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Home My WebLink About07-4803McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff Chase Home Finance LLC Cumberland County 10790 Rancho Bernardo Road Court of Common Pleas San Diego, CA 92127 v. Eddie Williams 20 Jane Lane Carlisle, PA 17013 and Number ~7 _ t.~.gD3 Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE 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. AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notification. Hate falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demands en contra suya sin previo aviso 0 notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. 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 1,AWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOL: WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE -1D # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC 10790 Rancho Bernardo Road San Diego, CA 92127 v. Eddie Williams 20 Jane Lane Carlisle, PA 17013 and Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number d ~ - SI ~ d 3 C'%~c,~ ~u•~^' CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is Chase Home Finance LLC, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Eddie Williams, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 20 Jane Lane, Carlisle, PA 17013. 3. The Defendant is Barbara A. Williams, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 20 Jane Lane, Carlisle, PA 17013. 4. On 05/07/1998, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Advanta Finance Corporation which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1452, Page 513. 5. On 04/15/2002, the aforesaid mortgage was thereafter assigned by Advanta Finance Corporation to Bankers Trust Company of California, N.A. by Assignment of Mortgage recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Book 686, page 1811. 6. The aforesaid mortgage was further assigned by Bankers Trust Company of California, N.A. to Chase Home Finance LLC, Plaintiff herein, by Assignment of Mortgage which will be duly recorded in the Office of the Recorder of Cumberland County. 7. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known 20 Jane Lane, Carlisle, PA 17013. 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/ 15/2007 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following amounts are due on the mortgage: Principal Balance $ 97,744.04 Interest 03/15/2007 through 07/20/2007 $ 2,365.79 (Plus $ 25.11 per diem thereafter) Attorney's Fee $ 4,887.20 Corporate Advances $ 648.43 Title Search $ 200.00 GRAND TOTAL $ 105,845.46 10. 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 based on work actually performed. 11. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $105,845.46, together with interest at the rate of $25.11 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG D CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/s'~ is the Attorney for the Plaintiff in the within action, and that he/sl~ is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/h~knowledge, information and belief and further states that false statements herein are made subj ect Ito the penalties of 18 PA.C. S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY, P.C. ~~ ,~ ~t~~ BY: Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ..: 14~is ~ • • .. .. • ; n ,'~. ' 98 (~~ ~ :~ :~ Pfd 2 13 Parcel Number: 29-16-1094-075 ~iy~a~~~ Space Above This Line for Recording Data ~0 ~ Z~ ~ p~ MORTGAGE THIS MORTGAGE (hereinafter referred to as "Security lnstrument'~ is given on this 7TH day of MAY , 19 98 .The Mortgagor is EDDIE AND BARBARA A. WILLIAMS (herein "Borrower"). This Security instrument is given to Advanta Finance Corp., a corporation organized and existing 4811 JONESTOWN RD. SUITE 223 HARRISBURG, PA 17109 under the laws of Nevada, whose address is (herein "Lender"). BORROWER, does hereby mortgage, grant and convey to Lender the following described property ("Property") located in the County of rrtMB~'uLl~il~ ,State of Pennsylvania: SEE "SCHEDULE A" Together with the buildings and improvements thereon, and the rights, alleys, ways, waters, privileges, appurtenances and advantages thereto belonging or in anywise appertaining, in order to secure repayment of the indebtedness evi- denced by Borrower's: ^ If checked, Revolving Loan Agreement of even date herewith. OPEN-END MORTGAGE: THIS MORTGAGE SECURES FUTURE ADVANCES. It obligates Lender, subject to the conditions stated therein, to advance to Borrower up to a Credit Limit of $ ,plus finance and other charges due and payable on ®If checked, Note of even date herewith, in the principal sum of $ 103, 660.26 payable in monthly installments of principal and interest, with the balance of the indebtedness, if not sooner paid, due and payable on 5 / 15 / 2 8 This Mortgage also secures any extensions, future advances, renewals, modifications, or refinancing thereof; and the . payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Security Instrument and the performance of the covenants and agreements herein contained, XQ If checked, the Revolving Loan Agreement or Note contains provisions for a variable interest rate. The payment amount or term of the indebtedness may vary, as may the amount of interest secured by this Security I ; rume eoo~ 1.;52 ~acE 5i3 Initials:~,_ _t~~ 61037-PA (Rev. 08-97) SEE OTHER PAGES FOR ADDITIONAL TERMS PAGE 1 OF 5 .~ ~~~'~, ?' a x. ~ e* ADDITIONAL TERMS A§ additional security for payment of thforesaid indebtedness, Borrower hereby presen~y and absolutely assigns to Lender all rents, profits, rights and benefits accruing under all leases now or hereafter placed on said Properly, and the lessee, assignee or sublesseers hereby directed on production of this Security Instrument, or certfied copy thereof, to pay said rents, profits, rights and benefits to Lender. In the event of default in the covenants and conditions of tlys Security Instrument, or other obligation secured hereby, Lender shad have the right peaceably to enter upon and take possession of said Property and assume control of the transactions having to do with rents and profits, to collect the same and to apply them to payment of the aforesaid indebtedness. Provided that if the said Borrower, executors, administrators, or assigns, shall well and truly pay, or cause to be paid, the aforesaid indebtedness stated above and all the installments of interest thereon, when and as each of them shall respectively be due and payable as aforesaid, and shall perform each and all of the covenants herein on their part to be performed, then this Security Instrument shall be released. BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby mortgaged end has the right to mortgage the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. Borrower and Lender further covenant and agree as follows: 1. Payment of Principal and Interest; Late Charges. Borrower shat! promptly pay when due the principal of and interest on the debt evidenced by the Revolving Loan Agreement or Note and any prepayment, late and other charges due thereunder. 2. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender shall be applied: first to any prepayment or other charges due under the Revolving Loan Agreement or Note; second, to interest due; and last to principal due. 3. Charges; Lkns. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay these obligations on time directly to the person owed payment. Borrower shall prompty furnish to Lender aU notices of amounts to be paid under this paragraph. Upon Borrower making these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b} contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 4. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term of "extended coverage' and any other hazards, including floods or flooding, for which Lender requires insurance. The insurance shall be maintained in the amounts and for the periods that Lender requires. The Insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 6. A11 insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. Unless prohibited by applicable law, (i) Borrower shall endorse over to Lender any insurance proceeds check made payable to Borrower, and at lender's option (ii) aN insurance proceeds for restoration or repair of the Property shall be placed with an independent third party funds control entity, chosen by Lender, which shall be responsible for monitoring such restoration or repair and disbursing payment therefor. Borrower shall cooperate with Lender and such third party funds control entity to accomplish the purposes hereof, and Borrower shall pay all fees associated with the funds control process. If the restoration ar repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower, If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instru- ment, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments or change the amount of the payments due Lender. If the Property is acquired by Lender hereunder, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisfion shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. 5. Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Properly or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as provided herein, by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in defaultrf Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any information) in connection with the loan evidenced by the Revolving Loan Agreement or Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall compty with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. e00r~.;52PAGE 514 Initials: 11 _ ~?~ 61037-PA (Rev. 08-97} SEE OTHER PAGES FOR ADDITIONAL TERMS PAGE 2 OF 5 ADDITIONAL TERMS 6. Protection of Lender's Rights in t roperty. 1f Borrower fails to perform the cove and agreements contained in this Security Instrument; or there is a legal proceeding that may signficantty affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemnation or forteiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of the Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in court, (Saying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 6, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 6 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the date of disbursement at the Revolving loan Agreement or Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 7. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 8. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender. In the event of a total taking of the property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b} the fair market value of the Property immediately before the taking. Any balance shalt be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments or change the amount of such payments due Lender. 9. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or mod cation of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shalt not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instru- ment by reason of any demand made by the original Borrower or $orrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 10. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of Paragraph 15. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Revolving Loan Agreement or Note: (a) is co-signing this Security Instrument only to mortgage that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Secuhty Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Revolving Loan Agreement or Note without that Borrower's consent. 11. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that taw is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Joan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already pollected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Revolving Loan Agreement or Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Revolving Loan Agreement or Note. 12. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 13. Goveming Law; Severability. This Security Instrument shall be governed by the law of the state of Pennsylvania. In the event that any provision or clause of this Security Instrument or the Revolving Loan Agreement or Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Revolving Loan Agreement or Note which can be given effect Hnthout the conflicting provision 7o this end the provisions of this Security Instrument and the Revolving Loan Agreement or Note are declared to be severable. 14. Borrower's Copy. Borrower shall be given one conformed copy of the Revolving Loan Agreement or Note and of this Security Instrument. 15. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by applicable law as of the date of this Security Instrument. If Lender exerases this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrowe- fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. aooYi~52~ACE 515 Initials: ~'~ 61037-PA (Rev. 08.97) SEE OTHER PAGES FOR ADDITIONAL TERMS PAGE 3 OF 5 • • ADDITIONAL TERMS • 16. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior 5 days (or such other period as applicable law may specify for reinstatement) of entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Revolving Loan Agreement or~Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instru- ment, Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 15. 17. Sale of Revolving Loan Agreement or Note; Change of Loan Servicer. The Revolving Loan Agreement or Note or a partial interest in the Revolving Loan Agreement or Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer') that collects monthly payments due under the Revolving Loan Agreement or Note and this Security instrument. There also may be one or more changes of the Loan Servicer unrelated to a sale of the RevoAng Loan Agreement or Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 18. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notfied by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law As used in this paragraph, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph, "Environmental Law" means state and federal laws and laws that relate to health, safety or environmental protection. 19. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration follownng Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 15 unless applicable law provides otherwise). The notice shall specify: (a) the default; (b) the action required to cure the default; (c) a date, not less than 30 days from the date the notice is given to Borrower, by which the default must be cured; and (d) that failure to cure the defauR on or before the date specked in the notice may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. The notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured on or before the date specified in the notice, Lender, at its option, may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose the Security Instrument by judicial proceeding. Lender shall be entitled to collect all costs and expenses incurred in pursuing the remedies provided in this paragraph, including, but not limited to, attorneys' fees and costs of title evidence. 20. Release. Upon payment of all sums secured by this Security Instrument, Lender shall release this Security Instrument. Borrower shall pay a!I recordation, taxes and other costs associated therewith. Lender may charge Borrower a fee for releasing this Security Instrument if.the fee is permitted under applicable law. 21. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 22. Reinstatement Period. Borrower's time to reinstate provided in paragraph 16 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 23. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 24. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Revolving Loan Agreement or Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Revolving Loan Agreement or Note. 25. Rehabilitation of Loan Agreement. Borrower shall fu1511 all of Borrowers obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with fender. Lender, at Lender's option, may require Borrower to execute and deliver to lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property. BOOK ~~52 PacE 516 Initials;~_ _! Lr~Sd.L 61037-PA (Rev. 06-97} SEE OTHER PAGES FOR ADDITIONAL TERMS PAGE 4 OF 5 • ` • REQUEST FOR NOTICE OF DEFAULT • - "ND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage, of any defauR under the superior encumbrance and of any sale or other foreclosure action. IN WITNESS WHEREOF, Borrower has executed this Mortgage. Witness ~~~"`=-~/f~4~ (Seal) ROBERT A. KEENER EDDIE WILLIAMS B0r''01N~ ]'T ~ ~ Borrower C/ BARBARA/ A. WILLIAMS` - rn~~ iSeal} (~} Borrower rte) Borrower Certificate of Residence ~~ p~~ p,,,y~ I, ROBERT H . HUNTER , do hereby certify that the correct address of the within-named Lender is 4811 JONESTOWN RD. SUITE 223 HARRISBURG, P 7 9 Witness my hand this 7THdaY °f MAY, 1998 Agent of Lender ~ COMMONWEALTH OF PENNSYLVANIA, ~, ~ //~~ (J~((J County ss. ~~ d O thi th t j ~ ' e ay a n s, I~ r M ,before rne, the urxiersigned officer personally appeared C 1 _ I ;~ ~ j r r if ~ L y ~A ~ lr ~ ~~ A ' „ 1r ~ ~ ~S 7 ''t KA ' ' su bscribed to t he within person S whose names instrument and aclmowledged that ~ -;,•i „~-- ~. •.. executed the same for the purposes herein contained ~ ~..~ ~~ a~ s'`~ ~ . :,.~. J,,.qr~ ty ~` to y dI4F~. `'~ 1 ~~, IN WITNESS WHEREOF, I hereunto set my hand and official seal. . . ~ 111~1 7 `~' 1 r,~';,, ~"~~"K°;~': ~ :'~' ' My Commission Expires- Notarid Seat Rabedl A Keener pioEtfry Pudic s~ ~ . ~-''' "'"'~ r:, . ~;~'~-:.~~„~~~~ e,~, • lower Atlen Twp-. Osupr~in County . ~:: „ • - !'~ . ``~ - MN Comrr>fesion Expires Dec. 17, 2001 le of Officer .: Member, PWrnayiv~rMa Areoc~ion d Notaries (Space Below this line Reserved Far I~nder and Recorder) $OOK iiar32 PAGE Jr1.7 67 037-PA (Rev. 0&97) SEE OTHER PAGES FOR ADDITIONAL TERMS PAGE 5 OF 5 ,, ?• • SCHEDULE A ,Name of $orrower(5) EDDIE AND BARBAR~P, ~. WILLIAMS ACCT#-32492661 CrderNumberPA000480617 regal ~escripdon cf Real Property: All chat certain prapsrty in the Township of North Middleton, CQiJM'TY of Cumberland, and COMMONWSALTli of Pennsylvania, Qaresl I. D. ~~9-lE•I094-075, being mprc fully described in Deed dated a4/oi/92, racorded 04/01/82, and appearing aaaong the land records of the County and Stats net forth above, in Book 5-29, page 739. State of Pennsylvania 88 County of Cumberland Recorded in the office for the recording of Deeds e t. 'n and for ~}~mberland County4 P~ i~ Book ZVot' Page witne my hanQ~and saai of office ~ Car{isle, PA thislL.._----day o ~- aA3i ~roperry ~;,mmoncv ~r,own .-s: 20 JANE LANE CARLISLE, PA 17013 ~~.~' ,~/. S/y/yam, Signature Oate ~ignattue EDDIE WILLIAMS Date ' ~ Y-S Jam".:' - 9~~' ~~gnature `~~ arras SARSARA A. WILLIAMS 0~° 6, oaa toy-~, aooK ~~52 PacF 518 ~ ~ ~ "T y T Mw - " C"' ~' hJ ~ ~ ~~ O ~T T.,u.. ---~ } +~ - y .. -.-_.; ^~` C7'~ -~C Q SHERIFF'S RETURN - REGULAR EASE "i~tO: 2007-04803 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS WILLIAMS EDDIE ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILLIAMS EDDIE the DEFENDANT at 2054:00 HOURS, on the 23rd day of Au ust 2007 at 20 JANE LANE CARLISLE, PA 17013 BARBARA WILLIAMS by handing to (SPOUSE) a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Postage .41 Surcharge 10.00 .00 ~q~b4'D~ ~ x.21 Sworn and Subscibed to before me this So Answers: .~~ " !~ R. Thomas Kline 08/24/2007 MCCABE WEISBERG & CONWAY By: day Deputy heriff of A.D. ~"~, 1 1 ,~ '~ ~~..'~ ~1 SHERIFF'S RETURN - REGULAR. QASE-PTO: 2007-04803 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE HOME FINANCE LLC VS WILLIAMS EDDIE ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILLIAMS BARBARA A the DEFENDANT at 2057:00 HOURS, on the 23rd day of August 2007 at 20 JANE LANE CARLISLE, PA 17013 by handing to BARBARA WILLIAMS a true and attested copy of COMPLAINT - 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 Sworn and Subscibed to before me this day So Answers: " / - ,~i% R. Thomas Kline 08/24/2007 MCCABE WEISBERG & CONWAY By: Deput Sheriff of A.D. .~,• • - ~` McCAB1E, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (2151790-1010 Chase Home Finance LLC Plaintiff Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY v. Eddie Williams and Barbara A. Williams Number 07-4803 Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 105,845.46 Interest 07/21/2007 to 09/26/2007 $ 1,707.48 Paid Taxes $ 7,415.82 Total $ 114,968.76 BYCABf%E~EISBE G ~CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE AND NOW, this day of , 2007 Judgment is entered in favor of Plaintiff, Chase Home Finance LLC, and against Defendants, Eddie Williams and Barbara A. Williams and damages are assessed in the amount of $114,968.76, plus interest and costs. BY THE PROTHONOTARY: ~ Q M~CABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - lD # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendants, Eddie Williams and Barbara A. Williams, 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; and that the Defendants, Eddie Williams and Barbara A. Williams, are over eighteen (18) years of age, and reside as follows: Eddie Williams 20 Jane Lane Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS~7 DAY OF -~Y"- ~ , 2007. F ~ ~ ~ ~ OTARY PUBLIC SJt! ~N+:4~,i.:F`-" ~yr,~:.Ht#5~'LVANIA ~~pRiA D. Q~tl'°f G'r"r~t_l., ~,~tary Public '' City of Phitaclet `~'sa, Ptr~~ X11 My Comm~°n Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 McCABE, WEISBERG, AND CONWAY, P.C. BY: ~~~ `k` Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE `Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 SEP-13-2007 08:13:03 ~ Last Name First/Middle Begin Date Active Duty Status Service/Agency WILLIAMS Barbara A Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~o-~_ ~,-.a~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 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. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/f~/ in s/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/13/2007 1Zequest for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: LSOTIJOMCQ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/13/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 SEP-13-2007 08:12:29 `~ Last Name First/Middle Begin Date Active Duty Status Service/Agency WILLIAMS Eddie Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~ -~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 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. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htt~://www.defenselink.mil/faa/nis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/13/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: LSOKUIOQEA https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/13/2007 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 CERTIFICATION The undersigned, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN TO AND SUBSCRIBED ('h- BEFO~RE ME THIS~~ DAY OF ~'`I" , 2007. Cil~~ TARY PUBLIC cor.;~P~,:~raa~ _r,:..=; -, ~r :~~.~~s`P'!_VANIA ~~~~~:~"'..'~L ~Er:L GLGii4 D. i,;? s'~;-iWLL, Li~;kiary Pudic y l!1y Cif 5~i?iii;~ ?~;"rim, Nlliia. County h~ Contmiasion Exp;res June 2, 2011 McCABE, WEISBERG, AND CONWAY, P.C. BY: Attofneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary September 13, 2007 To: Eddie Williams 20 Jane Lane Carlisle, PA 17013 Chase Home Finance LLC vs. Eddie Williams and Barbara A. Williams Cumberland County Court of Common Pleas Number 07-4803 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 (IO) 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 ABOUTAGENCIES THAT MAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Baz Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, BY: NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCR-TA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (IO) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y LISTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFIC[NA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Baz Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 ;RG D C AY, P.C. ~~s.~ • Attorneys for Plaintiff 1 TERRENCE J. McCABE, ES MARL S. WEISBERG, ESQ EDWARD D. CONWAY, ES MARGARET GAIRO, ESQUIRE A TJM/hm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary September 13, 2007 To Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Chase Home Finance LLC vs. Eddie Williams and Barbara A. Williams Cumberland County Court of Common Pleas Number 07-4803 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE [N 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 AGAtNST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A IUDGMENT MAY BE ENTERED - AGAINSTYOU WITHOUT A HEARING AND YOU MAY LOS E 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 Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, BY: /~~.~ ~ ~Iia Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIItO, ESQUIItE NOTIFICACION IMPORTANTE `JSTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRrSENTADO UNA COMPARECENCIA ESCRITA, YA SEA PEY.SONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECI,AMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (IO) DIAS DE LA FECHA DE ESTA NOi[FICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COhtPARECER LISTED EN CORTE U 0[R PREUBA ALGUNA, DICTAR SEt~ IENCIA EN SU CONTRA Y LISTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INh9EDIATAMENTE. SI LISTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAlO. ESTA OFICINA LO PUEDE PR.?PORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABnGADO. v; LISTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARJO REI]UCiDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Y, P.C. TJM/hm VERIFICATION The undersigned, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. McCABE~EISB , A CONWAY, P.C. BY: ~~ ~. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ~.^~r S~ S'--~ t~ ~--~ c_;:~ r1 ~.( ~ ~ i`1 ~ ~ f y nF Q V ~j OO ~ ~t, w5 ' ~ "~ 00 -` i ~'` c ~ ~; - " } ' • OFFICE OF THE PROTHONOTARY • COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, PA 17013 Curt Long Prothonotary To: Eddie Williams 20 Jane Lane Carlisle, PA 17013 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 07-4803 Defendants NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curt Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway P.C. at (2151790-1010. 9/as/o7 /s/ ~.u~4es ~. ~axg nus . , X Judgment by Default Money Judgment _ Judgment in Replevin _ Judgment for Possession • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, PA 17013 Curt Long Prothonotary To: Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 07-4803 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curt Long Prothonotary If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway. P.C. at X215) 790-1010. 9~as/o~ Ihl THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Lhase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants FILE NO.: 07-4803 Civil Term AMOUNT DUE: $114,968.76 Interest from 7/21/2007 to 3/5/2008 DATE OF SALE plus $18.90 per diem thereafter ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendants 20 Jane Lane, Carlisle, PA 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendants in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: la3 So ~t.oad `.~- f , S4e o'togo F~hi la , P a Iq 109 115-'Jqp~ Toro McCABE,~VFySBE CONWAY, P.C. BY: ~~"" Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE ~' Ib~i41. MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ~w w:~~c,s~$ ¢' ~ 9' ... tn~ao o ~' ~ ~ oo Q v ~ ~ - _ a° ~ cr' ~Co ~ 1 ~j' ~ -~ e ~'> m ,-,~ 4 ~~ " rs ~ ~v"'1 E.f ^i, I ~1 ,1 } ~ w7 ~. ~+'} . ' .. ' - ; ,~ «:~ 1 ~_ c? !r V McCABE,' WEIBBERG AND CONWAY, P.C. E BY:'' TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants Name and address of Owners or Reputed Owners: AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 20 Jane Lane, Carlisle, PA 17013 (Tax Parcel #29-19-1096-075), a copy of the description of said property is attached hereto and marked Exhibit "A". Name Eddie Williams Barbara A. Williams 2. Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 Address 20 Jane Lane Carlisle, PA 17013 20 Jane Lane Carlisle, PA 17013 Name and address of Defendants in the judgment: Name Eddie Williams Barbara A. Williams Address 20 Jane Lane Carlisle, PA 17013 20 Jane Lane Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on ~ ~ the real property to be sold: Name Address Plaintiff herein Belvedere Medical 850 Walnut Bottom Road Corporation Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Ford Consumer Discount Co., Inc. 9220 Tillman Drive Bensalem, PA 18020 5. Name and address of every other person who has any record lien on the property: Name None 6. Address Name and address of every other person who has any record interest in the property which maybe affected by the sale: Name None 7. Address Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Tenants Commonwealth of PA Department of Public Welfare Domestic Relations Cumberland County Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 20 Jane Lane, Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 320 Carlisle, PA 17013 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Department of Public Welfare TPL Casualty Unit Estate Recovery Program United States of America c/o U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7`n & Grant Streets Pittsburgh, PA 15219 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. Section 4904 relating to unsworn falsification to authorities. September 26, 2007 McCABE, WEISBER~~AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ~'_ cry ' S°l -- , i' ~' ~ ~ -n - f-: _; ~tl _- ~'`~ ~. !'-.~ C~J .- C.. • =z _` ~•. -' McCABE; WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendants are: Eddie Williams 20 Jane Lane Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS ~~IDAY OF ~~' ~, 2007. OTARY PUBLIC r..r. .. ',;.. ~i (~ v{~, ~y(~S 1 ....,~.. ~ Y~ Cep tt 1~~3`+IJf° ~ '~p+~~'~,..~ ""." L' ~, Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 McCABE, WEISBERG, ND CONWAY, P.C. BY: ~~_ Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE {- ~ i~ ~~ ~ ~ ~ . ~~ i' ~~~~ ~~ ~3 ~: ~:, ~ 7 -h ° r i1 . ; ~, _ , _ CIVIL ACTION LAW Chase Home Finance LLC COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Eddie Williams and Barbara A. Williams Number 07-4803 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Eddie Williams 20 Jane Lane Carlisle, PA 17013 Your house (real estate) at 20 Jane Lane, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland. County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $114,968.76 obtained by Chase Home Finance LLC against you. 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 canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg_and Conway P.C. at (215) 790-1010. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 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 McCabe, Weisberg_and Conway, P.C. at (215) 790-1010. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. i .a 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe. Weisberg and Conway P_C. at (215) 790-1010. 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. You have a 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 maybe entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 r ~' CIVIL ACTION LAW Chase Home Finance LLC v. Eddie Williams and Barbara A. Williams COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Your house (real estate) at 20 Jane Lane, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $114,968.76 obtained by Chase Home Finance LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg_and Conwav, P.C. at (215) 790-1010. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe. Weisberg and Conway P.C. Esquire at (215) 790- 1010. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. r 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To ' find out if this has happened, you may call McCabe. Weisberg and Conway P.C. at (215) 790-1010. 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. You have a 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 maybe entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYF,R 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4803 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, Plaintiff (s) From EDDIE WILLIAMS & BARBARA A. WILLIAMS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $114,968.76 L.L. $.50 Interest from 7/21/07 to 3/05/08 DATE OF SALE plus $18.90 per diem thereafter Atty's Comm Atty Paid $168.21 Plaintiff Paid Date: 9/28/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs C is R. Long, Prothonota By: Deputy Name TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG & CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff v. Eddie Williams and Barbara A. Williams Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-4803 AFFIDAVIT OF SERVICE I, the undesigned, attorney for the Plaintiff in the within matter, hereby certify that on the 10th day of January, 2008, a true and correct copy of the Notice of Sheriff s Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A." Copies of the letter and certificates of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 10~ DAY OF JANUARY, 2007. 'ARY McCABE, WEISB G, AND CONWAY, P.C. BY~ Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIItE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE KEVIN DISKIN, ESQUIRE Notarial Seal Susan J. Markowitz, Notary Public City o(Philadelphia, Philadelphia County My Commission Expires Feb. 13, 2011 ~' ~ McCABE, WEISBERG AND CONWAY, P.C- ' BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WELSBERG, ESQUIIZE - ID # 17616 EDWARD D. CONWAY, RSQUIRE - ID ~ 34687 #. 1vtAttGAR~T GARtO, ~SQIiIRE - ~ ~ 3449 ~ , ; 123 Sout1~ isroacl ~~ree~, ~ni4e 2b8b ~a~e~phia, ~'erihsy~vahia ~9~b9 ! ~~k' ; i ,, Chase dome Finance LLC COURT OF COMMON PLEAS Plaintiff CUM~3FRLAND COURT'TY v. Eddie `'~'il1i~:~~s and 1}aruwra ~,. ~~Tilliu:~ie t~7~::~~~er 07-4803 Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 20 Jane Lane, Carlisle, PA 17013 (Tax Parcel #29-19-1096-075), a copy of the description of said property is attached hereto anti mazked Exhibit "A". 1. Dame and address of Owners or Reputed Owners: Name Eddie Williams Address 20 Jane Lane Cazlisle, PA 17013 Barbara A. Williams 20 Jane Lane Cazlisle, PA 17013 2. Name and address of Defendants in the judgment: Name Eddie Williams Address 20 Jane Lane Cazlisle, PA 17013 Barbaza A. Williams Attorneys for Plaintiff 20 Jane Lane Cazlisle, PA 17013 ~y~B~~A 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to ~e sold: Name ~ A~~ress ~'laintff $eirein . ~~ ' $e~ve~ere 1V~edica~ $Sb Wa~ntit Bottom load Corporation Cat~is~e, ~'A 17013 t 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Ford Consumer Discount Co., Tnc. 9220 Tillman Drive Bensalem, PA 18020 5 Name and address of every other person who has any record lien on the property: Name None 6. Address Name and address of every other person who has any record interest in the property which maybe affected by the sale: Name None 7. Address Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which maybe affected by the sale: Name Tenants Commonwealth of PA Department of Public Welfare Domestic Relations Cumberland County Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 20 Jane Lane, Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 320 Carlisle, PA 17013 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Sq ~ D artment #280601 ~ ' ~~ Harrisburg, PA 17128 t Department o~~ublic Welfare T~'L Casia~ty knit B,state ~: 1Zecovery Pro~ratn ~nterria~ ~evenile ~erv~Ce Department o~ 1'u~~ic Welfare TPL Casualty Lj'nit Estate Recovery Program United States of America c% U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA Wi~~ow Oa1c Building Y.~. Box 8486 '~ ~aris~~~, pA ~71b5-~8~$6 '~ec~ca~ Sti~por~ Group, William Green ~'edera~ bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Wiiiow oalc Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7~' & Grant Streets Pittsburgh, PA 15219 Clearance Support Department 281.230 Harrisburg, PA 17128-1230 ATTN: Sheriff s Sales 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. Section 4904 relating to unsworn falsification to authorities. September 26, 2007 McCABE, WEISBER AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ~:: { ,~: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC Plaintiff Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY v. Eddie Williams and Barbara A. Williams Number 07-4803 Defendants DATE: January 10, 2008 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Eddie Williams and Barbara A. Williams PROPERTY: 20 Jane Lane, Carlisle, PA 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff s Sale on March 5, 2008 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. ~; ~;: ti ~O 00 J O~ U A W N 1r C ~ ~ -+ b ~ ~~ ~ J y ~ 00 00 d ~' ~ [_] x'd i~~C7 ~ C~~ ~o ' pox! y'-' ~°o ~~ ~ xC~;SbdA ca ~''-Ci ° m 'd"'""'A ~or°ro n"anC ~~a o x"dCA ~ ~ o AN--~ ~~° W`O's1 f~OObd ~` ° • p O r m ~; td~ n n~ m B ...R'ti a moo i , ~ m ~~ A~ m @ y m ~.^y ~ av~-•~ 9~ ~•Cd~~ ..~ m~ u^; W~ B m m ~;e o G off, m ,.jn < . ~. ~ !~$ x CO m~ .C.~ ~ ~ C ee „~~W~Am '17 U C ~ ~ C p~CO C.yy A.:I O O p ~ ;~Z7~'O 'O ~ a p rCO.~.~~ ~ ~ ri . CTO O ~ ~ C .Cr AA~ rr tC^O C~ ^'C7 rCfo~p p ~t QQ A~bm ,f'' oe b ~ ~rO~C/~A C e a yA Oq ~Cy,(/1A F. r- o m C.~ A ~ ~ m ~N.7 ~ o a ;P. ~~ 04 ae~~.A ~ m b Y~ ° bm G o > a ~~A ~ a~~ ~, b g b ~ bNm m ~~. _ nm ~ ~.., ~ ~m o o N° ~ b ~ ~ „~ ~~~ ~ ~ _. Y ~ y A ~ o ~ ° °°`+'~ o n a ~°, ~ ~ ~ o o s ' 00 ~m- ` A ~ ^p a ~rn M C A "1 ~ t9 yo V1 p pp y .G pa ' ow .t ~ d fp '! ~ ~ k! ^~ ~ IO W O 00 rh .. ~ ~~v ! C fC e~- :: ~ ~ A ~ d b O io Ai ; D t~ ...~ ',~ L ~~ ,,, .. _ , _ r. i , ,, ~ ~ ,. `, i.°. . d y-; ~: ~ oo Ur A N o ~ am p• ~'~ ~ ~~ y .~ V 1 Q ti e' _ ~ ~ i n ~~ ~. r: O.Z~ . Ip ~'!"i ,} ~ O~ ~ ... ~ ~ f ~: ~~~ri~. ,% y'41~i ~ ~ ~ A~~ g w - C .o $® L ~ ~~ ~~ e QJ0 ~.r W w~ ~ I~' i ~~ ~I I >~dn~ do ~~w~o o ~ U~o o ~Nm o a ~ Cl O ~ ~ C/1 p OO ,~ I A C/1 O n O ~ CJ p ~ ~ V1 ,~ Cn ~,~N~ccm ,~~°~`e~ b~~o a m~~o~ $ ~~ o a ~ ~ m Q 0 y C? ` ~: i ~~ cc~ -,~. ~~, McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Chase Home Finance LLC COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Eddie Williams and Barbara A. Williams No. 07-4843 Defendants SUGGESTION OF RECORD TO THE PROTHONOTARY: It is hereby suggested of record that the Defendant, Eddie Williams, departed this life on November 6, 2007. Thus, the title to the property being foreclosed upon in the herein action, vests solely in Defendant, Barbara A. Williams, Co-Defendant and wife of Eddie Williams, by operation of law. !%~~ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff t'~ ~ - ~ `~. ~-~~ _~ - ;-s ~sx j ~: ~ =~- t"~2 ~ ~~ _..:, ~._r ,, , , ~ ~... °"S . s :.~ ~, ~ Chase Home Finance LLC In the Court of Common Pleas of VS Cumberland County, Pennsylvania Eddie Williams and Barbara A. Williams Writ No. 2007-4803 Civil Term Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on December 06, 2007 at 1815 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Barbara A. Williams, by making known unto Barbara Williams, personally, at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Eddie Williams, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sheriff s Sale and Description as NOT SERVED as to the defendant, Eddie Williams. Per the defendant's widow, Eddie Williams is deceased. Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1130 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Eddie Williams and Barbara A. Williams located at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Barbara A. Williams by regular mail to her last known address of 20 Jane Lane, Carlisle, PA 17013. This letter was mailed under the date of January 8, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Terrence McCabe. Sheriffs Costs: Docketing 3 0.00 Poundage 2448.45 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy 20.00 Surcharge 30.00 Law Journal 355.00 Patriot News 296.12 Share of Bills 16.17 $3,232.84 / ..~,,, ~ /~ ~~ G Y So Answ s: w~ R. Thomas Kline, Sheriff ~s ~ a , ~` uv .~ ti.. F ~ ~' y ~~~ Real Estate'Sergeant ,;l ~. q .~ C, ~J f~~L. ' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 Chase Home Finance LLC Attorneys for Plaintiff COURT OF COMMON PLEAS Plaintiff v. CUMBERLAND COUNTY Eddie Williams and Barbara A. Williams Defendants Number 07-4803 AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 20 Jane Lane, Carlisle, PA 17013 (Tax Parcel #29-19-1096-075), a copy of the description of said property is attached hereto and marked Exhibit "A". 1. Name and address of Owners or Reputed Owners: Name Eddie Williams Address 20 Jane Lane Carlisle, PA 17013 Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Name Eddie Williams Address 20 Jane Lane Carlisle, PA 17013 Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 • 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Belvedere Medical 850 Walnut Bottom Road Corporation Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Ford Consumer Discount Co., Inc. 9220 Tillman Drive Bensalem, PA 18020 Name None 6. Address Name and address of every other person who has any record interest in the property which maybe affected by the sale: Name None 5 Name and address of every other person who has any record lien on the property: Address 7 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Tenants Commonwealth of PA Department of Public Welfare Domestic Relations Cumberland County Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 20 Jane Lane, Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 320 Carlisle, PA 17013 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Department of Public Welfare TPL Casualty Unit Estate Recovery Program United States of America c/o U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7~' & Grant Streets Pittsburgh, PA 15219 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales 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. Section 4904 relating to unsworn falsification to authorities. September 26, 2007 McCABE, WEISBER AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARL S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CIVIL ACTION LAW Chase Home Finance LLC COURT OF COMMON PLEAS v. Eddie Williams and Barbara A. Williams CUMBERLAND COUNTY Number 07-4803 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Eddie Williams 20 Jane Lane Carlisle, PA 17013 Your house (real estate) at 20 Jane Lane, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $114,968.76 obtained by Chase Home Finance LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe Weisberg and Conway~P C at (215) 790-1010. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 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 McCabe, Weisberg and Conway P C at (215) 790-1010. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. 'The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To . find out if this has happened, you may call McCabe, Weisberg and Conway P C at (215) 790-1010. 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. You have a 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 maybe entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 CIVIL ACTION LAW Chase Home Finance LLC I COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Eddie Williams and Barbara A. Williams Number 07-4803 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Your house (real estate) at 20 Jane Lane, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $114,968.76 obtained by Chase Home Finance LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Chase Home Finance LLC the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway P C at (215) 790-1010. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 McCabe, Weisberg and Conwav P C Esquire at (215) 790- 1010. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3• The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway P C at (215) 790-1010. 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 a 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 maybe entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, 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. LAWYER REFERRAL, SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected Situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 2 on the Plan of Section 9 of Noll Manor as recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 24, Page 104; Containing 65 feet along Jane Lane, having a depth along the South of 125 feet along Lot No. 3 on said Plan, having a width in the rear along the East of 85 feet and having a depth along the North along Lot No. 1 on said Plan of 125 feet. BEING improved with a brick and frame bi-level dwelling known as 20 Jane Lane, Carlisle. BEING KNOWN AS 20 JANE LANE, CARLISLE, PA 17013. Being the same premises which Gerald M. Henry and Kitty S. Henry, husband and wife, by deed dated 4/1/1982 and recorded 4/1/1982 in the office of the Recorder in and for Cumberland County in Deed Book 529, Page 739, granted and conveyed to Eddie Williams and Barbara A. Williams, husband and wife„ in fee. TAX MAP PARCEL NUMBER: 29-19-1096-075 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4803 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, Plaintiff (s) From EDDIE WILLIAMS & BARBARA A. WILLIAMS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $114,968.76 L.L. $.50 Interest from 7/21/07 to 3/05/08 DATE OF SALE plus $18.90 per diem thereafter Atty's Comm Atty Paid $168.21 Plaintiff Paid Date: 9/28/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs 5 ~, rtis R. Long, Prothonotary By: Deputy Name TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG & CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swol-n, 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: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL E8TATE SALE MO. 31 Writ No. 2007-4803 Civil 1Sa Marle Coyne, E itor Chase Home Finance LLC vs. Eddie Williams and S~ TO f1ND SUBSCR ED before me thi Barbara A. Williams s __ $ day O f February 2008 Atty.: Margaret Gairo DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected Situate in North Middleton Notary Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEING Lot No. 2 on the Plan of Section 9 of Noll Manor as recorded i n the Office of the Recorder of Deeds of C b N07ARIAL SEAL DEBORAH A COLLI um erland County in Plan Book 24 NS , Page 104; Containin 65 feet alon g g Jane Lane, having a depth along the Notary Pubiic CARLISLE BORO, CUMBERLANp COUNTY South of 125 feet along Lot No. 3 on MY Commission Expires Apr 28, 2010 said Plan, having a width in the rear along the East of 85 feet and having a depth along the North along Lot No. ' T,he •Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE ~he~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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. PUBLICATION COPY This ad ran on the date(s) shown below: ..,e.,.~.,...., -..,.._......... REAL ESTATE SALE N0.31 Writ No. 2007-4803 Clv(1 Term Chase Home Flnance LLC vs Eddie Wrlllams and Barbara A. Wlllrams ....... . Artorney Wlargaret Gairo DESCRIPTION Sworn to anc~: ~-L THAT CERTAIN trot of ]and with the `°~" improvements thereon erected Situate in North Middleton Township, Cmmberland County, Pennsylvania, bounded and described as follows: BEING I.m No. 2 on the plan of Segion 9 of Noll Manor as recorded in the Office of the Recorder of Ikeds Qf Cumberland County in 01/30/08 02/06/08 02/13/08 i~~ "_ _ _ ............... . before ryie tY~is'2~a~6 of February, 2008 A.D. Notary Public L COMMONWFrgI~~ Ol= ;~_~----~ f~P;..~Y E +I4ks.t Viz:' .;a~1 Shern~; _ +C~.s~ ~,.~:>~~~, public y OfHs~msbra, R~ ,hin county ~7or ~ " ov. 26, 2011 Member, Pennsylvai7ir c,;~'~iaron of N- o~~