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Home My WebLink About99-04033 v H I? r c? Cl) M HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORAITON Plaintiff VS. LAWRENCE A. BRADY AND TRACI M. BRADY Defendants THIS LAW FIRM IS A DEBT TO COLLECT A DEBT OWED OBTAINED FROM YOU WILL COLLECTING THE DEBT. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1/433 Gum CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COLLECTOR AND WE ARE ATTEMPTING TO OUR CLIENT. ANY INFORMATION BE USED FOR THE PURPOSE OF N O T I C E You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 A V I S 0 LE HAN DEMANDADO A USTED EN LA COUTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA COUTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A ON ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA. DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row; ?arlisle, PA 17013 717-243-9400 HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff Vs. LAWRENCE A. BRADY AND TRACI M. BRADY Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 9633 CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff V8. LAWRENCE A. BRADY AND TRACI M. BRADY Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- '4053 CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C O M P L A I N T 1. Plaintiff, HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION, is a Florida corporation, with an address of 7301 Baymeadows Way, Jacksonville, Florida, 32256. 2. Defendant, LAWRENCE A. BRADY, is an adult individual whose last known address is 4808 BAKER PLANTATION DRIVE, ACTWORTH, GEORGIA 30101-3404. Defendant, TRACI M. BRADY, is an adult individual whose last known address is 4808 BAKER PLANTATION, ACTWORTH, GEORGIA 30101-3404. 3. On or about September 29, 1994, the said Defendants executed and delivered a Mortgage Note in the sum of $69,939.00 payable to BANCPLUS MORTGAGE CORPORATION, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. Homeside Lending, Inc. is successor by Merger to BancPlus Mortgage Corporation. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 1107 PHEASANT DRIVE NORTH, CARLISLE, PENNSYLVANIA 17103-1252 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on February 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 66,649.75 (b) Interest at $12.10 per day from 1/1/99 to 7/1/99 (based on contract rate of 6.625%) 2,190.10 (c) Accumulated Late Charges 124.80 (d) Late charges at $24.96 per month for 6 months 1749.76 (e) Escrow Deficit 39.40 (f) 516 Attorney's Commission 3,332.49 $ 72,486.30 *Together with interest at the per diem rate noted in (b) above after July, 1 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.625°s ($12.10 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. PURCELL/ iMuG & HALLER By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 0 I? p WM ON Wlg1 W ~S W03131Y16 'YGIL?•AOiG'.[Y?031311 1t6itY 'T HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4033 LAWRENCE A. BRADY AND TRACI : CIVIL ACTION - LAW M. BRADY : IN MORTGAGE FORECLOSURE Defendants RETURN OF SERVICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9TH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC., NO. 99-4033 SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION CIVIL ACTION - LAW Plaintiff IN MORTGAGE FORECLOSURE versus LAWRENCE A. BRADY AND TRACI M. BRADY Defendant Know all persons by these presents that I, Christopher Gray , was assigned to duly execute this service upon the following defendant: LAWRENCE A. BRADY at 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404, 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private investigator. I hereby certify that on 12 / 30 / 9 9 at approximately 7 : 30 Oa. m. mp.m. a true and correct copy of the COMPLAINT IN MORTGAGE FORECLOSURE were served on the above-named party or witness in the following manner: ® 1 personally delivered them into the hands of the person to be served. ? By leaving a copy at his/her usual place of abode with whose relationship to the defendant is and who is of suitable age and discretion and also residing therein. ? By leaving a copy with defendant resides. the manager/clerk of place of lodging in which ? By leaving a copy with , the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process Description of Recipient: Sex: M Race: B Approximate Height: 55 r 99 "Approximate Weight: 175 Approximate Age:_ FURTHER AFFIDAVIT SAYTH NOT. 7t ?°yL t- ??Az-'--L Subscribed and sworn to before me this 3rd Sigr a of Process Server day of January3j-VV "Ba* 2000 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9TH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC., NO. 99-4033 SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION CIVIL ACTION - LAW Plaintiff IN MORTGAGE FORECLOSURE versus LAWRENCE A. BRADY AND TRACI M. BRADY Dcrcndant Know all persons by these presents that I, Christopher Gray , was assigned to duly execute this service upon the following defendant: TRACI M. BRADY at 4808 BAKER PLANTATION DRIVE. ACTWORTH. GA 30101-3404. 1 hereby depose and say: I ) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private investigator. I hereby certify that on 12 / 3 0 / 9 9 at approximately 7 * 30 ?a.m. ap.m. a true and correct copy of the COMPLAINT IN MORTGAGE FORECLOSURE were served on the above-named party or witness in the following manner: ? I personally delivered them into the hands of the person to be served. ?r By leaving a copy at his/her usual place of abode with Lawrence Brady, whose relationship to the defendant is husband and who is of suitable age and discretion and also residing therein. ? By leaving a copy with defendant resides. the manager/clerk of place of lodging in which ? By leaving a copy with , the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process because: Description of Recipient: Sex: M Race: B Approximate Height: 519 n Approximate Weight: 175 Approximate Age:_ FURTHER AFFIDAVIT SAYTH NOT. Sign cure of Process Server Subscribed and sworn to bei?ore me this 3rd day of January -A92'k 2000 Notary M, Commission Expirs ry Sept 272N2 C r• (Y. ? J N -?•f, U it 1 +ly ;? . ? o U a ? ? u r P .' Z LE C7 Q H .a'?, a LL ? u m a_ m n7 c? cnoo ?F ?? ? ?Fn. l U O W pO=HH ?a o ~ m ?,H ? ? vJ W?7 ? UWW C. a a ?Q?Q``'' ?. ss? as.osouo• ie csus•.o ell's a. irooc m.bJl wG3,Nvlflw SHERIFF'S RETURN - REGULAR CASE NO: 1999-04033 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMESIDE LENDING INC ET AL VS. BRADY LAWRENCE A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon BLAISDELL DAVID (TERRE TEN) the defendant, at 8:50 HOURS, on the 23rd day of July 1999 at 1107 PHEASANT DRIVE NORTH CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to DAVID BLAISDELL a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers- 18.00 Docketing 7 Service 3.10 P Affidavit .00 Surcharge 8.00 R I nomas ine, eri $2 9. 0 PU CE/139KRUG & HAL ER 0723 9 by Sworn and subscribe to before me this ,13. 1- day of uepucy bnerixi 19?? A. D. k SHERIFF'S RETURN - REGULAR CASE NO: 1999-04033 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMESIDE LENDING INC ET AL VS. BRADY LAWRENCE A ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BLAISDELL NANETTE (TERRE TEN) the defendant, at 8:50 HOURS, on the 23rd day of July 1999 at 1107 PHEASANT DRIVE NORTH CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to NANNETTE BLAISDELL a true and attested copy of the COMPLAINT - MORT FORE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 6.00 ?s7P .00 .00 8.00 R-KIin'e,-5 ei ri f- ?.UU-07/CPL KRUG & by C'? Sworn and subscribed to before me this .7 3A4(. day of 19 (IFy A. D. ror- nonoCdly HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION, PLAINTIFF VS. LAWRENCE A. BRADY AND TRACI M. BRADY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4033 IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants LAWRENCE A. BRADY AND TRACI M. BRADY for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $66,649.75 Interest $ 2,190.10 (Per diem of $12.10 from 1/1/99 to 7/1/99) Accumulated late charges $ 124.80 Late charges $ 149.76 ($24.96 per month to 7/99) Escrow Deficit $ 39.40 5% Attorney's Commission $ 3,332.49 TOTAL $72,486.30** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. 7 PURCELL, KRUG & ER By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LMOMEWWDOGS'DDMDERLA`.BRADY P HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BANCPLUS CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE CORPORATION, PLAINTIFF CIVIL ACTION - LAW VS. LAWRENCE A. BRADY AND NO. 1999 4033 TRACI M. BRADY, DEFENDANTS IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on February 16, 2000 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant (s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ae? R p HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff Vs. LAWRENCE A. BRADY AND TRACI M. BRADY Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-04033 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: February 16, 2000 TO: LAWRENCE A. BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH, GA 30101-3404 TRACI M. BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH, GA 30101-3404 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE TO COLLECT A DEBT OWED TO OUR CLIENT. ANY OBTAINED FROM YOU WILL BE USED FOR THE COLLECTING THE DEBT. ATTEMPTING PURPOSE OF 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: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 PUR?CELL, KRUG &/ ER i By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER. TO BANCPLUS CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE PLA-NTIFF CIVIL ACTION - LAW VS. LAWRENCE A. AND NO. 1999 4033 Tiv`.i M. BRAD _", DEFENDANTS IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE A30VE-NA.IIED DEFENDANTS: You are hereby notified that on the following judgment has been entered against you in the above- captioned matter: $72,486.30 and for the sale and foreclosure of your property located az:: 1107 PHEASANT DRIVE NORTH, CARLISLE, PA 17013 Dated: PROTHONOTARY Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certif:: that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Lawrence A. Brady 4808 Baker Plantation Drive , Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 I' HOME `MKFOOCS':CUMBERLA' BRADY N IM J J C 111 ` /? J... ?? II"U - L O U l HOMESIDE SUCCESSO MORTGAGE VS. LAWRENCE TRACI M. LENDING, INC., BY MERGER TO BANCPLUS CORPORATION, PLAINTIFF A. BRADY AND BRADY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4033 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1107 PHEASANT DRIVE NORTH, CARLISLE, PA: 1. Name and address of the owner(s) or Reputed Owner(s) : Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) S. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating t :o unsworn falsification to authorities. Leon P. Haller PA I D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 3, 2000 o. q- C% j 4 w C%J _ 4 Ct G- C J U C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: HCMESIDE LENDING, INC. , SUCCESSOR by merger to BANCPLIJS MO TG.AGE CORPORATICN, Plaintiff VS. LAWRENCE A. BRADY AND TRACI M. BRADY, Defendants ( ) Confessed Judgment ( XX) Other IN MORTGAGE FORECLOSURE File No. 1999 4033 Amount Due $ 72,486.30 Onre9 $102.10 from 4,114.00 Late charges at $24.96 299.52 crcr Deficit ' osts 713,699.82 sts TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs, upon the following described property of the defendant(s) 1107 Pheasant Drive North Carlisle PA 17013 IN MORTGAGE FORECLOSURE PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) REAL ESTATE: 1107 Pheasant Drive North, Carlisle, PA 17013 EAL OWNER: Lawrence A. Brady and Traci M. Brady and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). C3 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of defendant(s) described in the attached exhibit. Date _ MAR C cu, a Signature: Print Name: Leon P. Haller Esquire Purcell, Krug & Haller Address: 1719 North FU,nt; Street Harrisburg, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No.: #15700 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. • f LEGAL DESCRIPTION ?LL'I'11,1'I' CERT.%IN lot or tract of ground siutate in North Middleton Township, Coijnt% Co:nmo nveafth of Pennsykanlit, more pitrticulrtrly shown on it certain pian entitled: "Final Subdi.,ision Plan of Pheasant Run Esimes, Phase 11 and Phase III for lfetlanco Inc. North : fiddleton To%%nship, Cumberland Cc , Pennsylvania Sale V=50' April 9, 1975 Revised: April 30, 1975" by Geri! J. L'etz Associates, Inc., Engineers S Survcvcrs, 6 East :Main Street, Shiremanstown, Pennsylvania, which plan is ed in Pi;::: Book 29, Pave 71 in the Office of the Recorder of Deeds for Cllntberland Cotnut Said lot is more naittcu!arlp bounded and described.as follows: BEGINNINC at a point on the southern right-of- tiav line Of Pheasant Dri%c North at :1, tine of Lots #52 and 51 as shown on the above refeft'ed to plan; thence by ;:foresai:! ,outhern right-of-way !tile, South 83 degrees 10 minutes 21 seconds East 30.50 fret to it point; thence Lv a ct:r:e to the right, it radi::s of 20.00 feet, an arc length of 31.42 feet to a point on the western right-of-way line of Pheasant Drive South; thence i,% aforesaid right-of-. ay line, South 06 degrees 49 minutes 39 seconds West 120.00 feet t1; a point on the northern line of Lot 9;50; thence L-. aforesaid line, 'north 83 degrees N minutes 21 seconds NVest 50.50 feet to a point on the eastern line of Lot #52; thence be aforesaid lot line, North 06 degrees 49 minutes 39 seconds Last 140.00 feet to a Igo:al, being the place of BEGINNING. BLiI`'C Lot #5l on it Final Subdivision Plan of Pheasant Run Estates, Phase 11 and Phase 111, recorded in Plan Book 29, Page 7. HAVING ERECTED THEREON A DWELLING KNOWN AS 1107 PHEASANT DRIVE NORTH, CARLISLE, PA. BEING THE SAME PREMISES--KVICH Leland E. Scott, Jr. and Malaria A.Scott by deed dated September 29, 1994 and recorded in Cumberland County Deed book 112 Page 612 granted and conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX I.D. 29-17-1583-089 LNJ 1= C _ V c,. ,> t aJ ^ J ?4 4) 1 .5 L: M iC 7 F T ?.1] O ? O C U Q4 HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO °_ANCPLUS MORTGAGE CCRP0RATION, PLAINTIFF vs. LAWRENCE A. BFADY AND TRACI M. SRAD`l, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4:33 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff' s Sale of Real Property (real estate) will be held: DA=E: WEDNESDAY, JUNE 7, TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD -Jo deli.. atcd in d°t, 1 in -- 1 al cy^ description mainly consisting of a ^statement of~ the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1107 PHEASANT DRIVE NORTH CARLISLE COUNTY, PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 04033 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LAWRENCE A. BRADY AND TRACI M. BRADY A SCHEDULE OF DISTRIBUTION, beina a list of the persons and/or _o.ern ._.._ c _cc_ate e..t_ties _ =_enri eeing entitled to receive~ ^f-_- _= the c,cee,^s of he sale -_::e--.ed and to be disbursed Sner_ f for example, to banks that hold mortgages and municipalities that are owed taxes) wi' be filed by the Sheriff t: ".'s Cou:1z:% _-irty ;3C? days after the sale and d1SCrlb.a 1. JL C.he croceeds of sale -n ac?:crdance with this _., rn:t, ..t -.ade ':nless _3meone =cjeCts by filing exceptiD::s with]). ten 110) days ..f the ,.ate it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas o° the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights menzicnec in the preceding paragraphs must be presented to the Ccurt of Common Pleas of the within County. ':he petition must be served on the attorney for the creditor or on the _rediter before presentation to the court and a proposed order or rule must be a_tached to he petition,. If s specific return date is desired, scci. date must be e:.tained from z:-e Court Administrator's Office - Civ-,l Division, of ti- within County Courthouse, before a presentation of the petition to the Court. A copy of the writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys fcr Plaintiff 1719 North Front Street -arrisburg, PA 17_72 (717) 234-4179 tIA.'I'II%T CEIZT\IN lot or tract of ground situate in Nurtl: \;: ule:on Township, C.. .. C. "10 WA da!01 `i 1:1m, Ino IC ..Il:'r' sl•n.,?.n oil annam On c...._.. "Fina! SubJ owan Plan of Pheas i:t Run status, Phast If ar.J Hose use Ili for Mct anco Inc North Wdlcion To-xn-;hip, Cum'e_ and Cc, Peuasylvania Sc.. 1-= Apr.! 9, 1975 ReviAd ApnI A 1975" by GerI Betz Associates, Inc. Englecs Ac Surimcrs, 6 East Main Street, Shhemanstown,Puc: lv:u:ia, which plan is .i in P:.:r. Bo,'; J, Page ?, in the Office of the Recorder of Deeds for Cumberland C-nlntn Suid lot is :nor, ualuculr.rly bounded and described.as follows: BEGINNING at a point on the southern tight-of-way line of Pheasant Drive North at JAW,: re of Lou #52 and 51 as shown on the above referred to plan, thence by moresai2 southern right-of-w;1y tine, South 33 degrees 10 minutes 21 seconds East R50 to a r ,tithes by n curse to A e right, a radius of 20.00 feet, an arc length of 31 42 fee; to a pcc•.: on the western right-of-way line of Phea_an: Drive Soub; thence aforesaid right-okay line, South 06 degrees 49 minutes 39 seconds West 12100 feet •-, a poet: on the r:onhun We of Lot *51 thence by aforesaid line, North 93 degrees 12 minuses 21 seconds TV= 5010 feet to a point on the eastern line of Lot #52; thence b:: aforesaid let line, North 06 degrees 49 minutes 39 seconds East 140.00 feet to a 1-:.:tt, bests= the pl,:.c of BEGINNING. BL•'ING Lot #51 on a Final Subdivision Phan of Pheasant Run Estates, Phase 11 and Phase III, recorded in Plan Book 29, Page 7 HA7ZNG ERECTED THEREON A DWELLING KNOWN AS ::07 PHEASANT DRIVE NCF7H, CARLI.._ , PA. BEING THE SAME PREMISES WHICH Leland E. Sco Jr. and Malana A.Szott by deed dated September 29, 1994 and recorded in Cumberland County Deed book 112 Page 612 granted and conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX Z.D. 29-17-1583-089 >- G , ?J - UJ i7G Lc?rl -L 0- C JLLJ U o .,,. HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO MORTGAGE CORPORATION, PLAINTIFF VS. LAWRENCE A. BRADY AND TRACI M. BRADY, CIVIL ACTION - LAW NO. 1999 4033 DEFENDANTS IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on a true and correct copy of the Notice of Sale cf Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 . IN THE COURT OF COMMON PLEAS BANCPLUS : CUMBERLAND COUNTY, PENNSYLVANIA By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL, KRUG AND HALLER 1719 NOR'I'II FRONTSTREE'T' IIARRISIIURO. PENNSYLVANIA 17102.2392 .1011N W. N11W 1.1, TELEPHONE(717) 234-4178 HOWARD It, lu411(i FORECLOSURE DEPT. FAX (717) 23.1206 I.[ON 1'. I IAIJ 11( JOIIN W. PI RCH1 .11t. DIt1AN .I. 'I NTIAt .II LI. M. WINPXA O (7) 533.3636 NOTICE TO: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 JOSEPH NISSLEY (1910.1882) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold ag inst the said real estate will be divested by the sale and that u have an opportunity to protect your interest, if any, notified of said Sheriff's Sale. By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. LAWRENCE A. BRADY AND NO. 1999 4033 TRACI M. BRADY, DEFENDANTS IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, JUNE 7, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal dcscription mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1107 PHEASANT DRIVE NORTH CARLISLE CUMBERLAND COUNTY, PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 04033 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LAWRENCE A. BRADY AND TRACI M. BRADY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION ?Ll- TI A'I' CERTAIN lot or !ract of ground situate in Nonni >hddletOll Township, C':::!bellend CcLin1%, Currmonwealth of Pennsykania, more piwicnlar!v sho•.vn on a cer;nin plan entitled: "Final Subdivision Plan of Pheasant Run Estates, Phase Il and Phase III for %Ietlanco Inc. North Nfiddleton Township, Cumberland Co , Pennsylvania Scale: 1"=50' April 9, 1975 Revised: April 30, 1975" by Gerrit 1. Betz Associates, Inc., En'Zineers S Su:vevors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is fi!r. ! in Pl.!:,. Book =9, Pane 7, in the Office of the Recorder of Deeds for Cumberland C ant Simi lot is more narucularly bounded and described.as follows: BEGINNING at a point on the suuthern right-of-way line of Pheasant Drive North at ti:e divide:; !ice of Lots #52 and 51 as shown on the above referred to plan; thence by resiid southern right-of-way line, South 33 degrees 10 minutes 21 seconds East 30.50 to it point; thence by a ct:rve to the right, it radius of 20.00 feet, au arc length of 31.42 feet to a point on the western right-of-way line of Pheasant Drive South; thence ! . aforesaid right-of-way line, South 06 degrees 49 minutes 39 seconds Nest 120.00 feet 10 a point on the northern line of Lot #50; thence by aforesaid line, North 33 degrees 10, minutes 21 seconds Nest 50.50 feet to a point on the eastern line of Lot #52; thence by aforesaid lot line, North 06 degrees 49 minutes 39 seconds Last 140.00 feet to a po::,t, being the place of BEGINNING. BEING Lot #51 on a Final Subdivision Plan of Pheasant Run Esta cs, Phase 11 and Phase 111, recorded in Plan Book 29, Page 7. HAVING ERECTED THEREON A DWELLING KNOWN AS 1107 PHEASANT DRIVE NORTH, CARLISLE, PA. BEING THE SAME PREMISES WHICH Leland E. Scott, Jr. and Malaria A. Scott by deed dated September 29, 1994 and recorded in Cumberland County Deed book 112 Page 612 granted and conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX I.D. 29-17-1583-089 Re: Homeside v. Brady Cumberland Sale 6/7/00 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Postage: Postage: Postmark: 1?; U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 U. S. POSTAL SERVICE CERTIFICATE OF NAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 one piece of ordinary mail addressed to: Postmark: David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Postage: Postmark: Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 i. 1 Ir I` 1 ^ \?ll Z 495 294 957--- ' US Po j* Service celpt for Certified Mall No Insurance Coverage Provided. LAWRENCE A BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404 Special Delivery Fee Restdcted Delivery Fee ? Return Receipt ShovNq to ?, 2 S Whom 8 Date Dap Ream RereOt mr, Date, 8 Adh TOTAL Po §0 Fee: Posonark or - ?? J S? H 3 8 m s7 LL U) Z,495 294 95.6 US Postal service <--? ^---• .. TRACI M BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404 - S^ Ceain- d Fee Special Delivery Fee Roslnded Dahmry Fee Retum Recept Slowing to Nhom A Date Delivered z Poslege a Fees a 3 ti ? U) r' _J ? 111 ' ? llJ ( i Gam' .? y ?4 HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION, PLAINTIFF vs. LAWRENCE A. BRADY AND TRACI M. BRADY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . NO. 1999 4033 DEFENDANTS SUppLEMENT?E MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 _ PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTI I FRONTSTREET IIARRISDURG, PENNSYLVANIA 17102-2392 JOIIN W. KIRCTI.I. TELEPHONE (717) 2344178 1IOWA RD B. KIIIJLI FORECLOSURE DEPT. FAX (717) 234-1205 LEON 1'. IIALLIiR IOIIN W. rORCEI-1. JR. IIRIAN l.'I'YLER 111.1. M. WINFKA (117) 533-3838 NOTICE TO: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 JOSEPH NISSLEY (1910.1992) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect- your interest, if said Sheriff's Sale. By: Leon P. Attorney you hold against the said and that .You have an any by-,b,'-f nq notified of Taller PA I.D.15700 for Plaintiff HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO 13ANCPLUS CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE CORPORATION, PLAINTIFF CIVIL ACTION - LAW VS. LAWRENCE A. BRADY AND NO. 1999 4033 TRACI M. BRADY, DEFENDANTS IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE, That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 7, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1107 PHEASANT DRIVE NORTH CARLISLE CUMBERLAND COUNTY, PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 04033 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: LAWRENCE A. BRADY AND TRACI M. BRADY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION \I.L Tll:-*%T CERT;%IN lot or tract of g;otmd situate in North Middleton Township, C.:;nbetland Count, Coinntonwealth of PellllSVlvatllfl, more p,uticularly shown on a certain plat entitled: "Final Subdivision Plan of Pheasant Run Estates, Phase 11 and Phase 111 for Nletlanco Inc. North Sliddleton 'township, Ctnnbcrland Co., Pennsylvania Scale: ]"=50' April 9, 1975 Revised: April 30, 1975" by Gerrit J Betz Associates, Inc., Em,ineers S Survevors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is f,!ed in Pi:ut Book _9, Page 7, in the Office of the Recorder of Deeds for Cumberland C;ttnty. Said lot is more particularly bounded and.described.as follows: BEGINNING at a point On the suuthern right-of-way line of pheasant Drive North at t!:e dividit:_ litre of Lots #52 and 51 as shown on the above referred to plan; thence by toreseid southern right-of-way line, South 33 degrees 10 minutes 21 seconds East 30.50 feet to it puint; thence by a curve to the right, a radius of 20.00 feet, an arc length of 31.42 feet to a point on the western right-of-way line of Pheasant Drive Soutlr, thence b% aforesaid right-of-way line, South 06 degrees 49 minutes 39 seconds West 120.00 feet to P. point on the northern line of I_at #50; thence by aforesaid line, North 33 degrees 10 minutes 21 seconds West 50.50 feet to it point on the eastern line of Lot #52; thence by aforesaid lot line, North 06 degrees 49 minutes 39 seconds East 140.00 feet to a po!:r!, being the place of BEGINNING. ISGING Lot #51 on a Final Subdivision Plan of Pheasant Run Estates, Phase II and Phase 111, recorded in Plan Book 29, Page 7. HAVING ERECTED THEREON A DWELLING KNOWN AS 1107 PHEASANT DRIVE NORTH, CARLISLE, PA. BEING THE SAME PREMISES WHICH Leland E. Scott, Jr. and Malaria A.Scott by deed dated September 29, 1994 and recorded in Cumberland County Deed book 112 Page 612 granted and conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX I.D. 29-17-1583-089 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9TH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC., SUCCESSOR BY NO. 1999 4033 MERGER TO BANCPLUS MORTGAGE CORPORATION CIVIL ACTION - LAW Plaintiff IN MORTGAGE FORECLOSURE versus LAWRENCE A. BRADY AND TRACI M. BRADY thkndan( Know all persons by these presents that I, Donnie Briley was assigned to duly execute this service upon the following defendant: TRACI M. BRADY at 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404. 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private investigator. I hereby certify that on 3/27/00 at approximately 10: 100a.m. )Mp.m. a true and correct copy of the NOTICE OF SHERIFF'S SALE were served on the above-named party or witness in the following manner: ? 1 personally delivered them into the hands of the person to be served. ® By leaving a copy at his/her usual place of abode with Lawrence Bradv whose relationship to the defendant is Husband and who is of suitable age and discretion and also residing therein. ? By leaving a copy with the manager/clerk of place of lodging in which defendant resides. ? By leaving a copy with the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process Description of Recipient: Sex: Mf?)Race: Black Approximate Height: 5' 10 Approximate Weight: 185Approximale Age: 18 AFFIDAVIT SAXT}i NOT. Subscribed andworn to before me this oA day of A-9 2000. Notary Public my commission Evp Cap! "7 : F% COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9T" JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC., SUCCESSOR BY NO. 1999 4033 MERGER TO BANCPLUS MORTGAGE CORPORATION CIVIL ACTION - LAW Plaintiff IN MORTGAGE FORECLOSURE vemus LAWRENCE A. BRADY AND TRACI M. BRADY Iknendant Know all persons by these presents that 1, Donnie Briley , was assigned to duly execute this service upon the following defendant: LAWRENCE A. BRADY at 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404. 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private investigator. I hereby certify that on 3/27/00 at approximately _10.10pa.m. X30.m. a true and correct copy of the NOTICE OF SHERIFF'S SALE were served on the above-named party or witness in the following manner: ® 1 personally delivered them into the hands of the person to be served. ? By leaving a copy at his/her usual place of abode with whose relationship to the defendant is and who is of suitable age and discretion and also residing therein. ? By leaving a copy with defendant resides. the manager/clerk of place of lodging in which ? By leaving a copy with the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process Description of Recipient: Sex: A Race: Black Approximate Height: 5' 1 (Approximate Weight: 18 5 Approximate Age: 38 AFFIDAVIT SAYTA NOT. / Subscribed aqd swom to before me this aS Server day ofA ° < h 2000. Nora Public c:- ' socru c Re: Homeside v. Brady Cumberland Sale 6/7/00 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 U. S. POSTAL SERVICE CERTIFICATE OF MAILING In comnpliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 '. r P\ 11\\ // Ul U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 l fi ?\ Z 495 294 957' US Po aService Reteipt for Certified Mail No Insurance Coverage Provided. LAWRENCE A BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404 m 0 co LL R Special Delivery Fee Restricted Delivery Fee Return Receipt Showing to 'L S Whom A Date Deav Ream Rwept Dde,d NNr TOTALPoaI yFeee. CC? F 4- s 294 956 US Postal Service M-? ^-- - TRACI M BRADY 4808 BAKER PLANTATION DRIVE ACTWORTH GA 30101-3404 Z 495 Postmark or alp -<? J Fee Special Delivery Fee N Restricted Delivery Fee m MUM Receipt Showing 7 ?o TOTAL Postage & Fees Postmark or Dale ti 0- ?/ ` ?, r u: ?_?_ - c? _ } ? ? .? :: ."i -- ' '''u _ ? _ ? ? O t 7 b J HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4033 CIVIL TERM LAWRENCE A. BRADY AND TRACI M. BRADY : CIVIL ACTION - LAW Defendants : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: December 1. 1999 PURCELL, KRUG & HALLER 7 BY Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Attorney for Plaintiff Attorney ID4 15700 IC) H c. m 3?a z m?? w ? ??MO? s E ry ?H I?mtil H? ?? ? o ex.wuv•mssuvlo see sv•.e eeuv ON nb0? 03I WM hail ma, STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND SS. 1 - -Robert P Ziegler-------------------------------------------------------Recorderof Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________ SECretary of Housing & Urban Dev of Washington D C -------------------------------------- ------------------°---------------- is the grantee the same ha 7th ving been sold to said grantee on the _______________________________________________ day of ------------ June ----------- A D M2000 _- under and by virtue of a writ______________ ----- Execution 8th ------------------------------------------------issued on the ------------------------------------- March xx2000 day of __________________________ A. D., 19out of the Court of Comman Pleas of said County as of ----------- Civil ------------------------------ --------------------------------- Term, 19_29---- Number__ 4033 - atthesuitof__HOmeside Lending Inc sbm Banc lus Mt -Corp A & Traci M Brady -----------------------------------against------- Lawrence recorded in Sheriff's Deed Book No, 225 ____, Page ___ 474 -- IN TESTIMONY WHEREOF, I have hereunto set my hand and sea] of said office this day of ----- -- ----------- f AV D.,19-- _15 -- 'Q.`e Reco er of Deeds Recorder of Deeds, Cumberland Courtly. Cediele, FA My Commission Erpires the first Monday of Jan. 2002 Homeside Lending, Inc. Successor In the Court of Common Pleas of By Merger To Baneplus Mortgage Cumberland County, Pennsylvania Corporation No. 1999-4033 Civil -VS- Lawrence A. Brady and Traci M. Brady Shannon M. Sunday Deputy Sheriff, who being duly sworn according to law, says On March 31, 2000 at 10:20 o'clock A.M. EST, she posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action on the property of Lawrence Brady and Traci Brady located at 1107 Pheasant Run Drive, North, Carlisle, Cumberland County Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action upon one of the within named defendants to wit: Traci Brady by Certified Mail Return Receipt Requested Restricted Delivery, Deliver To Address Only to her last known address 4808 Baker Plantation Drive, Actworth, Ga. This letter was mailed under the date of March 28, 2000 and received by Traci Brady on March 31, 2000 the return receipt card signed by Traci Brady. R. Thomas Kline, Sheriff, who being duly sworn according to law says he made diligent search and inquiry for one of the defendants to wit: Traci Brady, but was unable to locate her in his bailiwick. He therefore returns same Not Found as to defendant Traci Brady. House is vacant. R. Thomas Kline, Sheriff, who being duly sworn according to law says he made diligent search and inquiry for one of the defendants to wit: Lawrence A. Brady, but was unable to locate him in his bailiwick. lie therefore returns same Not Found as to defendant Lawrence Brady. House is vacant. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the defendants to wit: Lawrence A. Brady by Certified Mail Return Receipt Requested, Restricted Delivery Deliver to Addressee Only to 4808 Baker Plantation Drive, Actworth, Georgia. This letter was mailed under the date of March 28, 2000 and returned to the Sheriffs Office on April 24, 2000 with reason checked UNCLAIMED. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Lawrence Brady by First Class Mail to 4808 Baker Plantation Drive, Actworth, Georgia. This letter was mailed under the date of April 7, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The !.Sheriff mailed a notice of the Pendency of the action to one of the within named defendants to wit: Traci Brady by first Class Mail to 4808 Baker Plantation Drive, Actworth, Georgia. This letter was mailed under the date of April 7, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on June 7, 2000 at 10:00 O'clock A.M.EDST, and sold the same for the sum of $ 1.00 to attorney Leon P. Haller for The Secretary of Housing and Urban Development Of Washington D.C., his successor and/or assigns. It being the highest bid and best price received for the same The Secretary Of Housing And Urban Development Of Washington D.C., his successors and/or assigns of One Sentry Place, 475 Sentry Parkway, Suite 5000, Blue Bell, PA being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 989.95 it being Costs. Sheriff's Costs: Docketing 30.00 Poundage 19,41 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 3.10 Certified Mail 15.25 Levy 15.00 Surcharge 30.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed Sworn and Subscribed To Before Me 414.20 315.19 24.80 25.00 26.50 $ 989.95 Pd By Atty 6/22/00 This j ),.r Day of 2000, A.D. lug Prot o otd ary R. Thomas Kline, Sheriff By _ Real Estate Deputy .e+ _ ao to a l l.7 %?, ? ?i 197 pc'-6 , gP916 COPY HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO BANCPLUS CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE COP,PC:_`,TiCN, vs. PLAINTIFF CIVIL ACTION - LAW ' LAWRENCE A. BRADY AND NO. 1999 4033 TRACI M. BRADY, DEFENDANTS IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1107 PHEASANT DRIVE NORTH, CARLISLE, PA: 1. Name and address of the Owner (s) or Reputed Owner(s): Lawrence A. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 Traci M. Brady 4808 Baker Plantation Drive Actworth, GA 30101-3404 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales Dept. Box 280946 Harrisburg, PA 17128-0946 Pheasant Run Condominium Assn. 1824 Sterrets Gap Avenue Carlisle, PA 17103 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): f 5. Name and address of every other person who has any record lien on the osooerty: UNKNOWN 5. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... David Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 Nanette Blaisdell 1107 Pheasant Drive North Carlisle, PA 17013-1252 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S; Section 4904 relating to unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 3, 2000 is .. THE LOCATION of your property to be sold is: 1107 PHEASANT DRIVE NORTH CARLISLE COUNTY, PENNSYLVANIA HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLLTS MORTGA__ CORPC _=.TION, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - T W I,A Va'. LAWRENCE A. IRA--Y AND NO. 139 4033 T_ACI X. BRAD'i, DEFENDANTS IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: Th=: the Sheriff's Sale of Real Property (real es=ate) will be held: DA==: :EDNESDAY, JUNE 7, 2000 TIi:E: 10:00 O'clock A.M. LCCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: is: NO. 1999 04033 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property LAWRENCE A. BRADY AND TRACI M. BRADY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or c-.zrnt:ental _- =pcrate entities or agencies being en,:itled to Ye 7e1Ve part the proceeds of the sal- recei'!ed -and to be d=_'oi.;rsed ^ t. Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filled by the S::=riff of --:.s C,tunty thirty (30) days after the sale and the croce=_ds of sale in accordance with this s_'.:zd; _ ---, -•• =act, be made unless s=,:-one .tb'ects by filing ex_ept___._ t., _t within ten (10) days of the date it is filed. In=ormation about the Schedule of Distribution may be obtained frcm the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. Yctc may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (7171 249-3166 THE LEGAL RIGHTS YOU MAY RAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This Petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned -,-e preceding paragraphs :rust be presented C^"- tp the ?-..?t Of CO:c(ncn ?leas of .he within Cour.^y. The petition must be Ser':ed cn me attornev for the creditor or on the 'reditor before presentation to the court and a proposed order or rule must be attached to e petition. == a sp_cific return date is desired, suc date must be obtained from the Court Administrator's office - the vith.ia Connty Courthouse, before a Cn of Divisica, of Presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALL.R Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA :7102 (7171 234-4173 tLLCERTnIN lot cr tract of ground tinnate in Nora:: li d;e;on To%knship, ?....:he:....d C-.... C.ceai,i: ?f 1'e:.,a;,!va: ,.?.'• -!:c•.?r an a taint :ar =40d 'Fi?na! 01: i 1m P!an of Phcns.t ts:d:es, Phase II and P:.tsc III or `.ltQrico Inc. North `1101ton 'ro•.%n :::P1 C': Pennsylvania MY, V=51 Apr! 9, 1975 Rc:isc April 30, 1973" oy Ge. .' t131=Associ.._=s, Inc. Eina neers S Sune•:ors, 6 East Main Street, Shhemarstown, Pe••:a::enr.ia, which plan is in P;.:r Bc?k '9. Pace in the Office of the Recorder c.' Deeds for C:t=.::berland Du m,; Said lot is moreypa:ttcula0y bounded an0clescKed.as follows: BEGINNING at a point on the southern H gItt-of-way line of Pheasant Dri%e North at ..c dr. 0n; 4C or Luts Aq: and :1 as shown an the above re:e.:,d to plan; thence by nsaid sowhcrn right-of byline, South 33 degrees 10 mizwtes 21 seconds East 30.50 nZI to it P00, •';_..__ y .. _,...,, w .,. right, a radho of 20.00 Net, an arc length of 31 42 feet to a poi::: on the western r'eh:t-of-way line of Pitea=_::n: Drive Sou:'.:: thence y nforesaid nghnaNnay lire. South 06 degrees 49 minutes 39 seconds Rest 120.00 feet - a oak: on the northern line of Lot 050; thence b.: aforesaid lute, North 83 degrees Q n inums 21 seconds Nest 5010 feet to a point on the eastern line of Lot :`52; thence by aforesaid let line, North 06 degrees 49 minutes 39 seconds East 140.00 feet to a loot, fang the place of BEGINNING. BL•:ING Lot #51 on a Final Subdivision Plan d Pheasant Run Gnues, Phase 11 and Phase III, recorded in Plan Book 29, Page 7. HAVING ERECTED THEREON A DWELLING KNOWN AS __J7 ?HEr\51NT DRIVE NC=.TFI, CARLISLE, PA. BEING THE SAME PREMISES WHICH Leland E. Scot, Jr. and Malana A.Scott by deed dated September 29, 1994 and recorded in Cumberland County Deed book 112 Page 612 granted and conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX I.D. 29-17-1583-089 .. i 1 J L' ,'j . I 1, ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4033 CIVILXMLM 4 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF cumberland COUNTY: To satisfy the debt, interest and costs due Ham lid Lending, Inc G , sGnr by meaer to Bancplus Mortgage Corporation PLAINT!FF(S) from Lawrence A Brady and Traci M_ Brady 4808 Bak Plantatinn-i2rive, r r. .+, (1) You are directed to levy upon the property of the defendant(s) and to 1107 Pheasant Qzziye North Ca 1'clP pa 17013 (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 than a named garnishee, you are directed tonotly hinuher that he/she has been added as a garnishee and Is enjoined as above stated. Amount Due $ 72,486.30 L.L. $0.50 $12.10 from 7/1/99 to 6/7/00 Interest 4.114.00 Due Prothy 1.00 Afty's Comm Atty Paid Plaintiff P 115.10 Date:_ March 8. 2000 REOUESTING PARTY: Purcell Kruqq & Haller Name Tenn P. Hal Tpr?Fgrnii rp Address: 1719 North Front Street Harrisburg, Pa. 17102 Attorneyfor: ll ,P ti f Telephone: (717) 234717) 234-4178 Supreme Court ID Nols-7()n Other Costs Late Charges at $24.96 $299.52 Escrow Deficit $2,000.00 Curtis R. Long Prothonotary, Civil Division by: Deputy REAL ESTATE SALE NO-51 Un m9 4.C'r?t / y D. dro the sheriff levied upon thedefendanis Interest in the real property situated ift dga,7`Q Ec. Cumberland County, Pa., known and numbered as: Zio7?'- '0-A r'sa? and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date:, -2 i ? ?' f ' n REAL ESTATE SALE NO-51 un rnl -u? J% 2 "-0 the sheriff levied upon the defendants Interest In the real property situated inta/aAck ? - Z&? Cumberland County, Pa., known and numbered as: !/v 7 d.-;t 4L.? A-0- and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: --- /Z :V- By: ' y.r f THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Rct No. 587. RDDroued May 16. 1929 Commonwealth of Pennsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respectively, and all have boon 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/issuos which appeared on the 2nd, 0th and 16th day(s) of May 2000. 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 n resolution unanimously passed and adopted severally by the stockholders and board of directors of the anld Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of to Ilia In Mlnrellanoous Book "M", Volume 14, Page 317. " M PUBLICATION%? COPY Sworn to and subserlbod before nict thiii Ind day ofJGo 20,MA.D. SALEN51 REAL'WATE SALE No,5 Wit WTain -* W4 '. Inc. ?'ti rfenei vend Attttyy;IAMa . Na lot `QFBAIIPiION .: ali,wAT'rPRTAna ter ,.. rmylvanu1pme:Igr000la shown on a teAaM`plan entltled.•.'.FAial Su 'vision Plan ofPheasanl Run:ENale;'Phase II and Phase 111 •far Mellmka I (-North Middleton T*6hiiy Cum Co., Pannsslvania Srak:1 .50' AP. 9"1 Revised: April 30, 19A13 - Certll A Associates, Inc., En `& SurV*'A 6 East Main Street, T Sh=oatowu, Palania, which plan is filed in Dian 7, in the office of Ci the Recoided?ou for Cumberland ba Cowry, SaW loth Tatoltiolarly bounded 14014,141 Sail / I airy l I lOnau. Nolarry Pnpiir I tammwg. I faurMen e,rwnq NOT PUBLIC My COmnr•ssmn l'ap,aa ,haw 6.'1 V Mombur, PonmytvnnN Aaanawl"ol utaws atnlaalon expires Juno 6, 2002 CUMBERLAND COUNTY SHEI7IFFS OFFICE CUMBERLAND COUNTY COUKHOUSE CARLISLE. PA. 17013 Statement ol-Aturtleing Costs To THE PATRIOT•NEWS CO., Dr. For publishing the notice of publlcntlon attached hereto on the above Wiled dates $ 313.69 Probating mamo Notary Fee(s) $ 1.50 Total $ 315.19 .sher'S Receipt for Advertising Cost Ier of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general aceipt of the aforesaid notlco and publication costs and certifies that the same have THE PATRIOT-NEWS CO. By .................................................................... to i poing lh'anoa 6hyy a cone to the richl, a radius of 2800 heUSn arctPnxth of JU1 hvl tea point. on the NCSlerd xhlKdmar lineal Pheasant Drive South; thence by alum.ald riahwf-war, hate.South 06 Jenrees Iv on f i, y 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: APRIL 28, MAY 5, 12, 2000 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. 51 Writ No. 1999-4033 Civil Homeside Lending, Inc.. Successor By Merger To Bancplus Mortgage Corporation Rog M. Morgenthal, Editor VS. Lawrence A. Brady and Traci M. Brady Atty.: Leon P. Haller LEGAL DESCRIPITON ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County. Com- monwealth of Pennsylvania, more par- ticularly shown on a certain plan entitled: "Final Subdivision Plan of Pheasant Run Estates, Phase 11 and Phase III for Metlanco Inc. North Mid- dleton Township, Cumberland Co., Pennsylvania Scale: 1"=50' April 9. 1975 Revised: April 30, 1975" by Ger- rit J. Betz Associates, Inc., Engineers & Surveyors, 6 East Main Street. Chl"mnnctnwn. Pennsvlvania. which SWORN TO AND SUBSCRIBED before me this 12 day of MAY, 2000 NOTARIAL SEAL LOIS E. SNYDER, hloeory Pubiic Carlisle Eoro, Cumberland County, PA My Commission Expiree /Aomh 5, 2007 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: APRIL 28, MAY 5, 12, 2000 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 BALE NO. 51 Writ No. 1999-4033 Civil Homeside Lending. Inc.. ??-- -- Successor By Merger To ?--- Bareplus mortgage corporation Rog M. Morgenthal, Editor VS. Lawrence A. Brady and Traci M. Brady Ally.: Leon P. Haller LEGAL DESCRIPr10N ALLTHAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Com- monwealth of Pennsylvania, more par- Ucularly shown on a certain plan entitled: "Final Subdivision Plan of Pheasant Run Estates, Phase II and Phase III for Metlanco Inc. North Mid- dleton Township. Cumberland Co.. Pennsylvania Scale: 1"=50' April 9, 1975 Revised: April 30, 1975" by Ger- rtlJ.BetzAssociates. inc.. Engineers & Surveyors, 6 East Main Street, Shiremanstown. Pennsylvania. which plan is filed in Plan Book 29. Page 7. in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and de- scribed as follows: BEGINNING at a point on the southern right-of-way line of Pheas- ant Drive North at the dividing line of Lots #52 and 51 as shown on the above referred to plan: thence by aforesaid southern right-of-way line, 1 South 83 degrees 10 minutes 21 sec- onds East 30.50 feet to a point: thence by a curve to the right, a radius of 20.00 feet, an arc length of 31.42 I feet to a point on the western right- of-way line of Pheasant Drive South: thence by aforesaid right-of-way line. South 06 degrees 49 minutes 39 sec- onds West 120.00 feel to a point on the northern line of Lot #50; thence by aforesid line. North 83 degrees 10 minutes 21 seconds West 50.50 feet to a point on the eastern line of Lot 852: thence by aforesaid lot line. North 06 degrees 49 minutes 39 sec- onds East 140.00 feel to a point. being the place of BEGINNING. BEING Lot B51 on a Final Subdi- vision Plan of Pheasant Run Estates. Phase II and Phase III, recorded In Plan Book 29, Page 7. HAVING erected Unereon a dwell. Ing known as 1107 Pheasant Drive North, Carlisle, PA. BEING THE SAME PREMISES WHICH I.eland E. Scott. Jr. and Malana A. Scott by deed dated Sep- tember 29, 1994 and recorded In Cumberland Countv Deed Book 112 Page 612 granted aid conveyed unto Lawrence A. Brady and Traci M. Brady. TO BE SOLD AS THE. PROPERTY OF LAWRENCE A. BRADY AND TRACI M. BRADY ON JUDGMENT NO. 1999 4033. TAX I.D. 29.17.1583-089. SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 1000 -- 98 A NOIAf"E Al tots E. SNYDER, Notary Pula2e Cadiw9 Soto, Cumb*dand County„ PA My Commiawon Expirn March $, 2001 y t f Real Estate No 51 $1000.00 Advance Costs Paid 3/14/00 Atty Leon 1'. Haller Assessed Valuation $ 7,620 Writ No 1999-4033 Civil Homeside Lending, Inc. Successor By merger To Bancplus Mortgage Corporation -vs- Lawrence A. Brady and Traci M Brady 1107 Pheasant Drive North Carlisle, PA Real Debt $ 72,486.30 Interest fir 7/1/99-6/7/00 $ 12.10 4,114.00 Atty's Fees Atty's Writ Cost 115.10 Escrow 2,000.00 Late Charges 299.52 Sheriff's Costs Docketing 30.00 Poundage 19.41. Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 3.10 Certified Mail 15.25 Levy 15.00 Surcharge 30.00 Postpone Sale Out of County Legal Search Law Journal 414.20 Patriat News 315.19 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 TAXES 2000 County. Library Township 397.92 Refuse 422.71 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF HOMESIDE LENDING, INC., SUCCESSOR BY MERGER TO BANCPLUS MORTGAGE CORPORATION Plaintiff VS. LAWRENCE A. BRADY and TRACI M. BRADY Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 4033 IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendants satisfied of record. PURCELL & HALLER B Leon P . ller ID #15700 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Dated: May 18, 2007 ..? -a _ '? a^+ '' `?? .-i t sh r-_ ??a --+ s .,.., s? •? N #`?t .?-? ;,; ::.