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HomeMy WebLinkAbout03-3561FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 STEVE T. ROBISON A/K/A STEVEN T. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY LISA M. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 77039 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TW~ENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. File #: 77039 Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, 1NC. 711 HIGH STREET DES MOINES, IA 50392-0780 The name(s) and last known address(es) of the Defendant(s) are: STEVE T. ROBISON AflK/A STEVEN T. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 LISA M. ROBISON ! 19 DILLSBURG, PA 17019 NEW CUMBERLAND, PA 17170 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 05/31/2002 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to WAYPOINT BANK which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1760, Page 2922. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 due 05/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File#: 77039 The following amounts are due on the mortgage: Principal Balance Interest 04/01/2003 through 07/21/2003 (Per Diem $12.95) Attorney's Fees Cumulative Late Charges 05/31/2002 to 07/21/2003 Cost of Suit and Title Search Subtotal $65,173.32 1,450.40 1,225.00 57.39 $ 550.00 $ 68,456.11 Escrow Credit - 110.22 Deficit 0.00 Subtotal $- 110.22 TOTAL $ 68,345.89 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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. This action does not come under Act 91 of 1983 because the mortgage premises is not the principal residence of Defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 68,345.89, together with interest from 07/21/2003 at the rate of $12.95 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. FEDERMAN AND PHEL~N~P' By: /s/Francis S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 77039 All ' (44] deq~eos ~o~y-~ve {45) m~nu~es wes~ one hundred PREHISES BEING: 424 WATER SlqIEET. VERIFICATION TRACY MARTIN, hereby states that she is MANAGER OF FORECLOSURE of PRINCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 Plaintiff, STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DIVISION NO. 03-3561 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against STEVE T. ROBISON A/K/A STEVEN T. ROBISON and LISA M. ROBISON, 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 PlaimilYs damages as follows: As set forth in Complaint Interest from 7/22/03 to 9/25/03 TOTAL $68, 345.89 $854.70 $69,200.59 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY FEDERMAN .~ND PHELAN, LLP -FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA,. SUITE 1400 PHILADELPHIA, PA 19103 (?l s) s6~-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC Plaintiff Vs. STEVE T. ROBISON LISA M. ROBISON Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CML DMSION : CUMBERLAND COUNTY : NO. 03-3561 TO: STEVE T. ROBISON 424 WATER STREET NEW CUMBERLAND, PA 17170 DATE OF NOTICE: SEPTEMIIER 10, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN AI-fI.ZMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.Il= YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN Ai-itrMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH iNFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP -FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL[NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (~1 ~;) ~63-7000 PRINCIPAL RESIDENTIAL MORTGAGE, [NC Plaintiff Vs. STEVE T. ROBISON LISA M. ROBISON Defenda~xts ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-3561 TO: LISA M. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 DATE OF NOTICE: SEPTF, MBER 10, 2003 THIS FIRM IS A DEBT COLLECTOR Af-i'IzMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATYEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HERE[N, AND ANY INFORMATION OBTAINED FROM YOU 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 AS ENFORCEMENT OF 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 fRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. I-IALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (915) 56'~-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC Plaintiff Vs. STEVE T. ROBISON LISA M. ROBISON Defendants : COURT OF COMMON PLEAS : CML DMSION : CUMBERLAND COUN'I~ : NO. 03-3561 TO: STEVE T. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 DATE OF NOTICE: SEPTEMBER 10, 200'; THIS FIRM IS A DEBT COLLECTOR ArltzIvipT1NG TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.I~ YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITtrMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE tN 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ' FR~I~K FEDERIV~N, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff 'FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL[NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (915) ~63-7000 PRINCIPAL RESIDENTIAL MORTGAGE, [NC Plaintiff Vs. STEVE T. ROBISON LISA M, ROBISON Defendmats ATTOILNEY FOR PLAINTIFF COURT OF COMMON PLEAS CML DMSION CUMBERLAND COUNTY NO. 03-3561 TO: LISA M. ROBISON 424 WATER STREET NEW CUMBERLAND, PA 17170 DATE OF NOTICE: SEPTEMBER 10, 200'~ THIS FIRM IS A DEBT COLLECTOR Al i'IfMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU 1N AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HERE[N, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE 1N BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AiTLMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALL[NAN, ESQUIRE Attorneys for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDER3IAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, STEVE T. ROBISON A/FdA STEVEN T. ROBISON LISA M. ROBISON Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3561 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant ( X ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215} 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, lA 50392-0780 Plaintiff, STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3561 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant STEVE T. ROBISON, A/K/A STEVEN T. ROBISON is over 18 years of age and resides at, 119 ROBSON ROAD, DILLSBURG, PA 17019. (c) that defendant LISA M. ROBISON is over 18 years of age, and resides at, 119 ROBSON ROAD, DILLSBURG, PA 17019. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center SEP-23-2003 12:08:32 Military Status Report Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 Currently not on Active iMilitary Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to sscra.helpdesk~osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owa/sscra.prc_Select 9/23/2003 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, STEVE T. ROBISON AfK/A STEVEN T. ROBISON LISA M. ROBISON Defendant(s). No. 03-3561 TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/25/03 to MARCH 3, 2004 (per diem -$11.38) TOTAL $69, 200.59 $1,820.80and Costs $71,021.39 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the westerly line of Water Street, said point being the center of the center wall between houses Nos. 422 and 424 Water Street, New Cum ~berland, Pennsylvania; thence north forty=five (45) degrees, fifteen (15) minutes west seventeen and three-te~ (17.3) feex to land now or late of Herbert Kimmel; thence along said Kimmel land south forty-four (44) degrees forty-five (45) minutes west one hundred fifty (150) feet to Walnut Alley; thence along Walnut Alley south forty-five (45) degrees fifteen (15) minutes east seventeen and three-tenths (17.3) feet to a point; thence on a line parallel with Fourth Alley north fony4our (44) degrees forty-five (45) minutes east and through the center of the partition wall between houses Nos. 422 and 424 Water Street one hundred fifty (150) feet to the place of Beginning. HAVING thereon erected the western half of a two and one-half story double frame dwelling house No. 424 Water Street, New Cumberland, Pennsylvania. Tax Parcel g25-24-0813-055 TITLE TO SAID PREMISES IS VESTED'IN Steven T. Robison and Lisa M. Robison, his wife by Deed from Sharon J. Whipkey dated 5/8/1987 and recorded 5/13/1987 in Deed Book Volume 32-Q, Page 898. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3561 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From STEVE T. ROBISON, AfK/A STEVEN T. ROBISON, LISA M. ROBISON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also cVtrected 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 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 garff~shee and is enjoined as above stated. AmoumDue $69,200.59 L.L. $.50 Interest FROM 9/25/03 TO 3/3/04 (PER DIEM - $11.38) ~ $1,820.80 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $269.26 Other Costs Plaintiff Paid Date: OCTOBER 1, 2003 (Seal) CURTIS R. LONG Prothonot~.~ Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3561 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,424 WATERS STREET, NEW CUMBERLAND, PA 17170. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 119 ROBSON ROAD DILLSBURG, PA 17019 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: NaiTle None Last Known Address (if address cannot be reasonably ascertained, please indicate) Nalne 5. Name and address of every other person who has any record lien on the property: Last Known Address (if address cannot be reasonably ascertained, please 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 424 WATERS STREET NEW CUMBERLAND, PA 17170 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. September 23, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, STEVE T. ROBISON A/K]A STEVEN T. ROBISON LISA M. ROBISON Defendant(s). CUMBERLAND COUNTY No. 03-3561 September 23, 2003 TO: STEVE T. ROBISON A/K/A STEVEN T. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 LISA M. ROBISON 119 ROBSON ROAD DILLSBURG, PA 17019 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSL¥ RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINSTPROPERTE ** Your house (real estate) at, 424 WATERS STREET, NEW CUMBERLAND, PA 17170, is scheduled to be sold at the Sheriff's Sale on MARCH 3, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $69, 200.59 obtained by PRINCIPAL RESIDENTIAL MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the westerly line of Water Street, said point being the center of the center wall between houses Nos. 422 and 424 Water Street, New Cumberland, Pennsylvania; thence north forty-five (45) degrees, fifteen (15) minutes west seventeen and three-tenths (17.3) feet to land now or late of Herbert Kimmel; thence along said Kimmel land south forty-four (44) degrees forty-five (45) minutes west one hundred fift)t (150) feet to Walnut Alley; thence along Walnut Alley south forty-five (45) degrees fifteen (15) minutes east seventeen and three-tenths (17.3) feet to a point; thence on a line parallel with Fourth Alley north forty-four (44) degrees forty-five (45) minutes east and through the center of the partition wall between houses Nos. 422 and 424 Water Street one hundred fifty (150) feet to the place of Beginaing. HAVING thereon erected the western half of a two and one-half story double frame dwelling house No. 424 Water Street, New Cumberland, Pennsylvania. Tax Parcel 3/25-24-0813-055 TITLE TO SAID PREMISES IS VESTED' IN Steven T. Robison and Lisa M. Robison, his wife by Deed from Sharon J. Whipkey dated 5/8/1987 and recorded 5/13/1987 in Deed Book Volume 32-Q, Page 898. SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-03561 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS ROBISON STEVE T AKA STEVEN T R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT ROBISON STEVE T AKA STEVEN T unable to locate Him in his COMPLJ~INT - MORT FORE , ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and ROBISON bailiwick. but was He therefore returns the the within named DEFENDANT ROBISON 424 WATER STREET NEW CUMBERLAND, PA 17070 424 WATER STREET NEW CUMBERLAND IS VACANT. DEFENDANT'S CURRENT ADDRESS IS 119 ROBSON RD DILLSBURG, ROBISON STEVE Sheriff's Costs: Docketing 18.00 Service 12.42 Not Found 5.00 Surcharge 10.00 .00 45.42 , NOT FOUND , as to T AKA STEVEN T PA 17019. R. Thomas Kli-r~e Sheriff of Cumberland County FEDERMAN & PHELAN 09/30/2003 Sworn and subscribed to before me this ~.~ day of 2 oo3 A.D. Pro~n~not ary SHERIFF'S RETURN - NOT FOUND CASE~NO: 2003-03561 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS ROBISON STEVE T AKA STEVEN T R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT ROBISON LISA M unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT , ROBISON LISA M 424 WATER STREET NEW CUMBERLAND, PA 17070 424 WATER STREET NEW CUMBERLAND IS VACANT. DEFENDANT'S , NOT FOUND , as to CURRENT ADDRESS IS 119 ROBSON ROAD DILLSBURG, Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 PA 17019. So answerD-~ ~,~,J .~J/~ { R. Thom~c~K~ine Sheriff of Cumberland County FEDERMAN & PHELAN 09/30/2003 Sworn and subscribed to before me this 2~( day' of ~u~ A.D. Prdt t~onot ary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-03561 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS ROBISON STEVE T AKA STEVEN T R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT ROBISON STEVE T AKA STEVEN T but was unable to locate Him deputized the sheriff of YORK serve the within COMPLAINT Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: ROBISON in his bailiwick. County, - MORT FORE He therefore Pennsylvania, to On September 30th , 2003 attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep York County 79.84 .00 104.84 09/30/2003 FEDERMAN & PHELAN Sworn and subscribed to before me this 2~c day ~o-o~ A.D. ! ; Prothonotar~ this office was in receipt of the So answ9 ~r~~ /-3 ~/~__/ Sheriff of Cumberland County SHERIFF'S RETURN CASE NO: 2003-03561 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS ROBISON STEVE T AKA STEVEN T OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT ROBISON LISA M but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, - MORT FORE He therefore Pennsylvania, to On September 30th , 2003 , attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 09/30/2003 FEDERMAN & PHEIJ~N Sworn and subscribed to before me this 2,,~t day of ~ ~0~_5 A.D. / · Prothonotary this office was in receipt of the So answers: R. Thomas Kline Sheriff of Cumberland County 1 of 2 ~-K1'OWNE~INESSFOMR~;~tT)225-0363.FAX(717)225-0357 --- ~*~1~ Nm-r. OFFICE OF THE SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN 1. PLAINTIFF/S/ PRINCIPAL RESI])I~N'rTAT. MORTGAGE, INC. S[[ VICE CALL ( ] ') 771-9601 INSTRUCTIONS PLEASE 'rYPE ONLY LIN;: I THRU ].2 DO NOT DETACH ANY COPIES 2. COURT NUMBER 03-3561 civi;[ 4 TYPE OF WRIT OR COMPI 3. DEFENDANT/S/ STI/V~- T. & LISA H. ROBISON HORTGACE FORECLO$[rRE SERVE ~' 5. NAME~F~ND~DUAL~C~MPANY,C~RP~RAT~N~ET~T~SER~E~RDES~R~T~N~FPR~PERTYT~BELE~lED~ATrA~F ~!ORSOLD $'£twE T. ROBISON, A/K/A S'z't~vF_,~ T. ROBISON _. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APE NO., CITY, BORe, TWP, STATE AND ZIP CODE) AT 119 ROBSON ROAD, DILLSBURC, PA 17019 NOW July 28 .20 03 I, SHERIFF OF YORK COUNTY, PA, do hereby dep t ize the sheriff of York COUNTY to execute t~,,~44,and, ma~e return the '~3f according to law. This deputization being made at the request and risk of the plaintiff. -~ , ,?--.- ::: ..... SHERIFF OF~YOR~"¢OI 8 SPECIAL INSTRUCTIONS OR OTHER IN FORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cm~berJ_~T~cl OUT OF COUN [Y CUHBERLAND Please send re~urn of service ~o C~nberland County Sheriff ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under ~ ~1 ~in wht may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy c I e shedff to any plaintiff herein for any loss, destruction, or removal of any property before shedlPs sale thereof. FIf&I]~,AN & pHKLAN l.T.p~ #NKXI~KNNXKKkaKKTJXK~li:XX&##~XI~NZ~CXXXI~AX--- -- (215)563-7000 7-25-03 ~-~ ~J~l~ ,~.E~) SE~C E~]~ ~C~E AND ADDRESS BELOW: Cl~qis area must be completed ft notice is to be mailed). l~l)]~d~[N & pRI[I.AN I.l.P, O1~ PI~I C~I~'/'F.K, ST[ 1400, PHII.AnI~HIA, PA 19103 SPACE I~ELOW FOR USE OF THE SHERIFF -- DO NOT WRITE BELOW T/HIS LINE-- 13. I acknowledge receipt of the writ 14. DATE CEIVED ~ 5. Expiration/Hearing Date or complaint as indicated above. / ~. A H~ENS ¢¢C;I.~ 16, HOWSERVED: PERSONAL~ RESIDENCE( ) POSTED( ) POE( ) SHERIFF'SOFFICE(~' OTHER( ) ' SEE REMARKS BELOW 17. LI I hereby cerff fy and return ~ ~.LgT f'Ou~[J ~ecause_~am unable to locate the individual, company, etc, name above, (See remarks below.) ~1~. ~NAME ~ TIIhE,"'~'~QIVLDUAL SERVE~,~RESS HERL~IIF~NOT SHOWN ABOVF~latiort~eip to J;~[endant) [ 19 I~ta of Se* 23. Advance Costs 75.00 1 WHITE - Issuing Authodty 24. Service Costs 25, N/F 26. Mileage 27. Postage 28. SubTotal 30. Notary 29. Pound 3,.Surchg. 32. Tot. Costs ,'[:~orRefun, ~cl~~ 24.00 51.84 75.84 4.00 79.84 4.84 41.AFFIRMED and subscribed ,o before me this ~- ~ .. ~. ~.~ ~¢ I / J) [/~O~AN~R~I~ -' / MELISSA J SHAFFER, No~ ...... '~ui~S~dff / I ~ // ' /J , ,~.u~,.c NZ% HOS~ 9 Z8 03 2 of 2 COUNTY OF YORK OFFICE OF THE SHERIFF (717) 771.9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DE'TACH ANY COPIES 1. PLAINTIFF/S/ 2. COURT NUMBER 03-3561 civil PRINCIPAL RESIDENTIAL MORTGAGE, INC. 4 TYPEOFWRITORCOMPLAINT 3. DEFENDANT/S/ SERVE ~" 5. NAME Of INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION Of PROPERTY TO BE LEVIED, A'CFACHED, OR SOLD LISA M. ROBISON 6. ADDRESS (STREET OR RFO WITH BOX NUMEER, APT NO, CIT~, BORO,/WP., S/ATE AND ZIP CODE) AT 119 ROBSON ROAD, DILLSBIIRG, PA 17019 7 INDICATE SERVICE: LJ PERSONAL Q PERSON IN CHARGE ~)EPUTIZE C'~'~nd J 1ST CLASS MAIL L.I POSTED O OTHER NOW July 2~ ,20 03 I, SHERIFF OF YORK COUNTY, PA, do h~,ereby deputize the sheriff of York -- COUNTY to execute this~ return ther~rding to law. This deputization being made at the request and risk of the plaintiff. ~ '~"'_~ SHERIFF OF YORK OOUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cfu~berlc~nd OUT OF COUNTY Please send return of service to Ct~nberland County Sher~J~BERLAND ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within wdt may leave same without a watchman, in custody ef whomever is found in possession, after notifying person of levy or attachment, witheut liabifity on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any praperbj before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of A~-FORN EY / ORIGINATOR and SIGNATUR~~~~ 10(215)563_7000TELEPHONE NUMBER 11. DATE FILED ~'~ & pHKI.A~ 1.T.P ~ 7-25-03 t2. SEND NOT~CE OF SERVICE COPY TO NAME AND ADDRESS SELOW: (This area must be completed if notice is to be mailed). SPACE BELOW FOR USE OF THE SHERIFF -- DO NOT WRITE BELOW THIS LINE 13 I acknowledge receipt of the writ 14 DATE RECEIVED 15. Expiration/Headng Date orcomplaintasindicatedabove.. ~,~N T~ ~.g*4nES$ '7-30-03 8-24-03 16 HOWSERVED: PERSONAL(~'"- RESIDENCE(~9- POSTED( ) POE( ) SHERIFF'SOFFICE( ) OTHER( } SEE REMARKS BELOW 17. [~ I hereby cer[i~n a NOT F~I~ because I am unabta to locate the individual, company, utc. name above. (See remarks below.) 18. NAME_~N~'~E_ O.F ~NDIVID~a~'SE~,~ED / LIST ADDRESS HERE IF NOT SHOWN ABOVE ~elationship to Defendant) 119 Date~of Service 120. Time of Se~ice 23. Advance Costs 24. Service Costs 25, N/F 26. Mileage 27. Postage 28. SubTotal 34. Foreign County Costs I 35. Advance Costa I 36. Service Costs I 37. Notary Ced. I 38. Mileage/Posted/Not Found I 39. Total Costs 41. AFFIRMED and subscribed to before me this 1 ~ SO ANSWERS , . Signature of ~%~1/~ I MELISSA J. SMAFFER, Notary Cu~J~ Signatureo!York ~ City of York, York County ~ . County Sheriff ./.'? //__~.~ -- ,/~ JgMyC~mmission Expirejs~i~120 200~ [ WILLIAM H 46. Signature of Foreign County Sheriff 1 WHITE - Issuing Authority 29. Pound 30, Notary 31. Surchg. 32. Tot. Costs 33 Costs Due or Refund Check NC 40. Costs Due or Refund 2 PINK - At[omey 3 CANARY - Sheriffs Office 4 BLUE - Sheriffs Office · 9-18-03 49. DATE 51 DATE RECEIVED PLAINTIFF ~FF~DAVIT OF SERVICE PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY KMD No. 03-3561 OZFEm)A T(S) STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON SERVE STEVE T. ROBISON A/K/A STEVEN T. ROBISON AT 119 ROBSON ROAD DILLSBURG, PA 17019 ACCT. #001821893-3 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 3, 2004 SERVED Served and made known to LJ$O t~Oil'.,qO ,r/ , Defendant, on the t~l'~ day of t~t~- ,200~, , o'clock~.m., at //.~A~0J$0n ~,/'~?/_c_~o5o; ~O/~_/y/jt~, , Commonwealth of Pennsylvania, in the manner described below: Wq¢la~se.y /tPa,,~ lg~ow ti ,ffa,'~ AL5 *//~or.i~t /90 -.~,v,.,r/ __ Defendant personally served. .~,~ Adult~r with who,m Defendant(s) reside(s). Relationship is _' Adult in charge~6FDefendant(s) s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. Description: Age ~t~ -,fi0 · e adrkess ~tdicated a an officer of said Defendant(s)'s company. Height Sworn to and subscribed before me this ~d~ day of _dtgt~/ ,200~. Notary: Race /~ Sex f Other ~2,/~j,ff~..7 sworn according to law, depose and state that I personally handed as set forth herein, issued in the captioned case on the date and at PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200__, at __ Moved __ Unknown No Answer 1st Attempt:. / / Time: : 3rd Attempt:. / / Time: : o'clock __.m., Defendant NOT FOUND because: Vacant 2aa Attempt:. / / Time: Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 PLAINTIFF AFFIDAVIT OF SERVICE PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY No. 03-3561 DEFENDANT(S) STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON SERVE LISA M. ROBISON AT 119 ROBSON ROAD DILLSBURG, PA 17019 ACCT. #001821893-3 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 3, 2004 SERVED Se vedandr deUownto L/sa /~, /~t~t~]XOf] ,Dcfendant, onthe ,2oo , at Id,' q5 . o'clo kC.m., at day of ff~7" , Commonwealth of Pennsylvania, in the manner described below: .X Defendant personally served. __ Adult family member with whom Defendant(s) reside(s). Relationship is __ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age ~O-,gt9 Height,5''$~1 WeightJ_.~ Race YP' Sex F OtherG/a$,Sc, y I, ~d YC~ ~ ~ Jg ~d Xo ~ , a competent ~ult, berg duly sworn according to law, d~ose ~d state ~t I persomlfy ~ded~ ~e and c~t copy of ~e ~ m~e ~er as set fo~ here~, issued ~ ~e captioned case on ~e date ~~/a before ~ r~s ~ day ~~,~,~ ~ ) ~ ~ ~ ATTEMPTED. NOT SER~D On the day of ,200__, at __ Moved __ Unknown__ No Answer 1st Attempt: / / Time: : o'clock __.m., Defendant NOT FOUND because: __ Vacant 2"d Attempt:. / / Time: 3rd Attempt:. / / Time: : Sworn to and subscribed before me this __ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 KMD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRINCI?AL RESIDENTIAL MORTGAGE, 1NC. VS. STEVE T. ROBISON A/K/A STEVEN T. ROBISON LISA M. ROBISON CIVIL ACTION CIVIL DIVISION NO. 03-3561 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for PRINCIPAL RESIDENTIAL MORTGAGE~ INC. hereby verify that on October 9~ 2003 tree and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: February 3, 2004 FRANK FEDERMAN, ESQUIRE Attorney for Plaimiff Principal Residential Mortgage Inc. VS Steve T. Robison a/k/a Steven T. Robison and Lisa M. Robison In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3561 Civil Term R. Thomas Kline, Sheriff; who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Poundage 890.64 Advertising 15.00 Posting Handbills 15.00 Levy 15.00 Surcharge 30.00 Service 11.73 Out of county 9.00 York County 40.96 Law Journal 270.05 Patriot News 270.97 Law Library .50 Prothonotary 1.00 Share of Bills 29.32 $1692.17 paid by attorney 03/12/04 Sworn and subscribed to before me This /~' ~ day of ~ 2004, A.D. (~ ;afft~ ~ )?q~% 4~ Prothonotary R. Thomas Kli~e, Sheriff Real Estfite Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. 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 Daup~ir~ in M~ook "M", Volume 14, Page 317. , PUBLICATION , COPY REAL F. SVATE 8ALE WHt NO. ~0~3~1 Inc. Va / A~/. Rr~k r~lmm~n ~ D~ :UPTION Notarial Seal J / I / ~ / ~' MyCommissionExpiresJune D06 I N~"TARY PUBLIC [ ~embe"Perms'/'va~'~*"'~'~OVN°~commission e~pires June 6, 2006 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 Total $ 270.97 Publisher's Receipt for Advertising Cost :o., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general Jge receipt of the aforesaid notice and publication costs and certifies that the same have 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. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Joumai, 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 ail legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the primed notice or publication attached hereto is exactly the same as was primed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 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. ILY~L ESTATE ~ALE NO. 20 Writ No. 2003-3561 Civil Principal Residential Mortgage, Inc. VS. Steve T. Robison. a/k/a Steven 'L Roblson and Lisa M. Roblson Atty.: Frank ]?ederman ALL THAT CERTAIN tract or par - eel of land and premises, situate, lyip4~ and belr~g in the Borough of New Cumberland in the County of Cumberland and Commonwealth of Pennsylvmnla. more particularly de- scribed as follows: BEGINNING at a point on the westerly line of Water Street. said point being the center of the center wall between houses Nos. 422 and 424 Water Street. New Cumberland, Pennsylvania; thence north forty-five (45) degrees, fifteen [15) minutes west seventeen and three-tenths (17.3] feet to land now or late of Herbert Klmmel; thence along smd Klmmel land south forty four {44) degrees forty-five (45) minutes west one hundred fifty (150) feet to Wal nut Alley; thence along Walnut Alley south forty five (45) degrees fifteen (15) minutes east seventeen and three-tenths [17.3) feet to a point; thence on a line parallel with Fourth Alley north forty four [44) degrees forty-five (45) minutes east and are Coyne, l~ditor SWORN TO AND SUBSCRIBED before me this 30 _day of JANUARY 2004 ,~/ NOTARIAL SEAL ~' LOIS E. SNYDER, flota~/Public Carlisle Bom, Cumberland County My Commission F..x~ires March 5, 2005 point beiiug the center of tbe center wall between houses Nos, 422 and Pemksylvania; thence north forty-five (451 degrees, fifteen (151 minutes west seventeen and three-tenths {t7.3) feet to land now or late of Herbert Klmmel: thence along said Klmmel land south forty-four (441 degrees forty five {451 minutes west one hundred fifty i150) feet to nut Alley; thence along Walnut Alley south forty-five (451 degrees fifteen (151 minutes east seventeen and three-tenths {17,3) feet to a point: thence on a line parallel with Fourth Alley north forty-four (441 degrees forty-five {451 minutes east and wa~ between houses Nos. 422 and 424 Water Street one hundred fifty {1501 feet to the place of Beginning. HAVING thereon erected the western half of a two and one-ha]f story double lYame dwelling house No. 424 Water Street, New Cumber- land, Pennsylvania. Tax Parcel #25 24 0813-055. TITLE TO SAID PREMISES IS VESTED IN Steven T. Robison and Lisa M, Robison. his wife by Deed from Sharon d. Whipkey dated 5/ 8/1987 and recorded 5/13/1987 in Deed Book Volume 32-Q. Page 898, FEDERMAN AND PHELAN By: DANIEL SCHMIEG IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) ~63-7000 PRINCIPAL MORTGAGE, INC. RESIDENTIAL Plaintiff Defendant(s) VS. STEVE T. ROBISON LISA M. ROBISON ATTORNEY FOR PLAINTIFF County Court of Common Pleas CIVIL. DIVISION NO. t)3-3561-CIVIL PRAI=ClPF T~3 RATIRFY JUD~MFNT WITH~3UT PR~JUDIC~ TO THE PROTHONOTARY: Kindly satisfy the Judgment which was entered on 10/1/03 against STEVE T. ROBISON and LISA M. ROBISON, Defendant(s), in the amount of $ 69,200.59 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. D~NIEL SCHMIIEG, ESQ~IR~ Attorney for Pla~tiff --~, Dated: July 29, 2004