALTH OF PENNSYLVANIA) NO. 99-3886 CIVIL 19 _ COUNTY OF CUMBERLAND) CIVIL ACTION - LAW C TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Norwest Mortgage inc. Thomas W. Johnson, Jr. (1) You are directed to levy upon the properly of the defendant(s) and to sell See legal description of property (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 defendant(s) not levied upon an subject to attachment is found in the possession of anyone other thana named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. Amount Due $80,824.03 L.L. 33 99 $.50 Interest from 8/Si/568t2212/8/99 (per diem DuelPiothy 51.00 Ally's Comm _% Ally Paid $104.20_ Other Costs Plaintiff Paid Date: June 17, 1999 Curtis R. Long Prothonotary, Civil Division REQUESTING PARTY: Name Frank Podprnvan Pact. Address: Two Penn Center Plaza, Suite 900 Attorneyfor: Pta;nr;ff by: 4Z6rw ?fny Telephone: (91,;) 563-2nn0 Supreme Court ID No. 199aR i e rte.:. ` 3z-? On f3?* $ r 99 9 the sheriff levied upon the defendants interest in the real property situated in 4" •-p ".1a"4 Cumberland County, Pa., known and numbered as: y%,vJ s - jx? / and roore full; described on Exhibit "A" filed with this writ and by this roference incorporated herein. Oate: / 999 By. vlNtl o SN,M3d 668 Nj sa 6 81 Sol (EY c ln'" ri ,,,fla ,?jiUyHS .;Hl iU 311??0 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE. OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical 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 SALE NO. 32 Writ No. 99-3886 Civil Nonvest Mortgage. Inc- vs. Thomas W. Johnson. Jr. Atty.: Frank Federman DESCRIPTION ALLTHAT CERTAIN lot of ground situate on the South side of West Keller Street in the Borough of Mechanicsburg. in the County of Cumberland and State of Pennsylva- nia, bounded and descried as fol- lows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wtlbur. thence along said Street. East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs. now of Annie M. Kunkle: thence Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this _j _day of NOVEMBER. 1999 NOTARIAL SEAL Lois E. SNYDER, Notary Pubk CarWe loro, Cumbodard County, PA My Commiuion Expire March 5, 2001 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical 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 Afffant 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. RFAL ESTATE E{MZ NO. 32 Writ No. 99-3886 Civil Norwest Mortgage. Inc. VS. Thomas W. Johnson. Jr. Atty.: Frank Federman DESCRIPTION ALLTHAT CERTAIN lot of ground situate on the South side of West Keller Street in the Borough of Mechanicsburg. In the County of Cumberland and State of Pennsylva- nia. bounded and described as fol- lows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street. East twenty-five (25) feet and six (6) Inches to a point at corner of lot formerly of Solomon Mohler Heirs. now of Annie M. Kunkle; thence along said lot. South one hundred forty (140) feel, more or less. to an Alley; thence along said Alley. West twenty-six (26) feet to lot of Harold Wilbur aforesaid: thence along said lot North one hundred forty (140) feet. more or less, to the place of begmmng and having erected thereon a two and one-half story frame dwell- ing house numbered 49 West r street, and other necessary build- ings. Tax Parcel #16-24-0787,022, TITLE TO SAID PREMISES IS VESTED IN'IlromaS W Johnson, Jr. singleman by Deed from William E. Stone and Joan L. Slone, a/k/aJoart R. Stone, husband and Will dated 9/7/95, recorded 93 29/95, in Deed Book 128 page 0 Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this _j -day of NOVEMBER. 1999 NOTARIAL SEAL LOIS E. SNYDER, Notary Pu61k Carlub 6oro, Cumbrian County, PA My Commis4on Expira Manh S, 2ix)I S (y s v t REAL ESTATE SALE N& 32 W CM TOM Nolwed umve ' Ift THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Rct & IR Rooro gad M^ i i6 19 9 Commonwealth of Pennsylvania, County of Dauphin} so 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 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published In their regular daily and/or Sunday 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 directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #32 Sworn to and subscribed before me this 18th day of November 1999 A.D. NOTARY PUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE COURTHOUSE CARLISLE, PA. 17013 Statemen of Advertising Coctc To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 221.25 Probating same Notary Fee(s) $ 1.50 Total $ 222.75 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 .................................................................... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORWEST MORTGAGE, INC. Plaintiff CIVIL DIVISION VS. No. 99-3886 CIVIL TERM THOMAS W. JOHNSON, JR. Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for NORWEST MORTGAGE, INC. hereby verify that on AUGUST 23. 1999, true and correct copies of the Notice of Sheriff'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 23. 1999 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ?o F WK FEDE MAN, ESQUIRE ttorney or Plaintiff Date: November 8, 1999 ? E J $?E ? d ? g S m Q gaa o yLL ? ?. ?,??ry-g ?02 d ?N$ N ¢LL ? WC ? CW?GCj Ewq N O o 3D y? `g3cv1gg 'd . i E c ^ aY;$ a - ?+ a y E ? gQ g 6 $2f ? n v- 34 g 0 g 5 7a V; <- i ? L? N G E y N t C ct yy pp ?? go UIZ? iV - sS ??445 =9q G UU ? S i y a 1 y y N 6?p LL T F A¢'=w a° g n E? m W 0 m' 0 O S , g¢=U U ^ ? 8 a z ? E $ a 2 O z p W m 1 d O? 6 V1 F F ? ly O E m y ¢ Z w W F a o H 0 O N Z o = F W C) w W G V m m m w W - S m 6?' V O N U V W ap Z 6. F W z m \ F Z Z r+ F ...7 n 'od 8'' Z 6 ¢ ¢ S In .. z m E $ W 6 U cz 9 S w Z E V £ E o V 2 9 z w W pZCcza ?a ?aco? W ? w w -+ x w x ? ? u E E W ? E? y 2 2 < o c J N co C I!7 10 I? co Ol O ^ ^ ^ ° p f J d a i C C 3 c' s E E U c LL IIeW alge;unooad job _pusTmARK- DEBATE AETOn? . yE1:F4:EDDtrrvER'. ' ' D CERTIFIED (EE RETURN RECEIPT _ 8<Nn F. Et T , SENT TO: ?:m EOn nETEnN?nowEtiin " Ei . ,... .. .... ..lip i ... _ ? ] .J fl mK- m m N r N ..0 M1 CL C PS FORM 3800 US Postal Service Receipt for Certified Mail ?, R, : ?'_ L-, ? . UJ'?' (.? ? ;- a_ t 7 C' P 1 i:, i _ C?? _ c- _ i- .. Ll. fn _ U r,^. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 NORWEST MORTGAGE, INC. CUMBERLAND Plaintiff, V. No. 99-3886 THOMAS W. JOHNSON, JR. Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $80,824.03 Interest from 8/13/99 TO 3/07/01 7 5$ , 88.59 and Costs (per diem - $13.29) $ 88.412.62 TOTAL FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff 1 1t i Note: Please attach description of property.No. A 0 °o N w? z o tn ? o c WWW ?? U OFa iz w z x; xxa C6 d cn w u O ` ? ?? Uz H a: x O o ?w a ° ? 3 W F w O ; d n z d ?u F N CC oe0n O c p3U m ¢ x w U? p F Uv x? z b r V a E A a L 3 ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-six (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel N 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29195, in Deed Book 128, Page 1037. fA Lo ;t -' A 0 ? 0 0 0 ? -_? ? ? Q ,Y ? ?+ 0 0 0 Po ri L7 CN) G q L Y V. a W?'lls (•,r v UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ??, ,? < I r IN RE: 7/1WN K)L(F Thomas Willard Johnson, Jr. Chapter No. 13 -------- Debtor(s) Bankruptcy No. 99-05155 RJW Wells Fargo Home Mortgage Inc., { F/K/A Norwest Mortgage Inc. Movant V. Thomas Willard Johnson, Jr. Respondent (s) ORDER 4,u • 2000. upon AND NOW, this q Tv day of consideration of the Motion for Relief and Motion for Default of Movant, Wells Fargo Home Mortgage Inc., F/K/A Norwest Mortgage Inc., it is hereby ORDERED that the Order for Relief be entered by default with respect to premises at 49 West Keller Street, Mechanicsburg, PA 17055, to allow the vtovant to foreclose on its mortgage, which mortgage was recorded in Cumberland County, in Mortgage Book 1284, Page 335, to allow the Movant to foreclose on its mortgage, and allow the purchase of said premises at Sheriffs sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. By the Court: /s/ Robert J. Woodside Robert J. Woodside, Bankn4ptcy Judge cc: Judith T. Romano, Esquire Two Penn Center Plaza. Suite 900 Philadelphia, PA 19102 Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 F1L - NOY 0 9 2000 Charles J. Dehart, 111. Esquire (Trustee) P.O. Box 410 Hummelstown. PA 17036 Thomas Willard Johnson.. 49 West Keller Street Mechanicsburg, PA 17055 U 111 iJ _ cn C7 oa VtNrS I NORWEST MORTGAGE, INC. Plaintiff, V. THOMAS W. JOHNSON, JR. Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3886 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) NORWEST MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 49 WEST KELLER STREET, MECHANICSBURG. PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS W. 49 WEST KELLER STREET JOHNSON, JR. MECHANICSBURG, PA 17055 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 everyjudgment 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.) None 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.) 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.) 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 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.) Tenant/Occupant 49 WEST KELLER STREET MECHANICSBURG, PA 17055 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 unswom falsification to authorities. December 11, 2000 DATE FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff i re In it ) t r, s 2 t L) C) y N t NORWEST MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, V. No. 99-3886 THOMAS W. JOHNSON, JR. Defendant(s). December 11, 2000 TO: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 49 WEST KELLER STREET, MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriffs Sale on MARCH 7. 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by NORWEST MORTGAGE, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the JUNE 6, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if thejudgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Nlechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Solomon Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-six (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel N 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29/95, in Deed Book 128, Page 1037. :LU FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 NORWEST MORTGAGE, INC. Plaintiff, V. THOMAS W. JOHNSON, JR. Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3886 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff st+l? ?' '?' '- ? ? ' , i 1 ?? '?: r ? ?. LI i(L t. :') ,_J ?•:? U AFFIDAVIT OF SERVICE PLAINTIFF NORWEST MORTGAGE, INC. CUMBERLAND No.99-3886 DEFENDANT(S) THOMAS W. JOHNSON, JR. Type of Action SERVE AT 49 WEST KELLER STREET - Notice of Sherlfrs Sale MECHANICSBURG, PA 17055 SERVED Sale Date: MARCH 7, 2001 Served and made known to 7 ALMS b,;- 49VSQa J)2, Defendant, on the --QJS L l- day of E(7. 2000, at X9.)6 , o'clock L. m., at yet CJEST WknfR 9; & A1AVj4T f 0 pA /ryOSS- , Commonwealth of Pennsylvania, in the manner described below: iLDefendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age -2-L- Height Weight J.?o Race L1 Sex t_ Other I, PAuI I. L)PAO ttER -iQ ., a competent adult, being duly swum according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the [Wanner asset forth herein, issued in the captioned case on the date and at the address indicated above. l?t W NOTSERVED V 200_, at o'clock _ m., Defendant NOT FOUND because: No Answer Vacant Sworn to and subscribed before me this _ day of 200-. Notary: By: Swom to and subsc 'bed before his d ota By:vJ? Z), r?AR A. PE otary Publi FayeS!eville, ranklln County M Commiselon Expires Aug. 20, 2002 On the day of _ Moved Unknown Other: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 - :; - ;_ SALE DATE: MARCH 7. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NORWEST MORTGAGE, INC. VS. THOMAS W. JOHNSON, JR. No.: 99-3886 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 49 W. KELLER STREET, MECHANICSBURG, PA 17055. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed), and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February 7, 2001 NORWEST MORTGAGE, INC. THOMAS W. JOHNSON, JR. V. Plaintiff. Defendant(s). CUMBERLAND COUNTY COURT OF COivIhION PLEAS CIVIL DIVISION NO. 99-3886 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) NORWEST MORTGAGE. INC, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was tiled the following information concerning the real property located at 49 WEST KELLER STREET 11VIECHANICSBURG. PA 17055, 1. Name and address of Owner(s) or reputed Owner(s): 3. NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS W. 49 WEST KELLER STREET JOHNSON, JR. MECHANICSBURG, PA 17055 Name and address of Defendant(s) in thejudgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above Name and address of everyjudgment 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.) None 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.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please 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 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.) Tenant/Occupant 49 WEST KELLER STREET MECHANICSBURG, PA 17055 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 s ')ject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. December It, 2000 DATE FR4NK FEDER?fAN, ESQUIRE Attorney for Plaintiff DATE: DECEMBER 12, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) THOMAS W. JOHNSON, JR. PROPERTY: 49 WEST KELLER STREET MECHANICSBURG, Pa 17055 Improvements: Residential Property CUMBERLAND The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 7. 2001, at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street. Carlisle PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH V U °o e ? O y •? 7 J E? oo a > >, o z< c?Co¢ Q U ° 5 r^ Q L?GJ v ? 6) 'O L d H d L L z e `0 _ a ? Yd -yv c eZ Y.L 3 ^ 0v y 3 3 Y ? ? -yFrE 7 ?C = H 6 N1 ?a a.5 C's'2 =3 A Q U G. 04 aycYa ? ? y 8 Y VI L , j V L o y a? t C .? ? i u n ? d U ? s C V C- , `, 4 Q o F ?x U L u E..; az x 0 U -• N N1 V v1 v^ t? W G1 ? -' N rv1 'd' ? ? J r '? N I .t 1. - . . STATE OF PENNSYLVANIA, i COUNTY OF CUMBERLAND J SS. Robert P Ziegler I,------------------------------- Deeds in and for said County and State do'hereby certify that the Sheriffs Deed in which ________________ SEcretary of Veterans Affairs ------------------------- is the grantee the same having been sold to said grantee on the _ 6th --------------------- day of June 01 ---------------------------------------- A. D.,' under and by virtue of a writ-------------- ----Execution 13th -----------------------------------issued on the --------- ---------------------------- day of -Dec ---------- A. D., 2000 _, out of the Court of Comman Pleas of said County as of ---- Civil 1999 ------------------...._ ----------------------------- g -------------------- N"t" ------------- ,iliHesuit of__________-_________ Norwest Mtg Inc - - - ----------------------------- ----------------------------------- against-------- Thomas W Johnson Jr duly recorded in Sheriffs Deed Book No. __ 247----- Page ---321 ---- IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ____?&;t__ day of ------------U ' " -- -- A. D., dw o 1 Recorder o V Rseade. d Delft &Wbffkw patap, pt fek !!1 My otann 00 EOM MI flat M Ita 2EEt Norwest Mortgage, Inc. -vs- Thomas W. Johnson, Jr. In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-3886 Civil Shawn Harrison. Deputy Sheriff, who being duly sworn according to law, says on January 8, 2001 at 8:12 o'clock P.M. EST, he served a true copy of real estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Thomas W. Johnson Jr. by makin gknown unto Lisa Johnson at 49 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the saute time handing to her personally the said true and attested copies of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, says on January 8, 2001 at 8:12 o'clock P.M.EST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Thomas W. Johnson, Jr located at 49 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says lie 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 the defendant Thomas W. Johnson Jr by regular mail to his last known address 49 West Keller Street, Mechanicsburg, Pennsylvania. This letter was mailed under the date of January 9, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, 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 the Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock A.M., E.D.S.T. and sold the same for the sum of $1.00 to Attorney Dale Shughart for Secretary of Veterans Affairs, An Officer of the United States of America. It being the highest bid and the best price received for the same Secretary of Veterans Affairs, An Officer of the United States of America, of VARO Cleveland(MPD 262 PHI) P.O. Box 99640 Cleveland, OH, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $803.88 it being costs. Sheriffs Costs Docketing 30.00 Poundage 13.76 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 County 1.00 Mileage 6.20 Certified Mail 4.45 Levy 15.00 Surcharge 20.00 Postpone Sale 20.00 Law Journal 237.50 Patriot News 206.94 Share of Bills 25.53 Distribution of Proceeds 25.00 Sheriffs Deed 26.54 $701.88 paid by attorney- June 20, 2001 Sworn and subscribed to before me This go k' day of ??4 2001 A.D. Q. -)7tJ ' P othonotary R. Thomas Kline, Sheriff By UCLA?u- Deputy heriff 36" "' ? i v C? Ck- 330"?1 ilYF?S? NORWEST MORTGAGE. INC. V. Plaintiff, THOMAS W. JOHNSON, JR. Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3886 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) NORWEST MORTGAGE INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 49 WEST KELLER STREET MECHANICSBURG. PA 17055 1. Name and address of Owner(s) or reputed Owner(s): 2. NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS W. 49 WEST KELLER STREET JOHNSON, JR. MECHANICSBURG, PA 17055 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 Name and address of everyjudgment 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.) None 4. 5. 6. 7 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.) 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.) None 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 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.) Tenant/Occupant 49 WEST KELLER STREET MECHANICSBURG, PA 17055 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 unswoom falsification to authorities. December 11, 2000 L' DATE FRANK FEDEILtitAN, ESQUIRE Attorney for Plaintiff NORWEST MORTGAGE, INC. Plaintiff, V. THOMAS W. JOHNSON, JR. Defendant(s). CUMBERLAND COUNTY No. 99-3886 December 11, 2000 TO: THOMAS W. JOHNSON, JR. 49 WEST KELLER STREET MECHANICSBURG, PA 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 49 WEST KELLER STREET, MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriffs Sale on MARCH 7, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by NORWEST MORTGAGE, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the JUNE 6, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE, TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur; thence along said Street, East twenty-five (25) feet and six (6) inches to a point at corner of lot formerly of Soloman Mohler Heirs, now of Annie M. Kunkle; thence along said lot, South one hundred forty (140) feet, more or less, to an Alley; thence along said Alley, West twenty-six (26) feet to lot of Harold Wilbur aforesaid; thence along said lot, North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel # 16-24-0787-022 TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from William E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95, recorded 9/29/95, in Deed Book 128, Page 1037. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3886 CIVIL TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Nonvest Mortgage, Inc. PLAINTIFF(S) from Thomas W. Johnson, Jr., 49 West Keller Street, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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 properlyof the defendant(s) not levied upon an subject to attachment is found inthe possessionof anyoneother than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $80,824.03 8/13/99 to 3/7/01 - $7,588.59 and Interest ests (per diem $13-29) Atty's Comm Atty Paid $703.81 Plaintiff Paid L.L. Due Frothy. Other Costs Date: December 13, 2000 Curtis R. Long Prothonotary,, Civil Division may' Deputy REQUESTING PARTY: Name Frank Federman Esq. Address: One Penn Center at Suburban Station, Suite 1400 Philadelphia PA 19103 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 REAL ESTATE SALE NO. 34 u1i Aa?S Aowd the sheriff levied upon the defendants O?W 44 Interest in the real property situated in Cumberland County, Pa k umbered as: VF e.J &ja )1 ano m rt; this writ and by this ieterene j on Exhibit "A" flied with ;rated herein. By'J f(N ( y L ?. y sw? y g 9 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which Is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 30th day(s) of January and the 6th and 13th day(s) of February 2001. 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 duty authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County ff Tauphir7-in Miscellaneous Book "M", Volume 14, Page 317. II //11 PUBLICATION COPY SALE#36 .................................................... rr -tgis 27th daY d1Febr(fjRy 2001 A.D. Terry L. Russell, Notary ruo c Harrisburg, Dauphin County .?r2 G My commission Expires June 6,2 Member, Pennsylvania Assocleibn of Notaries TARP PUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 205.44 Probating same Notary Fee(s) $ 1.50 Total $ 206.94 Publisher's Receipt for Advertising Cost The Patriot Ne ublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby ackno fn? said notice and publication costs and certifies that the same have been duly paid. :<_; iv.?> • 7° REAL ESTATE SALE NQ 36 WrnNO. illolt- 6 CMITOrm N~rkrt", br- By .................................................................... on the or IS VESTED IN 1 5 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 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: JANUARY 19, 26, FEBRUARY 2, 2001 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 SALE NO. 36 Roger M. Morgenthal, Editor Writ No. 1999-3886 Civil Norwest Mortgage. Inc. VS. Thomas W. Johnson. Jr. Ally.: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsyl- vanta, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur: thence along said Street. East twenty-five (25) feet and six (6) Inches to a point at SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY 2001 NOTARIAL SEAL LOIS E. SNYD9t, Notory Public Codi,19 Eoro, C.rmburlood CounPA My Comr w,, Expro, March S, 2001 CORRECTION Previous Image Refollmed to Correct possible Error PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 19, 26, FEBRUARY 2, 2001 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 SALE NO. 36 Writ No. 1999-3886 Civil Norwest Mortgage. Inc. VS. Thomas W. Johnson. Jr. Ally.: Frank Federman DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of West Keller Street. in the Borough of Mechanicsburg. In the County of Cumberland and State of Pennsyl- vania, bounded and described as follows, to wit: BEGINNING at a point on said West Keller Street and at corner of lot of Harold Wilbur: thence along said Street. East twenty-five (25) feet and six (6) inches to a point at corner or lot formerly of Solomon Mohler Heirs. now of Annie M. Kunkle: thence along said lot. South one hundred forty (1401 feet, more or less. to an Alley: thence along said Alley. West twenty-six (26) feet to lot of Harold Wilbur aforesaid: thence along said lot. North one hundred forty (140) feet, more or less, to the place of beginning and having erected thereon a two and one-half story frame dwelling house numbered 49 West Keller Street, and other necessary buildings. Tax Parcel #16-24-0787-022. TITLE TO SAID PREMISES IS VESTED IN Thomas W. Johnson, Jr., singleman by Deed from Wil- liam E. Stone and Joan L. Stone a/k/a Joan R. Stone, husband and wife dated 9/7/95 recorded 9/29/ need Book 128. Page 1037. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY. 2001 NOTA91AL SEAL LOIS E. SNYDER, Notary Public Corlirte Eoro, Cw Iossdond County, PA Mr Commhuon Expires Kutch S, 2001 1 1`