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HomeMy WebLinkAbout03-4326WASHINGTON MUTUAL BANK, FA SUCCESSOR 1N INTEREST TO FLEET MORTGAGE CORP. Plaintiff VS. DEBORA A. POORMAN AND ROBERT L. POORMAN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WIlL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the clff~ms 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 claim in the Complaint of 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 F1ND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO 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 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUIqTO 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 PERI)ER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CI IMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP. Plaintiff VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF 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 mount 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 with 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 1719 North Frout Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WASHiNGTON MUTUAL BANK, FA SUCCESSOR iN INTEREST TO FLEET MORTGAGE CORP. Plaintiff VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW ,g).3 - Y.-~& (, : : ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., is a Corporation, with an address of P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53201. Defendant, DEBORA A. POORMAN, is an adult individual, whose last known address is 3815 DORSET DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, ROBERT L. POORMAN, is an adult individual, whose last known address is 3815 DORSET DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. On or about, April 22, 1998, the said Defendants, executed and delivered a Mortgage Note in the sum of $139,000.00 payable to GATEWAY FUNDiNG DIVERSIFIED MORTGAGE SERVICES, LP. The Said Note is not accessible to Plaintiffand is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiffalso avers that the within Mortgage foreclosure complaint is based upon the Mortgage and that the attachment ora copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1448, Page 15 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to FLEET MORTGAGE CORP. and recorded in the aforesaid County in Mortgage Book 574, Page 509. Washington Mutual Bank, FA is Successor in Interest to Fleet Mortgage Corp. The Said Mortgage and Assigmnent are incorporated herein by reference. 5. The land subject to the Mortgage is: 3815 DORSET DRIVE, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "A" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on March 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $24.53 per day From 02/01/2003 To 10/01/2003 ( based on contract rate of 6.875%) Accumulated Late Charges Late Charges $45.66 From 03/01/2003 to 10/01/2003 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $130,278.18 $5,936.26 $0.00 $365.28 $862.50 $6,513.91 $143,956.13 **Together with interest at the per diem rate noted above after September 01, 2003 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 SherifFs 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 ir~.any jurisdiction. 9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiffhas complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have 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 6.875% ($24.53 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriffs Sale and for foreclosure and sale of the property within described. /~/~/~ /~//] By: PIJRCELL, Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) ~/.~ '98 f~?r~ ~3 f~lq 9 ,90 Parcel Num~': MORTGAGE IIBIBIIIIIB# TOGETHI~ BOP. ROWE payments may ne tong~ be r~qu~r~cl, at th~ option of L~nder, i~ mongag~b~ura~c~ covea'ag~ (ia t~ amount a~d for tb~ period ~ of aay righ or remedy. 1  Ad~s~ab ~. Rate P. ld~ ~ Comiomlai~l Rid~' [~ 1-4 Fa~ly Riger First American Title Insurance Company SCHEDULE C Commitment No. 642324 County of Cumberland} 8~ Recorded in the office fm the ~ e~ I)eada ect. in and for Cuml~nd~(]~atmy. f~l,~ ~, 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 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP. Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: September 3, 2003 Leon P. Haller, Esquire SHERIFF'S RETURN - REGULAR CASE NO: 2003-04326 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA ETC VS POORM3~N DEBORA A ET AL KENNETH GOSSERT , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE POORMAN DEBORA A DEFENDANT , at 0935:00 HOURS, at 3815 DORSET DRIVE MECHANICSBURG, PA 17055 DEBORA POORMAN a true and attested copy of COMPLAINT - Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 9th day of Septenf0er, 2003 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me this /? ~ day of  ~6~3 A.D. SO Answers: R. Thomas Kline 09/10/2003 PURCELL KRUG HALLER SHERIFF'S RETURN - REGULAR CASE NO: 2003-04326 P COMMON-WEALTH OF PENNSYLV~NIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA ETC VS POORMA_N DEBORA A ET AL KENNETH GOSSERT , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE POORMAN ROBERT L DEFENDANT , at 0935:00 HOURS, at 3815 DORSET DRIVE MECHA/~ICSBURG, PA 17055 DEBOP~A POORMAN, WIFE a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 9th day of September, 2003 by handing to - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /7~ day of So Answers: R. Thomas Kline 09/10/2003 PURCELL KRUG HALLER /~ WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC, PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 MORTGAGEFORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) DEBORA A. POORMAN AND ROBERT L. POORMAN for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest Per diem of $24.53 From 02/01/2003 To 10/01/2003 Accumulated Late Charges Late Charges ($45.66 per month to 10/01/2003) Escrow Deficit $130,278.18 $5,936.26 $o.oo $365.27 $862.50 5% Attomey'sCommission TOTAL $6,513.91 $143,956.13 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL,~ By 'Leo~onP~ Hailer PA I.D. ~0 1719 North Front Street Harrisburg, PA 17102 (717) 234~4178 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMES1DE LENDING, INC, PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on October 6, 2003 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. Hall Attorney foffPlaintiff Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP. Pl~finfiff VS. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4326 DEBORA A. POORMAN AND ROBERT L. POORMAN CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: October 6, 2003 TO: DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 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 TIlE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE II-IE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 71%24%3166 PURCELL, KRUG & HALLER By ,_ LE~E~ey for Plaintif[ I.D. # 15700 1719 N. From St., Hamsburg, PA 17102 (717) 234-4178 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC, PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT1ON LAW NO. 03-4326 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ~tay (~i4~IONWEALTH OF PENNSYLVANIA Trad M. Colm, N~ Public Member, pennsylvania As~c~iat~on Of Notaries 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 03-4326 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) Total Judgment Amount Interest Per diem of $24.53 to sale date 6/9/2004 Late Charges $45.66 per month to sale date 6/9/2004 Escrow Deficit $143,956.13 $6,157.03 $365.28 $2,000.00 TOTAL WRIT $152,478.44 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, June 09, 2004 (PROTHONOTARY'S USE) Pltf. Paid Det~. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: March 9, 2004 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY HAViNG THEREON ERECTED A DWELLiNG KNOWN AS 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING THE SAME PREMISES WHICH James R. Hegeman and Laura T, Hegeman, by Deed dated 4/22/98 and recorded 4/23/98 in Cumberland County Deed Book 175, Page 1026, granted and conveyed unto Robert A. Poorman and Debora A. Poorman. TO BE SOLD AS THE PROPERTY OF DEBORA A. POORMAN AND ROBERT L. POORMAN ON JUDGIVlENT NO. 03-4326 ASSESSMENT NO. 10-16-1056-154 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO03~4326 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP Plaintiff (s) From DEBORA A POORMAN AND ROBERT L POORMAN (1) You are directed to levy upun tha property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) (2) You are also directed to attach the property of the defendant(s) not levied upun 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 possessiun 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. Amoum Due $143,956.13 L.L.$0.50. Interest PER DIEM OF $24.53 TO SALE DATE 6/9/04 $6,157.03 Atty's Corem % Due Prothy $1.00 Atty Paid $135.66 MONTH TO SALE DATE 6/9/04 $365.28 Plaintiff Paid Date: MARCH 10, 2004 (Seal) REQUESTING PARTY: Name LEON P HALLER Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Other CostsLATE CHARGES $45.66 PER Escrow Deficit $2,000.00 CURTIS R. LONG Prothonotary Deputy Attorney for: PLAINTIFF Telephone: (717)234-4178 Supreme Court ID No. 15700 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP. PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 1N MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. ItALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ~ay 20 Notary Public COMMONWEALTH OF PENNSYLVANIA Yrad M. C.~m, ~ PuUic City Of ~rg, Dauphin County My Co~m~s~n ~res ~ug. 2t 2OO7 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiffin the above action, by its attorneys, Purcell, Krug & Hailer, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 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 is a record lien on the real property to be sold: Irwin Union Bank & Trust Company 12677 Alcosta Boulevard Suite 500 Sam Ramon, CA 94583 Francis S. Hallinan, Esquire Federman & Phelan 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 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 of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street 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 l~alse statements herein are mad_~ubject to the penalties of 18 PA C.S. Section 4904 relating to unsworn f~~ Purcell, Krug & Hailer / 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:March 9, 2004 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 09, 2004 TIME: 10:00 O'clock A.M. LOCATION: 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: 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 03-4326 JUDGMENT AMOUNT $143,956.13 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: DEBORA A. POORMAN AND ROBERT L. POORMAN 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 exemise 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, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 HAVING THEREON ERECTED A DWELLING KNOWN AS 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING THE SAME PREMISES WH/CH James R. Hegeman and Laura T. Hegeman, by Deed dated 4/22/98 and recorded 4/23/98 in Cumberland County Deed Book 175, Page 1026, granted and conveyed unto Robert A. Poorman and Debora A. Poorman. TO BE SOLD AS THE PROPERTY OF DEBORA A. POORMAN AND ROBERT L. POORMAN ON JUDGMENT NO. 03-4326 ASSESSMENT NO. 10-16-1056-154 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-432.6 IN MORTGAGE FORECLOSURE RETURN OF SERVICE · I hereb.v certify that I have deposited in the U S Mails at H,trrisburg, Pennsylvama on ~//- 7--~tf , a true and correct co of the'~ot~ce ~, ' ....... ~. ..... PY ' of Sale, of Real Estate pursuant to PA et.ua-. 6 ~ 29.1 to me oetendants 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: DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 Irwin Union Bank & Trust Company 12677 Alcosta Boulevard Suite 500 Sam Ramon, CA 94583 Francis S. Hallinan, Esquire Federman & Phelan 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 ~~L, ~RUG & HALL~A~ Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 HOWARD B. KRUG LEON p. HALLER JOHN W. PURCELL JR. JILL M. WINKA BRIAN J. TYLER N1CHOLE M. STALEY O'GORMAN DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 LAW OFFICES 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533.3836 JOSEPH NISSLEY (1910-1982) JOHN W, PURCELL VALERIE A GUNNOF COUNSEL ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 Irwin Union Bank & Trust Company 12677 Alcosta Boulevard Suite 500 Sam Ramon, CA 94583 Francis S. Hallinan, Esquire Federman & Phelan 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street 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 312'9.1 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 against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if~notified of said Sherifl~s Sale. By: LZon,~er~I.D. 15700/ Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT[ON LAW NO. 03-4326 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE .PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be iheld: DATE: TIME: Wednesday, June 09, 2004 10:00 O'clock A.M. LOCATION: 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: 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 03-4326 JUDGMENT AMOUNT $143,956.13 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: DEBORA A. POORMAN AND ROBERT L. POORMAN 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 Sheriffofthe 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 FIN[} 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, Pennsylvania 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. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ..... . .' (100.00) co the P~ace o~ HAVING THEREON ERECTED A DWELLING KNOWN AS 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING THE SAME PREMISES WHICH James R. Hegeman and Laura T. Hegeman, by Deed dated 4/22/98 and recorded 4/23/98 in Cumberland County Deed Book 175, Page 1026. granted and conveyed unto Robert A. Poorman and Debora A. Poorman. ' TO BE SOLD AS THE PROPERTY OF DEBORA A. POORMAN AND ROBERT L. POORMAN ON JUDGMENT NO. 034326 ASSESSMENT NO. 10~16-I056-154 WASHINGTON MUTUAL BANK, FA v. DEBORA A. Cumberland County Sale 6/9/2004 POORMAN ROBERT L. POORMAN Received from: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 U. S. POSTAL SERVICE CERTIFICATE OF MAIL1NCi ~In compliance with Postal Service Fo[m 3877D Postage: Postmark: Received from: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 U. S. POSTAL SERVICE C~ERTIFICATE OF MAILING fin compliance with Postal Service For,,, _3877} Postage: Postmark: Received from: Purcell, Krug & Hailer l 719 North Front Street Harrisburg, PA l 7102 One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 U. S. POSTAL SERVICE C~ERTIFICATE OF MAILINC ~In compliance with Postal Service Form 3!177} Postage: Postmark: $ 00.90° WASHINGTON MUTUAL BANK, FA v. DEBORA A. POORMAN ROBERT L. POORMAN Cumberland County Sale 6/9/2004 Received from: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Irwin Union Bank & Trust Company 12677 Alcosta Boulevard Suite 500 Sam Ramon, CA 94583 U. S. POSTAL SERVICE C_EERTIFICATE OF MAILING l~n compliance with Postal Service For~'~ 3__..~ Postage: Postmark: Received from: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Francis S. Hallinan, Esquire Federman & Phelan 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 U. S. POSTAL SERVICE C~ERTIFICATE OF MAILING compliance with Postal Service Form 38~ Postage: Postmark: Washington Mutual Bank, FA successor In The Court of Common Pleas of In interest to Fleet Mortgage Corp. Cumberland County, Pennsylvania VS Writ No. 2003-4326 Civil Term Debora A. Poorman and Robert L. Poorman R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Leon Hailer. Sheriff's Costs: Docketing 30.00 Poundage 19.02 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 17.94 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 390.95 Patriot News 386.35 Share of Bills 29.26 $ 970.02 paid by attorney 07/07/04 This ~'~ dayof~.~ ~ ~j R. Thomas Kline, Sheriff 2004, A.D. , B¥~- Prothonotary WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POOR.MAN, DEFENDANT(S) 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attomeys, 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 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): DEBORA A. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 ROBERT L. POORMAN 3815 DORSET DRIVE MECHANICSBURG, PA 17055 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 is a record lien on the real property to be sold: Irwin Union Bank & Trust Company 12677 Alcosta Boulevard Suite 500 Sam Ramon, CA 94583 Francis S. Hallinan, Esquire Federman & Phelan 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP., PLAINTIFF VS. DEBORA A. POORMAN AND ROBERT L. POORMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-4326 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: TIME: Wednesday, June 09, 2004 10:00 O'clock A.M. LOCATION: 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: 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 03-4326 JUDGMENT AMOUNT $143,956.13 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: DEBORA A. POORMAN AND ROBERT L. POORMAN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD~ TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 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. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 HAVING THEREON ERECTED A DWELLING KNOWN AS 3815 DORSET DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING THE SAME PREMISES WHICH James R. Hegeman and Laura T. Hegeman, by Deed dated 4/22/98 and recorded 4/23/98 in Cumberland County Deed Book 175, Page 1026, granted and conveyed unto Robert A. Poorman and Debora A. Poorman. TO BE SOLD AS THE PROPERTY OF DEBORA A. POORMAN AND ROBERT L. POORMAN ON JUDGMENT NO. 034326 ASSESSMENT NO. 10-16-1056-154 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) ' NO03-4326 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK FA SUCCESSOR IN INTEREST TO FLEET MORTGAGE CORP Plaintiff (s) From DEBORA A POORMAN AND ROBERT L POORMAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) (2) Y°u 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 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 $143,956.13 L.L.$0.50. Interest PER DIEM OF $24.53 TO SALE DATE 6/9/04 $6,157.03 Atty's Comm % Due Prothy $1.00 Atty Paid $135.66 MONTH TO SALE DATE 6/9/04 $365.28 Plaintiff Paid Date: MARCH 10, 2004 (Seal) REQUESTING PARTY: Name LEON P HALLER Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Other CostsLATE CHARGES $45.66 PER Escrow Deficit $2,000.00 CURTIS R. LONG Prothonotary By: %~... ~ ~ Deputy Attorney for: PLAINTIFF Telephone: (717)234-4178 Supreme Court ID No. 15700 Real Estate Sale #75 On March 10, 2004 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 3815 Dorset Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 10, 2004 Real Estate Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 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 ~'he 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 27th day(s) of April and the 4th and 11th day(s) of May 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 Dauphin in Miscellaneous Book "M", Volume 14, Page 317. '~ ~,~7/~/_~,?~_~2..~j~' PUBLICATION C O P Y Sworn to 28th ~ o~f/~ 2004 A.D. S A L E #75 ~-- Terry L. Russell, Nolary I // - - ~mber, Pennsyiva~F-~a~r~oe~¢l~o?~ta~0~K~omrnisslon expires 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 386.35 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of ~and Th n P tr' t- w , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE 1N 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 Cotmty and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 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 tree. REAL ESTATE 8ALE NO. 75 Writ No. 2003-4326 Civil Washington Mutual Bank, FA successor in interest to Fleet Mortgage Corp. VIS. Debora A. Poorman and Robert L. Pooman Atty.: Leon P, Hailer ALL THAT CERTAIN tract or par- cel of land and premises, situate, ly- ing and being in the Township of Hampden in the County of Cumber- land and Commonwealth of Penn- sylvania, more particularly de~crlbed as follows: Being Lot #147, Kings- wood, Phase II. as recorded in Cum- berland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Dorset Drive said point also being a distimce of Slx Hun- arie Coyne, E~tor SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004 hTntr--' NOT~,~. SEAL c,,' LOIS E. SNYDER, Notary Public I Carlisle Boro, Cumberland County My Commission Expires Mamh 5, 2005 lng and being in the Township of Hampden in the County of Cumber- land and Commonwealth of Penn- sylvania, more particularly described as follows: Being Lot //147, Kings- wood, Phase II, as recorded in Cum- berland County Plan Book 55. Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the South side of Dorset Drive said point also being a distance of Six Hun- (ired Ninety-Four and One One-Hun- dredths feet (694.01~) West of the intersection of the West side of Chlppenham Road and the South side of DorseL Drive, thence by the line of Lot No. 148 South forty de- grees thirty-two minutes twenty sec- onds West {S 40° 32' 20" V~ a dis- tance of One Hundred Nineteen and Seventy-Six One-Hundredths feet (119.76'} to a point in AT&T right- of-way, at line of Lot No. 166 Hamp- den Square Section I. Plan Book 51, Page 2; thence by same and Lot No. 167 North fifty degrees fifteen min- utes forty-two seconds West {N 50° 15~ 42" W) a distance of Ninety-Five and Fifty-Six One-Hundredths feet (95.56') to a point; thence by Lot No. 167 North sixty-three degrees thirteen minutes forW-five seconds West (N 63° 13' 45" W) a distance of Four and Ninety-Eight One Hun- dredths feet (4.98') to a point at line of Lot No. 146; thence by same North forty degrees thirty-two minutes twenty seconds East (N 40° 32' 20'~ E) a distance of One Hundred Twen- ty-two and Nineteen One-Hundredths feet {122.19') to a point on the South side of Dorset Drive; thence by same South forty-nine degrees twenty-sev- en minutes for~y seconds East {S 49* 27' 40" E) a distance of One Hun- dred feet (100.00) to the Place of BE- GINNING, CONTAINING 12,008.30 square feet. known and numbered as 3815 Droset Drive, Mechanicaburg, HAVING THEREON erected a dwelling known as 3815 Dorset Drive Mechar~icsburg, Pennsylvania 17055. BEING THE SAME PREMISES WHICH James i% Hegeman and Lau- ra T. Hegeman. by Deed dated 4/ 22/98 and recorded 4/23/98 in Cumberland County Deed Book 175. Page 1026. Granted and con- veyed unto Robert A. Poorman and Debora A. Poorman. TO BE SOLD as the property of Debora A. Poorman and Robert g Poormar~ on Judgment No. 03-4326 ASSESSMENT NO. 10-16-1056- 154. ~kT~-~! NOTARIA LOIS E. SNYDEI~ Cafliste Bom, Cu~ My Commission Ex~. Leon P. Haller Purcell, Krug &Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller@Dkh.com WASHINGTON MUTUAL BAi~K, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., Plaintiff VS. DEBOP~AA. POORMAN, POORM3~N AND ROBERT L. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2003 - 4326 IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Please mark the P RA E C I P E judgment entered against the Defendants satisfied of record, because the mortgage has been reinstated and the default cured. DATE: September 30. 2004 p~~LLER BY- Leon P. Haller ID ~15700 Attorney for Plaintiff