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HomeMy WebLinkAbout99-04442v Q L 31 i C) a c 21 U 2 = T r 1 CJ LJ :? 3 c OAJ L[Lpp6 RI ui p?5p2L2 WB T,rP+^yai.pp cPp1rr )o m,.wa n vamp ? 'wm ums-nr FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A.. F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY 2270 ERIN COURT LANCASTER, PA 17601 V. Plaintiff NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORACE 1544 SELTZER COURT MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. qg CUMBERLANDCOUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE 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 SIIOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 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 mcnty (20) days after this Complaint and Notice are served, by entering a written appearance personall% or by artorney and tiling in writing kith the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE . SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY 2270 ERIN COURT LANCASTER. PA 17601 2. The name(s) and last knolvn address(es) of the Defendant(s) arc: NORMAN MORACE. A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORACE 1544 SELTZER COURT MECHANICSBURG, PA 17055 who is/are the mortgagor(s)and real owner(s) of the property hereinafter described. 3. On 4/27/88 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 901. Page i96. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthhl payments of principal and interest upon said mortgage due 12/27/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $63,181.69 Interest 3,206.78 11/27/98 through 7/1/99 (Per Diem $14.71) Attorney's Fees 3,159.00 Cumulative Late Charges 136.36 4/27/88 to 7/1/99 Cost of Suit and Title Search 550.00 Subtotal 70,233.83 Escrow Credit 0.00 Deficit 77.52 Subtotal 77.52 TOTAL $70,311.35 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 of 1983, has terminated because either: (i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with 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 ct 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 $70,311.35, together with interest from 7/1/99 at the rate of $14.71 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. ank Fcdcrnian 2S/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Keystone Financial Mortgage CorporatiokV, 2270 Erin Court P.O. Box 7748 Lancaster, PA 17604-7748 14100-KEY-8131 (717) 399.8498 FAX (717) 397.2834 This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE OF INTENTION TO FORECLOSE MORT AGE March 11, 1999 CERTIFIED MAIL; RETURN RECEIPT REQUESTED Norman A Morace 1544 Seltzer Court Mechanicsburg PA 17055 Teresa K Morace 1544 Seltzer Court Mechanicsburg PA 17055 Re: Loan No.:140848 The MORTGAGE held by Keystone Financial Mortgage Corporation (hereinafter we, us or ours ) on your property located at 1544 Seltzer Court, Mechanicsburg PA 17055 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $574.68 each for the months of December 1998 through February 1999 and late and other charges of 550.24. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $1,774.28. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the above amount of $1,774.28 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order to us at 2270 Erin Court, Lancaster, PA 17604. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount in default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. EXHIBIT A We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have began, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six months from the date of this notice. A notice of the dale of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: (717) 399-7082. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sherifl s sale will end your ownership of die mortgaged property and your right to remain in it. If you continue to live in the property after the Shcrilrs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the mortgaged property. YOU HAVE THE RIGHT TO SELL THE MORTGAGED PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE MORTGAGED PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE TIME OF THE SALE (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES, IF ANY, THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three (3) titres in any calendar year. Very tndy yours, Beth A Bossert Vice President EXHIBIT A Keystone Financial Mortgage Corporatio k V? 2270 Erin Court P.O. Box 7748 Lancaster, PA 17604.7748 ACT 91 NOTICE 1800-KEY-8131 (717) 3998498 FAX (717) 397-2834 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La notificacion en adjunto es de suma importancia pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion- obtenga una traduccion immediatamente Ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numbero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assitance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. EXHIBIT B Keystone Financial Mortgage Corporation?? 2270 Erin Court P.O. Box 7748 Lancaster, PA 17604-7748 1.800-KEY-8131 (717) 3998498 FAX (717) 397-2834 This Is an attempt to collect a debt and any information obtained will be used for that purpose IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Marsh 11, 1999 CERTIFIED MAIL; RETURN RECEIPT REQUESTED Norman A Morace 1544 Seltzer Court Mechanicsburg PA 17055 Re: Loan No.: 140948 Teresa K Momce 1544 Seltzer Court Mechanicsburg PA 17055 Your mortgage with Keystone Financial Mortgage Corporation is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $1,774.28. This sum includes the following: Outstanding payments due on your mortgage for the months of December 1998 through February 1999 in the amount of $574.68 and late and other charges accrued in the amount of $50.24. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of your rights. Under the Act, you are entitled 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 the lender, or with a designated consumer credit counseling agency. The purpose of the meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. The meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of the meeting. EXHIBIT 6 The name, address and telephone number of the lender's representative Is: Denise Lowrie Keystone Financial Mortgage Corporation 2270 Erin Court Lancaater,PA 17601 (717) 399-7082 or (800) 760-1257 The names and addresses of designated consumer credit counseling agencies in your area are shown on the attached sheet It is only necessary to schedule one face-to-face meeting. You should advise the leader immediately of your intentions. if yoc have tried and are unable to resolve this problem at or after your face-to-face mating, you pave the right to apply for financial assistance from the Homeowners' Emergency Assistance Fund. In order to do this, you must fill cut, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed above. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the otter time periods set forth in this letter, foreclosure may proceed against your home immediately and you will forfeit your eligibility for assistance. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Pennsylvania Housing Finance Agency under the eligibility criteria established by the Act It is extremely important that your application is accurate and complete in every respect The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foredosme proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street Post Office Box 8029 Harrisburg, Pennsylvania 17105 (717) 780-3800 or (800) 342-2397 Under separate cover, you will receive another a?' . e from the leader. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights dcO Oribed in this notice, the lender cannot foreclose upon you during that time. Also, if you receive financial assistance for the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Sincerely, 4th 0' ?? Beth Bossen Vice President EXHIBIT B Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lycoming-Clintan Counces Cammiss(an Far Conuauaicj Acton (y7?) 2138 Lincoln Street P. O. Box 1328 (W-1 570) PA 17703 (570)326-0547 FAX (570) 322-2 IS-, CCCS of Xor_4eastern PA 201 Basin SL-eec (uliamsport, p.417703 (570)323$627 FAX (570) 323-6626 31 W. Market Street POS 1127 Wilkes-Barre. PA 18702 (570) 821-0837 or (800) 922.9537 F IC(570) 821.1785 CLL`!TO_ M cc) CCCS OfNorheastera P4 1631 S Arhermn at Suite 100 Stare College, P;16801 (814)238.3668 FAX (814) 238.3669 COLU.IBLA C0Uh1^I CCCS ofNor_4eastern Pennsv(vania 1400 Abington Execadve Par's Suite 1 Clarks Summ(r. PA 18411 (570) 587-9163 or (800) 922.9537 F4.'((570)587.913-9135 Commission on Economies Opportuaity of Luzerne County 163 Amber Lane Wilke-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 F.9-X (570) 829.16665-CALL BEFORE FAXLNG (570) 455-4994 H-aZELTON FA-'S (570) 455-5631-CALL BEFORE F.A-I NG (570) 836-4090 Booker T. Washington. Center 1720 Holland Street Erie, PA 16503 (814)453.5744 F? X (814) 453-5749 John F Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Greater Erie Community Ac=on Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 4564161 Shenaago Valley Urban League, Inc 601 Indiana Avenue Farrell. PA 161-01 (412) 981.5310 CUMERLIND COU`PPY CCCS of Wester-a Pennsylvania, Inc. Financial Counseling Services of Franklin 2000 Ling!estown Road - 31 West 3rd Scat Har.:sburg. PA 17102 Waynesboro, P.A. I r.68 (717j) 541.1757 (717)762.3295 Urban League of Metropolitan Harrisburg YWCA of Carlisle N. 6th Street 301 G Street Harrisburg, PA 17101 Carlisle, PA 17013 (717) 234-5925 (717) 243-3818 FAX (717) 234-9459 FAX (717) 731.9549 Cotnmuniry Acton Comm of the Capital Region Adams Councj Housing Autharicj 1514 Derv Street 139-143 Carlisle St Harrsburg, PA 17104 Gettysburg, PA 17325 (717)232.9757 (717) 334.1518 F.A.( (717) 234.2227 F.4X (717) 334-8325 T 1 CX?jIP W 1, PENNSYLVANIA BULLETIN, VOL 29, NO. = NNE 5, 1999 ALL THAT CERTAIN piece or parcel of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to Witt BEGINNING at a point marked by a monument on the southern dedicated right-of-way line of Mountain View Road, T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum, as shown on the Plan of Lots hereinafter mentioned; thence along said dividing line South 17 degrees 20 minutes 35 seconds East, a distance of two hundred sixty-four (264) feet to a point at the dividing lines between Lots Nos. 20 and 21, as shown on said Plan of Lots; thence along said dividing line between Lots Nos. 20 and 21, South 48 degrees 55 minutes 13 seconds West, a distance of two hundred forty-five and eighty-nine hundredths (245.89) feet to a point on the northern side of a cul-de-sac at the northern end of Seltzer Court; thence along right-of-way line of Seltzer Court on a curve to the left having a radius of sixty (60) feet, an arc distance of fifty-seven and sixty hundredths (57.60) feet to a point on the same at the dividing line between Lots Nos. 20 and 19, as shown on said Plan of Lots; thence along the dividing line between Lots Nos. 20 and 19, North 6 degrees 4 minutes 53 seconds West, a distance of which has the address of ....1544. SELTZER. COURT ..................................... MECNAAICSB.URG........ . Pennsylvania ....... L7056....1.......... ("Progeny Address'); VERIFICATION Beth Bossert hereby states that he/she is vice President of KEYSTONE FINANCIAL MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she 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/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of is Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Beth Bossert - Vice President DATE: ('??' JJ SHERIFF'S RETURN - REGULAR CASE NO: 1999-04442 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK ET AL VS. MORALE NORMAN ET AL KENNETH GOSSERT , 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 MORACE NORMAN A/K/A MORACE NORMAN A the defendant, at 16:35 HOURS, on the 23rd day of July 1999 at 1544 SELTZER COURT MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to NORMAN MORALE 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: Docketing Service Affidavit Surcharge So answers: 18.00 8.68 .00 8.00 R-Thomasline, S eri $34.bb FEDERMAN & PHELAN 07/26/1999 by Sworn and subscribed to before me this dL V? day of 19_Qq A.D. e u i rotnonozary SHERIFF'S RETURN - REGULAR CASE NO: 1999-04442 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK ET AL VS. MORACE NORMAN ET AL KENNETH GOSSERT , 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 MORALE TERESA A/K/A MORACE TERESA K the defendant, at 16:35 HOURS, on the 23rd day of July 1999 at 1544 SELTZER COURT MECHANICSBURG, PA 17055 ,CUMBERLAND County, Pennsylvania, by handing to NORMAN MORACE (HUSBAND) 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: Docketing Service Affidavit Surcharge 6.00 So answers: f 00 2 8.00 omas ine, 01 $T4.UU FEDERMAN & PHELAN 07/26/1999 ep y PRer by Sworn and subscribed to before me this ;LG day of a ?f 19 QQ A. D. <1 n. hie. ro ono ar FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND CUMBERLAND COUNTY TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION Va. NORMAN MORALE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORALE NO. 99-4442 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. F K FEDERMA?, ESQUIRE Attorney for plaintiff >_ ,,_ ._ ?_ , _. ' ? ? ? ? ? - _ ? - ._ - ;- ?_ ;_;; : -: - ?, ? , _ ?: L "ll ?. V. _ ?.. ?t? L FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY 2270 ERIN COURT LANCASTER, PA 17601 Vs. NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORACE 1544 SELTZER COURT MECHANICSBURG, PA 17055 Attorney for Plaintiff . CUMBERLAND COUNTY . COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-4442 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 TERESA K. MORACE, Defendant(s) Plaintiff's Complaint within 20 Foreclosure and Sale of the Plaintiff's damages as follows: As set forth in Complaint Interest - 7/1/99 TO 9/7/99 TOTAL for failure to file an Answer to days from service thereof and for mortgaged premises, and assess $70,311.35 $ 1,014.99 $71,326.34 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. DAMAGES ARE HEREBY ASSESSED AS INDI DATE: F K FEDE MAN, ESQUIRE Attorney for Plaintiff i fr ;i f!' h. u C_ L ii j Cpl "i u, ? j FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNAYLVANIA NATIONAL BANK AND TRUST COMPANY Plaintiff Vs. NORMAN MORALE, A/K/A NORMAN A. MOP-ACE TERESA MORACE, A/K/A TERESA K. MORACE Defendant(s) TO: NORMAN MORACE, A/K/A NORMAN A. MORACE 1544 SELTZER COURT MECHANICSBURG, PA 17055 DATE OF NOTICE: AUGUST 13, 1999 ATTORNEY FOR PLAINTIFF . COURT OF COMMON PLEAS . CIVIL DIVISION . CUMBERLAND COUNTY . NO. 99-4442 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 FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza ATTORNEY FOR PLAINTIFF Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNAYLVANIA NATIONAL BANK AND TRUST COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION . CUMBERLAND COUNTY Vs. NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORALE Defendant(s) TO: TERESA MORALE, A/K/A TERESA K. MORACE 1544 SELTZER COURT MECHANICSBURG, PA 17055 DATE OF NOTICE: AUGUST 13, 1999 NO. 99-4442 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 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND CUMBERLAND COUNTY TRUST COMPANY COURT OF COMMON PLEAS . CIVIL DIVISION VS. NORMAN MORALE, A/K/A NORMAN A. MORALE TERESA MORALE, A/K/A TERESA K. MORACE NO. 99-4442 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 NORMAN MORALE, A/K/A NORMAN A. MORACE is over 18 years of age and resides at 1544 SELTZER COURT, MECHANICSBURG, PA 17055. (c) that defendant TERESA MORALE, A/K/A TERESA K. MORACE is over 18 years of age, and resides at 1544 SELTZER COURT, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F K FEDERd , ESQUIRE Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY Plaintiff Vs. NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORACE Defendants NO. 99-4442 CIVIL TERM Notice is given that a Judgment in the above-captioned matter has been entered against you on -SEPTEMBER Y/ /1 , 1999. By: a/t EPUTY If you have any questions concerning this matter, please contact: F E` E M& ES U R A torney 56r 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.** n ?? rc? 1 i PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY Plaintiff V8. NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORACE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO.99-4442 CIVIL TERM PRAECIPE FOR WRIT OF ERECIIPION (MORTGAGE FORECLOSURE) Defendant(s) TC THE DIRECTOR OF THE OFFICE OF THE PROTHONO'PARY: Issue writ of execution in the above matter:, / Amount Due $71,326.34 V Interest from 9/7/99 TO $ 1,090.89 and Costs 12/8/99 (PER DIEM - $11.73) $72,417.23 Total L F K FEDERM , ESQUIRE TW PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. A a, m ?E H F H a H Uu N ?r w w a% m 6 z W O w? a a O? U 00 F O? F? ?U 0 U E V1 b a E fA z 0 El M w a w z m H N zz w 0 HE W W D4 ww U U O a? w d W o a z° H W o O ? \ F ? w° D C W d \\ O? vu w o a a' oP4 zE v v w Ln Ln C. n pad P m U H D 0 V a w N a M w w w r-I b ro ?i v N A m w d m a ,EqI S m m w b a DESCRIPTION ALL THAT CERTAIN piece or parcel of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point marked by a monument on the southern dedicated right-of-way line of Mountain View Road, T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum, as shown on the Plan of Lots hereinafter mentioned; thence along said dividing fine South 17 degrees 20 minutes 35 seconds East, a distance of two hundred sixty- four (264) feet to a point at the dividing lines between Lots Nos. 20 and 21, as shown on said Plan of Lots; thence along said dividing line between Lots Nos. 20 and 21, South 48 degrees 55 minutes 13 seconds West, a distance of two hundred forty-five and eighty-nine hundredths (245.89) feet to a point on the northern side of a cul-de-sac at the northern end of Seltzer Court; thence along right-of- way line of Seltzer Court on a curve to the left having a radius of sixty (60) feet, an arc distance of fifty-seven and sixty hundredths (57.60) feet to a point on the same at the dividing line between Lots Nos. 20 and 19, as shown on said Plan of Lots; thence along the dividing line between Lots Nos. 20 and 19, North 6 degrees 4 minutes 53 seconds West, a distance of three hundred and thirty-four and seventy-two hundredths (334.72) feet to a monument on the southern right-of-way line of Mountain View Road, T-625, being the road first mentioned above; thence along said southern right-of-way line of Mountain View Road, T-625, North 72 degrees 39 minutes 20 seconds East, a distance of two hundred two and ninety three hundredths (202.93) feet to a monument on the same land now or formerly of John S. and Susan R. Yocum, the place of BEGINNING. BEING LOT Number 20 on the Subdivision Plan of Mountain View East, Block 4, as laid out by Ovidio and Edith L. Acri; said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 24, page 133. CONTAINING 73,900 square feet of land. HAVING THEREON ERECTED a dwelling house known as 1544 Seltzer Court. Tax parcel #09-15-1286-009 Y ? C C L 71) f1_ + 4? ?j `CSI ?^/ J\\ ?lj FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND CUMBERLAND COUNTY TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION Va. NORMAN MORALE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORALE NO. 99-4442 CIVIL TERM 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. F K FEDERM ESQUIRE Attorney for laintiff Ci: -? ?_ ?_. r, N :?. J.' C_:::: J '. J J Yl in L x'111 ,. ? i/J 1:. C1 -j L vl (_? I KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY Vs. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NORMAN MORALE, A/K/A NORMAN A. MORALE TERESA MORALE, A/K/A TERESA K. MORACE NO. 99-4442 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY September 4, 1999 TO: NORMAN MORALE, A/K/A NORMAN A. MORALE TERESA MORALE, A/K/A TERESA K. MORALE 1544 SELTZER COURT 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 1544 SELTZER COURT, 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 $71,326.34 obtained by KEYSTONE FINANCIAL 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 piece or parcel of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point marked by a monument on the southern dedicated right-of-way line of Mountain View Road, T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum, as shown on the Plan of Lots Hereinafter mentioned; thence along said dividing line South 17 degrees 20 minutes 35 seconds East, a distance of two hundred sixty- four (264) feet to a point at the dividing lines between Lots Nos. 20 and 21, as shown on said Plan of Lots; thence along said dividing line between Lots Nos. 20 and 21, South 48 degrees 55 minutes 13 seconds West, a distance of two hundred forty-five and eighty-nine hundredths (245.89) feet to a point on the northern side of a cul-de-sac at the northern end of Seltzer Court; thence along right-of- way line of Seltzer Court on a curve to the left having a radius of sixty (60) feet, an arc distance of fifty-seven and sixty hundredths (57.60) feet to a point on the same at the dividing line between Lots Nos. 20 and 19, as shown on said Plan of Lots; thence along the dividing line between Lots Nos. 20 and 19, North 6 degrees 4 minutes 53 seconds West, a distance of three hundred and thirty-four and seventy-two hundredths (334.72) feet to a monument on the southern right-of-way line of Mountain View Road, T-625, being the road first mentioned above; thence along said southern right-of-way line of Mountain View Road, T-625, North 72 degrees 39 minutes 20 seconds East, a distance of two hundred two and ninety three hundredths (202.93) feet to a monument on the same land now or formerly of John S. and Susan R. Yocum, the place of BEGINNING. BEING LOT Number`20 on the Subdivision Plan of Mountain View East, Block 4, as laid out by Ovidio and Edith L. Acri; said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 24, page 133. CONTAINING 73,900 square feet of land. HAVING THEREON ERECTED a dwelling house known as 1544 Seltzer Court. Tax parcel #09-15-1286-009 KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY VS. NORMAN MORALE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORACE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-4442 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No 1) BANK AND TRUST COMPANY, 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 1544 SELTZER COURT, 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) NORMAN MORACE A/K/A 1544 SELTZER COURT NORMAN A. MORACE MECHANICSBURG, PA 17055 TERESA MORACE A/K/A 1544 SELTZER COURT TERESA K. MORACE 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 COMMERICAL CREDIT CORP. LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 3300 HARTZDALE DRIVE SUITE 111 CAMP HILL, PA 17011 5. Name and address of on the property: NAME NONE every other person who has any record lien LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 1544 SELTZER COURT 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. September 4. 1999 L DATE F K FEDERMAN ESQUIRE A torney for laintiff ?? ? r r-? - .. - , , ,? ?- -? " : . =: ; ?. ?_, ,;; ; -- G. _ _ IILI l:. i C? V. _ ft1 ?? `= v l i NOV 2 2 199)6 FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Keystone Financial Bank, N.A. f/k/a Pennsylvania National Bank and Trust Company Plaintiff VS. Norman Morace a/k/a Norman A. Morace Teresa Morace a/k/a Teresa K. Morace Cumberland County Court of Common Pleas CIVIL DIVISION NO. 99-4442 Civil Defendant (s) ORDER TO VACATE /JUDGMENT AND NOW, this Zi_ day of W? 1999, after consideration of Plaintiff's Motion to Vacate Judgment, it is hereby ORDERED AND DECREED that the judgment entered on September 8, 1999 in the amount of $71,326.37 is VACATED without prejudice. SY-TIE .CO: ? W J. a ?r I 9gN ?Qlr0???!cOr?RY ?UMa1 OP23 41f /0.. 1 P ???Vy w? uc o, cs FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Keystone Financial Bank, N.A. f/k/a Pennsylvania National Bank and Trust Company Norman Horace Horace Teresa Horace Horace Plaintiff Vs. a/k/a Norman A. a/k/a Teresa K. Defendant(s) Cumberland County Court of Common Pleas CIVIL DIVISION NO. 99-4442 Civil MOTION TO VACATE JUDGMENT Plaintiff, by its counsel, Federman and Phelan, petitions this Honorable Court for an Order to vacate judgment in the above captioned matter and in support thereof avers the following: 1. Judgment was entered in favor of Plaintiff in this mortgage foreclosure on September 8, 1999 in the amount of $71,326.34. 2. Due to reinstatement of Defendants' account, Plaintiff petitions the Court to vacate the judgment in the instant matter. WHEREFORE, Plaintiff respectfully requests that the judgment be vacated without prejudice. FEDERMAN AND PHELAN BY Frank Federman, Esq. Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 Keystone Financial Bank, N.A. £/k/a Pennsylvania National Bank and Trust Company Plaintiff VS. Norman Morace a/k/a Norman A Morace Teresa Morace a/k/a Teresa K Morace Defendant (s) ATTORNEY FOR PLAINTIFF Cumberland County Court of Common Pleas CIVIL DIVISION NO. 99-4442 Civil PLAINTIFF'S MEMORANDUM OF LAW Plaintiff petitions this Honorable Court for an order to vacate judgment entered on September 8, 1999. Plaintiff desires to vacate the judgment entered due to the reinstatement of Defendants' account. Accordingly, Plaintiff respectfully requests an Order vacating judgment without prejudice. Respectfully submitted, FEDERMAN AND PHELAN By: a4 i Frank Federman, Esq. Attorney for Plaintiff VERIFICATION Frank Federman, Esquire, hereby states that he is the attorney for Plaintiff in the instant action, that he is authorized to make this verification, and that the statements made in the foregoing Motion to Vacate Judgment are true and correct to the best of his knowledge, information and belief. The undersigned also understands that his statement herein is made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: Frank Fe erman, Esq. Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 Keystone Financial Bank, N.A. f/k/a Pennsylvania National Bank and Trust Company Va. Plaintiff Norman Morace a/k/a Norman A. Morace Teresa Morace a/k/a Teresa K. Morace Defendant(s) ATTORNEY FOR PLAINTIFF Cumberland County Court of Common Pleas CIVIL DIVISION NO. 99-4442 Civil CERTIFICATION OF SERVICE Frank Federman, Esquire, hereby states that he is the attorney for Plaintiff in this action and that a true and correct copy of the within pleading was sent to the following interested parties on the date indicated below by first class mail, postage prepaid: Norman Morace a/k/a Norman A. Morace Teresa Morace a/k/a Teresa K. Morace 1544 Seltzer Court Mechanicsburg, PA 17055 Date: Cwt 1 ? Frank Federman, Esq. Attorney for Plaintiff (. 1 Keystone Financial Bank, N.A. -vs- Norman Morace a/k/a Norman A. Morace Tersea K. Morace In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-4442 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 172.29 Posting Bills 15.00 Advertising 15.00 Law Library .50 County 1.00 Mileage 17.36 Certified Mail .74 Levy 15.00 Postpone sale 20.00 Surcharge 24.00 Share of Bills 23.63 Law Journal 350.00 Patriot News 532.50 $ 1,217.02 pd by atty 12-02-99 So answe Sworn and Subscribed To Before Me R. Thomas Kline, Sheriff This 3 ? ( Day okl, By ?, _ Real Estate Deputy .2?1vre A.D. Q ' /ill ?&' r Prot o otary KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY V8. NORMAN MORALE, A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORACE s CUMBERLAND COUNTY s COURT OF COMMON PLEAS CIVIL DIVISION : NO. 99-4442 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No 1) Mawr' (i1V:.: -EMUST COMPANY, 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 1544 SELTZER COURT, 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) NORMAN MORALE. A/K/A 1544 SELTZER COURT NORMAN A. MORACE M_ECHANICSBURG, PA 17055 TERESA MORACE. A/K/A 1544 SELTZER COURT TERESA K. MORACE MECHANICSBURG. PA 17055 2. Name and address of Defendant (s) in the judgment: NA,1E 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) COMMERICAL CREDIT CORP. 3300 HARTZDALE DRIVE SUITE 111 CAMP HILL. PA 17011 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 . TENANT/OCCUPANT DOMESTIC RELATIONS OF CUbIBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 1544 SELTZER COURT 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. Seutember 4 1999 L DATE F K FEDERMAN ESQUIRE A torney for aintiff OFFICE OF THE SHERIFF OU,_ a ry SEP 9 3 si PM '99 FEt?NS'i LVAr?IA L:. V It r ?J I Y KEYSTONE FINANCIAL BANK, N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION NORMAN MORALE, A/K/A NORMAN A. MORACE TERESA MORALE, A/K/A TERESA K. MORACE NO. 99-4442 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY September 4, 1999 TO: NORMAN MORACE, A/K/A NORMAN A. MORACE TERESA MORACE, A/K/A TERESA K. MORACE 1544 SELTZER COURT 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 1544 SELTZER COURT, 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 $71,326.34 obtained by KEYSTONE FINANCIAL BANK N.A., F/K/A PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY (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, lace 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 NAY 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 ALL THAT CERTAIN piece or parcel of land situated in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point marked by a monument on the southern dedicated right-of-way line of Mountain View Road, T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum, as shown on the Plan of Lots Iiereinafter mentioned; thence along said dividing line South 17 degrees 20 minutes 35 seconds East, a distance of two hundred sixty- four (264) feet to a point at the dividing lines between Lots Nos. 20 and 21, as shown on said Plan of Lots; thence along said dividing line between Lots Nos. 20 and 21, South 48 degrees 55 minutes 13 seconds West, a distance of two hundred forty-five and eighty-nine hundredths (245.89) feet to a point on the northern side of a cul-de-sac at the northern end of Seltzer Court; thence along right-of- way line of Seltzer Court on a curve to the left having a radius of sixty (60) feet, an arc distance of fifty-seven and sixty hundredths (57.60) feet to a point on the same at the dividing line between Lots Nos. 20 and 19, as shown on said Plan of Lots; thence along the dividing line between Lots Nos. 20 and 19, North 6 degrees 4 minutes 53 seconds West, a distance of three hundred and thirty-four and seventy-two hundredths (334.72) feet to a monument on the southern right-of-way line of Mountain View Road, T-625, being the road first mentioned above; thence along said southern right-of-way line of Mountain View Road, T-625, North 72 degrees 39 minutes 20 seconds East, a distance of two hundred two and ninety three hundredths (202.93) feet to a monument on the same land now or formerly of John S. and Susan R. Yocum, the place of BEGINNING. BEING LOT Number'20 on the Subdivision Plan of Mountain View East, Block 4, as laid out by Ovidio and Edith L. Acri; said Plan being recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 24, page 133. CONTAINING 73,900 square feet of land. HAVING THEREON ERECTED a dwelling house known as 1544 Seltzer Court. Tax parcel #09-15-1286-009 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4442 CIVIL 1g COUNTY OF CUMBERLAND) CIVIL ACTION . LAW TO THE SHERIFF OF __ Qxnberl And COUNTY: To satisfy the debt, interest and costs due Keystone Financial Bank N.A., F/K/A Pennsylvania National Bank and Trust Company PLAINTIFF(S) from Norman Morace, A/K/A Norman A. Morace and Teresa Morace, A/K/A Teresa K. Morace (1) You are directed to levy upon the property 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 properly of the defendant(s) or otherwise disposing thereof; (3) If properlyof the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above staled. Amount Due- $71.z 6.14 L.L. S.50 Interest €&P Uyg99 t?11T//t8/99 $1.,090.89 Due Frothy_ $1.00 Atty's Comm % Other Costs Atty Paid $120.68 Plaintiff Paid Date: ___ Septenber 8, 1999 Curtis R. Long Prothonotary, Civil Division by. Deputy REQUESTING PARTY: Name Frank Federman, Esq. TRUE C^PY F"'' "rte ?"D Address: -Two Penn Center Plaza Suite 900 In Testimony e.h r "I il : ply hand Philadelphia, PA 19102 and the seal of said Court at Car?i:sle., Pa. _,o....., 19.J Attorney for: Plaintiff This .... ._..,_day of Telephone: (215) 563-7000 ...............?.i.?? Supreme Court ID No. _ 12248 Prothonotary REAL ESTATE SALE Naha Cn,L$4- '- ? t 999 the sheriff levied upon the defendants interest in the real property situated in f?,f l:gyy-o? Cumberland County, Pa., known and numbered as: 1syy .I.ol(iq? and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. d Date: 94 999 gy; ?? rte m z c? CO x T.. , m ? ?. Ca m c; C . < C D m r :y a a THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ret No. 587. Roorou d Mau 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 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 91h 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 dirdctors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Coj my of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 1 PUBLICATION V1 if 1 h _ COPY Swor fore me this 18th A ova b 9 A.D. S A L E #52 Ho t 1I.No TerryL.nusr1Pubiic NOT Y PUBLIC burgConnly "Y Commission EYptrns Juno G, 2002 MAL.ESTA;MSALE No•52 'YYfltl{#..2 foernbi,r,Pennsy,vaoacs::oaabo N919F9 ission expires June 6, 2002 A71Y1tsTom, I CUMBERLAND COUNTY SHERIFFS OFFICE A COURTHOUSE P?11 CARLISLE, PA. 17013 Why Ilonse Statement of Advertising Costs A.Mtxaoe To THE PATRIOT-NEWS CO., Dr. TiI#MaUonee For publishing the notice or publication attached pll(fAfI11N#(LMMa hereto on the above stated dates $ 531.00 Agy;IFrAitkFadsrmen pE$CRIP'fiON Probating same Notary Fee(s) $ 1.50 tof ALL THAT CERTAIN P or Total $ 532.50 of East alhro0sad Mt;lhe TownahlD F , CounNefCuINparnd?lier's NI more particularly i Receipt for Advertising Cost ylvdt Pen" bajndederiddsstxlbedatiloliows,towh: of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general BEGINNING at e,Pdnt marked by a lipt of the aforesaid notice and publication costs and certifies that the same have it on the -eouthem dedicated p l a ttl a lin r Ntsdeln View Rued, between Lot t ok, _- ? THE PATRIOT-NEWS CO. ns ta orlormerNo John No. ib a and 1101111111 Itow By .................................................................... elNY1 b Wpm, as ahown on the & and , ' of;: lAb r mentioned: plih no line South 17 ?qa ?p l deprsas.20 36 seconds East, a d aklty-four (264) dlNanoQ Ot 1w0 fe the dividing lines 4 okd <el I 1 p v, , I Nr, 0? DalWaln lpb Nbi 29 and 21, as shown gong said Ple on na i . 2D and tMNdlrg inutes 13 55 m y two hundred hundred" ";?pktt on the northern d et the northern an Saltrar ca,n thence along right-of- a . f s a county Mr (60 fast, q?Y " r hMnp,a tsdWe o and sixty .1 toan point on the s .. t fa yibign dNfdln9 line between Lae Of wn on sell Plan '20 d an 19, as sho l 4,fge, the dividing 2a and 19, North 6 4lpfsN, 4 tttl PA-.1.1 undlad and N 59 IIWO ae iMrty tour t a fi ' a (334.7z1 hu tea sweetly lra'ndredth am light eauth C ? to III rNarNM on the 26, grte rilp4ountekl ? llaned above; tfN load Orel men hto -way dg ' ^ r^.? ?IIMtoY:abnb said eoudlem ""Inc ourvuAT rAIHIUT-NEWS were established arc t 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 verily 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 ColrntL of Dauphin In Miscellaneous Book "M", Volume 14, Page 317, f 1 PUBLICATION COPY SALE #52 F l: 18th Terry L. Ruts'll, NO ?ry pudic HanistIt D NOT AMY P q. . imCOUnly UBLIC ` My Comm, ssinn Exnirr., Juno 6 2002 SALE 1 40.52 . 994442 murnbw.r-unnsyivama nsscamlo NE9111 isslon expires June 6, 2002 lean Financial CUMBERLAND COUNTY SHERIFFS OFFICE L;FAUA COURTHOUSE n National at Company CARLISLE, PA. 17013 maraca I Statement of Advertising Cos1tq A.D. A. M0race I To THE PATRIOT-NEWS CO., Dr. NlI For publishing the notice or publication attached *knnon hereto on the above stated dates $ 531 00 T10N piece or parcel of . Probating same Notary Fee(s) $ 1.50 Total township of East $ 532.50 Cumberland and more , Particularly her Is Receipt for Advertising Cost as followe,to wit of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general int'nisfited by a dedfeeted rlPt of the aforesaid notice and publication costs and certifies that the same have Intalnsy! AOBd W bNiMesri Lot THE PATRIOT-NEWS CO. Ylb n dy'olJohn ai;Q+am cn an By .................................................................... a lam ,. w..-.. and w- e to a 20 gsocnds East, d two and ninety a3)-'" to a o now or lend' Susan R. Yocum, if 2b .on the nW6 Vlsw East, vWioand Edith L. reccfded in the f Deeds In and for PennsyNanle, in ING 7900 square feet of THEREON- ERECTED a oa. lalewn as 1644 Softer I ?? I , ?r L` 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, 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. 62 writ No. 99-4442 Civil Keystone Financlal Bank. N.A.. F/K/A Pennsylvania National Bank And Trust Company VS. Norman Morace. A/K/A Norman A. Morace, Teresa Morace. A/K/A Teresa K. Morace Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece or par- cel of land situated in the Township of East Pennsboro. County of Cum- berland and Slate of Pennsylvania, more particularly bounded and de- scribed as follows, to Mt: BEGINNING at a point marked by a monument on the southern dedl- rnlrri rlohl-nf-a:nv line of Mmintnln Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 5 day of NOVEMBER. 1999 i NOTARIAL SEAL I I 1016 E. SNYDER. Notary Pubk Carhl* Dora, Cumberland County, PA My CammiWon E:pir" March S, 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, 1999 Afftant 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 SAT NO. 52 Writ No. 99-4442 Civil Keystone Financial Bank. N.A., F/K/A Pennsylvania National Bank And Trust Company VS. Norman Morace, A/K/A Norman A. Morace, Teresa Morace, A/K/A Teresa K. Morace Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece or par- cel of land situated in the Township of East Pennsboro. County of Cum- berland and State of Pennsylvania. more particularly bounded and de- scribed as follows, to wit: BEGINNING at a point marked by a monument on the southern dedb rated right-of-way line of Mountain View Road. T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum. as shown on the Plan of Lots hereinafter mentioned: thence along said dividing line South 17 degrees 20 minutes 35 seconds East. a (Ins- tance of two hundred sixty-four (264) feel to a point at the dividing lines between Lots Nos. 20 and 21. as shown on said Plan of Lots: thence along said dividing line between Lots Nos. 20 and 21, South 48 degrees 55 minutes 13 seconds West, a distance Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 5 day of NOVEMBER. 1999 NOTARIAL SEAL L016 E. SNYDER, Notary Public C dwe ®om, Cumberlond County, PA My C: miwim Explrat Morch S, 2001 of two hundred forty-five and eighty- nine hundredths (245.89) G'el to a Point on the northern side ut a rub de-sac at the northern end of ti'llzer Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that lie 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. 62 Will No. 99-4442 Civil Roger M. Morgenthal Editor Keystone Financial Bank, N.A., , F/K/A Pennsylvania National Bank And Trust Company pany M Trust C SWORN TO AND SUBSCRIBED b f Vs. e ore me this 5 day of NOVEMBER 1999 Norman Morace. A/K/A Norman A. Morace, Teresa Morace. A/K/A Teresa K. Morace / Ally.: Frank Federman Fµ- DESCRIPTION NOTA IR AL SEAL ALL THAT CERTAIN piece or par- LOIS E. SNYDER. Notary Public Cc"* tom, Cumbodand County, PA cel of land situated In the Township of East Pennsboro, County of Cum- My Commiuion Eaplr" March 3, 2001 berland and Slate of Pennsylvania, more particularly bounded and de- scribed as follows, to wlt: BEGINNING at a point marked by a monument on the southern dedi- rated right-of-way line of Mountain I View Read. T-625, at the dividing line between Lot No. 20 and lands now or formerly of John S. and Susan R. Yocum, as shown on the Plan of Lots I hereinafter mentioned: thence along said dividing line South 17 degrees 120 minutes 35 seconds East. a dls. tance of two hundred sixty-four (264) feel to a point at the dividing lines J between Lots Nos. 20 and 21, as t shown on said Plan of Lots; thence along said dividing line between Lots Nos. 20 and 21. South 48 degrees 55 minutes 13 seconds West, a distance of two hundred forty-five and eighty- nine hundredths (245.89) feet to a F point on the northern side of a cut- de-sac at the northern end of Seltzer , Court; thence along right-of-way line of Seltzer Court on a curve to the left having a radius of sixty (60) feel, an , are distance of fifty-seven and sixty hundredths (57.60) feet to a point on the same at the dividing line between Lots Nos. 20 and 19, as shown on said Plan of Lots; thence along the dividing line between Lots Nos. 20 and 19, North 6 degrees 4 minutes . 53 seconds West. a distance of three `It hundred and thirty-four and sev- enty-two hundredths (334.72) feet to a monument on the southern right- I<! of-way line of Mountain View Road, t T-625, being the road first men- tioned above; thence along said southern right-of-way line of Moun- tain View Road, T-625, North 72 de- grees 39 minutes 20 seconds East, a distance of two hundred two and ' ninety three hundredths (202.93) feet to a monument on the same land nowor formerlyofJohn S. and Susan R. Yocum, the place of BEGINNING. BEING LOT Number 20 on the Subdivision Plan of Mountain View East, Block 4, as laid out by Ovidlo and Edith L. Acri: said Plan being recorded in the Office of the Recorder (-. of Deeds In and for Cumberland , County, Pennsylvania. In Plan Book 24, page 133. 1 CONTAINING 73.900 square feel of land. 1 1,' HAVING THEREON ERECTED a dwelling house known as 1544 Selt- zer Court. - - r ' ! Tax parcel ®o9-15-1286-009.