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Home My WebLink About99-07122a, CJ N BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. e79. 7?1z ll T4.- : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE DANIELLE LYNN DUM Defendant THIS LAW FIRM IS A DEBT TO COLLECT A DEBT OWED OBTAINED FROM YOU WILL COLLECTING THE DEBT. COLLECTOR AND WE ARE ATTEMPTING TO OUR CLIENT. ANY INFORMATION BE USED FOR THE PURPOSE OF N O T I C E You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 A V I S O LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SO ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 9- 7/ -2-Z CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C O M P L A I N T 1. Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, is a corporation with a servicing agent of Alliance Mortgage Company, with an adress of 8100 Nations Way, Jacksonville, Florida 32256. 2. Defendant, DANIELLE LYNN DUM, is an adult individual whose last known address is 537 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025. 3. On or about February 2, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $53, 350.00 payable to MELLON BANK, N.A. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possessopn of De f endants . Plaintiff alos avers that the within Mortgage foreclosure complaint is based upon the Mortgage ans that attachment of a complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 10 19(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and i Commonwealth conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to BANKERS TRUST COMPANY OF CALIFORNIA, N.A. TRUSTEE OF MELLON MORTGAEG CRA MORTGAGE LOAN TRUST 1966-A and recorded in the aforesaid County in Mortgage Book 582, Page 113 on July 20, 1998. Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 860 VALLEY STREET, ENOLA, PENNSYLVANIA 17025 and is more particulary described in Exhibit "A" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 51,261.88 (b) Interest at $9.12 per day from 6/1/99 to 12/1/99 (based on contract rate of 6.500%) 1,668.96 (c) Accumulated Late Charges 67.44 (d) Late charges at $16.86 per month for 6 months 101.16 II (e) Escrow Credit 12.48 Itl (f) 5a Attorney's Commission 2,633.09 $ 55, 720.05 *Together with interest at the per diem rate noted in (b) above after December 1, 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennslyvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM,, for the aforementioned total amount due I; together with interest at the rate of 6.5005k ($16.86 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. E PURCELL R LER I • S By Leo P. Haller Attorney for Plaintiff i I.D. #15700 i! 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 1 POLICY NO. D148674CP EXHIBIT A ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows according to survey of Ernest J. Walker, Professional Engineer, dated December 5, 1968, to wit: BEGINNING at a point in the center line of Legislative Route 21051, now known as Valley Road, said point being 1690 feet in an Easterly direction from the intersection of the center line of Legislative Route 21051, now known as Valley Road and the center line of Township Road 660, said point being also on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said line of Legislative Route 21051, now known as valley Road, North 71 degrees 30 minutes East 78.4 feet to a point on line of lands now or late of John Bressler; thence along lands now or late of John Bressler, South 18 degrees 30 minutes East 299 feet to a point on line of lands now or late of John C. Roth; thence along said lands South 71 degrees 30 minutes West 78.4 feet to a point on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said lands North 18 degrees 30 minutes West 299 feet to a point, the Place of BEGINNING. HAVING thereon erected a one story frame dwelling. BEING the same premises which Michael R. Cunningham and Shelley Renee Cunningham, his wife and Allean Welker, Trustee and Robert L. Welker, II, Trustee and Executor of the Estate of Rebecca Jane Cunningham by their Deed dated February 12, 1996 and intended to be recorded immediately prior hereto, granted and conveyed unto Danielle Lynn Dum, MORTGAGOR HEREIN. •, of Pannsylvania Ss -t,uy of Cumberland v'dud in the office for the recording of Deeds antill moorland Coun my hand I of ofti r Lio PA da r1f'" 19 Recor er CLTIC Forty 1780 Page BO11K1303PAGE 32 VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE, and that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 19, 1999 Leon P. Haller, Esquire BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW VS. NO. 99-7122 CIVIL TERM DANIELLE LYNN DUM IN MORTGAGE FORECLOSURE Defendant P R A E C I P E TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned action. Dated: January 5, 2000 PURCELL, KRUG HALLER By: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff +^!- h J tM1. .! RUST 1996-A : . ^ m xs: ,doctGl:l6j$D 171 Plaintiff NO. g 7/1,Z ecir-l Tc vs. CIVIL ACTION - LAW - DANIELLE LYNN DUM IN MORTGAGE FORECLOSURE Defendant THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANy INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURpOSE OF COLLECTING THE DEBT. You have been sued in court,N O_ T I E forth in the following pages, you must takeuactiontoefe d against the claims set Complaint and notice are served, b twe attorney and filin in by entering a written a my (20) days after the claims set forth againstwryou. iting You with the court your defensearoxc ob eraonally or by Proceed without I. are warned that if you fail to do so th ne to the Further notice you a money claimed may be entered against you b so the c may relief re for an y in Y the Court without quested by the Plaintiff. You ma the Complaint or £ Important y or to you. Y lose money or any other claim or YOU SHOULD TAKE THIS PAPER TO YOUR LAWYE AT ONCE. YOU DO NOT Y property or other rights OR CANNOT AFFORD ONE, GO TO OR TELEPHONE HER OFFICE SETF FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. HAVE A LAWYER Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. S Irvine Row, Carlisle, PA 17013 717-243-9400 i LE HAN DEMANDADO A USTED EN AA V PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO SI DESEA DEFENDERSE CONTRA DESPUES DE SER SERVIDO CON ESTA DE QUE USTED RESPONDA DENTRO 2p V Z US TED USTED, O SU ABOGADO, REGISTRE CON MANDA Y AVISO. DE EN F PAR' DEFENDERSE ES NECESSARIO QUE Y CUALQUIER OBJECCION CONTRA CORTE EN FORMA ESCRITA, RECUERDE: SI USTED NO REPONDE pQESTAS DE ESTA DEMANDA EL PVNTO DE VISTA DE PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE pUEDE, SIN NOTIFI FAVOR DEL DEMANDANTE Y MANDA, SE PUEDE PROSEGUIR CON EL DEMANDA, FOR REQUERIRA QUE USTED CUMPLA CON TODAS LAS CARIO, DECIDIR A RAZON DE ESA ON, .TONES DE PROPIEDAD U OTROS DERECHOS IVMPORTANTES,S POSSIBLE QUE USTED p UEDAV PERDER DINERO,A LLEVE ESTA DEMANDA A UN ABOGADO IFII4EDIATAMENTE. SI NO REFERENCIA DE ONOCE OS N, AZ OS A2Do,,- LLAME AL "LAWYER REFERENCE SERVICE" 6300. (SERVICIO DE Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. B Irvine Row, Carlisle, PA 17013 717-243-9400 TRUE COPY FROM RECORD in Testimony whoraof, I hire urr;o set my hand and the seal of said Court at OaPosle, ft Th 3.4 ay prothonotary "I r"l C3 BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff Vs. DANIELLE LYNN DUM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 91601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff BANKERS TRUST COMPANY OF : IN THE COURT OF COMMON PLEAS CALIFORNIA, N.A. AS TRUSTEE : CUMBERLAND COUNTY, PENNSYLVANIA OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff NO 99- 7.71 C?" t." VS. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE DANIELLE LYNN DUM Defendant C 0 M P L A I N T 1. Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, is a corporation with a servicing agent of Alliance Mortgage Company, with an adress of 8100 Nations Way, Jacksonville, Florida 32256. 2. Defendant, DANIELLE LYNN DUM, is an adult individual whose last known address is 537 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025. 3• On or about February 2, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $53,350.00 payable to MELLON BANK, N.A. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possessopn of Defendants. Plaintiff alos avers that the within Mortgage foreclosure complaint is based upon the Mortgage ans that attachment of a complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to BANKERS TRUST COMPANY OF CALIFORNIA, N.A. TRUSTEE OF MELLON MORTGAEG CRA MORTGAGE LOAN TRUST 1966-A and recorded in the aforesaid County in Mortgage Book 582, Page 113 on July 20, 1998. Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 860 VALLEY STREET, ENOLA, PENNSYLVANIA 17025 and is more particulary described in Exhibit "All attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 51,261.88 (b) Interest at $9.12 per day from 611199 to 12/1/99 (based on contract rate of 6.500%) 1,668.96 (c) Accumulated Late Charges 67.44 (d) Late charges at $16.86 per month for 6 months 101.16 (e) Escrow Credit 12.48 (f) 5°6 Attorney's Commission 2,633.09 $ 55,720.05 *Together with interest at the per diem rate noted in (b) above after December 1, 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennslyvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.50016 ($16.86 per diem), together with other charges and costs including escrow advances incidental thereto to the date of sheriff's Sale and for foreclosure and sale of the property within described. PURCELL R ALLER By Leo P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 POLICY NO. D148674CP EXHIBIT A ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows according to survey of Ernest J. Walker, Professional Engineer, dated December 5, 1968, to wit: BEGINNING at a point in the center line of Legislative Route 21051, now known as Valley Road, said point being 1690 feet in an Easterly direction from the intersection of the center line of Legislative Route 21051, now known as Valley Road and the center line of Township Road 660, said point being also on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said line of Legislative Route 21051, now known as Valley Road, North 71 degrees 30 minutes East 78.4 feet to a point on line of lands now or late of John Bressler; thence along lands now or late of John Bressler, South 18 degrees 30 minutes East 299 feet to a point on line of lands now or late of John C. Roth; thence along said lands South 71 degrees 30 minutes West 78.4 feet to a point on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said lands North 18 degrees 30 minutes West 299 feet to a point, the Place of BEGINNING. HAVING thereon erected a one story frame dwelling. BEING the same premises which Michael R. Cunningham and Shelley Renee Cunningham, his wife and Allean Welker, Trustee and Robert L. Welker, II, Trustee and Executor of the Estate of Rebecca Jane Cunningham by their Deed dated February 12, 1996 and intended to be recorded immediately prior hereto, granted and conveyed unto Danielle Lynn Dum, MORTGAGOR HEREIN. of Ponnsylvania SS ' • Oty of Cumberland } e,-dad in the office for the recording of D"ds end mbarlond Coun .?? (fuck 1J? Vol.-Peg . PA .:U". my hand d 1 of oHi ( ?? 1gCi de Recor et CLTIC Form E80 Page VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE, and that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 19, 1999 Leon P. Haller, Esquire OFFI 'r. nr 7i1i j? No 23 q 02 fll '99 ,., ? L „a?ifh. r CASE NO: 1999-07122 P SHERIFF'S RETURN - NOT FOUND COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERS TRUST COMPANY OF CALIF VS. DUM DANIELLE LYNN R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DUM DANIELLE LYNN but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND , as to the within named defendant DUM DANIELLE LYNN MORTGAGED PROPERTY IS VACANT, DEFT. NO LONGER RESIDES AT ADDRESS STATED. NOT FOUND AS PER ATTY. Sheriff's Costs: So answ s: Docketing 18.00 Service 9.92 Not Found Return 5.00 tea` Surcharge 8.00 F? oi?i maw it ne,-` eri $?? PU CELL RUG & HALLER Sworn and subscribed to before me this I,/ 'x-f day o? 10 -;2&lro A.D. -fj""Fro ono ary'P 7IN 1996-A 7/aZ1 Cu, C Tc Plaintiff NO. q?- VS. : CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE DANIELLE LYNN DUM Defendant THIS LAW FIRM IS A DEBT TO COLLECT A DEBT OWED OBTAINED FROM YOU WILL COLLECTING THE DEBT. COLLECTOR AND WE ARE ATTEMPTING TO OUR CLIENT. ANY INFORMATION BE USED FOR THE PURPOSE OF N 0 T I C E You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 17013 8 Irvine Row, Carlisle, PA 717-243-9400 A V I S O LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS USTED, 0 SO ABOGADO,,DR GISTRE CON LAP. DCO TE EN FORMA ESCR TA,, EL PUNTOCDESVISTA E USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, BE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association Carlisle, PA 17013 717-240-6200 Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013 717-243-9400 TRUE COPY FROM RECORD in Tastlaw" whereof, t We unto set AN hand and the seal at s3id Court at Gartt he, Pa. Thls z3.c.z- day Ot`7?o,.r-1Q.4Q ' Prothonotary r BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff ? y BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CPA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 6I /- 7/1 2 Ctu:! CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE C O M P L A I N T 1. Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, is a corporation with a servicing agent of Alliance Mortgage Company, with an adress of 8100 Nations Way, Jacksonville, Florida 32256. 2. Defendant, DANIELLE LYNN DUM, is an adult individual whose last known address is 537 NORTH ENOLA DRIVE, ENOLA, PENNSYLVANIA 17025. 3. On or about February 2, 1996, the said Defendant executed and delivered a Mortgage Note in the sum of $53,350.00 payable to MELLON BANK, N.A. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possessopn of Defendants. Plaintiff alos avers that the within Mortgage foreclosure complaint is based upon the Mortgage ans that attachment of a complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth conveying to original mortgagee the subject premises. The Mortgage was subsequently assigned to BANKERS TRUST COMPANY OF CALIFORNIA, N.A. TRUSTEE OF MELLON MORTGAEG CRA MORTGAGE LOAN TRUST 1966-A and recorded in the aforesaid County in Mortgage Book 582, Page 113 on July 20, 1998. Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 860 VALLEY STREET, ENOLA, PENNSYLVANIA 17025 and is more particulary described in Exhibit "A" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 51,261.88 (b) Interest at $9.12 per day from 611199 to 12/1/99 (based on contract rate of 6.500%) 1,668.96 (c) Accumulated Late Charges 67.44 (d) Late charges at $16.86 per month for 6 months 101.16 (e) Escrow credit 12.48 (f) 5; Attorney's commission 2,633.09 $ 55,720.05 *Together with interest at the per diem rate noted in (b) above after December 1, 1999 and other charges and costs to date of Sheriff's Sale. j ?r The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennslyvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.500% ($16.86 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. PURCELL,i-CRTW &/43ALLER By // // Leol? P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 POLICY NO. D148674CP EXHIBIT A ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows according to survey of Ernest J. Walker, Professional Engineer, dated December 5, 1958, to wit: BEGINNING at a point in the center line of Legislative Route 21051, now known as Valley Road, said point being 1690 feet in an Easterly direction from the intersection of the center line of Legislative Route 21051, now known as Valley Road and the center line of Township Road 660, said point being also on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said line of Legislative Route 21051, now known as Valley Road, North 71 degrees 30 minutes East 78.4 feet to a point on line of lands now or late of John Bressler; thence along lands now or late of John Bressler, South 18 degrees 30 minutes East 299 feet to a point on line of lands now or late of John C. Roth; thence along said lands South 71 degrees 30 minutes West 78.4 feet to a point on line of lands now or late of Andrew D. and Roxie B. Lightner; thence along said lands North 18 degrees 30 minutes West 299 feet to a point, the Place of BEGINNING. HAVING thereon erected a one story frame dwelling. BEING the same premises which Michael R. Cunningham and Shelley Renee Cunningham, his wife and Allean Welker, Trustee and Robert L. Welker, II, Trustee and Executor of the Estate of Rebecca Jane Cunningham by their Deed dated February 12, 1996 and intended to be recorded immediately prior hereto, granted and conveyed unto Danielle Lynn Dum, MORTGAGOR HEREIN. of Pennsylvania SS .-!nty of Cumberland :o•dod in the office for the recording of Dtwds .jndLGAmberlend Coun .?? Vu .L2.VoT'=Pap Q my hand d I of oHi f ?? - I •': :rfic , PA da 19 Recor er CLTIC Form 1380 Page --....4 gnQ,.A. Z7 VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, BANKERS TRUST COMPANY OF CALIFORNIA, N.A. AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE, and that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 19, 1999 Leon P. Haller, Esquire pFFltr f,c 7.i` SIIi:i7i:yF rCf' f ov Z3 Ll 02 F11 139 Vj?y ? I it? BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7122 CIVIL TERM IN MORTGAGE FORECLOSURE ACCEPTANCE OF SERVICE I, Danielle Lynn Dum, hereby accept service of the Complaint in the above captioned action. ?U Aq gm Dum Danielle Lynn Dum Dated: 10 1 0?000 c ate. L? t CJ N - J C,r y - Ci ? r ,T ?U W L. G? ? C ? O :J BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff Vs. DANIELLE LYNN DUM Defendant t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7122 CIVIL TERM IN MORTGAGE FORECLOSURE O R D E R AND NOW, this I O'T' day of G / i^'/,,?? 2000, upon consideration of the within Stipulation of parties attached thereto, IT IS HEREBY ORDERED that judgment in mortgage foreclosure in rem be entered in favor of Plaintiff, Bankers Trust Company of California, N.A., as Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A, and against Defendant, Danielle Lynn Dum in the amount of $55,720.05, together with interest at the rate of $9.12 per day from December 1, 1999, together with any additional advances for taxes and insurance. BY ca -0q -0 0 A9S llr I? ? a-oo RXJ Ck # /3y/? 0900 ?- I/ A.tz.+ 9as?a BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Plaintiff VS. DANIELLE LYNN DUM Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7122 CIVIL TERM IN MORTGAGE FORECLOSURE S T I P U L,A T I 0 N IT IS HEREBY stipulated and agreed by and between Leon P. Haller, Attorney for Plaintiff, Bankers Trust Company of California, N.A., as Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A, and Defendant, Danielle Lynn Dum, that judgment in mortgage foreclosure in rem be entered in favor of Plaintiff, Bankers Trust Company of California, N.A., as Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A, and against Defendant, Danielle Lynn Dum in the amount of $55,720.05, together with interest at the rate of $9.12 per day from December 1, 1999, together with any additional advances for taxes and insurance. Le n P. Haller, Attorn y for Plaintiff, Bankers Trust Company of California, N.A., as Trustee for Mellon Mortgage CRA Mortgage Loan Trust 1996-A Mc. VYVn JO/,(/)2, Danielle Lynn Dum Dated: pill ? 10 /.20U0 I BANKERS TRUST COMPANY OF IN THE COURT OF COMMON PLEAS CALIFORNIA, N.A., AS TRUSTEE OF CUMBERLAND COUNTY, PENNSYLVANIA MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, CIVIL ACTION - LAW PLAINTIFF VS. NO. 1999 - 7122 DANIELLE LYNN DUM, DEFENDANT IN MORTGAGE FORECLOSURE RELIEF FROM STAY CONSENT y? UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: DANIELLE L. BEERS Debtor BAKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A Movant VS. DANIELLE L. BEERS a/k/a DANIELLE LYNN DUM and MARKIAN R. SLOBODIAN, Trustee BANKRUPTCY NO. 1-99-05201 CHAPTER 7 FIL60 f ll.t u;?,, ?? TI",rc A.M. P.M DEC 17 1999 1r" aro?r A kof the Bznkmp;c? . :n lCrk I Respondents O R D E R ??yy1^?0? AND NOW, to wit, this ? day of k -k upon consideration of the Motion of Bankers Trust Company of California, N.A., as Trustee of Mellon Mortgage CPA Mortgage Loan Trust 1996-A, to Obtain Relief from Stay, the parties having consented thereto, the Motion is hereby granted and the automatic stay is terminated as to the Movant relative to property situate at 860 Valley Street, Enola, Pennsylvania 17025. BY THE COURT: 14.N0bul $j V_Yaodside Robert J. Woodside Bankruptcy Judge _C Lr) C ?f_:? C_ C) C.- 7 J (13 co aw UJ r u O CJ y5; 11 ??et•1111111 mmvn? BANKERS TRUST COMPANY OF IN THE COURT OF COMMON PLEAS CALIFORNIA, N.A., AS TRUSTEE OF CUMBERLAND COUNTY, PENNSYLVANIA MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, CIVIL ACTION - LAW PLAINTIFF VS. NO. 1999 - 7122 DANIELLE LYNN DUM, DEFENDANT IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant DANIEL LYNN DUM pursuant to the Stipulation of judgment dated February 1, 2000 as follows: Amount of Judgment $55,720.05** **Additional interest of $9.12 per diem from 12/1/99 to sale date and any additional advances for taxes and insurance. PURCELL, KRUG & By Leon P. aller PA I.D. 415700 1719 North Fr Ant Street Harrisburg, A 17102 (717) 234-4178 BR0I.IEV.IKFlDOCS',CUI.IOERLA CUM P BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, PLAINTIFF VS. DANIELLE LYNN DUM, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 - 7122 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237 I hereby certify that on MARCH G, 2000 I served a true and correct copy of the Praecipe to enter judgment required by Pa. R.C.P. 237 on the Defendant(s) in this matter by regular first class mail, postage prepaid (copy attached), addressed as follows: Danielle Lynn Dum a/k/a Danielle L. Beers 107 Hallmark House Hershey, PA 17033 Dated: March 6, 2000 By /, Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 a l? V1 ? r O p p v? J V T, ?pJ Lo ` UCi 5t `-?'-?3 ue ?. ALU O U ?T7 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: BANTERS TRUST COdPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE IRAN TRUST 1996-A, Plaintiff Vs. DANIELLE LYNN DUM, DEFENDANT ( ) Confessed Judgment ( XX) Other IN MORTGAGE FORECLOSURE 1999 7122 File No. / Amount Due $ 55,720.05 111R/1/yy $9.12 $ 1,714.56 Late charges $16.86 $ 84.30 FCscraw Deficit $ 1,500.00 osts Total $59,018.91 TO THE PROTHONOTARY OF THE SAID COURT: plus costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County. for debt, interest and costs, upon the following described property of the defendant(s) Real estate: 860 Valley Street, Enola, PA IN MORTGAGE FORECLOSURE PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) REAL ESTATE: 860 Valley Street, Enola, PA REAL OWNER: Danielle Lynn Dum (now by marriage Danielle Lynn Beers aA/a and all other property of the defendant(s) in the possession, custody or congooll off ees2id Rrrniis?ee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real es of the defendant(s) described in the attached exhibit. v NIAR Date ZKS Signature: Print Name: Leon P Haller Esquire Purcell, Krug & Haller Address: 1719 N zth F + G* t Harrisburg, PA 17102 Attorney for: Telephone: Supreme Court ID No.: PLAINTIFF 717-234-4178 #15700 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR TRACT OF LAND situate in the East Pennsbof0 Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, according to a to survey of Ernest J. Walker, Professional Engineer, dated December 5, 1968, BEGINNING at a point in the center line of Legislative Route 21051. now known as Valley Road, said point being 1,690 feet in an easterly direction from the intersection of the center line of Legislative Route 21651, now known as Valley Road and the center line of Township Road 660, said point being also on tine of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said line of Legislative Route 21051, now known as Valley Road, North 71 degrees, 30 minutes, East 78.4 feet to a point on line of lands now or formerly of John Bressler; THENCE, along lands now or formerly of John Bressler, South 18 degrees, 30 minutes, East 299 feet to a point on lands now or formerly of John C. Roth; THENCE, along said lands, South 71 degrees, 30 minutes West 78.4 feet to a point on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said lands, North 18 degrees, 30 minutes West 299 feet to a point, the place of BEGINNING. HAVING ERECTED THEREON A DWELLING KNOWN AS 860 VALLEY STREET, ENOLA, PA. deed BEING THE SAME PRE 9196 and Hrecorded in Cumberland CountylDeed book dated February 12, 134 Page 1177 granted and conveyed unto Danielle Lynn Dum. EBEESOLD AS THE RS A/K/A DANIELLE TL.OBEERS) ON JUDGMENT NO. 1999 77122 LYNN . Assessment: 09-12-2992-038 LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR TRACT OF LAND situate in the East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, Professional Engineer, dated December 5, 1968, to wit: BEGINNING at a point in the center line of Legislative Route 21051, now known as Valley Road, said point being 1 ,690 feet in an easterly direction from the intersection of the center line of Legislative Route 21651, now known as Valley Road and the center line of Township Road 660, said point being also on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said line of Legislative Route 21051, now known as Valley Road, North 71 degrees, 30 minutes, East 78.4 feet to a point on line of lands now or formerly of John Bressler; THENCE, along lands now or formerly of John Bressler, South 18 degrees, 30 minutes, East 299 feet to a point on lands now or formerly of John C. Roth; THENCE, along said lands, South 71 degrees, 30 minutes West 78.4 feet to a point on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said lands, North 18 degrees, 30 minutes West 299 feet to a point, the piece of BEGINNING. HAVING ERECTED THEREON A DWELLING KNOWN AS 860 VALLEY STREET, ENOLA, PA. BEING THE SAME PREMISES WHICH Michael Cunningham et al by deed dated February 12, 1996 and recorded in Cumberland County Deed book 134 Page 1177 granted and conveyed unto Danielle Lynn Dum. TO BE SOLD AS THE PROPERTY OF DANIELLE LYNN DUM (A/K/A DANIELLE LYNN BEERS A/K/A DANIELLE L. BEERS) ON JUDGMENT NO. 1999 7122. Assessment: 09-12-2992-038 Cil 97) 0 o U ? BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, PLAINTIFF VS. DANIELLE LYNN DUM, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 - 7122 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.RX.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 860 VALLEY STREET, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) : Danielle Lynn Dum a/k/a Danielle L. Beers 107 Hallmark House Hershey, PA 17033 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address Plaintiff has knowledge who may be affected by the sale: of every other person of whom the has any interest in the property which TENANTS IF ANY ... DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made_ subject to the penalties of 18 PA C.S. Section 4904 relating unsworn falsification to authorities. DATE: March 6, 2000 Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 In s...- l nn/,j? ??_? BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MCRTGAGE CRA MORTGAGE LOAN TRUST 1995-A, VJ. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 1999 - 7122 DANIELLE LYNN CUM, DEFERDA-NT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the S^eriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 7, 2000 TIME: !0:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 860 VALLEY STREET ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 - 7122 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property IAHOP.IE11.IKPDOCS'CUNIBERLV DUkI NOS DANIELLE LYNN DUM A/K/A DANIELLE L. BEERS A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or go-:ernmental or corporate entities or agencies being entitled to receive part the proceeds of the =a-.e received and to be di=bursed by t"e Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes,' Sri'- be filed by the Sheriff of this County thirty (30) d--,-s after the sale and distribution of the proceeds of sale i^ accordance with this sc edule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days'of the-date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common =leas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used agains_ vou. 2. After the Sheriff's Sale you may file a Cetition with the Court of Common Pleas of the within Count*,- to set aside the sale for a grossly inadequate price or for o.^er proper cause. This petition. MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising z:--- legal issues or rights mention=_d in the preceding paragraphs - t be presented to the Court of Common Pleas of the within Cour.=v. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from-the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A coon of the Writ of Execution is attached hereto. PURCELL, KR'-'G & LLkLLER Attorneys for Plaintiff 1719 North :ront Street Harrisburg, PA 17102 (717) 234-4178 'F. ? -- LEGAL DESCRTnr70?1 ! T HAT CERTAIN LOT OR TRACT OF LAND sauata in the East Pennsoorc Townsnip, Cumberland County, Pennsylvania, more particularly bounded and descnced as fcl!cws, according to a survey of Ernest J Walker, Professional Eneineer, dated December 5, 1968, to wit: BEGINNING at a point in the center line of Legislative Route 2105', no:v xnc .- as Valley Rcad, said point being 1,E90 feet in an easterly direction from the intersection of the center line of Legislative Route 211.551, now known as Valley Road and :he center line of Township Road 660, said point being also on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said 'ire of Legislative Route 21,051, now known as Valley Rcad, Norm 71 degrees, 3C :^inutes, East 78.4 feet to a point on line of lands now or formerly of John Bressler; T H E N C E, along lands now or formerly of John Bressler. South 18 degrees, 30 minutes, East 299 feet to a point on lands now or formerly of John C. Roth; T H E N C E, along said lands, South 71 degrees, 30 minutes West 78.4 feet to a point on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, a;ong said lands. North 18 degrees, 30 minutes West 299 feet to a point, the place of BEGINNING. HAVING ERECTED THEREON A DWELLING KNOWN AS 860 VALLEY STREET, ENOLA, PA. BEING THE SAME PREMISES WHICH Michael Cunningham et al by deed dated February 12, 1996 and recorded in Cumberland County Deed book 134 Page 1177 granted and conveyed unto Danielle Lvnn Dum. TO BE SOLD AS THE PROPERTY OF DANIELLE LYNN DUM (A/K/A DANIELLE LYNN BEERS A/K/A DANIELLE L. BEERS) ON JUDGMENT NO. 1999 7122. Assessment: 09-12-2992-038 ti H IJJC3 ?A Y L•? T W U O U BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, PLAINTIFF VS. DANIELLE LYNN DUM, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 - 7122 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Danielle Lynn Dum a/k/a Danielle L. Beers 107 Hallmark House Hershey, PA 17033 East Pennsboro Township Municipal Authority 98S. Enola Drive Enola, PA 17025 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS OFFICE CUMBERLAND COLTNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL7 KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 JOSEPH NISSLEY 11910.1964) JOHN W. PURCEI.I. TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 ANTHONY DiSANTO ;R OF COUNSEL LEON RD LEON r. nA LLIU?Ja JOHN W. PORCEI.I. JR. HERSHEY BRIAN 1. TYI.ER 1099 GOVERNOR ROAD JILL N. WINERA (717) 533-3936 NOTICE TO: Danielle Lynn Dum a/k/a East P$1IL9bOIU Township Danielle L. Beers µ Cipal. Authority 107 Hallmark House Hershey, PA 17033 98 S. Enola Drive Enola, PA 17025 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold ainst the said real estate will be divested by the sale and tha mu have an opportunity to protect your interest, if any, e'ng notified of said Sheriff's Sale. ? By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRA MORTGAGE LOAN TRUST 1996-A, PLAINTIFF VS. DANIELLE LYNN DUM, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 - 7122 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 7, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 860 VALLEY STREET ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 - 7122 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property 11MOMERAWDOCS' CUMBER ATUM NOS , . y ?t is: DANIELLE LYNN DUM A/K/A DANIELLE L. BEERS A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 Association 17013 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. Court of Common Pleas e of ftheSwithin uComay file a unty to sete aside thehsale for a grossly inadequate price or for other proper cause. This Petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR TRACT OF LAND situate in the East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, Professional Engineer, dated December 5, 1968, to wit: BEGINNING at a point in the center line of Legislative Route 21051, now known as Valley Road, said point being 1,690 feet in an easterly direction from the intersection of the center line of Legislative Route 21651, now known as Valley Road and the center line of Township Road 660, said point being also on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said line of Legislative Route 21051, now known as Valley Road, North 71 degrees, 30 minutes, East 78.4 feet to a point on line of lands now or formerly of John Bressler; T H EN CE, along lands now or formerly of John Bressler, South 18 degrees. 30 minutes, East 299 feet to a point on lands now or formerly of John C. Roth; TH E N C E, along said lands. South 71 degrees, 30 minutes West 78.4 feet to a point on line of lands now or formerly of Andrew D. and Roxie B. Lightner; THENCE, along said lands, North 18 degrees, 30 minutes West 299 feet to a point, the place of BEGINNING. HAVING ERECTED THEREON A DWELLING KNOWN AS 860 VALLEY STREET, ENOLA, PA. BEING THE SAME PREMISES WHICH Michael Cunningham et al by deed dated February 12, 1996 and recorded in Cumberland County Deed book 134 Page 1177 granted and conveyed unto Danielle Lynn Dum. TO BE SOLD AS THE PROPERTY OF DANIELLE LYNN DUM (A/K/A DANIELLE LYNN BEERS A/K/A DANIELLE L. BEERS) ON JUDGMENT NO. 1999 7122. Assessment: 09-12-2992-038 Re: Alliance/Bankers Trust v. Dum Cumberland County Sale 6/7/00 U. S. POSTAL SERVICE CERTIFICATE OF NAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Danielle Lynn Dum a/k/a Danielle L. Beers 107 Hallmark House Hershey, PA 17033 1 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 Postage: Re: ALLIANCE VS. DUM, Danielle Lynn Cumberland County Sale June 7, 2000 U. S. POSTAL SERVICE Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: East Pennsboro Township Municipal Authority 98 S. Enola Drive Enola, PA 17025 LPs-A ' / !m 11-'.- ? Cl) i ) l' i V l_) U STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND Robert P Ziegler ---------------------------------- SS. -------------------------------------- Recorderof Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ________________ f Bankers Tr Co of California N A Tr for Mellon Mtg CRAi.41--,jfigjjnTr 1996- ------------------------------------------------------------------------------------Mpg 5th the same having bcen sold to said grantee on the _______________________________________________ day of --- ----------- ndo and by virtue of a writ______________ July ------------------------------ A D 1x2000 - -- Execution 8th -------------------------issued on the ------------------------------------- day of ___ March --------------- A D., 1§x2000out of the Court of Comman Pleas of said County as of -------- ---- ---Civil---------------------------------------------------------------------- Tenn, 19--- --99 7122 Bankers Trust Co of Cal N A Tr for Mellon Number --------------- at the suit of iltg CR7Y ittg-t6att-Tr -1?J9S= ----------------------- ----------------------------------- against ----- Etjnielle Lynn Dum aka DAn.ielle L ,gnBeers -- Aka "t)an-i--e7le-li" Seers duly recorded in Sheriffs Deed Book No.___ 226____, Page ___-?8 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ------- --------------- A. D., f`===Y ?a: rder oI Deeds Recorder of fkbt, Dimberhnd fbuary, fift ?A Mr fktttrnom Dom ft riot fthnaey of At 2m Bankers Trust Company of California In the Court of Common Pleas of N.A. As Trustee of Mellon Mortgage CRA Cumberland County, Pennsylvania Mortgage Loan Trust 1996-A No. 99-7122 Civil -vs- Danielle Lynn Dum Harold J. Weary, Deputy Sheriff who being duly sworn according to law, says on March 29, 2000 at 6:27 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Danielle Lynn Dum located at 860 Valley Street, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the defendant to wit: Danielle Lynn Dum a/k/a Beers by Certified Mail Return Receipt Requested, Restricted Delivery Deliver To Addressee Only to 107 Hallmark House, Hershey. This letter was mailed under the date of March 28, 2000 and returned to the Sheriffs Office on April 14, 2000 with reason checked UNCLAIMED. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he made diligent search and inquiry for the within named defendant to wit: Danielle Lynn Dum a/k/a Beers, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the above Real Estate Writ Notice Poster and Description according to law. Dauphin County Return: Now April 5, 2000 at 11:15 am served the within Real Estate Writ Notice Poster and Description upon Danielle L Dum aka Danielle L Beers by personally handing to John Narkin- person in charge 1 true and attested copy of the original Real Estate Writ Notice Poster and Description and making known to him the contents thereof at 107 Hallmark House, Hershey, PA Served by Nan A. Granzow Deputy Sheriff Dauphin County. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant to wit: Danielle Lynn Dum aka Beers by first class mail to 107 Hallmark House, Hershey, Pennsylvania. This letter was mailed under the date of April 17,2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on July 5, 2000 at 10:00 o'clock A.M. EDST and sold the same for the sum of $ 1.00 to Attorney Leon P. Haller for Bankers Trust Company of California, N.A. As Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A. It being the highest bid and best price quoted for the same Bankers Trust Company of California, N.A. as Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A of 8120 Nations Way, Building 100, Jacksonville, FL being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 927.93 it being costs. Sheriffs Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Postpone sale Out of County Dauphin County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed Swom and Subscribed To Before Me This 7 tr_ Day of QL 2000, A.D. n._ kgdq• Pr thonotary 30.00 18.06 15.00 15.00 30.00 10.00 .50 1.00 9.92 6.80 15.00 30.00 20.00 9.00 30.50 358.40 252.45 24.80 25.00 26.50 $ 927.93 Pd by Atty 7/26/00 S ?aasN ? R. Thomas Kline, Sheriff ByV,71e/ti .!. e Real Estate Deputy uN ? 1' c-re. ??aoG ('iw. g, S54 BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CRP. MORTGAGE LOAN TRUST 1996-A, PLAINTIFF VS. DANIELLE LYNN DUM, DEFENDANT COPY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1999 - 7122 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property. located at 860 VALLEY STREET, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) : Danielle Lynn Dum a/k/a Danielle L. Beers 107 Hallmark House Hershey, PA 17033 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the F::_ save: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY .. DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HIGH AND HANOVER STREETS CARLISLE PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 6, 2000 a :? ;!!t OFF ,-v rr+" N!aa ? ?I u? Pil'?? A BANKERS TRUST COMPANY OF CALIFORNIA, N.A., AS TRUSTEE OF MELLON MORTGAGE CPA NDRTGAGE LOA-N; TRUST 1996-A, PLA:NT_c F , vs. DA`:=ELL= LYNN DUM, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1993 - 7122 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: he_ Tha= the Sheriff's Sale of Real Property (real estate) will be ?. DATE: WEDNESDAY, JUNE 7, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 860 VALLEY STREET ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 1999 - 7122 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property LIHOME LIRROOCSICUMBER1 DIM NOS ._0 is: DANIELLE LYNN DUM A/K/A DANIELLE L. BEERS A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental corporate entities or agencies being entitled to receive cart the proceeds of the sale received and to be disbursed by to Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) :;ill be filed by the Sheriff of this County thirty (30) days after the sale •ind distribution c-- the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days'of the, date it is filed. Information about the Schedule of Distribution may be obtained from the Sheri" of t^e Court of Common Pleas of the within County at tiie Courthc•.:se address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment T against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sher'iff's Sale you may file a petition with the Court of Common Pleas of the within Count to set aside the sale for a gross!}- inadeouate price or for other proper cause. :h15 petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceaing paragraphs must be presented to the court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition.. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & FALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 =GA_ DESCRIPTION A?L THAT C-n7.41N LOT OR TRACT OF LAND situate in :ne East Penrscorc Towrsnip, Cumberland County, Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J Walker, Professional Engireer, dated December 5, 1958, to wit: BEGINNING at a point in the center line of Legislative Route 2105' now: =ncw:r as Valley Road, said point being 1,690 feet in an easterly direction from the intersection of the center line of Legislative Route 211051, now known as Valley Road and :ne center line of Township Road 660, said point being also on line of lar„ s now, or formerly of Andrew D. and Roxie B. Lightner; T H E N C E, along said line or agislative Route 21051, now known as Valley Road, Ncr,r. 71, degrees, 30 minutes. East 78.4 feet to a point on lire of lands now or formerly cf John Bressler: THENCE, along lands now or formerly of John Bressler, South 18 degrees. 30 minutes, East 299 feet to a point on lands now or formerly of John C. Roth; THENCE, along said lands, South 71 degrees, 30 minutes West 78.4 feet to a point on line of lands now cr formerly of Andrew D. and Roxie B. Lightner, THENCE, along said lands, North 18 degrees, 30 minutes West 299 feet to a point, the place or BEGINNING. HAVING ERECTED THEREON A DWELLING KNOWN AS 860 VALLEY STREET, ENOLA, PA. BEING THE S.BuME PREMISES WHICH Michael Cunningham et al by deed dated February 12, 1996 and recorded in Cumberland County Deed book 134 Page 1177 granted and conveyed unto Danielle Lynn Dum. TO BE SOLD AS THE PROPERTY OF DANIELLE LYNN DUM (A/K/A DANIELLE LYNN BEERS A/K/A DANIELLE L. BEERS) ON JUDGMENT NO. 1999 7122. Assessment: 09-12-2992-038 ..r.. -----.. HAR J q of "Il '00 r ; , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-7122 CIVIL X9 TERM CIVIL ACTION - LAW TO THE SHERIFF OF CLnnberl and COUNTY: To satisfy the debt, interest and costs due Bankers Trust Company of California N .as Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A PLAINTIFF(S) from Danielle Lynn Dum 107 Hallmark House Hershey. Pa 17033 (now merriag_ Danielle Lvnn Beers a/k/a Danielle L Beers) (1) You are directed to levy upon the property of the defendant(s) and to Real Estate 860 Valley S-treet- Engle. Ea_ 17025 .1 11 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S)-as follows: and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $ 55 720.05 L.L. S0_50 vWist12/1/99 to16/r7?0& Due Prothy $1 nn Atty's Comm Afty Paid 112.92 Plaintiff Paid Date: March 8, 2000 Other Costs Late Charges $16.86 $84.30 EncMd, Deficit S 1.500.00 Curtis R. Lon n,,.,,- Prothonotary, Civil Division by: P, 11LJJ / Deputy REQUESTING PARTY: Purcell, I( 11g & Haller Name Leon P Haller Esquire Address: 1719 North Frnn St'rppt' Harrisburg, Pa. 17102 Attorney for: Plaintiff Telephone: 717-234-4178 Supreme Court ID No. 15700 REAL LS ATE SALE: NO.sI- un / % a,-o the sneriff levied upon the defendants Interest in the real property situated in ra?Z =QUO 9, Cumberland County, Pa., known and numbered as: a and more fuit; :jascrlbed on Exhibit "A" filed Witn this writ and by this reference incorporated herein. nate:u _ D i y, a dry ffy. 00, Ili co ? 6 "G 1 H 65D n`iJ $1000.00 Advance Costs Paid 3/14/00 Assessed Valuation $ 5,520 Real Estate No 52 Atty Leon P. Haller Writ No. 1999-7122 Civil Bankers Trust Company of California, N.A. As Trustee of Mellon Mortgage CRA Mortgage Loan Trust 1996-A -vs- Danielle Lynn Dum 860 Valley Street Enola, PA Real Debt $ 55,720.05 Interest $ 9.12 12/2/99 to 6/7/00 1,714.56 Atty's Pees Atty Writ Costs 112.92 Escrow 1.500.00 Late Charges 84.30 Sheriff's Costs Docketing 30.00 Poundage 18.06 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 9.92 Certified mail 6.80 Levy 15.00 Surcharge 20.00 Postpone Sale Out of County 9.00 Dauphin County 30.50 Legal Search Law Journal 358.40 Patriot News 252.45 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 TAXES Sewer & Sanitation 593.00 t A THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication tinder8ct No 587, neeroued Mau 16. 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow being duly sworn according to low, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 2nd, 9th and 16th day(s) of May 2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. r I 111 n A ) X\ n M _ PUBLICATION COPY SALE#52 Notarial Seat L. Russell, Nola A.D. My Com"ssleq Expires June 6; 2002 1NO:fARY PUBLIC Member, Pennsylvania Assooialio"l`NbitAission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. '17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 250.95 Probating same Notary Fee(s) $ 1.50 Total $ 252.45 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. THE PATRIOT-NEWS CO. By ............................. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 28, MAY 5, 12, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 62 Writ No. 99-7122 Civil Bankers Trust Company of California N.A.. As Trustee of Mellon Mortgage CPA Mortgage Loan Trust 1996-A VS. Danielle Lynn Dum Atty.: Leon P. Haller LEGAL DESCRIPTION ALL THAT CERTAIN LOT OR TRACT OF LAND situate in the East Pennsbom Township. Cumberland County. Pennsylvania, more particu- larly bounded and described as fol- lows. according to a survey of Ernest J. Walker. Professional Engineer. dated December 5. 1968, to wit: BEGINNING at a point in the cen. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 LOMB E. SNYDER, Notary Public Ca rude aoro, Cumbodond County, PA my Commisur Exp r" Momh 5, 2001