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Home My WebLink About03-4982GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 62%1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS 1NC. SERVICING LP 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. EDWIN RODRIGUEZ Mortgagor(s) and Real Owner(s) 416 Hillside Road New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY C1VIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term CIVIL ACTION: MORTG/~GE I=E~ECL(:~URE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You bare been sued in couth If you wish to dethnd against the claims set fo~h in the thllowing pages, you must take action within )~v e nty (20) days aRer the Complaint and notice are served, by entering a written appearance personally or by attorney and Sling in writing with the court your defenses or objections to tl~ 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 thrlber notice for any ~no~'~y claim in the Complaint of for any other claim or rebel requested by the Plaintiff You may lose money or properly or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR Ln. WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO 'FO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP LEGAL SERVICES INC 8 Irzine Row Carllsle, PA 17013 717-243-9400 CUMBERLAND COUNI~ BAR ASSOCIATION 2 Lib~lty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USIED EN LA CORTE. SI DESEA DEFENDERSE CONIRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAM ENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REG1STRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA, RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORIANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAM ENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. LEGAL SERVICES INC 8 Brine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libel%' Avenue Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffis COUNTRYWIDE HOME LOANS INC. SERVICING LP, 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. The name(s) and address(es) of the Defendant(s) is/are EDWIN RODRIGUEZ, 416 Hillside Road, New Cumberland, PA 17070, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On November 29, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#: 1584 Page: 932. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due May 0l, 2003, 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. 6. The following amounts are due on the mortgage: Principal Balance Interest fi.om 04/01/2003 through 09/30/2003 at 8.3750% Per Diem interest rate at $17.58 Attorney's Fee at 5.0% of Principal Balance Late Charges fi.om 05/01/2003 to 09/30/2003 Monthly late charge amount at $30.84 Costs of suit and Title Search Monthly Escrow amount $170.11 $76,619.15 $3,217.13 $3,830.96 $154.19 $900.00 $84,721.43 $84,721.43 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attomey's Fees will be charged based on work actually performed. 8. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $84,721.43, together with interest at the rate of $17.58, per day and other expenses incurred by the Plaintiffwhich are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. GO/L~BECIqMcCAFFERTY & McKEEVER B~f.)/JOSEPH A. GOLDBECK, JR., ESQUIRE A~FORNEY FOR PLAINTIFF VERIFICATION I, Michael D. Vestal, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relat'mg to unswom falsification to authorities. COUNTRYWIDE HOME LOANS INC. Le~,al Descriotion: ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRH~ED AS FOLLOWS: BEGINNING AT A POINT ON THE WEST SIDE OF HILLSIDE ROAD AT THE DIVIDING LINE BETWEEN LOTS lI AND 12 ON THE HEREINAFI'~'.R MENTIONED PLAN OF LOTS; THENCE ALONG THE WEST SIDE Olr HILLSIDE ROAD, SOUTH 18 DEGREES 08 MINUTES 12 SECONDS EAST, A DISTANCE OF 50.00 FEET TO A POINT AT THE LINE OF LOT NO. 13; THENCE ALONG THE DIVIDING LINE OF LOTS 12 AND 13, SOUTH 71 DEGREES $1 MINUTES 48 SECONDS WEST, A DISTANCE OF 120.00 FEET TO POINT AT LINE OF LAND NOW OR LATE OF GORDON WILLIS, ET AL; THENCE ALONG SAID PROPERTY LINE NORTH 18 DEGREES 08 MINUTES IZ SECONDS WEST, A DISTANCE OF $0.00 FEET TO A POINT AT THE LINE OF LOT NO. 11; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS 11 AND 12, NORTH 71 DEGREES 51 MINUTES 48 SECONDS EAST, A DISTANCE OF 120.00 FEET TO A POINT ON THE WEST SIDE OF HILLSIDE ROAD, THE PLACE OF BEGINNING. BEING LOT NO. 12 ON THE SUBDIVISION PLAN OF NEW CUMBERLAND HOMES, RECORDED IN THE RECORDER OF DEEDS OFFICE OF CUMBERLAND COUNTY IN PLAN BOOK 41, PAGE 150, HAVING THEREON ERECTED A BRICK DWELLING HOUSE KNOWN AND NUMBERED AS 416 HILLSIDE ROAD, NEW CUMBERLAND, PENNSYLVANIA 17070. SHERIFF'S RETURN - REGULAR CASE NO: 2003-04982 P COMMONWEALTH OF PENNSYLVA/~IA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS RODRIGUIZ EDWIN KENNETH GOSSERT , Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE RODRIGUEZ EDWIN DEFENDANT at 1128:00 HOURS, at 416 HILLSIDE ROAD NEW CUMBERI_~AND, PA 17070 EDWIN RODRIGUEZ a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 25th day of September, by handing to together with - MORT FORE 2003 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.73 Affidavit .00 Surcharge 10.00 .00 39.73 Sworn and Subscribed to before me this ~,~L. day of ~}~_, ~ ~ A.D. honorary So Answers: R. Thomas Kline 09/26/2003 GOLDBECK MCCAFFERTY MCKEEVER ? GOI~DBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for plaintiff COUNTRYWIDE HOME LOANS INC. SERVICING LP 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. EDWIN RODRIGUEZ Mortgagor(s) and Record Owner(s) 416 Hillside Road New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 03-4982 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c} {27 Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ( ( ( IF ( ( ( Personal Service by the Sheriff's Office/c~, ' ' ' ': (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriff's Office. Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. ;ERVICE WAS ACCOMPLISHED BY COURT ORDER. Premises was posted by Sheriff's Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject~to the penalties provided by Section 4904. l~L~q~t.~fffftted,/ ~-x~~ J~e~h ~. G~beck, Jr. AttOrney for Plaintit~f 18 P.S. 7160 3901 9848 1440 2353 TO: RODRIGUEZ. EDWl~q EDWIN RoDRIGUEZ 416 Hillsid': Road 170'70 'New Cum'~ edand, PA k GoLDBECK D. ficCAFFERTY i, sENDER: ~o~ ~ REFERENCE: ~ 03/03/04 US postal ~Service Receipt tot Certified Mail C~RGEs FOR ANy Sc,~'~ETURN RECEIPT F~ ~ ~ER~cEs. 1 De ac~ the fo~ 3811, Domestic tatum m~ ing le~ to right acro~ pe~ A~a~ to maJlpie~ pt by tea~ back the adhesive std s spa~pe~ts. O~...P and affixing to fmc, · b~ ~eel~ng ,-~w~se a~x to ba~ of- ~,.o~ ma~/p~e~ 2.. If you do not ,~ra~p~e~. want the receipt pos mar . a~,cle , labe, to the r,~ht of the return addres[k.~:,st'ck ~he , ume re~lp and retain the re~ipt. 3. If you Want this m~ be~een the ~,- . pt post~a~e~ ,. edge of the re~ ~pt, and the ~'~'~P the 3800 re~i t held he m ~P~ to the gummed edTM ~nd s ide t~Pe o~ se~i~'~ '~ pla~ to present o ~ of ad,es,ye. This will -m~ow. (SEE ILLUS~Y~a~I~n e~ or post ~ ~ 5. Save this ._.. ~.mls receipt. ~ "~ me appropriate ~~ent it if you make a- * - Countrywide Home Loans, Inc. Servicing LP VS Edwin Rodriguez In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-4982 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 05, 2003 at 4:55 o'clock PM, 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: Edwin Rodriguez, by making known unto Edwin Rodriguez, personally, at 416 Hillside Road, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2004 at 4:20 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Edwin Rodriguez located at 416 Hillside Road, New Cumberland, 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: Edwin Rodriguez, by regular mail to his last known address of 416 Hillside Road, New Cumberland, PA 17070. These letters were mailed under the date of January 12, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me This day of 2004, A.D. Prothonotary R. Thomas Kline, S'heriff Real Estate(~e~uty ' GO'LDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attomey for Plaintiff cOUNTRYWIDE HOME LOANS INC. SERVICING LP 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. EDWIN RODRIGUEZ Mortgagor(s) and Record Owner(s) 416 Hillside Road New Cumberland, PA 17070 Defendant(s) Plaintiff IN TH[! COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-4982 AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC. SERVICING LP, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 416 Hillside Road New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): EDWIN RODRIGUEZ 416 Hillside Road New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: EDWIN RODRIGUEZ 416 Hillside Road New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ALLFIRST BANK P.O. Box 17282 Baltimore, MD 21203 5. Name and address of every other person who has any record interest in or record lien on the property and whose may be affected by the sale: interest 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANT/OCCUPANT 416 Hillside Road New Cumberland, PA 17070 (attach separate sheet if more space is needed) 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. DATED: February 24, 2004 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND j~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Countrywide Home Loans/nc is the grantee the same having been sold to said grantee on the 3rd day of March A.D., 2004, under and by virtue of a writ Execution issued on the 13th day of November, A,D., 202003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 4982, at the suit of Countrywide Home Lns Inc, Servicing L P against Edwin Rodriguez is duly recorded in Sheriff's Deed Book No. 262, Page 858, IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ff~ , A.D2004 O~ ~/~/~ day of ,~eCorder of Deeds Countrywide Home Loans, ]nc. Servicing LP VS Edwin Rodriguez In The Court of Common Pleas of Cumberland County, Pem~sylvania Writ No. 2003-4982 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 05, 2003 at 4:55 o'clock PM, 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: Edwin Rodriguez, by making known unto Edwin Rodriguez, personally, at 416 Hillside Road, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Bryan Ward, Deputy Sheriff} who being duly sworn according to law, states that on January 12, 2004 at 4:20 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Edwin Rodriguez located at 416 Hillside Road, New Cumberland, 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 Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Edwin Rodriguez, by regular mail to his last known address of 416 Hillside Road, New Cumberland, PA 17070. These letters were mailed under the date of January 12, 2004 and never returned to the Sherif£s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 3, 2004 at 10:00 o'clock A.M. He sold the same for the sum orS1.00 to Attorney Joseph Goldbeck for Countrywide Home Loans, Inc. It being the highest bid and best price received for the same, Countrywide Home Loans, Inc. of 7105 Corporate Drive, PTX C-35, Plano, TX 75024-3632, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $738.64, it being costs. Sherifl's Costs: Docketing $30.00 Poundage 14.48 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 23.46 Levy 15.00 Surcharge 20.00 Law Journal 256.10 Patriot News 213.28 Share of Bills 29.32 Distribution of Proceeds 25.00 Sheriff's Deed 40.50 $ 738.64 This R. Thomas Kline, Sheriff 2004, A.D. l~rothonotary B~ jC Real Estatq~Deputy Real Estate Sale # 47 On December 03, 2003 the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA Known and numbered as 416 Hillside Road, New Cumberland, more fully described on Exhibit "A" flied with this writ and by this reference incorporated herein. Date: December 03, 2003 By: Real Estgte Deputy TI-IE P3.TR'IOT N] WS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and aJJ 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 dai~y and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of ~auphi.n ~ Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S A L E #47 REAL ESTATE SALE No. 47 Writ No. 2003-4~ Civil Tram Servicing LP Edwin Rodrlguez Arty: Joeeph Goldbeck DESCRIP~3N l~mmylva~ia; more pa~cula~y desc~b~d a~ Sworn to and subscribed )re/rt',his 23rd day/~f Feb~ry 2004 A,D. C~ ~ Hamsburg: Dau~n ( ,u,~~/ ~ ~ { / ~ ~'~ ~L My ~i~ E~r~ J~e 6, ~ N~A~Y PUBLIC ~, ~~~ commission expires June 8, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 213.28 Publisher's Receipt for Advertising Cost Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general edge receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law 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 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 47 Writ No. 2003 4982 Civil Cotmtrywide Home Loans, Inc. Servicing LP Edwin Rodriguez Atty.: Joseph Goldbeck LEGAL DESCRIPTION ALL THAT CERTAIN tract or par eel of land and premises, situate, lying and being the Borough of New Cumberland in the County of Cumberland aild Commor~wealth of Pennsylvaxda, inOl-e particularly de- scribed as follows: BEGINNING at a point on the West side of Hillside Road at the dividing line between Lots 11 and 12 on the hereinafter mentiormd Plm~ of Lots: thence along the West side of Hillside Road. South 18 de- grees 08 minutes 12 seconds East, a distance of 50.00 feet to a point at the line of Lot No. 13; thence e Coyne itor SWORN'TO AND SUBSCRIBED before me this 30 day of JANUARY 2004 ~L SEAL ~ LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 scribed as follows: BEGINNING at a point on the West side of Hillside Road at the dividing line between Lots 11 and 12 on the hereinafter mentioned Plan of Lots; thence aloug the West side of Hillside Road, South 18 de grees 08 minutes 12 seconds East, a distance of $0,00 feet to a point at the line of Lot No. 13; thence along the di¥iding line of Lots 12 and 13, South 71 degrees 51 rran- of 120,00 feet to point at line of land now or late of Gordon Willis, et al; thence along said property line North 18 degrees 08 minutes 12 seconds West, a distance of 50.00 feet to a point at the line of Lot No. Ih thence along the dividing line between Lots 11 and 12, North 71 degrees 51 minutes 4,8 seconds East, a distance of 120.00 feet to a point on the West side of Hillside Road, the place of beginrdng. BEING LOT NO. 12 on the Sub~ division Plan of New Cumberland Homes, recorded in the Recorder of Deeds Office of Cumberland County in Plan Book 41, Page 150. HAVING THEREON ERECTED a brick dwelling house known and numbered as 416 Hillside Road, New Cumberland, Pennsylvania 17070. Carlisla Bom, Cumberland County My Commission Expires Mamh 5, 2005