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HomeMy WebLinkAbout07-5312MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Citibank N.A. as Trustee 701 Corporate Center Drive Raleigh, NC 27607, Plaintiff, Vs. William M. Mekeal 1919 Maple Street New Cumberland, PA 17070, and Margaret E. Mekeal 1919 Maple Street New Cumberland, PA 17070, Defendants. Attorney for Plaintiff File: 55.06894 COURT OF COMMflN FLEAS CUMBERLAND COUNTY No.: a~ - 531 a C~~~ ~ Term CIVIL ACTION MORTGAGE FORECLOSURE {00189396} 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 fait to do so the case may proceed wtl~out you and a judgment mad be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may Lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. iF YOU. DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Baz Association 32 S. Bedford Street Cazlisle, PA 17013 717-249-3166 {00189396} ****~,~x*yr~r*ie~e,ir~**,ir~~,ir+t*~r*********,~*,ie~***~erx~,u~r,~r,~***~**,e~r*+e*~r~t**,~r~*~r* NOTICE PURSUANT TO FAIR DEBT COLLECTION .PRACTICES ACT 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion hereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the dQbt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. {00189396} MILSTEAD & ASSOCIATES, LLC BY:Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Citibank N.A. as Trustee, 701 Corporate Center Drive Raleigh, NC 27607, Plaintiff, Vs. William M. Mekeal 1919 Maple Street New Cumberland, PA 17070, and Margaret E. Mekeal 1919 Maple Street New Cumberland, PA 17070, Defendants. Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, Citibank N.A. as Trustee (the "Plaintiff'), is a Pennsylvania corporation registered to conduct business in the Commonwealth of Pennsylvania and having an office and place of business at 701 Corporate Center Drive, Raleigh, NC 27607. 2. Defendants, William M. Mekeal and Margaret E. Mekeal, (collectively, the "Defendants"), aze adult individuals and aze the real owners of the premises hereinafter described. 3. William M. Mekeal, Defendant, resides at 1919 Maple Street, New Cumberland, PA 17070. Mazgazet E. Mekeal, Defendant, resides at 1919 Maple Street, New Cumberland, PA 17070. {00189396} 4.On Mazch 26, 1997, in consideration of a loan in the principal amount of $53,500.00, the Defendants executed and delivered to TMS Mortgage Inc., d/b/a The Money Store a note (the "Note") with interest thereon at 10.500 percent per annum, payable as to the principal and interest in equal monthly installments of $489.39 commencing May 1, 1997. 5. To secure the obligations under the Note, the Defendants executed and delivered to TMS Mortgage Inc., d/b/a The Money Store a mortgage (the "Mortgage") dated March 26, 1997, recorded on March 31, 1997 in the Department of Records in and for the County of Cumberland under Mortgage Book 1372, Page 266. Said Mortgage was assigned by way of an Assignment of Mortgage to The Bank of New York, as Trustee under the pooling and Servicing Agreement dated as of February 28,.1997, Series 1997-A-I. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. Plaintiff is proper party plaintiff by way of an assignment to be recorded. 6. The Mortgage secures the following real .property (the "Mortgaged Premises"): 1919 Maple Street, New Cumberland, PA 17070. A legal description of the Mortgaged Premises is attached hereto as Exhibit "A" and made a part hereof. 7. The Defendants aze in default of their obligations pursuant to the Note and Mortgage because payments. of principal and interest due April 1, 2007, and monthly thereafter aze due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late chazges, escrow deficit (if any) and costs of collection including title seazch fees and reasonable attorney's fees. 8. The following amounts are due on the Mortgage and Note: Balance of Principal ..................................$49,076.84 Accrued but Unpaid Interest from 311 /07 to 9/4/07 @ 10.500% per annum {00189396} ($14.12 per diem) ............................. ...........$2,654.56 Accrued Late Chazges ...................... ..............$146.82 Title Seazch Fees ....................:......... ........:.....$350.00 Monies in Suspense .......................... ............ -$842.87 Reasonable Attorney's Fees ............. ...........$1,250..00 TOTAL as of 09/04/2007 ................. .........$52,635.35 Plus, the following amounts accrued after September 4, 2007: Interest at the Rate of 10.500 per cent per annum ($14.12 per diem); Late Charges of $24.47 per month. 9. Plaintiff has complied fully with Act No. 91 (35 P.S.'1680.401(c) of the 1983 Session of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the Defendants at 1919 Maple .Street, New Cumberland, PA 17070 as well as to address of residences as listed in paragraph 3 of this document on June 19, 2007, the notice pursuant to § 403-C of Act 91, and the applicable time periods therein have expired. WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8, namely, $52,635.35, plus the following amounts accruing after September 4, 2007, to the date of judgment: (a) interest of $14.12 per day, (b) late charges of $24.47 per month, (c) plus interest at thelegal rate allowed on judgments after the date of judgment, (d) additional attorney's fees (if any) hereafter incurred, (e) and costs of suit. MILSTEAD & ASSOCIATES, LLC ~i^' Chrisovalante P. Fliakos, Esquire Attorney. for Plaintiff {00189396} VERIFICATION I, Chrisovalante P. Fliakos, hereby certify that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff's behalf. I verify that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief.. This verification is made subject to the penalties of 18 Pa. C.S. ' 4904, relating to unsworn falsification to authorities. Name: hrisovalante P. Fliakos, Esquire Title: Attorney j00189396} .' ~- • ',~ . ~~~ f 1~',~ Schednl,e "A" 1 ^1U ttfat oYt,in lat or pieco of 2agd •ituat• in the Sarough of NCw Cualbar~and, County o! CwnDerland snd stato of Ponnsylvania, bounded and do•eribed as follows, W wits i a~pibMING at the aoath•satcrn corner oG Caru1 Street {formorly Jcffcraori B,Crset} and Naplo StCest; tbeaco ."•outh tRirty-t+so t)2} dogroos.forty-five (A5) Minutes Bast, ala»y tha bastern line of ttapie 9trec~, ens Hundred thirty (130} feat to o paint et i twenty (40) fcst n~layr thanes North fitly-seven {37) ~A~grses fiitosn {151 Mi»ut.e~ east, along the nozChasn lin•, of a ew•nty {2a)' Ewt a12ey, +ievei-ty {70} fe.r to n paintr tAenos North thirky-tyro (12) aegroos 'for~y,fivo (45} ainutes Hest, by a line. para12e2 with the dividirtq li a between Lots Nos. 123 and 144, Section T, of tba ereinsfcor `mos;tioned Plan of Lots,oae M+ndr~xt thircy (130} feet •to Cazol;Str'ect; thene~ South fifty-asvtn (S7) degrasa tiftsen (LS) minutoe Wee't, along tha aogthorn llna of Carat Street, seventy 70} toot toy the place of a~Oxetbtit~• . :t aaTllC Lot No. 123,. SectLoa 2, and the waarorn t!p (10} ft•t f Lot No. 134, 8eetion A, of tl;e llan Ot Cumberland Manor, said lan b~•ing r¢cardod in the Sscorder'a Offiea at Ceriis~e, Penn- ylvan.ts; !`a,81#~n Book 2, page 71, 2tavlnq Chareon arcCted a oao cosy ponaa~coxa home known as N0, 1919 kaplo SUre•t, Herr u-~orler{d, Penhsylvar-ia. > >i ~enr-sylvanie SS . •{ '3t Cunnberland ~~ {n tlla offwe for the recording ~ Qwwis mbar' 1~na cou ..~.1lt~is ~Y' B04K ~.3~ PAGE.' (-? rya to ('~ '69. ~_ :e ~ ~ ~ ~ ` ~ .: n r ~ rl __ `T' r r~-- t ~ rr u7 ~,' .3 ^~ ~ -.l ~ ~ ~ ~,. > _ . :: oi0 -.. ~ C -°h- . ~; D . f11 D .. ~- ;~ .~ .. .~- a_ --c SHERIFF'S RETURN - REGULAR CASE NO: 2007-05312 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK NA TRUSTEE VS MEKEAL WILLIAM M ET AL TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE MEKEAL MARGARET E was served upon the DEFENDANT at 1515:00 HOURS, on the 12th day of September, 2007 at 1919 MAPLE STREET NEW CUMBERLAND, PA 17070 1~RT Tf r'IT 7"1TT T 1~RLIVLITT by handing to 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 Service Affidavit Surcharge 9~a~~o~ ~ So Answers: 1s.oo 16.32 /jam . 00 ~(~ 10.00 R. Thomas Kline ~00 4/ 4.32 09/13/2007 MILSTEAD & ASSOCIATES Sworn and Subscibed to before me this of By: ~- day De uty Sheri f A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-05312 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK NA TRUSTEE VS MEKEAL WILLIAM M ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says,. that he made a diligent search and inquiry for the within named DEFENDANT MEKEAL WILLIAM M _ but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 1919 MAPLE STREET MEKEAL WILLIAM M NOT FOUND as to NEW CUMBERLAND, PA 17070 WILLIAM IS DECEASED PER WIDOW. Sheriff's Costs: So answers: Docketing 6.00 Service . 00 ----- Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 4lZ y/6 ~ ~., ~ 21.0 0 00/00/0000 Sworn and Subscribed to before me this day of , A.D. MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No. 55.06894 Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. ' No.: 07-5312 Civil Term William M. Mekeal, Praeciue to Dismiss Defendant Margaret E. and Mekeal, Only from the Mort~a~e Foreclosure Action Margaret E. Mekeal, Defeadants. TO THE PROTHONOTARY: Kindly dismiss William M. Mekeal, Only as a Defendant from the above captioned Mortgage Foreclosure Action. ~` & ASSOCIATES, LLC .ante P. Fliakos, Esquire ID No. 94620 {00197357} C') ,(X} ~~ ~y~ W "?`,S a l_ ~G j^""3 v F 4 (~ E' ~ J ~ ~ ~ ~ ~r',...' `" ~. ..~ __., c~ ~, N ".~~..) t ~2y ~~ c.~ cx3--, MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee ;COURT OF COMMON PLEAS 701 Corporate Center Drive ~ CUMBERLAND COUNTY Raleigh, NC 27607, Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased 1919 Maple Street New Cumberland, PA 17070, and Margaret E. Mekeal 1919 Maple Street New Cumberland, PA 17070, Defendants. PRAECIPE FOR JUDGMENT, INREM, FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter Judgment, in rem, in favor of Plaintiff and against Margaret E. Mekeal, Defendant, for failure to file an Answer on Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $52,635.35 Interest 9/5/07 through 11 /26/07 1,171.96 Late Charges 48.94 Additional Corporate Advance 2,213.50 Additional Escrow Advance 3,593.60 TOTAL $59,663.35 ~ I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above and (2) that notice has been given in accordance with Rule 237.1. copy attached. Chrisovalante P. Fliakos, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: .2 7, a..e~ '7 s ~ d~ OTHONOTARY ~,,,~ ~ C ~ ~° ~ ~.. rr~ ~ ~ ~ -~ ~ ~ ~ ~ _ ~ -,.~ ,~ . > :i ;::~ Q.. ~ ~ „a Wy, e~ ~ .~ F „ ~ -t ~- ... ~. -..~ e^~ f,l ~.. ~ rj t ., ~wi `~i. f 1 J 4 MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Our file number: 55.06894 Citibank N.A. as Trustee, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, No.: 07-5312 Civil Term Vs. William M. Mekeal and Margaret E. Mekeal, Defendants. TO: Margaret E. Mekeal 1919 Maple Street New Cumberland, PA 17070 DATE OF NOTICE: October 9, 2007 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. {00196903} Page I of 2 .~ 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 claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 32 S. BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MILSTEAD & ASSOCIATES, LLC ~~ By: Chrisovalante P. Fliakos, Esquire ID No. 94620 Attorney for Plaintiff {00196903} Page 2 of 2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary To: Margaret E. Mekeal Citibank N.A. as Trustee, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased, and Margaret E. Mekeal, Defendants. NOTICE PURSUANT TO RULE 236 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: CHRISOVALANTE P. FLIAKOS, ESQ. #94620 MILSTEAD & ASSOCIATES, LLC 856-482-1400 Notice Pursuant To Fair Debt Collection Practices Act This is an attempt to collect a debt and any information obtained will be used for that purpose. C'S ~ -•.,t °' F °~ ~'~ r. r - ~ ~; . { ~ .~. _~ ~ ~ MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased, and Margaret E. Mekeal, Defendants. VERIFICATION OF NON-MILITARY SERVICE Chrisovalante P. Fliakos, Esquire, hereby verifies that she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, she has knowledge of the following facts, to wit: 1. that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldier' and Sailors' Civil Relief Act of Congress of 1940, as amended, 2. defendant, William M. Mekeal, Deceased, is over 18 years of age and resides at 1919 Maple Street, New Cumberland, PA 17070, 3. defendant, Margaret E. Mekeal, is over 18 years of age and resides at 1919 Maple Street, New Cumberland, PA 17070. Chrisoval to P. Fliakos, Esquire C7 C] ~; ~.., ~ ,...~%~ ~~ ~ ~~ ~r ~. ~~ ~ o~~r ~..~ ~ ~. • f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Citibank N.A. as Trustee, ~ CIVIL ACTION Plaintiff, NO.: 07-5312 Civil Term Vs. ' PRAECIPE FOR WRIT OF EXECUTION William M. Mekeal, Deceased ~ (Mortgage Foreclosure) and Margaret E. Mekeal, Defendants. TO THE PROTHONOTARY OF CUMBERLAND COUNTY: 1. Directed to the Sheriff of CUMBERLAND County; 2. Against the Defendant(s) in the above-captioned matter; 3. and index this writ against the Defendant(s) as follows: William M. Mekeal, Deceased Margaret E. Mekeal Real Property involved: 1919 Maple Street New Cumberland, PA 17070 Amount Due Interest from 11/27/07 to Date of Sale at $9.81 per diem (6%) $59,663.35 TOTAL (Costs to be added) DATE: November 26, 2007 Respectively submitted, Milstead &,,Associates, LLC _ /t n Chrisovalante P. Fliakos, Esquire Attorney for Plaintiff 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 i~ ~ c ~ ~ ~ ~ (~ ° c~ ~ i , ~ 1 N a~i '~ °~ ~? r"' -~ ~.::, . of °U~ r '~~ f ~ ti ~ r^ ~:.i .~--P C c~ ~ CY ~ ~, d ~c ~ r ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE SOUTHEASTERN CORNER OF CAROL STREET (FORMERLY JEFFERSON STREET) AND MAPLE STREET; THENCE SOUTH 32 DEGREES, 45 MINUTES EAST, ALONG THE EASTERN LINE OF MAPLE STREET, 130 FEET TO A POINT AT A 20 FEET ALLEY; THENCE NORTH 57 DEGREES, 15 MINUTES EAST, ALONG THE NORTHERN LINE OF A 20 FEET ALLEY, 70 FEET TO A POINT; THENCE NORTH 32 DEGREES, 45 MINUTES WEST, BY A LINE PARALLEL WITH THE DIVIDING LINE BETWEEN LOTS NOS. 123 AND 124, SECTION 2, OF THE HEREINAFTER MENTIONED PLAN OF LOTS, 130 FEET TO CAROL STREET; THENCE SOUTH 57 DEGREES, 15 MINUTES WEST, ALONG THE SOUTHERN LINE OF CAROL STREET, 70 FEET TO THE PLACE OF BEGINNING. BEING LOT N0. 123, SECTION 2, AND THE WESTERN 10 FEET OF LOT NO. 124, SECTION 2 OF THE PLAN OF CUMBERLAND MANOR, SAID PLAN BEING RECORDED IN THE RECORDER'S OFFICE AT CARLISLE, PENNSYLVANIA, IN PLAN BOOK 2, PAGE 73. HAVING THEREON ERECTED A ONE STORY PERMA-STONE HOME. Being known as 1919 Maple Street, New Cumberland, PA 17070 Taz Parcel Number: 26-23-0543-078 C~ '~ ° -n +~..+1~ ~~- i l ~~ ` ~ _ ... ... #~_~ k ,_i ~ 5 ~, . , =y ~' ~ '~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5312 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK N A AS TRUSTEE Plaintiff (s) From WILLIAM M MEKEAL DECEASED AND MARGARET E MEKEAL (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 $S9,6b3.35 L.L.$0.50 Interest FROM 11/27/07 TO DATE OF SALE AT $9.81 PER DIEM (6%) Atty's Comm Atty Paid $ 184.32 Plaintiff Paid Date: NOVEMBER 27, 2007 (Seal) Due Prothy $2.00 Other Costs <~ ~ 2 ur is R. Long, Prothonotary ~. -' By: C~ ,~,~~ (,~ ~ 1- Deputy REQUESTING PARTY: Name CHRISOVALANTE P FLIAKOS ESQ Address: 220 LAKE DRIVE EAST SUITE 301 CHERRY HILL, N J 08002 Attorney for: PLAINTIFF Telephone: (856) 482-1400 Supreme Court ID No. 94620 I MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, No.: 07-5312 Civil Term Vs. William M. Mekeal, Deceased ~ AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 and Margaret E. Mekeal, Defendants. STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Citibank N.A. as Trustee, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 1919 Maple Street, New Cumberland, PA 17070: 1. Name and address of Owners(s) or Reputed Owner(s): William M. Mekeal, Deceased Margaret E. Mekeal 1919 Maple Street 1919 Maple Street New Cumberland, PA 17070 New Cumberland, PA 17070 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known t 4. Name and Address of the last recorded holder of every mortgage of record: Citibank N.A. as Trustee (Plaintiff herein) 701 Corporate Center Drive Raleigh, NC 27607 5. Name and address of every other person who has any record lien on the property: None Known 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant 1919 Maple Street New Cumberland, PA 17070 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 Department of Domestic Relations Cumberland County Courthouse 13 N. Hanover Street Carlisle, PA 17013 I verify that the statements made in the 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. Chrisoval to P. Fliakos, Esquire Attorney for Plaintiff Date: November 26, 2007 ~ ....~ ~ ~, ~ ..; ~.~ ~ ___s ~ .;.. ~ 4 " ~" ', 3 ii ~ ( A x . ~.yy 4! ~ ~ ~ / ' Y ._.. i '--- L_ ~ .f=" i"~ ...r .. =~,. -.i" ,~ MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased, ~ NOTICE OF SHERRIF'S SALE OF and ~ REAL PROPERTY PURSUANT TO PA.R.C.P.3129 Margaret E. Mekeal, Defendants. TAKE NOTICE: Your house (real estate) at 1919 Maple Street, New Cumberland, PA 17070, is scheduled to be sold at sheriff's sale on March 5, 2008 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of $59,663.35 obtained by Citibank N.A. as Trustee. 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: 1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may ca11856-482-1400. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See notice on following page 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead & Associates at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market 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 Milstead and Associates at 856-482-1400. 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 may be entitled to a shaze of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Cazlisle, PA 17013 717-249-3166 55.06894 ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE SOUTHEASTERN CORNER OF CAROL STREET (FORMERLY JEFFERSON STREET) AND MAPLE STREET; THENCE SOUTH 32 DEGREES, 45 MINUTES EAST, ALONG THE EASTERN LINE OF MAPLE STREET, 130 FEET TO A POINT AT A 20 FEET ALLEY; THENCE NORTH 57 DEGREES, 15 MINUTES EAST, ALONG THE NORTHERN LINE OF A 20 FEET ALLEY, 70 FEET TO A POINT; THENCE NORTH 32 DEGREES, 45 NIINUTES WEST, BY A LINE PARALLEL WITH THE DIVIDING LINE BETWEEN LOTS NOS. 123 AND 124, SECTION 2, OF THE HEREINAFTER MENTIONED PLAN OF LOTS, 130 FEET TO CAROL STREET; THENCE SOUTH 57 DEGREES, 15 MINUTES WEST, ALONG THE SOUTHERN LINE OF CAROL STREET, 70 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 123, SECTION 2, AND THE WESTERN 10 FEET OF LOT NO. 124, SECTION 2 OF THE PLAN OF CUMBERLAND MANOR, SAID PLAN BEING RECORDED IN THE RECORDER'S OFFICE AT CARLISLE, PENNSYLVANIA, IN PLAN BOOK 2, PAGE 73. HAVING THEREON ERECTED A ONE STORY PERMA-STONE HOME. Being known as 1919 Maple Street, New Cumberland, PA 17070 Tax Parcel Number: 26-23-0543-078 r~ t ~r ~ ~U E~.f ,', -tc;, T7 t1`~, ~ ' {'ta ~ ~ t ~ s ~TM ~ . " f ~7 ~,.~fj3 ti ~ ~; ..,~ MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff (;itibank N.A. as Trustee, ~ COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY i Vs. No.: 07-5312 Civil Term _ William M. Mekeal, Deceased, ~ NOTICE OF SHERRIF'S SALE OF and ?REAL PROPERTY PURSUANT TO PA.RC.P.3129 Margaret E. Mekeal, Defendants. TAKE NOTICE: Your house (real estate) at 1919 Maple Street, New Cumberland, PA 17070, is scheduled to be sold at sheriff s sale on March 5, 2008 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Cazlisle, PA 17013 to enforce the Court Judgment of $59,663.35 obtained by Citibank N.A. as Trustee. 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: 1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for Plaintiff, back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may cal1856-482-1400. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See notice on following page 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead & Associates at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compazed to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriffthe full amount due on the Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400. 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 may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Baz Association 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 55.06894 ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE SOUTHEASTERN CORNER OF CAROL STREET (FORMERLY JEFFERSON STREET) AND MAPLE STREET; THENCE SOUTH 32 DEGREES, 45 MINUTES EAST, ALONG THE EASTERN LINE OF MAPLE STREET, 130 FEET TO A POINT AT A 20 FEET ALLEY; THENCE NORTH 57 DEGREES, 15 MINUTES EAST, ALONG THE NORTHERN LINE OF A 20 FEET ALLEY, 70 FEET TO A POINT; THENCE NORTH 32 DEGREES, 45 MINUTES WEST, BY A LINE PARALLEL WITH THE DIVIDING LINE BETWEEN LOTS NOS. 123 AND 124, SECTION 2, OF THE HEREINAFTER MENTIONED PLAN OF LOTS, 130 FEET TO CAROL STREET; THENCE SOUTH 57 DEGREES, 15 MINUTES WEST, ALONG THE SOUTHERN LINE OF CAROL STREET, 70 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 123, SECTION 2, AND THE WESTERN 10 FEET OF LOT NO. 124, SECTION 2 OF THE PLAN OF CUMBERLAND MANOR, SAID PLAN BEING RECORDED IN THE RECORDER'S OFFICE AT CARLISLE, PENNSYLVANIA, IN PLAN BOOK 2, PAGE 73. HAVING THEREON ERECTED A ONE STORY PERMA-STONE HOME. Being known as 1919 Maple Street, New Cumberland, PA 17070 Tax Parcel Number: 26-23-0543-078 MILSTEAD & ASSOCIATES, LLC BY: Heidi R. Spivak, Esquire ID No. 74770 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Citibank N.A. as Trustee, Plaintiff, Vs. William M. Mekeal, Deceased, and Margaret E. Mekeal, Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 07-5312 Civil Term Entry of Aapearance Defendant(s). ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff, Citibank N.A. as Trustee, in the above captioned matter. MILSTEAD & ASSOCIATES, LLC He di R. Spivak, Esquire Attorney ID No. 74770 {oousszi} n,y - ~^ t. :ab ~ ~~ ~b ' ~ `t7 `- i FZ j ~ - wE:. .~ '.s;`» C=S ~ ,,. _. _ _ r _.J _-1 L MILSTEAD & ASSOCIATES, LLC BY: Heidi R. Spivak, Esquire ID No. 74770 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased, Praecine to Satisfy Default Judsment and and ;Discontinue and End L ~ ;`s a ~~ ~4:~ _ ~_3 Margaret E. Mekeal, i ~ ~' ~~~ ~y ~ .~ nj Defendants . - = ~ f` "- ~ r.~. ~- r, ~ l _, ~ ~ TO THE PROTHONOTARY: ^^~*, ~• ~. . _: ~;- ~{ Kindly Satisfy the Default Judgment filed on November 27, 2007 in the amohnt off' $59,663.35 and Discontinue and End the above captioned Mortgage Foreclosure action without Prejudice. MILSTEAD & ASSOCIATES, LLC 1~ ei i R. Spivak, Esquire Attorney ID No. 74770 {oozi3azs} -~ c` r.., c~ {:.3 . ~~ ~ ,~; ~ ; ~..3 _ ; ' . - ..w~. ~ f z ~ °• ~3 Citibank N.A. as Trustee VS William M. Mekeal, Deceased and Margaret E. Mekeal In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-5312 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Chrisovalante Fliakos. Sheriff s Costs: Docketing $30.00 Poundage 1,121.60 Advertising 15.00 Posting Handbills 15.00 Law Library .50 Prothonotary 2.00 Mileage 30.72 Levy 15.00 Surcharge 20.00 Share of Bills 16.17 $1,265.99 So Answers: ~--~~~. R. Thomas Kline, Sheriff B~ v'Cfi Real Estate S rgeant ~ S~ c~ Ga ~ o .~ ~~..1 d :s 4 / `~ MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON YLLA~ CUMBERLAND COUNTY Plaintiff, No.: 07-5312 Civil Term Vs. William M. Mekeal, Deceased ~ AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 and Margaret E. Mekeal, Defendants. STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Citibank N.A. as Trustee, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 1919 Maple Street, New Cumberland, PA 17070: 1. Name and address of Owners(s) or Reputed Owner(s): William M. Mekeal, Deceased Margaret E. Mekeal 1919 Maple Street 1919 Maple Street New Cumberland, PA 17070 New Cumberland, PA 17070 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None Known 4. Name and Address of the last recorded holder of every mortgage of record: Citibank N.A. as Trustee (Plaintiff herein) 701 Corporate Center Drive Raleigh, NC 27607 5. Name and address of every other person who has any record lien on the property: None Known 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant Department of Domestic Relations 1919 Maple Street Cumberland County Courthouse New Cumberland, PA 17070 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I verify that the statements made in the 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. Chrisoval to P. Fliakos, Esquire Attorney for Plaintiff Date: November 26, 2007 MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856)482-1400 Attorney for Plaintiff Citibank N.A. as Trustee, ~ COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. No.: 07-5312 Civil Term William M. Mekeal, Deceased, ~ NOTICE OF SHERRFF'S SALE OF and ~ ~~ PROPERTY PURSUANT TO PA.RC.P.3129 Margaret E. Mekeal, Defendants. TAKE NOTICE: Your house (real estate) at 1919 Maple Street, New Cumberland, PA 17070, is scheduled to be sold at sheriff s sale on Mazch 5, 2008 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Cazlisle, PA 17013 to enforce the Court Judgment of $59,663.35 obtained by Citibank N.A. as Trustee. . 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: 1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for ' Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may ca11856-482-1400. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the Sale. (See notice on following page 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 Sheriffl s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Milstead & Associates at 856-482-1400. 2. You maybe able to petition the Court to set aside the Sale if the bid price was grossly inadequate compazed to the market 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 Milstead and Associates at 856-482-1400. 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 tune, the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Cazlisle, PA 17013 717-249-3166 55.06894 ALL THAT CERTAIN LOT OR PIECE OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THE SOUTI~ASTERN CORNER OF CAROL STREET (FORMERLY JEFFERSON STREET} AND MAPLE STREET; TI~NCE SOUTH 32 DEGREES, 45 MINUTES EAST, ALONG THE EASTERN LINE OF MAPLE STREET, 130 FEET TO A POINT AT A 20 FEET ALLEY; TI~NCE NORTH 57 DEGREES, 15 MINUTES EAST, ALONG THE NORTHERN LINE OF A 20 FEET ALLEY, 70 FEET TO A POINT; THENCE NORTH 32 DEGREES, 45 NIlNUTES WEST, BY A LINE PARALLEL WITH THE DIVIDING LINE BETWEEN LOTS NOS. 123 AND 124, SECTION 2, OF THE HEREINAFTER MENTIONED PLAN OF LOTS, 130 FEET TO CAROL STREET; THENCE SOUTH 57 DEGREES, 15 MINUTES WEST, ALONG THE SOUTHERN LINE OF CAROL STREET, 70 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 123, SECTION 2, AND THE WESTERN 10 FEET OF LOT NO. 124, SECTION 2 OF THE PLAN OF CUMBERLAND MANOR, SAID PLAN .BEING RECORDED IN THE RECORDER'S OFFICE AT CARLISLE, PENNSYLVANIA, IN PLAN BOOK 2, PAGE 73. HAVING THEREON ERECTED A ONE STORY PERMA-STONE HOME. Being lmown as 1919 Maple Street, New Cumberland, PA 17070 Taa Parcel Number: 26-23-0543-078 WRIT OF EXECUTION and/or ATTACHMENT ~' , COMMONWEALTH OF PENNSYLVANIA) N007-5312 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK N A AS TRUSTEE Plaintiff (s) From WILLIAM M MEKEAL DECEASED AND MARGARET E MEKEAL (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 $59,663.35 L.L.$0.50 Interest FROM 11/27/07 TO DATE OF SALE AT $9.81 PER DIEM (6%) Atty's Comm Atty Paid $ 184.32 Plaintiff Paid Date: NOVEMBER 27, 2007 (Seal) REQUESTING PARTY: Name CHRISOVALANTE P FLIAKOS ESQ Address: 220 LAKE DRIVE EAST SUITE 301 CHERRY HILL, N J 08002 Attorney for: PLAINTIFF Telephone: (856) 482-1400 Due Prothy $2.00 Other Costs ~t/ w~~~ ~ ~i1M u is R. Long, Prothonotary ~,.. ~ _ /~~ ~ By: ,,, Laf )1~.l,~ Deputy Supreme Court ID No. 94620 Real Estate Sale #75 On November 30, 2007 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA Known and numbered as 1919 Maple Street, New Cumberland, more fully described on Exhibit "A" ~~/~ filed with this writ and by this reference ~~ ,,4 incorporated herein. Date: November 30, 2007 By: ~ r~ ~-- .:. __ ~.. Real Estate ergeant