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Home My WebLink About07-5404Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 7l 7.234.4178 mtg@pkh.com MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW ROBERTA M. KLEIN ACTION OF MORTGAGE FORECLOSURE Defendant ~~ THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR~THE PURPOSE OF COLLECTING THE DEBT. 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. .. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE 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 IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (2I5) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. ROBERTA M. KLEIN, Defendant CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. ROBERTA M. KLEIN, Defendant ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is MIDFIRST BANK, a corporation whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. Defendant, ROBERTA M. KLEIN, is an adult individual whose last known address is 4830 BRIAN ROAD MECHANICSBURG, PA 17050. 3. On or about, Apri109, 1999, the said Defendant executed and delivered a Mortgage Note in the sum of $92,800.00 payable to COLUMBIA NATIONAL INCORPORATED, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1533, Page 250 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and was recorded in the aforesaid County in Mortgage Book 731, Page 3685. The Mortgage was subsequently assigned to MIDFIRST BANK and will be sent for recording. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 4830 BRIAN ROAD MECHANICSBURG, PA 17050 and is more particularly described in Exhibit "B" attached hereto. ~_~yD~/ CIVIL ACTION -LAW 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on Mazch O1, 2007 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $17.44 per day From 02/01/2007 To 10/01/2007 ( based on contract rate of 7.0000%) Accumulated Late Charges Late Chazges $31.11 From 03/01 /2007 to 10/01 /2007 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $90,956.60 $4,220.48 $495.16 $217.77 $920.14 $4,547.83 $101,357.98 **Together with interest at the per diem rate noted above after October O1, 2007 and other chazges and costs to date of Sheriff s Sale. The attorney's fees set forth above aze 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 attorney's fees will be chazged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. 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. 12. Prior to the commencement of this foreclosure action, Plaintiff sent to Defendant written notice dated May 16, 2007, notifying her of the fact of default, amount needed to cure the delinquency and that if the account was not timely reinstated, a foreclosure action would be filed. A copy of the May 16, 2007 notice is attached hereto and marked Exhibit "C". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.0000% ($17.44 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By; ~ __ - ~ PUR LL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 03802279 Multistate NOTE PFIA 4u No. 441-5942819-703 April 9, 1999 IDaul 4830 Brian Rd. Mechanicsburg, PA 17055 Ism Mldressl i. PARTIES "Borrower' mu~vts earn person signing at the end of this Note, and the person's successors and assigns. 'Lender' ttxaas Columbia National Incorporated and its sucY:rssors and assigns. 2.80RROWER'S PROl1IISE TO PAY; Il\'fERE.Sf In return for a loan received from lender, Borrower promises w pay the principal stun of Ninety Two Thousand Eight Hundred and 00/100 Dollars (U.S. $ 92 , 800.00 ), plus intrust, to the order of !.coder. Intcrcct will be charged on unpaid principal, from tlu date of disbursement of the loan proceeds by Lrtrder, at the rate of Seven and No-Thousar~itha pen:ent ( 7.0 0 0 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar recarrity instrument that is dated the same date as this Note and tailed the "Security Instrument,"The Security Instrument protects the Larder Crom losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Titrle Borrower shall make a payment of principal and interest to Leader on the first day of each month begirmirtg on June 1 , 1999 .Any principal and interest trmaining on [hc first day of May , 2029 ,will be due on that date, which is calla! the "Maturity Date." (B) Place Payment shall be made ~ P.O. I;ox 3050, Columbia, MD 21045-6050 or ai such place as Lender may designate in writing by notitx to Borrower. (C) Arnamt Eadi rtatitlily payment of principal and interat will bt: in the amount of U.S. $ 617.41 .This amount will be part of a larser monthly payment rtxluirod by the Security Instrument, tha[ shall be applied to principal, interest and other items in thr ordt7 described in the Security Irtstrnrnent. (U) Allongc to this Note for payment adjustments !f an allonge providing for paymem adjustments is exetarted by Borrower together with this Note. the covenants of the allonge shall be intorpotated into and shall amend and supplement the wvenants of this Note as if the allonge were a part of this Note. (Check applicable boxJ OGradtiated Payntatt Allongc QGrowing Equity Allongc QOther (specify) 5. BORROWER'S RIGHT TO PREPAY Borrower has the right tts pay the debt evidenced by this Note, >r wholt or in part, without Marge or penalty, on the first day of any month. Leader shall accept prepayment oa other days provided that borrower pays interest on ~e amount prepaid for the remainder of the month to the extent required by [,ender acrd permitted by regulations of the Secretary. If Borrower makes a partial prepayment, rhea will be no changes in the due date or in the amount of the monthly payment althea Lender agrees in writing to those changes. FFIA MWlipale Ftical Rafe Note -10/95 -1R VFAF MORTGAGE FORMS •16001571.7291 •q- J1 I ~'~ Wps 7 nl 2 k"nrw %~ 83195459 ` ~ t l Cr' I ~ 6.140RRUVYER'S FAILURE TU PAY (A) Late Charge for Overdue Payments if Lender has not received the foil momiily paymwt required by the Saurity ]nstrumeat, as described in Pazagraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lcnda may collect a late charge in [he amount of Four and No-Thousandths percent ( 4.000 `16) of the overdue amount of each paytnatt. (13) Default If Borrowu defaults by failing ro pay in full any monthly itaytnettt, then Leader tray, except as limited by regulations of the Secretary in the case of payrrtettt defaults, require innrtediate paytrtent in full of the principal balance remaining due and all accrued interest. Lender ntay choose not to exercise this option without waiving its rights in the event of any subsequent default. In many cirratntstan+xs regulations issued by the Secretary will limit Lender's rights to rcyuire inurtediale paymatt in full in the case of paytnrnt defaults. This Note dogs trot authorize acceleration when not permitted by HUD regulations. As used in this Note, "Sccr~ary" tneans the Secraary of Housing and Urban Development or his or her designer. ((~ Payment of Costs and Expenses If Lender has required intm~iatc payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not ptvhibitod by applicable law. Such fees and costs shall beaz interest from the date of disbursement at [he same rate as the principal of Ibis Note. 7. WAIVERS Burrower and any other person who has obligations under this Note waive the rights of pre,9entment and notice of dishonor. "Presentment' means the rigbt to require Lender ro demand payment of amounts due. "Notice of dishonor" means tht right to reyuire Lender to give notice to other persons that amounts due have not been paid. 8. GIVING ON NOT'fCES Unless applicable law requires a different method, any notice that mast be given to Harrower under this Note will be given by delivering it or by mailing it by first class mail ro Borrower at the property address dove or at a different address if Borrower has given Lender a noticx of Borrower's different address. Any notice that must be given ro Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9, OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to koep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, sunKy or cttdorser of this Nate is also obligated to du these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser ol'this Note. is also abligatcxi to keep all of thr promises made in this Note. Lender may enfottx its rights under this Note against earn person individually or against all signatories together. Any one person signing this Nate may be required ro pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrows ~cepts and agrees to the ter wvenan in this Note. . , _ ~/ ~ ~ ~~<<~< <~ !~ ; C.~- (Seal) ~ (~) oberta M. Klein ~ .aortut-~er _~~ _ (Seal) _ -norrctwrr _ (Seel) _ •ROnDWEr _ (Seal) _ -ttom~wer _ (Seal) •Bprrowtr _ (Seal) -ttOrrpWOf .. (~) •ltorrower -1 R 19601) v~p 2 w 2 ALL THAT CBRTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with survey of William B. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the southerly line of Brian Road, which point is flighty-Five (85) feet east of Charles Road, thence along the southerly line of Brian Road south Eighty-Five (85) degrees Thirty (30) minutes east Fifty-six and Sixty-four one-hundredths (56.64) feet to a point; thence continuing along Brian Road south Eighty-Three degrees Twenty-Three minutes east Bight and Thirty-Six one-hundredths (8.36) feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same south four (4) degrees Thirty (30) minutes crest One Hundred Forty-six and Thirty-nine one-hundredths (146.39) feet to the northerly line of Lot No. 18, thence along the same south Eighty-seven (87) degrees Thirty-two (32) minutes eleven (11) seconds west thirty and twenty-three one-hundredths (30.23) feet to a point; thence north twenty-five (25) degrees fifty (50) minutes five (5) seconds west Sixty-nine and Forty-six one-hundredths (69.46) feet to a point; thence north four (4) degrees thirty (30) minutes east ninety and forty one-hundredths (90.41) feet to the point of BEGINNING. BEING Lot No. 48, Block D on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book e, Page 11. HAVING THBR8ON BRECTBD a one story brick dwelling known and numbered as 4830 Brian Road. GeneraA~>~$rall~f6~MIET E=w11~1r80gglD MORTGAGE REFERRAL WtgnaOaY, May 1B. 7.007 CQL R~BERTA M KLE1N 4830 BRIAN RD MECHANICSBURG RE: Loan * ~4262p87 pear Moxtc3agor (s) Midland Mortgage Ca. the above premises, holdex. [~R'fl~lED - .a m m s •----- m ~.oq.: PA T-407 P.O1/02 F-661 1VI idland 1V1 ortgage C o . 999 N.W- GTapd Boulevard Suite 11U Olclahama City, Cklsho=aa 73118 lnonc• (4Di) ~2s-32D0 Fri: (4DS) ~Z6.1779 ^ 17450-3013 A _ c ~°~ ? ~po~psF.» m ~~ o """"'_" ~~ ca arAaax,e. t~. --•- ~s the holder of a Mortgage and a Note on ox is the rnortgaga servicing agent for such As of the date of this notice, T>~a >a0>R~c~-G>~ IS I» D>sFJ-[JI'~' ST7lTVS because of nonpayment of the following: Payments, lace charges, aad advaaces from $1112407 through g114r2p47 The total amogunt ~ w xego ire a t eats a if3 a S2, 12.151 ; or iti other words get can ht u in y ur p ym All payments re€erxad to in this notice must be in the form of cas}lier's or certified check made payable to Midland Mortgage c3126a8888ustnot rlaterga hen P the B da es88 and ptimesmaspecified 7 herein. In the event: payment, as specified in the proce¢ding paragraph, is not madt idIT~O:I'i T>~Zit'1'Y (3D) DAY9 from the date of this letter, it is the t.ntent~on of the holder of the moragable through this company, to accel¢xate (declare due and p y immeda.ately the entire loan) the mortgage obl~.gation and all other lawful charges and instruct our attorney to ~.nstitute ~soAZOaas aoaacr.osv>Ra p>xocaa~~>sa. Click here to unlock TaIIPDF.NET I / ~ ~ ~ /~ l/.i Generat~aIIET ~~Akl~ylit~llD WORTGAGE REFERRAL T-407 P.02/02 F-661 t a) If you wish to C'fJZRB T~8 ngg,AULT within thirty c 3a ) days from the date of Lhis letter, you must pay the TOT74~. A Di]E stated above, plus an additional monthly installment if payment is made after the lsz day of the ~ e ~n~ o nd snot uittCludediabove~ laze charge if due at time P ~' a nt aid more than A y~~ ~ is due wj.th each raorrgage p y~ P fifteen (15) days after the due date. Xour current monthly installtnexit is 5777_sti (b) If paymsAC ~.s made ]LFT$3t TRIRTY (30) DAYS f=oAt the date of this letter. but R8FOx8 FOxBCLOSQit): wi11Na1scG iricludebthe started, cha amount you will have to pay es then due, plus. regular mantrily a.nscallments and late charq if incurred, any ATTO)RNBY' S 8R amour CT NOan TRb~ g5 oi~ta red aby title report costa, whic~ Co. at conxactxrig Midland Moxtgag 1-800-552-3000. 1-HT]iR FORgCLOSVR>a pgOCgapING 8715 EHBN START3D, You have the right to STO>? txie foreclosure aCLibA 11Ay c~.me up LO OAT>G l7•) Roux asFOex mheunto d e care the ftime~ swRhR h8sha11Lanclude Yall the en it 8 es, together w~.th delinquent installments and uri aid late chatq it>t#SON#RL~ i,R[#11L FRES #CT>if#LLY 1N ~~ ch ~amourit can be obLaisced related co the foreclosure aceiC~: at 1_ga0-552-3000. by caritacting Midland Mortgag the Should you F7~~i~ to reinstate the loan as outlined above, mortgage Premist$ will be SoLA S`T 883RLOF~ele~A~ ( 1)chwesks take place approximately seven (7} tollawzx1g S>i:RYICB of the Cotnplatnt iri Mortgage Foreclosure, at which time your Q1iIN8FtS8Sp interest is mortga4oceedinQss will be TE1t>sllti71x8A- and thereafter, if occupied, p taken to D8TAi>1i ppSggSSXON of the zeal estate. You have the r~ghz co A>zFID~J-DTCB TR8 ~natitutioxl ox T>81-NSFZRA T>8R p QOp gaT9 and subject co the existing the SJ11L8 RIGIiT TO CII>s<LZ TK8 ~fR>il~VLT a same limitation and requiremeAts. You may CT1A>Ir pgFA11I.T8 year. Upon curs of a as if there had been ~YONg oA your' behalf . Lp~-N with another lendsAq to another person, under That person ua.ll have s you have, subject to the up to three l3} times in any default you will bs iri the same NO DgF~QT.T. A default may be calendar pos~.ta.on cured bit loan was in default at the t~.me Midland are required co advise you that this debt collector, Ibis is an attempt to infors-aLioA obtained will be u$ed fox Please note that rf the began servxc~.ri4 lt. we com~aunication is from a collect a debt, and any that purpose. Sincerely. Midland Mortgage Co_ Collection Department +X}282a87 Click here to unlock TaIIPDF.NET COMPANY NAME: MIDFIRST BANK VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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. ~ a~ Title ~~ President N .~ w y o F ~' a '~.. ,~ ~=' as r= ~, n `;: ~` ~~~~ ~..p N ~-.+! .~' G!T V SHERIFF'S RETURN - NOT FOUND Y CASE N0: 2007-05404 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MIDFIRST BANK VS KLEIN ROBERTA M 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 - b unable to locate Him in his bailiwick. /'Y /1T RT1T T T1~TT Tl1(1TlT T/1T]L1 ut was He therefore returns the the within named DEFENDANT OCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 r"o/30l0 ~ ~/ 21.0 0 So answer ` R. Thomas Kline Sheriff of Cumberland County PURCELL KRUG HALLER 10/04/2007 Sworn and Subscribed to before me this day of A.D. NOT FOUND as to SHERIFF'S RETURN - REGULAR ti '";CASE N0: 2007-05404 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS KLEIN ROBERTA M STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KLEIN ROBERTA M the DEFENDANT at 1020:00 HOURS, on the 1st day of October 2007 at 4830 BRIAN ROAD MECHANICSBURG, PA 17050 by handing to ROBERTA M KLEIN 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 13.44 Affidavit .00 Surcharge 10.00 .00 l b J3C~L~ 7 ~ 41.4 4 Sworn and Subscibed to before me this day So Answers: ~~~ '~ r R. Thomas Kline 10/04/2007 PURCELL KRUG HALLER By: eputy Sheriff of A.D. MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA ROBERTA M. KLEIN, VS. DEFENDANT(S) CIVIL ACTION LAW NO. 07-5404 CIVIL MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) ROBERTA M. KLEIN for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff s damages as follows: Unpaid Principal Balance $90,956.60 Interest $4,220.48 Per diem of $17.44 From 02/01/2007 To 10/01 /2007 Accumulated Late Charges $495.16 Late Charges $217.77 ($31.11 per month to 10/01 /2007) Escrow Deficit $920.14 5% Attorney's Commission $4,547.83 ~,~,.n •~ '~'r TOTAL $1~A~ _~5:9~8- ~ >o~ 35'7. 9 P Oli F• **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriffs Sale. PURCELL, KRUG & ER By -- Leon P. Haller PA D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~9 a w ~C ;J °'P ~° ~ ~, 0,,. 4 ~1 ~ ~ ~ ~ ~~ -..r -r~,.. ~ .,,,.~ ~ <- ~ ;,; ; U~ ~ ... , ~ ?; MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW NO. 07-5404 CIVIL ROBERTA M. KLEIN, DEFENDANT IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ~ day of 20 ~~ ~ 'V1 No Public LEON P. HALLER, SQUIRE COMMONWEALTH OF PENNSYLVANIA Notarial Seal Traci M. Bernstein, Notary Public City OF Harrisburg. Dauphin County My Commission E~ires Aug. 21, 2011 Member, Pennsylvania Association of Notaries ~' ~. ,.~. ~ a~f:~ ~ ~ . ~ ~_. -~, t~ ~ om ~~ n ` W. ` ~ .?.4.,F ...h'^ '. L'_ ~ .,. ~.. J -- = _9 ~ `"G MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA Vs. ROBERTA M. KLEIN, CIVIL ACTION LAW NO. 07-5404 CIVIL IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on October 29, 2007 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. # 157 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 DEFENDANT(S) ..,.. . ~, ~` £, ~~w:t `~ ~. ~,~ ~ ' f ~i7 ;J~ . ~.+ .~ ' l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW AT NO. 07-5404 CIVIL MIDFIRST BANK, Total Judgment Amount $101,357.98 PLAINTIFF Interest $2,703.20 . Per diem of $17.44 to sale VS. date 3/5/2008 Late Charges $528.87 ROBERTA M. KLEIN, $31.11 per month to sale DEFENDANT(S) date 3/5/2008 Escrow Deficit $1,931.20 Property Inspection $144.00 TOTAL WRIT $106,665.25 *Plus additional interest, late charges and other costs to date of sheriff s sale. SALE DATE: Wednesday, March 05, 2008 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION -MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: November 21, 2007 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. # 15700 WRIT OF EXECUTION -MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 4830 BRIAN ROAD MECHANICSBURG, PA 17050 Date: PROTHONOTARY/CLERK CNIL DIVISION BY DEPUTY O ALL THAT CERTAIN piece or pazcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particulazly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' S" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHAIVICSBURG, PA 17050 BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4/12/99 in Cumberland County Deed Book 197, Page 323, granted and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF ROBERTA M. KLEIN ON JUDGMENT N0.07-5404 CIVIL ASSESSMENT NO. 10-21-0279-275 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ C ~ ~ ~ ~ ~ a ~ ~ ~ d ~ ~ ~- ~' O ~ 1 h `C W C ~1 C~ 7 c rU ~. rr-, _ -,~ ~ .~ '~ ~~ r~- .. ~ :1 ~~ ~; _ ~ , "~ f"'§ -~ ~' - a7°" ~ (` T, ;~ C7 _ _..,,~ . "'ti .. ~ ~ ~ "" C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5404 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK Plaintiff (s) From ROBERTA M KLEIN (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$101,357.98 L.L.$0.50 Interest PER DIEM OF $17.44 TO SALE DATE 3/05/08 $2,703.20 Atty's Comm Atty Paid $181.44 Due Prothy $2.00 Other CostsLATE CHARGES $528.87 $31.11 PER MONTH TO SALE DATE 3!5/08 ESCROW DEFICIT $1,931.20 PROPERTY INSPECTION $144.00 Plaintiff Paid Date: NOVEMBER 26, 2007 (Seal) REQUESTING PARTY: Name LEON P HALLER, ESQ Address: 1719 NORTH FRONT STREET HARRISBURG PA 17102 Attorney for: PLAINTIFF Telephone: (717)234-4178 5 ~~ urtis R. Long, Prothonotary By: ~6L~ ~,c~~•J Deputy Supreme Court ID No. 15700 MIDFIRST BANK, VS. ROBERTA M. KLEIN, PLAINTIFF DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-5404 CIVIL IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 4830 BRIAN ROAD MECHANICSBURG, PA 17050: 1. Name and address of the Owner(s) or Reputed Owner(s): ROBERTA M. KLEIN 4830 BRIAN ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: May Department Stores 111 Boulder Industrial Drive Bridgeton, MO 60344 Ron Z. Opher, Esquire P.O. Box 2245 Southeastern, PA 19399-2245 Hampden Township 230 South Sporting Hill Road Mechanicsburg, PA 17050 Keith O. Brenneman, Esquire Snellbaker & Brenneman 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 ,.. 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Michael McLaughlin 6135 Westover Drive Mechanicsburg, PA 17050 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANTlOCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller PA I.D. # 157 0 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 21, 2007 C~ rv C ~ p r ~ • ~~ = '' ' '"~ I'7~ T3 ~ ~~ ~ yg'j Pi"' :.~~ .. _T~ ``~ ~ .~7 w -.~ MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERTA M. KLEIN, DEFENDANT(S) CIVIL ACTION LAW IN MORTGAGE FORECLOSURE NO. 07-5404 CIVIL NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: Wednesday, March 05, 2008 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 4830 BRIAN ROAD MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 07-5404 CIVIL JUDGMENT AMOUNT $101,357.98 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ROBERTA M. KLEIN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for ezample, to banks that hold mortgages and municipalities that are owed tazes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's.- Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or pazcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Chazles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' S" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4/12/99 in Cumberland County Deed Book 197, Page 323, granted and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF ROBERTA M. KLEIN ON JUDGMENT N0.07-5404 CIVIL ASSESSMENT NO. 10-21-0279-275 C3 ~ ~ G- ~_~ ~_, -rt ..~ ;~~ ~ ~~ ~ :.i .. J ` ' ~ f'T 1 MIDFIIrST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW NO. 07-5404 CIVIL ROBERTA M. KLEIN, DEFENDANT(S) IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 1 ~ ~3~ x00-7 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, -which mailing receipts are attached. Service addresses are as follows: ROBERTA M. KLEIN 4830 BRIAN ROAD MECHANICSBURG, PA 17050 May Department Stores 111 Boulder Industrial Drive Bridgeton, MO 60344 Ron Z. Opher, Esquire P.O. Box 2245 Southeastern, PA 19399-2245 Hampden Township 230 South Sporting Hill Road Mechanicsburg, PA 17050 Keith O. Brenneman, Esquire Snellbaker & Brenneman 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 Michael McLaughlin 6135 Westover Drive Mechanicsburg, PA 17050 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 By PURCELL, KRUG & HAL R Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER ]OHN W. PURCELL ]R. ]ILL M. WINEKA NICHOLE M. STACEY O'GORMAN LISA A. RYNARD LATOYA C. WINFIELD 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234.4178 FAx (717) 233-1149 ROBERTA M. KLEIN 4830 BRIAN ROAD MECHANICSBURG, PA 17050 May Department Stores 111 Boulder Industrial Drive Bridgeton, MO 60344 Ron Z. Opher, Esquire P.O. Box 2245 Southeastern, PA 19399-2245 Hampden Township 230 South Sporting Hill Road Mechanicsburg, PA 17050 Keith O. Brenneman, Esquire Snellbaker & Brenneman 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 Michael McLaughlin 6135 Westover Drive Mechanicsburg, PA 17050 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 HERSHEY (717) 533.3836 JOSEPH NISSLEY (1910.1982) JOHN W.PURCELL VALERIE A. GUNN O( Counsel NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. sy: Leon P. Haller PA I. .15700 Attorney for Plaintiff MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERTA M. KLEIN, DEFENDANT(S) CIVIL ACTION LAW NO. 07-5404 CIVIL IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: Wednesday, March 05, 2008 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 4830 BRIAN ROAD MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 07-5404 CIVIL JUDGMENT AMOUNT $101,357.98 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ROBERTA M. KLEIN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' S" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4/12/99 in Cumberland County Deed Book 197, Page 323, granted and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF ROBERTA M. KLEIN ON JUDGMENT N0.07-5404 CIVIL ASSESSMENT NO. 10-21-0279-275 7160 3901 9845 2613 0339 TO: ROBERTA M. KLEIN _ 4830 BRIAN ROAD ~~ MECHANICSBURG, PA 17050 SENDER: NOS 03/05/08 REFERENCE: MIDLAND/KLEIN RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees p ~ Q US Postal Service Receipt for Certified Mail No Insurance Coverage Provided ~o Not Use for International Mail PO~7MARK ~ DATf{ ,.~ ~ ~a ';. ~~ "~ N ,~ ~ J .~____~ .MIDLAND MORTGAGE COMPANY v. ROBERTA M. KLEIN Cumberland County Sale 3/5/2008 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ROBERTA M. KLEIN 4830 BRIAN ROAD MECHANICSBURG, PA 17050 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Michael McLaughlin 6135 Westover Drive Mechanicsburg, PA 17050 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 ,~ i r~ ~ j ., ~`n1, c~ ~~~~ ~; ~a ~ z ~ 7 PIENEY H(IVyE_5 02 1A ~ 01.05° 0004353871 NOV30 2007 MAILED FROM ZIP CODE 1 71 02 .MIDLAND MORTGAGE COMPANY v. ROBERTA M. KLEIN Cumberland County Sale 3/5/2008 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: TENANT/OCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Ron Z. Opher, Esquire P.O. Box 2245 Southeastern, PA 19399-2245 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: May Department Stores 111 Boulder Industrial Drive Bridgeton, MO 60344 c~; ~~ ~'~i~ °~~A~~~ . ? ® I WTNEY B(Nfl/E5 0004353871 ~ O~pO~O MAILED FROM ZIP CODE 1 71 02 •MIDLAND MORTGAGE COMPANY v. ROBERTA M. KLE1N Cumberland County Sale 3/5/2008 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Hampden Township 230 South Sporting Hill Road Mechanicsburg, PA 17050 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Keith O. Brenneman, Esquire Snellbaker & Brenneman 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 ~ ~.. g'~P ~'F ~~ J'\ h ', 1 ~ ~ v~TNEV eoa!~~ $ 02.10° 02 1A r10V30 200? 0004353871 MAILED FROM ZIPGODE 17102 ~- ~, ~~ rv c--~ _ ~~~?~ _' ~ `r ~. _ r =:~ p; ~, <=- w ..? ~ ~ ~ -'~` K COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which MIDFIRST BANK is the grantee the same having been sold to said grantee on the 11TH day of JUNE A.D., 2008, under and by virtue of a writ Execution issued on the 26TH day of NOV, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, ,2oo7_vumber 5404, at the suit of MIDFIRST BANK against ROBERTA M KLEIN is duly recorded as Instrument Number 200823518. IN TESTIMONY WHEREOF, I have hefeunto set my hand a~ seal of said office this ~~ day of A.D. ~~z~ Deeds Deeds, CutibeAmd County, Ceifre, PA Men E h FkM Monday d ,fen. 2010 Midfirst Bank VS Roberta M. Klein In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-5404 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 27, 2007 at 1945 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: Roberta M. Klein, by making known unto Roberta Klein, personally at 4830 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania and its contents and at the same time handing to her personally the said true and correct copies of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to Iaw, states that on January 10 2008 at 2101 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 Roberta M. Klein located at 4830 Brian Road, Mechanicsburg, 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: Roberta M. Klein by regular mail to her last known address of 4830 Brian Road, Mechanicsburg, PA 17070. These letters were mailed under the date of January 08, 2008 and never returned to the Sheriff 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 June 11, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon P. Haller, on behalf of Midfirst Bank. It being the highest bid and best price received for the same, Midfirst Bank of 999 N.W. Grand Blvd., Suite 100, Oklahoma City, OK 73118, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,004.26. Sheriff s Costs: Docketing $30.00 Poundage 19.30 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2, 00 Mileage 23.04 Levy 15.00 Surcharge 20.00 Post Pone Sale 20.00 Law Journal 355.00 Patriot News 350.75 Share of Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,004.26 So Answers: ~1 ~~~ R. Thomas Kline, Sheriff ,., Real Estate rgeant / 7~/s~b p ~' J~' ~(.~ a- yv~ d~. ~y~~ 2 ~ ~ ~, i3 T MIDFIRST BANK, VS. ROBERTA M. KLEIN, ,~ Y PLAINTIFF DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA CIVIL ACTION LAW NO. 07-5404 CIVIL IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 4830 BRIAN ROAD MECHANICSBURG, PA 17050: 1. Name and address of the Owner(s) or Reputed Owner(s): ROBERTA M. KLEIN 4830 BRIAN ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: May Department Stores 111 Boulder Industrial Drive Bridgeton, MO 60344 Ron Z. Opher, Esquire P.O. Box 2245 Southeastern, PA 19399-2245 Hampden Township 230 South Sporting Hill Road Mechanicsburg, PA 17050 Keith O. Brenneman, Esquire Snellbaker & Brenneman 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Michael McLaughlin 6135 Westover Drive Mechanicsburg, PA 17050 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 4830 BRIAN ROAD MECHANICSBURG, PA 17050 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein aze made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller PA I.D. # 157 0 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 21, 2007 MIDFIRST BANK, VS. ROBERTA M. KLEIN, TAKE NOTICE: IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION LAW NO. 07-5404 CNIL DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 05, 2008 TIlVIE: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 4830 BRIAN ROAD MECHANICSBURG, PA 17050 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 07-5404 CIVIL JUDGMENT AMOUNT $101,357.98 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ROBERTA M. KLEIN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for ezample, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MU5T ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Baz Association 32 South Bedford Street Cazlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Cazlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you aze awaze of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding pazagraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN piece or pazcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Chazles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' S" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4/12/99 in Cumberland County Deed Book 197, Page 323, granted and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF ROBERTA M. KLEIN ON JUDGMENT N0.07-5404 CIVIL ASSESSMENT NO. 10-21-0279-275 ' ~ , , ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N007-5404 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK Plaintiff (s) From ROBERTA M KLEIN (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$101,357.98 L.L.$0.50 Interest PER DIEM OF $17.44 TO SALE DATE 3/05/08 $2,703.20 Atty's Comte Due Prothy $2.00 Atty Paid $181.44 Other CostsLATE CHARGES $528.87 $31.11 PER MONTH TO SALE DATE 3/5/08 ESCROW DEFICIT $1,931.20 Plaintiff Paid Date: NOVEMBER 26, 2007 (Seal) REQUESTING PARTY: Name LEON P HALLER, ESQ Address: 1719 NORTH FRONT STREET HARRISBURG PA 17102 Attorney for: PLAINTIFF Telephone: (717)234-4178 Supreme Court ID No. 15700 PROPERTY INSPECTION $144.00 ~rt s/R'~Long, Prothonotary ~,,.- BY~ ~~ li L 't`~~'-' Deputy Real Estate Sale #74 On November 30, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 4830 Brian Road, Mechanicsburg, more fu11y described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 30, 2007 By: Real Estate ~ ergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 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 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 3anuary 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 fiuther 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. Coyne, SWOR~V''I'O AND SUBSCRIBED before me this day of February, 2008 Notary N0IARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Writ No. 2007-5404 Civil Midfirst Bank vs. Roberta M. Klein Atty.: Leon Haller DESCRIPTION ALL THAT CERTAIN piece or par- cel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more par- ticularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer, dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along the Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point; thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same, South 4° 30' West, 146.39 feet to the Northerly line of Lot No. 18; thence slang the same, South 87° 32' 11"West, 3k?.23 feet to a point; thence North 25' S0' S" West, 69.46 feet to a point; thence North 4° 30' East, 90.41 fete to the point of BEGINNING. BEING Lot No. 48, Biock D, on Plan No. 3 of Del-Brook Manor, said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 11. HAVING THEREON ERECTED A DWELLING KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050. BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4/ 12/99 in Cumberland County Deed Book 197, Page 323, granted and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF Roberta M. Klein on Judgment No. 07-5404 Civil. ASSESSMENT NO. 10-21-0279- 275 ~. Thy Patriot-News Co. .~ •~ 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he ~llahiot News Now you know 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: 01 /30108 w )08 A. D. Notary Public 02106/08 02/13108 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sttsme L. IGsner, Notary Public C~lyOiiFMnir{burg Das~phinCourrty My Conrnlak~n xpires Nov. 26, 2011 Member, Pennsylvania Association of Notaries REAL ESTATE SALE N0.74 Writ No. 2007-5404 Civil Term Midfirst Bank VS Roberta M. Klein Attorney Leon Haller DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly bounded and described in accordance with a survey of William E. Whittock, Registered Professional Engineer. dated January 13, 1966. BEGINNING at a point on the Southerly line of Brian Road, which point is 85 feet East of Charles Road; thence along [he Southerly line of Brian Road, South 85° 30' East, 56.64 feet to a point thence continuing along Brian Road, South 83° 23' East, 8.36 feet to the line dividing Lots Nos. 47 and 48 on the hereinafter mentioned Plan of Lots; thence along the same. South 4° 30' West 146.39 feet to the Northerly line of Lot No. 18; thence along the same, South 87° 32' 11" West, 30.23 feet to a point; thence North 25° 50' S" West, 69.46 feet to a point; thence North 4° 30' East 90.41 feet to the point of BEGINNING. BEING Lot No. 48, Block D, on Plan No. 3 of Del-Brook Manor. said Plan recorded in the Cumberland County Recorder's Office in Plan Book 8, Page 1 I. HAVING THEREON ERECTED A DWELL[NG KNOWN AS 4830 BRIAN ROAD, MECHANICSBURG, PA 17050 BEING THE SAME PREMISES WHICH Joseph R. Fink, by Deed dated 4/2/99 and recorded 4112199 in Cumber]and County Deed Book 197, Page 323, gamed and conveyed unto Roberta M. Klein. TO BE SOLD AS THE PROPERTY OF ROBERTA M. KLEIN ON JUDGMENT N0. 07-5404 CIVIL ASSESSMENT N0. 10-21- 0279-275 LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717)234-4178 ATTORNEY FOR PLAINTIFF MIDFIRST BANK Plaintiff VS. ROBERTA M. KLEIN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-5404 CIVIL TERM IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendant satisfied of record. PURCELL, (717)234-4178 ER BY: Leon P . Hal er ID ##157 00 Attorney or Plaintiff 1719 Nor Front Street Harrisbur PA 17102 Dated: November 12, 2008 .~' ~ "64 ,,.,~ W .~ c ~ F~s`~ -irk G7 `mss"' ` ,..f" S ,: s W ''' ~^5 "4 ~yfi ~ '',..~ ~ ,•1 ..~ ~,