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HomeMy WebLinkAbout99-04604Orr A b 0 0 M. L? I- .y qci- 1 o- I / 1 rJ 0 C1?: .z N w ?O a a^ O ., 4 6 w? = U?y r_ s?dv 57 $ L OOBI!llIBCBM W UIGOtzz0 '?I"MO.duY1u1 alp VIII tl [GILD 1nb93l 31 3W1591tl FEDERMAN AND PHELAN By: FRANK FEDERMAN. ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA. SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MELLON MORTGAGE COMPANY, SB/M TO METMOR FINANCIAL. INC. 1775 SHERMAN STREET SUITE 1500 DENVER, CO 80203-4302 Plaintiff V. TERM NO. CA - 4?Q04 C?uLTeAr^ JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 Delcndant(s) CUMBERLAND COUNTY 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 TIIAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TIIIS CORRESPONDENCE SIIOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF ALIEN 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 twenty (20) days aRer this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgnunt may be entered against you by the court without further notice for any money clainied in the Complaint or for any other claim or relief requested by the Plaintiff. You nay 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 MELLON MORTGAGE COMPANY. S/B/M TO METMOR FINANCIAL. INC. 1775 SHERMAN STREET SUITE I.i00 DENVER, CO 90203-4302 2. The name(s) and fast known address(es) ofthc Defendant(s) arc: JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 1/15/92 mortgagor(s) made, oucutcd and delivered a mortgage upon the premises hereinafter described to SEARS MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1043, Page 734. By Assignment of Mortgage recorded 10/8/92 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 428, Page 642. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly pawnwnts of principal and interest upon said mortgage due 2/1/99 and each month thereafter are duc and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one nmonth, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $55,565.81 Interest 2,397.30 I/l/99 through 7/1/99 (Per Diem $13.10) Attorney's Fees 2,773.00 Cumulative Late Charges 109.40 1/15/92 to 8/1/99 Cost of Suit and Title Search 550.00 Subtotal 61,295.51 Escrow Credit 0.00 Deficit 172.46 Subtotal 172.46 TOTAL $61,467.97 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. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. 3 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 $61,467.97, together with interest from 7/1/99 at the rate of $13.10 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. ' /s/ Frank Federman FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN LOT Oft PIECE o.r land situate on the Meat. side of State Road, (now known as Eno).a Drive), East Pennaboro' Towns hip,' Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point tvcnty-five (25) feet southerly from the Southwest corner of State Road and Cumberland Street; THENCE Southwardly along the West side of State Road twenty-five "--,(2,5) feet, more or less, to a point, the Northern line of lot now or formerly of Harry Fortenbaugh, being Lot No. 29; THENCE along the Northern lint or :aid Lnt No. 29, Wcatwardly one hundred fifty-five (155) feet, more or less, to a public alley; THENCE along the Eastern line of said public alley, Northwardly twenty- five (25) feet, more or less, to a point, the dividing line between Lots Nos. 30 and 31; THENCE Eastwardly along the Southern line of Lot No. 31 and through the center of this and the adjoining property one hundred and forty (lho) feet, more or less, to the Eastern side of State Road, tlic place of BEGINNING. BEING THE Southern half of Lot No. 30 on Plan of Lots or J Jphn Q. Adams and Joseph Pyne and BEING known as 331 So. Enola Drive. ;l' I! PA.] M t VERIFICATION MICHELLE D. VINER hereby states that he/she is ASSISTANT VICE PRESIDENT of MELLON MORTGAGE COMPANY 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. Michelle D. Viner Assistant Vice President 2bq DATE: 6 SHERIFF'S RETURN - REGULAR CASE NO: 1999-04604 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE COMPANY ET AL VS. STONER JOEL E DAWN KELL , 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 STONER JOEL E the defendant, at 18:13 HOURS, on the 2nd day of August 1999 at 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to JOEL E. STONER 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 aniG.. Docketing 18.00 Service 9.92 2 Affidavit .00 Surcharge 8.00 R-I omah s Rrine; eri -08/06/1999 PHELAN by of l)1l epu y eri Sworn and subscribed to before me this ? day of 19gq A. D. UU /ro oy?oy? SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-04604 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE COMPANY ET AL VS. STONER JOEL E R. Thomas Kline Sheriff, who being duly sworn according to law, Pays, that he made a diligent search and inquiry for the within named defendant, to wit: STONER PATRICIA R but was unable to locate Her in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT FOUND , as to the within named defendant STONER PATRICIA R DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FWDG WITH P.O., RETURN NOT FOUND AS PER ATT. Sheriff's costs: So ansa =% Docketing 6.00 Not Found Return 5.00 tG??lr(??. Affidavit .00 Surcharge 8.00 ine, 5 eri $TF=. FEDERDIAN & PHELAN 08/06 1999 Sworn and subscribed to before me this (,-' day of 19 iFq A.D. C nn. 4IL7.,iFw L j "ro ono ary'? `C t IFFICE OF THE SHERIFF JUL 30 2 07 PH '99 .; PENN 3YI_VANIA O a a? o ;;a a 'a a 2 U Iv o« o= 'L'inr=a ' I%Xp'LLLBJ MwOI[OUZE ]ul ryuoilvuOlul alvlFrylo WWQtl [[Ica. 1tl03133tllSlltl FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 MELLON MORTGAGE COMPANY, SB/M TO METMOR FINANCIAL, INC. 1775 SHERMAN STREET SUITE 1500 DENVER, CO 80203-4302 V. Plaintiff' ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. "Iq^gQ04 CIVIL. CUMBERLAND COUNTY JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 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 SHOULD NOT BE CONSTRUED TO BE AN ATTE61PT TO COLLECT A DEBT BUT ONLY ENFORCEIIIENT 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 twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and tiling 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 miy 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. We tlsf CUMBERLAND COUNTY Aby 09r* the CUMBERLAND COUNTY BAR ASSOCIATION W" tO be a true Snd 2 LIBERTY AVENUE Clon1wCopy of the CARLISLE. PA 17013 _ nn . r i RECORD OrVna! ftled of record (717) 249-3166 Tf~.:.t, G r-; r°. ; Dr, WDERMA In TcsGwremj Yrjcrff, 1, ; ;Ito rPt rfry Nana NANO Plf?t p,N ; iha gal of safd C,- Car(,ie, Pa. Phis.. "j e 199 0A c1mrf-, -N, Prolilonctzry Defendant(s) CIVIL ACTION - LAW MORTGACE FORECLOSURE Plaintiff is MELLON MORTGAGE COMPANY. S/B/M TO METMOR FINANCIAL. INC. 1775 SHERMAN STREET SUITE 1500 DENVER, CO 80203-4302 2. The name(s)and Inst known address(es) of the Defendant(s)are: JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 1/15/92 mortgagor(s) made. executed and delivered a mortgage upon the premises hereinafter described to SEARS MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1043, Page 734. By Assignment of Mortgage recorded 10/8/92 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 428, Page 642. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage duc 2/1/99 and each month thereafter arc due and unpaid, and by the terms of said mortgage, upon default in such paynunts fora period of one month, the entire principal balance mid all interest duc thereon arc collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/99 through 7/1/99 (Per Diem $13.10) Attorney's Fees Cumulative Late Charges 1/15/92 to 8/1/99 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL 8. $55,565.81 2,397.30 2,773.00 109.40 550.00 61,295.51 0.00 172.46 172.46 $61,467.97 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50.000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $61,467.97, together with interest from 7/F/99 at the rate of $13.10 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. /s/ Frank Federman FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN LOT OR PIECE or lund situate on the West aide of State Road, (now known i Enala Drive), East Pennaboro Township,' Cumberland County, Pennaylvanim, bounded and described as follows, to wit: BEGINNING at a point twenty-five (25) feet southerly from the Southwest corner of State Rom,; and Cumberland Street; THENCE Southvardly along the West side of state Road twenty-five (25) feet, more or leas, to a point, the Northern line of lot now or formerly of Harry Fortcnbaugh, being Lot No. 29; THENCE along the. Northern line of said Lot No. 29, Westvardly one hundred fifty-five (155) feet, more or less, to a public alley; THENCE along the Eastern line of said public alley, Northwardly twenty- five (25) feet, more or less, to a point, the dividing line between Lots Nos. 30 and 31; THENCE EasLwardly along the Southern line of Lot No. 31 and through the center of this and the adjoining property one hundred and forty (140) rest, more or less, to the Eastern side of State Road, the place of BEGINNING. BEING THE Southern half of Lot No. 30 on Plan of Lots-or JJ John Q. Adams and Joseph Pyne and BEING known as 331 So. Enola Drive. `a I) CAM" nna tai. ..,py?ry.!...t ?: ... .r ... ? rn t a „A kC^ S ? 1S VERIFICATION MICHELLE D. VINER hereby states that he/she is ASSISTANT VICE PRESIDENT of MELLON MORTGAGE COMPANY 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 ana Deiiei. iaaa uaau oa oayuou understands that this statement is made subject to the penalties of is Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. , L a-?L Michelle D. Viner Abq Assistant Vice President DATE: u FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. Plaintiff VS. Attorney for Plaintiff . COURT OF COMMON PLEAS . CIVIL DIVISION . Cumberland County JOEL E. STONER PATRICIA R. STONER Defendants . No. 1999-04604 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: August 13, 1999 o w_ c? ? 4 O ??L = rc Ql O CT U 0 SHERIFF'S RETURN - REGULAR CASE NO: 1999-04604 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON MORTGAGE COMPANY ET AL VS. STONER JOEL E CHRISTOPHER EVANS Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STONER PATRICIA R the defendant, at 10:44 HOURS, on the 30th day of August 1999 at 12 DULLES DRIVE WEST CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to PATRICIA R. STONER a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof Sheriff's Costs: So answer Docketing 18.00 ? Service 9.30 Affidavit .00 Surcharge 8.00 rz omit asZline, 577eriff $3 FEDER & PHELAN 08/31 by9l? V-12tA Le 44y 4ei Sworn and subscribed,,teo befor me this 4-4 L day of S4 k- YU r FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC 1775 SHERMAN STREET SUITE 1500 DENVER, CO 80203-4302 Vs. JOEL E. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 Attorney for Plaintiff . CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION PATRICIA R. STONER 12 DULLES DRIVE WEST CAMP HILL, PA 17011-1110 NO. 1999-04604 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JOEL E. STONER AND PATRICIA R. STONER, Defendant (s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 7/1/99 TO 10/8/99 TOTAL I hereby certify that (1) Defendant(s) are as shown above in accordance with Rule 237.1, DAMAGES ARE HEREBY ASSESSED AS DATE : lU - I fy $61,467.97 $ 956.30 $64,424.27 the addresses of the Plaintiff and and (2) that notice has been given copy attached. F K FEDER , ESQUIRE Attorney for Plaintiff INDIC D. J ()14 PRO PROTHY FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF MELLON MORTGAGE COMPANY, S/S/M COURT OF COMMON PLEAS TO METMOR FINANCIAL, INC. CIVIL DIVISION Plaintiff vs. JOEL E. STONER PATRICIA R. STONER Defendant(s) CUMBERLAND COUNTY NO. 1999-04604 FILE copy TO: PATRICIA R. STONER 12 DULLES DRIVE WEST CAMP HILL, PA 17011-1110 DATE OF NOTICE: SEPTEMBER 21, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BAR ASSOCIATION Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN 'Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF MELLON MORTGAGE COMPANY, S/B/M COURT OF COMMON PLEAS TO METMOR FINANCIAL, INC. . CIVIL DIVISION Plaintiff VS. JOEL E. STONER PATRICIA R. STONER Defendant (s) TO: JOEL E. STONER. 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 . CUMBERLAND COUNTY . NO. 1999-04604 FILE Copy DATE OF NOTICE: SEPTEMBER 21, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BAR ASSOCIATION Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. Va. JOEL E. STONER PATRICIA R. STONER ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 1999-04604 VERIFICATION OF NON-MILITAP,Y 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 JOEL E. STONER is over 18 years of age and resides at 331 SOUTH ENOLA DRIVE, ENOLA, PA 17025. (c) that defendant PATRICIA R. STONER is over 18 years of age, and resides at 12 DULLES DRIVE WEST, CAMP HILL, PA 17011- 1110. This statement 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 Plaintiff ?? V3 r PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. Plaintiff VS. JOEL E. STONER PATRICIA R. STONER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 1999-04604 PRAECIPE FOR WRIT OF EXECIMON (MORTGAGE FORECLOMM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter Amount Due $64,424.27 Interest from 10/8/99 TO $ 1,487.70 and Costs 3/1/00 (PER DIEM - $10.26) $63.911.97 Total F K FEDER SQUIRE TW PENN CEN ER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. A co m rn v E w w 0 i rn m rn z° 0 W ?-1 z it. U CO V Oa F ?U z H H U H Z W 11 0 as u W a 0 z 0 a a ,z 2 m a 0 0 F N y z WH aU hF a ??0,. U^ d W 7 w ,o Q ?+ ?w wo W v v w a H H WU O M ha ul a 0 W ? N 0 dam axa za ? a W ? ?m W N N ? Ix F4 Q ..m mw Na v? vQ a N ri DESCRIPTION ALL THAT CERTAIN lot or piece of land situate on the West side of State Road, (now known as Enola Drive), East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point twenty-five (25) feet Southerly from the Southwest comer of State Road and Cumberland Street; thence Southwardly along the West side of State Road twenty-five (25) feet, more or less, to a point, the Northem line of lot now or formerly of Harry Fottenbaugh, being Lot No. 29; thence along the Northern line of said Lot No. 29, Westwardly, one hundred fifty-five (155) feet, more or less, to a public alley; thence along the Eastern line of said public alley, Northwardly twenty-five (25) feet, more or less, to a point, the dividing line between Lots Nos. 30 and 31; thence Eeswardly along the Southern line of Lot No. 31 and through the center of this and the adjoining property one hundred and forty (140) feet, more or less, to the Eastern side of State Road, the place of beginning. BEING the Southern half of Lot No. 30 on Plan of Lots of John Q. Adams and Joseph Pyne and being known as 331 S. Enola Drive. Tax Parcel /t 09-16-1050-009 TITLE TO SAID PREMISES IS VESTED IN Joel E. Stoner and Patricia R. Stoner, his wife by Deed from Randy J. Potteiger and Vicki Y. Potteiger f/k/a Vicki L. Young, his wife dated 1/15/92, recorded 1/15/92, in Deed Book M-35, Page 318. f ?1 1 1 ? 1 UVI FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. VS. JOEL E. STONER PATRICIA R. STONER ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 1999-04604 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: (XX) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) 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 FEDEIMA? ESQUIRE Attorney for Plaintiff ?G? ?.: - ?-- ,.- e: .> . - ,,: ? . :; " ?? ?., _ L.:.. ! ??' ? I.? L? C.? '1 C`? _? :\ 1, MELLON•MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS. JOEL E. STONER PATRICIA R. STONER . NO. 1999-04604 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL INC, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 331 SOUTH ENOLA DRIVE. ENOLA PA 17025 1. Name and address of Owner (s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) JOEL E. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 PATRICIA R. STONER 12 DULLES DRIVE WEST CAMP HILL. PA 17011-1110 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 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 CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 8, 1999 DATE F WK FEDER , ESQUIRE A torney for Plaintiff CJ G. l-1 ::n J I' MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC Va. JOEL E. STONER PATRICIA R. STONER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 1999-04604 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY October 8, 1999 TO: JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE 12 DULLES DRIVE WEST ENOLA, PA 17025 CAMP HILL, PA 17011-1110 "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 331 SOUTH ENOLA DRIVE. ENOLA, PA 17025, is scheduled to be sold at the Sheriff's Sale on MARCH 1, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $64,424.27 obtained by MELLON MORTGAGE COMPANY. S/B/M TO METMOR FINANCIAL, INC. (the mortgagee) against you. If the sale is postponed, the property will be relisted for the 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: 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. 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. 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 'FAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN lot or piece of land situate on the West side of State Road, (now known as Enola Drive), East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point twenty-five (25) feet Southerly from the Southwest corner of State Road and Cumberland Street; thence Southwardly along the West side of State Road twenty-five (25) feet, more or less, to a point, the Northern line of lot now or formerly of Harry Fortenbaugh, being Lot No. 29; thence along the Northern line of said Lot No. 29, Westwardly, one hundred fifty-five (155) feet, more or less, to a public alley; thence along the Eastern line of said public alley, Northwardly twenty-five (25) feet, more or less, to a point, the dividing line between Lots Nos. 30 and 31; thence Eastwardly along the Southern line of Lot No. 31 and through the center of this and the adjoining property one hundred and forty (140) feet, more or less, to the Eastern side of State Road, the place of beginning. BEING the Southern half of Lot No. 30 on Plan of Lots of John Q. Adams and Joseph Pyne and being known as 331 S. Enola Drive. Tax Parcel # 09-16-1050-009 TITLE TO SAID PREMISES IS VESTED IN Joel E. Stoner and Patricia R. Stoner, his wife by Deed from Randy J. Potteiger and Vicki Y. Potteiger f/k/a Vicki L. Young, his wife dated 1/15/92, recorded 1/15/92, in Deed Book M-35, Page 318. ti ?) ? 1.11''. ? ??: '?•= I? 1 C.: l :n • . U? iJ Mellon Mortgage Co. s/m/b to Metmor Financial Inc. Joel E. Stoner and Patricia R. Stoner In the Court of Common Pleas of Cumberland County, Pennsylvania No.99-4604 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 14.43 Posting Bills 15.00 Advertising 15.00 Law Library .50 County 1.00 Mileage 29.14 Certified Mail .84 Levy 15.00 Postpone Sale 20.00 Surcharge 24.00 Share of Bills 25.08 Law Journal 293.50 Patriot News 252.45 $ 735.74 Pd By Atty 02-24-00 So an. r Sworn and subscribed to before me This i 7 w day of 1999, A.D. Yk t??• r thonotary R. Thomas Kline, Sheriff BY ,e4 Real Estate Deputy 1,7U clJL ????.'? ,G I VCU/• g MELLON MORTGAGE COMPANY, f/B/M TO METMOR FINANCIAL, INC VS. JOEL E. STONER PATRICIA R. STONER . CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION . NO. 1999-04604 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 331 SOUTH ENOLA DRIVE, ENOLA, PA 17025. 1. Name and address of owner(s) or reputed owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) JOEL E. STONER 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 PATRICIA R. STONER 12 DULLES DRIVE WEST CAMP HILL. PA 17011-1110 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 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 CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 331 SOUTH ENOLA DRIVE ENOLA, PA 17025 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 8, 1999 DATE F WK FEDER , ESQUIRE A torney for Plaintiff 40 MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. VS. JOEL E. STONER PATRICIA R. STONER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 1999-04604 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY October 8, 1999 TO: JOEL E. STONER PATRICIA R. STONER 331 SOUTH ENOLA DRIVE 12 DULLES DRIVE WEST ENOLA, PA 17025 CAMP HILL, PA 17011-1110 "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 331 SOUTH ENOLA DRIVE, ENOLA, PA 17025, is scheduled to be sold at the Sheriff's Sale on MARCH 1, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $64,424.27 obtained by MELLON MORTGAGE COMPANY, S/B/M TO METMOR FINANCIAL, INC. (the mortgagee) against you. If the sale is postponed, the property will be relisted for the 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. i 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 i DESCRIPTION ALL THAT CERTAIN lot or piece of land situate on the West side of State Road, (now known as Enola Drive), East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point twenty-five (25) feet Southerly from the Southwest comer of State Road and Cumberland Street; thence Southwardly along the West side of State Road twenty-five (25) feet, more or less, to a point, the Northern line of lot now or formerly of Harry Fortenbaugh, being Lot No. 29; thence along the Northern line of said Lot No. 29, Westwardly, one hundred fifty-five (155) feet, more or less, to a public alley; thence along the Eastem line of said public alley, Northwardly twenty-five (25) feet, more or less, to a point, the dividing line between Lots Nos. 30 and 31; thence Eastwardly along the Southem line of Lot No. 31 and through the center of this and the adjoining property one hundred and forty (140) feet, more or less, to the Eastern side of State Road, the place of beginning. BEING the Southern half of Lot No. 30 on Plan of Lots of John Q. Adams and Joseph Pyne and being known as 331 S. Enola Drive. Tax Parcel # 09-16-1050-009 TITLE TO SAID PREMISES IS VESTED IN Joel E. Stoner and Patricia R. Stoner, his wife by Deed from Randy J. Potteiger and Vicki Y. Potteiger f/k/a Vicki L. Young, his wife dated 1/15/92, recorded 1/15/92, in Deed Book M-35, Page 318. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4604 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dueMellon Mortgage Co.s/b/m to Metmor Financial Inc. PLAINTIFF(S) from Joel E. Stoner, 331 S. Enola Dr., Enola PA 17025 and Patricia R. Stoner, 12 Dulles Dr. West, Camp Hill PA 17011.-1110 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at 331 S. Enola Dr., Enola PA 17025. (See attached legal description.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) lfpropertyof the defendant(s) not leviedupon an subjectlo attachment isfound in the possession of anyoneother than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AntountDue $64,424.27 10/8/99 to 3/1/99 Interest $1,487.70 $10 26 par Al n Atty's Comm % AttyPaid $162.22 Plaintiff Paid Date: October 12, 1999 REQUESTING PARTY: Name Frank Federman, Esquire. Address: Two Penn Center Sq Ste 900 Philadelphia PA 19102 Attorney for: Plaintiff Telephone:(215) 5637000 Supreme Court ID No. 12248 L.L. $.50 Due Frothy. Other Costs $1.00 CURTIS R. LONG Protho ap ,Civil Division by: Deputy REAL ?a; On 10?? l9, r99 9 the sheriff lovied upon the defendants interest in the real property situated in E?I_?i¢?.yo?ikna Cumberland County, Pa., known and numbared as:33/.Z pl?__ anj mere fully described on ` Exhibit A filed with this writ and by this reference incorporated herein. ?',?ta: /4 S9 M zi aitivn? ?s,?t;3d 666 old YE E BI 110 PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL G. SCHMIEG IDENTIFICATION NO. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 215) % -7000 ATTORNEY FOR PLAINTIFF MELLON MORTGAGE COMPANY CUMBERLAND County Plaintiff Vs. JOEL E. STONER PATRICIA R. STONER Defendant(s) TO THE PROTHONOTARY: Court of Common Pleas CIVIL DIVISION NO. 99-4604 :PHS # 30328 Kindly Satisfy the Judgment which was entered against JOEL E. STONER and PATRICIA R. STONER, Defendants, relative to the instant matter, upon payment of your costs only. Dated: July 27, 2006 Attorney for Plaintiff c? co _i r'v 1]