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Home My WebLink About07-6239McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company 961 Weigel Drive Elmhurst, IL 60126 Attorneys for Plaintiff Cumberland County Court of Common Pleas V. Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Number 67 _ W S9 C iv i I Term CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE AVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y ]a notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company 961 Weigel Drive Elmhurst, IL 60126 Attorneys for Plaintiff Cumberland County Court of Common Pleas V. Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Number 01- 4,7 39 Cl 'v "i ! e? r r? CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Lewis E. Williams, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 440 Millrace Road, Carlisle, PA 17013. 3. On 02/19/1998, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1433, Page 758. 4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 440 Millrace Road, Carlisle, PA 17013. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/24/2007 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $ 88,446.01 Interest through 09/03/2007 $ 29,795.67 (Plus $ 19.38 per diem thereafter) Attorney's Fee $ 4,422.30 Late Charges $ 1,256.77 Title Search $ 200.00 GRAND TOTAL $ 124,120.75 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $124,120.75, together with interest at the rate of $19.38 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG AND CONWAY, P.C. BY: ir ,? Attorneys forpaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C. S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG AND CONWAY, P.C. BY: )A-6y'?c A Attorneys fo laintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE 71,3 to(P E MORTGAGE 0 IF BOX IS CHECKED, THIS MORTGAGE IS AN OPEN-END MORTGAGE AND SECURES FUTURE ADVANCES THIS MORTGAGE is made this 19TH day of FEBRUARY 19 98 , between the Mortgagor, LEWIS E. WILLIAMS ?? P i. 7 JOYCE E. WILLIAMS v -- (herein "Borrower"), and Mortgagee HOUSEHOLD F I NANCE CONSUMER D I SCOUNT COMPANY , a corporation organized and existing under the laws of PENNSYLVANIA whose address is 25 GATEWAY DRIVE, GATEWAY SQUARE/SUITE 107, MECHANICSBURG, PA 17055 herein "Lender"). The following paragraph preceded by a checked box is applicable. F-71 X WHEREAS, Borrower is indebted to Lender in the principal sum of $ 89, 531 .30 , evi enced by Borrower's Loan Repayment and Security Agreement or Secondary Mortgage Loan Agreement dated FEBRUARY 19, 1998 and any extensions or renewals thereof (herein "Note"), providing for monthly installments o principal an interest, including any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid, due and payable on FEBRUARY 19, 2028 WHEREAS, Borrower is indebted to Lender in the principal sum of $ , or so much thereof as may be. advanced pursuant to Borrower's Revolving l:,oan. Agreement dated and extensions and renewals thereof (herein "Note"), providing for monthly installments, an interest at the rate d under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of $ ; TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other, sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender.'s successors and assigns the following described property located in the County of CUMBERLAND Commonwealth If V of Pennsylvania: ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF SOUTH MIDDLETON IN THE COUNTY OF'CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 01/30/91 AND RECORDED 02/01/91, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME Y34 AND PAGE 820. 40-22-0485-070 TAX MAP OR PARCEL ID NO. r CO 1 C.n ...II C7 i•T? h•7 _ ? O - r ' : C!? . V 1 .... ""PA001241 ORIS'i 'L -2- TOGETHER with all the improvements now or hereafter erected on the property, and all easements;? rights, appurtenances and rents, all of which shall be deemed to b-- and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on a leasehold) are hereinafter referred to as the "Property." Borrower covenants that. Borrower, is, lawfully seised of the ;estate hereby conveyed and has the right to mortgage, grant and convey "the Property, and `that the property is unencumbered; except for .encumbrances of record. Borrower covenants that Borrower warrants and will defend, generally, the title to the.. Property. against all claims and demiands, sublact,to encumbrances of record. UNIFORM COVENANTS, Borrower and Lender -covenant ap. agree as follows:: . ,1, P,ay.`meut of: Principal' ancf Interest at . VanabW Rate .: I .s: mortgage secures ;all payments of `principal and interest., due on., a variable rate loan. :The. contract rate. of interest and payment amounts may ,be subject to change: as when due 1 amounts required. by the'-Note; provided in the Note: Borrowers shall promptly pay 2. Funds. for Taxes. and Insurance.. Subject to applicable. 44w.. or, waiver. by Lender, Borrower shall, pay to Lender on the day monthly. payments of principal. and interest are payable under the Note, until the Note is paid in. full, a sum (herein "Funds") equal to one-twelfth.of the yearly taxes and assessments (including condominium and planned unit development assessments, if any) which may attain priority over this Mortgage and ground rents on the Property, if any, plus, one-twelfth of yearly premium installments for ,hazard insurance,. plus one-twelfth of yearly premium installments for mortgage insurance, if any, all as reasonably estimated initially and from time to time by Lender on the basis of assessments and bills -and reasonable estimates thereof. Borrower shall not be obligated to make such payiriertts`-oVFurids 'to-L-ender to -the- extent--that -Borrower makes-such-.payments to, the holder-of -a: prior mortgage or deed of trust if such holder is an institutional lender. If Borrower pays Funds to Lender, the Funds shall be held in an institution the deposits or accounts of which are insured or guaranteed by a Federal or state agency (including: Lender if Lender is such an institution). Lender shall apply the Funds to pay said taxes,, assessments, insurance premiums and ground rents. Lender may not charge for so holding and applying the Funds, analyzing said account or verifying and compiling said assessments and bills, unless Lender.pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Borrower and Lender may agree in writing at the time of execution :of thi:i Mortgage, that interest on the, Ponds shall be paid to Borrower, and. unless. such agreement is made or applicable laW requires;.such. interest to be paid, Lender shall not be :earnings on the. Finds., Lender-,hall give, to.', Borrower, without charge,,. an required to pay ,ov?er any interest or. annual, accounting of, the P>lnds., showing.. credits- and debits to ahe Funds, and the .purpose for which each debt to..the Funds was made..The Funds. are _ .pledged as additional„security; for the sums secured, by this Mortgage.: t If.the amount of the Funds held :by, Lender, .together with,, lie. future monthly. installments of Funds payable prior, to the due. dates, of. taxes, assessments,..insurance premiums; and. ground rents,. shall. exceed the. amount .required. to pay said taxes,. assessments, insurance. premiums and: grovnd._rents.as t?iey,,fall due, :suah,_excess..sh_all _.be,. at Borrower's optiow, either promptly repaid to Borrower or credited to Borrower un monthly installments of Funds. If the amount of the Funds held by, Lender shall not be sufficient. to pay taxes, ass?sments, insurance premiums and ground rents as they fall due,.' Borrower shall pay to Lender any amount necessary to !make up the deficiency in one or more payments as Lender may require. Upon payment in full of all sums secured. by this Mortgage, Lender shall promptly refund to Borrower any funds held by Lender. If under paragraph 17 hereof the Property is-:sold or the Property is otherwise acquired by Lender, Lender shall apply, no later than immediately prior to the sale; of the Property or its acquisition by Lender, any Funds held by Lender at the time; of application as a credit against tl?e sums secured by this Mortgage. pplication of Payments:`%Fxcept'for,-loan-tzfade pursuant-to the-Perinsylvania'Consurner-fDiscotmt-Company Act, all payments received by Lender under the Note and paragraphs 1 and 2 hereof shall be applied by Lender first in payment of amounts payable to Lender by Borrower' under ::paragraph 2 hereof, then to interest, and then to the principal, 4. Prior Mortgages and Deed of Tryst; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenants to maker payments when die. Borrower shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions attributable to the Property which may attain a priority over this Mortgage, and leasehold payments or ground rents, if any.. 5. Hazard Insurance. Borrower shall 'keep the improvements now existing or hereafter erected on the Property insured against loss, by fire, hazards included within'. the term : "extended coverage, and such. other hazards as Lender may, require.. The insurance carrier. providing the, insurance, shall. be chosen by. the Borrower -subject to approval by Lender; provided; =that such approval shall. not be unreasonably .withheld:: All insurance,policies and renewals thereof shall: be in a form acceptable to Lender and shall include a standard mortgage clause in favor- of and in a form acceptable to Lender. Lender shall have the right tot hold the,,policies and. }enewals thereof, subject to the terms of any mortgage, deed of trust or other security agreemciM,YitlA lien which has priority over this Mortgage. 07-21-97 Mortgage PA I sOOKU33PAce 259 PA001242 ORIGINAL 111111.1 1101, 1®1 1111loll -3- .In he event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authoriaed:to collect, and apply the insurance proceeds at Lender's option either to restoration•or repair of the Property or o. e hsums secured'by?this Mortgage. ' 6. Preservation and Maintenance"of Property;' Leaseholds; Condominiums; 'Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment,pr;•deterioration of the Property and shall, comply with tlie`provisions of any lease'.if.this Mortgage is. on a leasehold:.If tlus•Mortgage'is on a unit,`in a condominium or a planned unit development, Borrower shall perform. all of 'Borrower's obligations tinder the `declaratian'or covenants-'cre"` ating'or_•governing be eondominiuri.,or planned. unit development; the-by-laws and regulations of the condominium or planned' unit' development; and constituent- ddcuments. 7. Protection of. Lender's Security.- If'Borrower fails to perform the covenants and agreements contained in this Mortgage, or if any action or,proceeding is commenced which materially affects Lender's interest in'the Property, then Lender, at Lender's option, upon notice to Borrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest • thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Mortgage, • Unless Borrower and Lender agree to other terms of payment, such amounts. shall be payable, upon notice from Lender to''Borrower requesting :payment thereof. Nothihizontairied in this paragraph 7 shall require Letider to induf any expense or. take anyaction lier`eunder. 8. Inspection. Lender may take or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall be ' paid to Lender, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this ;Mortgage. 10. Borrower Note Released; -.Forbearance By, Lender--Not a . Waiver. Extension of theZtinie`•for -payment or modification of `amortization' of the sums -secured by--this Mortgage granted by-lender to any successor in ,interest of ...Borrower shall no , operate to refease in any `manner, the `liabtlity'. of •tlie original Borrower and Borrower's successors s in interest. Ler ? i shall` riot be required to commence proceedings against such successor or refuse to' extend time for payment or- otherwise modify' amortization of the sums. secured, by this,Mortgage by -reason "of any -demand made -by the original' Borrower: arid- successors- in`'interest. Any forbearance- by'`Lender `in ,exercising any `right or remedy- herounderor"otherwise'afforded by'appliceble'lawshall'`rioa tvai'ver of or"preclvi3e~fTi.6-dxerciseI'df any such right-or remedy:.: ' 11. Successors and Assigns Bound; Joint -and Several Liability; Co-signers. The covenants and agreements' herein contained shall bind, and the rights hereunder shall inure to,?the respective successors and assigns `of Lender-and. Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms 'of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear; `or make --any other accommodations: with regard -to the terms of this Morfgage.or the Note without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender when given•in the manner designated herein.... 13. Governing Law; Severability. The state and local laws applicable to this, Mortgage'shall : be. the;.laws of the jurisdiction in which the Property. is-located. The foregoing sentence shall not'limit the applicability, of Federal law to this Mortgage 1!In'.the event that any prbvision or clause of this Mortgage-or the Note conflicts -with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without- the conflicting provision, `and 6.-:this end the provisions`of this Mortgage and the•Now-:gre'declared to the-severable.:As used herein, "costs;"` "expenses! and '"attorneys' fees" include all -sums to the extent 'not prohibited by applicable law or -limited herein: 14: Borrower's Copy. Borrower shall be furnished a conformed copy'of the'Note and of this Mortgage at the--time of execution or after rSordatipn hereof.: gppK .tttiePAGE r1? 4 07-2i-97 Mortgage PA PA001243 ORIGINAL -4- 15. Rehabilitation Loan Agreement. Borrower shall i'ulfill all of Borrower's obligations under an? home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at bender's option, may require Borrower to execute and deliver ty Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property.' part of the Pro rt or, an interest Pe y 16. Transfer of the Property. If Borrower sells or transfers. all or any interest therein, excluding (a) the creation of a lien or -encumbrance gubordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or less not containing an option to purchase, '-(d):.the' creation of a :purchase money security interest for household appliances;--(e)-a--transfer--to- a- relative resulting from the de th':of a...Borrower, W a-transfer -where--the spouse or children of the Borrower become an owner. of 'the .property, fig} a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreement, by which the spouse of the Borrower becomes an owner of the property; (h) a•..transfer into an inter vivos trust in which the Borrower is-and remains a beneficiary and which does not relate to a transfer 9'f. rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by# the Federal-Home Loan Bank Board, Borrower shall cause to be submitted information.required by Lender to eval?ate the transferee as if a new loan were being made to the transferee. Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree, to such sale or.:transfer, Lender mad declare all.of the sums secured by this Mortgage to be immediately due and pay`ib1e. 'If''Under ,exeircises °sbch option 16-ii era d, Uridei? shall-•raO -Borrower :notice of acceleration in accordance with paragraph 12 hereof.. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lender' may, without further notice or demand on Borrower, invoke any remedies permitted by. paragraph 17 hereof. i NON-UNIFORM COVENANTS. Borrower and Lender further: covenant and agree as follows: 17, Acceleration; Remedies. Except as provided' in paragraph 16 hereof, .upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the, covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in ..,.-. paragraph- I2.-hereof- specifying-.. (1) the-breach; (2) the. action required-to cure such- breach;- (3) a date,- not less than..30 days-from-.the, date the. not,icc_is..mailed,toJiorrower, by which such breach must'.be cured; and (4) that failure to cure such breach on or before the date specified in. the .notice may, result in scceleratior of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The notice shall further inform ? Borrower of the right to: reinstate after: acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in. the notice, tender'. at Lender's option, may declare all of the. sums secured by this Mortgage to be immediately due and payable without further,:demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such. proceeding all expenses of foreclosure, including; but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and titlereports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to. have an} proceedings :begun by Lender to enforce this Mortgage discontinued at. any time prior to entry of a, judgment enforcing • this- Mortgage. if: (a) Borrower pays Lender all sums which would be.'theri 'due under -this- My Agage and the Note had no acceleration occurred; (bl' ldrrower cures all breaches of any other covenants or agreements of Borrower contained in this - Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing 'the covenants and agreements of Borrower contained in- this Mortgage, and in enforcing Lender's remedies as provided in paragraph: 17 hereof, including, but not limited -to, reasonable attorneys' fees; and (d) Borrower takes such. action ?as Lender" may reasonably require to.wmre that.=the lien of this Mortgage, Lender's interest in the Property and Borrowers obligation to pay the sums secured by this Mort gage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured. hereby shall remain in full force and effect as if no acceleration had occurred. 19_ Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower b-ereby to Lender the rents of .tlie Property, provided that Borrower 'shall, prior-to acceleration under paragraph "lteleo , in abandonment of the Property, have the right to collect and retain such rents as they become due and payable. Upon. acceleration-under-paragraph 7 hereof or abandonment of the-:Property,, Lender shall be entitled to have a receiver appointed by a court to enter upon, 'take gossession.::ol and Ynanage the Property and to collect the rents of the Property including those past-due, All rents collected by'Ahe tecft"Ner shall be applied first to payment. of the costs of management of the Property and collection-, of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and'.then to le sums secured by this Mortgage. The receiver shall be liable to ageo?unt only for ,those rents actually received. 8001(.?A PASS?61 07-21-97 Mortgage' PO' ' ' PA001244 ORIGINAL -5- .tea - , 20. Release. Upon payment of all sums secured by this Mortgage, Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law. 22. Interest.Rate After Judgment,. Borrower. agrees the interest rate payable after a judgment is entered. on the Note or in an action of mortgage foreclosure. shall be the rate stated in the Note. REQUEST FOR .NOTICE:OF :DEFAULT. AND :FORECLOSURE UNDER-SUPERIOR MORTGAGES OR DEEDS OF.,TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action. . LEWIS E WILLIAMS -Borrower 0 E E WILLIAMS -Borrower I hereby certify that the precise address of -the Lender (Mortgagee) is: H O U S E H O L D FINANCE .25.GATEWAY DRIVE, M.ECHANICSBURG, PA:.17055 MANAGER.' On behalf : of : the :Lender. By: •' • MATT H'ER MA N.. Title: `:BRAN CH ...... .. COMMONWEALTH OF PENNSYLVANIA, County ss: I, ANNE A S T A F P O R Q Notary Public in and for said county 'and state,,do hereby certify that LEWIS•'•E •WILLIAMS & UOYZE?E •WILL.IANIS personally known to me to be the same person(s) whose name(s) are subscribed to the foregoing instrument, appeared before me this day in person, and acknowledge that t=hey signed and delivered the said instrument as h -air free voluntary act, for the uses and purposes therein- set-forth: Given under my hand and official seal, this 19th day of FEBRUARY , lg 9 8 My Commission expires: 0- ZK 01 09 1& K µ,..:..:. Notary Fyj?fe This instrument was prepared by: NOTARIAL SEAL ANNE A. STAFFORD < PA C0?1?118810NER OF DEEDS N ®? r• DIY CBhfMlS310N EXPIRES APRIL 02, HV ' ,^) 1 CORPORATION Y I: ry <iT ty?/?sV? {y/`? VEH(?y7V..W f?• .? 5" f ?`f Dove uite.107 ` 4 PA. J 7(M. ?` ?2Z^°?"':?'9g+ Address) State of Pennsylvania ,I' k •. ,.. County of r-umbarwRal 88 (space BAlp?a' Lender and Recorder) -. Recor 'cd i the office for the recordfng of D ` To e^f and f berlan? ?n . Bq - eo?County c old Finance' Corporation Page ''Zamont-Road wi na s y ha al of offic ; g mhurst; IL 60126 HOOK41 33 fACE 47621246 day of I C ) y oo - c- d v Cl) t McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Attorneys for Plaintiff Philadelphia, Pennsylvania 19109 (2 5 790-1010 Household Finance Consumer Discount Company COURT OF COMMON PLEAS CUMBERLAND COUNTY V. Lewis E. Williams Number 07-6239 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 124,120.75 Interest 09/04/2007 to 11/27/2007 $ 1,647.30 Total $ 125,768.05 McCABF,a WEISBERG,,,,4ND CONWAY, P.C. BY: )'fl ®r ?-- Attorneys for Plofntiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE AND NOW, this day of , 2005, Judgment is entered in favor of Plaintiff, Household Finance Consumer Discount Company, and against Defendant, Lewis E. Williams and damages are assessed in the amount of $125,768.05, plus interest and costs. BY THE PROTHONOTARY: 'j 1JA-A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant, Lewis E. Williams, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Lewis E. Williams, is over eighteen (18) years of age, and resides as follows: Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS 07' DAY OF 1110V', 2007. McCABE, WEISBERG, AND CONWAY, P.C. BY: / l L-0- C7 1--J6eZz-e-e1 Attorneys foolaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE OTARY P i . .?.., GLORIA r:°lic My Coy r. _-.._..,._- _.?. 2, 2011 Request for Military Status Department of Defense Manpower Data Center Ad& IF Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 NOV-16-2007 08:00:12 Last Name First/Middle Begin Date Active Duty Status Service/Agency WILLIAMS Lewis E Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: bt42://www.defenselink.mil/fac./pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/16/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:XOGNEEHVBS hqs://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/16/2007 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 CERTIFICATION The undersigned, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THISAI bAY OF ?19 d • , 2007. McCABE, WEISBERG, AND CONWAY, P.C. BY: / Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE --- NDTARX SEAL GLORIA G. MITCHELL, {rotary PUblic City of Philadelphia, Phila. County My Commission Expires June 2, 2011 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary November 16, 2007 To: Lewis E. Williams c/o Paul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 Household Finance Consumer Discount Cumberland County Company Court of Common Pleas vs. Lewis E. Williams Number 07-6239 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 INFORMATIONABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA FOR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBIECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG ANP CONWAY, P.C. BY: Z 47 .Q Attorneys for Plaintiff TERRENCE J. MCCABE, MARC S. WEISBERG, ESQ EDWARD D. CONWAY, ES MARGARET GAIRO, ESQ BONNIE DAHL, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE TJNUhm VERIFICATION The undersigned, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unworn falsification to authorities. MCC , WEISBERG AND CONWAY, P.C. BY: Attorneys for aintiff TERRENCE . McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE jet, IM F:z l co `' t_... 1 _ ,1 r - 'tea s OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, PA 17013 Curt Long Prothonotary To: Lewis E. Williams 440 Millrace Road, Unit 66 Carlisle, PA 17013 Household Finance Consumer Discount Company COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. No. 07-6239 Lewis E. Williams Defendant NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curt Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe. Weisberg and ConwgL P.C. at (215) 790-1010. 111-I8 fo7 /5/ " P. cc X? at8 OFFICE OF THE PROTHONOTARY ' COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, PA 17013 Curt Long Prothonotary To: Lewis E. Williams c/o Paul Bradford Orr, Esq. 50 East High Street Carlisle, PA 17013 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 07-6239 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curt Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe. Weisberg and Conway, P.C. at (215) 790-1010. 11/0/0-7 A/ ou.C? ,O. &r otz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, If PENNSYLVANIA CIVIL DIVISION Household Finance Consumer Discount FILE NO.: 07-6239 Civil Term Company Plaintiff AMOUNT DUE: $125,768.05 Interest $2,025.66 from 11/28/2007 to v. 3/5/2008 DATE OF SALE plus $20.67 per diem thereafter Lewis E. Williams Defendant ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant un;+ town 440 Millrace Road arlisle. PA 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: / La 7 D-7 Signature: M,49 '?c 21e-e'e? MCCABE, WEIS ERG, AND CONWAY, P.C. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE F v I ?z R? UUj SO ? o O ? 91 U) =L ? ? u 0 9 ? .?. o to o oo p O O O O Q rrs CO) McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 440 Millrace Road, Unit 66, Carlisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A". 1. Name and address of Owner or Reputed Owner: Name Lewis E. Williams Address 440 Millrace Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: Name Lewis E. Williams Address 440 Millrace Road Carlisle, PA 17013 3 4. 5 6. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Address Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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: Name Tenants Paul Bradford Orr, Esquire Commonwealth of PA Department of Public Welfare Domestic Relations Cumberland County Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 440 Millrace Road, Unit 66 Carlisle, PA 17013 50 East High Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 P.O. Box 320 Carlisle, PA 17013 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 r RAW Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Department of Public Welfare TPL Casualty Unit Estate Recovery Program United States of America c/o U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7' & Grant Streets Pittsburgh, PA 15219 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 27. 2007 DATE MCC WEISBERG D CONWAY, P.C. BY: Attorneys for P ntiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ,.. C:, r`a t.' a ?=-? ? a --? ? -- r.? T !`J r; i% ? ; e-- ?? "-? - - ?_ g, __i ? _. .??, f.._ <? ; ` -' t'a :. ? ? -C W ,> CIVIL ACTION LAW Household Finance Consumer Discount I COURT OF COMMON PLEAS Company V. I CUMBERLAND COUNTY Lewis E. Williams Number 07-6239 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Your house (real estate) at 440 Millrace Road, Unit 66, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on M4,RCH 5, 2008 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $125,768.05 obtained by Household Finance Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway P.C. at (215) 790-1010. 2. You 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and ConwU. P.C. at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6239 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From LEWIS E. WILLIAMS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $125,768.05 L.L.$ 0.50 Interest $2,025.66 from 11/28/07 to 3/05/08 DATE OF SALE plus $20.67 per diem thereafter Atty's Comm % Atty Paid $151.80 Plaintiff Paid Date: 11/28/07 (Seal) REQUESTING PARTY: Name MARGARET GAIRO, ESQUIRE Due Prothy $2.00 Other Costs Pfrrooth( notary By: Deputy Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 SHERIFF'S RETURN - REGULAR CASE NO: 2007-06239 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS WILLIAMS LEWIS E RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WTT,T TAMS LEWIS E the DEFENDANT , at 1426:00 HOURS, on the 26th day of October , 2007 at 440 MILL RACE COURT CARLISLE. PA 17013 by handing to LEWIS E WILLIAMS a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 l+fo1?'p? .00 `J 32.80 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 10/29/2007 MCCABE WEISBERG CONWAY By. ak??& Deputy S eriff A. D. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 AFFIDAVIT OF SERVICE I, the undesigned, attorney for the Plaintiff in the within matter, hereby certify that on the 7`' day of January, 2008, a true and correct copy of the Notice of Sheriff s Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A." Copies of the letter and certificates of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 7TH DAY OF JANUARY,2008. Attorneys for Plaintiff TERRENCE J. McCABE, ESQUI MARC S. WEISBERG, ESQU EDWARD D. CONWAY, ESQUI MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ ESQUIRE KEVIN DISKIN, ESQUIRE BY: ?--? L--::? AY, P.C. Notarial Seal . Susan J. Markowitz, Notary Public city of Philadelphia, Philadelphia County o nmissior, Expires Feb: 13, 2011 --71,777777-5t,7 of Notaries McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company COURT OF COMMON PLEAS Plaintiff V. Lewis E. Williams Defendant CUMBERLAND COUNTY Number 07-6239 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 440 Millrace Road, Unit 66, Carlisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A". 1. Name and address of Owner or Reputed Owner: Name Lewis E. Williams Address 440 Millrace Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: Name Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Address RA 3 4. 5. 6. 7 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Willow Crossing Condo 21 S. Pitt Street Apr/Ste. 1 Carlisle, PA 17013 Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Address Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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: Name Address Tenants 440 Millrace Road, Unit 66 Carlisle, PA 17013 Paul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 Commonwealth of PA Department P.O. Box 2675 of Public Welfare Harrisburg, PA 17105 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania 1400 Spring Garden Street Inheritance Tax Office Philadelphia, PA 19130 ?JC,?IB??? Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Department of Public Welfare TPL Casualty Unit Estate Recovery Program United States of America c/o U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7'b& Grant Streets Pittsburgh, PA 15219 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriffs Sales I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Januarx 7.2008 DATE CONWAY, P.C. BY:`-?' Attorneys for aintiff TERRENCE J. McCABE, ESQU MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE KEVIN DISKIN, ESQUIRE ANDREW L. MARKOWITZ, ESQU McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant DATE: January 7, 2008 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Lewis E. Williams PROPERTY: 440 Millrace Road, Unit 66, Carlisle, PA 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 5, 2008 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. r ,e? >N?z J W er 0 NPayoa ; ll O ?o N N 00 r ^' ° o O d A;,H ooooon b idHd `til "Hp ??,. ?'ee tC to ro wo. A 0,00 O Op' ?? O ti 3 m $ ??i. ?A SO =9 rd rr m O^A '4'O ? ^rSOfi ? .:r 1.0 -1 'A -P. SD rA w k O? O vi (,7 ^ 70 00 0 rd m p IQ p W e n -:0 Ow 0 ee y N p ee J m p• •, .-L 000 Otto p ?D4 C/1<C A- .1 r.? '+ X p Al m ?.jD^, 0 ? bUM= !jrAdw J/? $ 4?- pr O 006 o ,q c% tfb d A *ci as t3?UQ $, > N m ?!7 m a o Y ?ti r* O ?°.. m ? ° H "da.ov ¦ Oila e 0 O`d ? o:o as O ° o w J O ?, Wa .1 wG. y CD *A ci No=?i a m_ro o- o Y W o„ C Mn ~Op.? ?? 0Q y A Op~`!.Hp DMA p .C .? U1 Q\ M^ f7 00 M O y A H .r?. CT A Q i?••. I?•? a p"'p A . ?'. QO A A •q ?b l9 Go 00 PAD rAeSOQ •07 p p f ,. w an O o D C1 N O_ Fn OD r -n U% 0 K c. 1 40 m , CD ,p < v Z 00 0 r? ,t ?z S° e 3 It x S. r Ab, r !A r?P Y.Ci rD A A y .• ewe O '"? QQ W O c. 0 w >. dA wdo • 0 a G ?p CA G eAC ?G+? to AT ?.+ N O •• O ?• (A a a N Web O R Y ?p? At bA A Od m f1 0 C O G y N r rA N A WO O oo?F??a A 00 S W O ep v) to A r: O A+ r Ct'S a n ? NA [A e¢o ?n v'a "q A O ? Mr A? B T, - t? D COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which HOUSEHOLD FINANCE C D C 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 28TH day of NOV, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2007 Number 6239, at the suit of HOUSEHOLD FIN C D C against LEWIS E WILLIAMS is duly recorded as Instrument Number 200827535. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this f' day of Aw9_ _, A.D. lzlydO Recorder of Deeds Rscord l Of 06903, (Amoonand County, CaMb, PA My COnv4"on EW9& ft First Monday of Jan. 2010 Household Finance Consumer Discount In the Court of Common Pleas of Company Cumberland County, Pennsylvania VS Writ No. 2007-6239 Civil Term Lewis E. Williams David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on December 07, 2007 at 2054 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: Lewis E. Williams making known unto Lewis E. Williams, personally at 440 Millrace Road, Unit 66, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copies of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 9, 2008 at 1520 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 Lewis E. Williams located at 440 Millrace Road, Unit 66, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Lewis E. Williams by regular mail to his last known address of 440 Millrace Road, Unit 66, Carlisle, PA 17013. These letters were mailed under the date of January 8, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 Terrence McCabe, on behalf of Household Finance Consumer Discount Company. It being the highest bid and best price received for the same, Household Finance Consumer Discount Company, of 961 Weigel Drive, Elmhurst, IL 60126, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,075.40. Sheriffs Costs: Docketing $30.00 Poundage 21.09 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy Surcharge Post Pone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed So Answers: 15.00 20.00 20.00 425.00 383.54 16.17 25.00 39.50 $ 1095.40 ? Ji s/o g ?^ line R. S-fh Thomas K , BY ad Real Estate rgeant alzlk CIO Sv c s'-2 s' ktl? .,/3a,3G 4 McCABE, WEISbERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company Plaintiff V. Lewis E. Williams Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 07-6239 AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 440 Millrace Road, Unit 66, Carlisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A". 1. Name and address of Owner or Reputed Owner: Name Lewis E. Williams Address 440 Millrace Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: Name Lewis E. Williams Address 440 Millrace Road Carlisle, PA 17013 V Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Department of Public Welfare TPL Casualty Unit Estate Recovery Program United States of America c/o U.S. Attorney for the Eastern District of PA United States of America c/o U.S. Attorney for the Middle District of PA United States of America c/o Attorney for the Western District of PA Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 615 Chestnut Street Philadelphia, PA 19106 235 North Washington Street Scranton, PA 18503 633 U.S. Post Office and Courthouse 7`h & Grant Streets Pittsburgh, PA 15219 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. November 27. 2007 DATE MCC WEISBERG D CONWAY, P.C. BY: Attorneys for P tiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE CIVIL ACTION LAW Household Finance Consumer Discount Company COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Lewis E. Williams Number 07-6239 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Your house (real estate) at 440 Millrace Road, Unit 66, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on MARCH 5, 2008 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $125,768.05 obtained by Household Finance Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P. C. at (215) 790-1010. 2. You 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 the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe. Weisberg an d Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. 66 (the "Unit"), of Willow Crossing, A Condominium, located in South Middleton Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Willow Crossing, A Condominium (the "Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 386, Page 889 and Plan Book 61, Page E2 and First Amendmenf"ToD-6-61RWLion df Condominium for Wilrow--__._ _ Crossing, A Condominium (the,--"First Amendment to Declaration of -Condominium") and Declaration P is d Plan as-xVorded in the Office of 'the Recorder of Deeds of It erland County, Pennsylvania in Miscellaneous Book 388, Page 412-and Plan Book 61, Page 97. TOGETHER with an undivided 2.50% interest in Common Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans. TOGETHER with the right to use the limited common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration of Plats and Plans, and amendment thereto. Being known as 440 Mill Race Road. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. TAX MAP PARCEL NUMBER: 40-22-0485-070(U66)) BEING KNOWN AS 440 Millrace Road, Unit 66, Carlisle, PA 17013 Being the same premises which Robert E. Goodling and Judy S. Goodling, husband and wife and Pfeifer and Gross, Inc., A Pennsylvania Corporation, by deed dated the 1/30/1991, and recorded 2/1/1991 in the Office of the Recorder in and for Cumberland County in Deed Book Y34, Page 820, granted and conveyed to Lewis E. Williams and Joyce E. Williams, in fee. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6239 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From LEWIS E. WILLIAMS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 $125,768.05 L.L.$ 0.50 Interest $2,025.66 from 11/28/07 to 3/05/08 DATE OF SALE plus $20.67 per diem thereafter Atty's Comm % Atty Paid $151.80 Plaintiff Paid Date: 11/28/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs s L). 4m,q Protho otary (?' By: Deputy Name MARGARET GAIRO, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 SOUTH BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 Rol Estate Sale #60 On November 29, 2007 the Sheriff levied upon the &fendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 440 Millrace Road, Unit 66, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 29, 2007 By:?? V Q jReasta rgeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWO'R'D TO AND SUBSCRIBED before me this 8 day of February, 2008 C;a Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Rim. i WA T19 SALX NO. 60 Writ No. 2007-6239 Civil Household Finance Consumer Discount Company VS. Lewis E. Williams Atty.: Margaret Gairo DESCRIPTION ALL THAT CERTAIN Unit, being Unit No. 66 (the "Unit"), of Willow Crossing, A Condominium, located in South Middleton Township, Cum- berland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Willow Crossing, A Condominium (the "Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 386, page 889 and Plan Book 61, page 62 and First Amendment to Declaration of Condominium for Willow Crossing, A Condominium (the "First Amendment to Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania in Miscellaneous Book 388, page 412 and Plan Book 61, page 97. Together with an undivided 2.50% interest in Common Elements as more particularly set forth in the aforesaid Declaration of Condo- minium and Declaration Plats and Plans. Together with the right to use the limited common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Con- dominium and Declaration of Plats and Plans, and amendment thereto. Being known as 440 Mill Race Road. Under and subject to any and all covenants, conditions, restrictions, rights-of-way, easements and agree- ments of record in the aforesaid Of- fice, the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. Tax Map Parcel Number: 40-22- 0485-070 (U66). g known as: 440 Mill Race Road; nit 66, Carlisle, PA 17013. BdU?g the same premises which Robert E. Goodling and Judy S. Goodling, husband and wife and Pfeifer and Gross, Inc., a Pennsylva- nia Corporation, by deed dated the 1/30/199 1, and recorded 2/ 1/1991 in the Office of the Recorder in and for Cumberland County in Deed Book Y34, page 820, granted and conveyed to Lewis E. Williams and Joyce E. Williams, in fee. The Patriot-News Co. r 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ZhePatriot-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: 01/30/08 02/06/08 Notary Public of February, 2008 A.D. COMMONWEALTH O PE-NN SYLVANfA F__ 1 Notad a; > 71 m Shortie L. Kisnei. Public C7yy Of Hartisburg, 0 Rdprlln County MY Co rtrAmion Expires N vv. 26, 2011 Member, Pennsylvania As, ciation of Notaries 02113/08 REAL ESTATE SALE NO. 60 Writ No. 2007-6239 Civil Term Household Finance Consumer Discount Company VS Lewis E. Williams Attorney Margaret Gairo DESCRIPTION ,OLL THAT CERTAIN Unit, being Unit No. h4- (the "Unit'), of Willow Crossing, A Condominium, located in South Middleton. Township, Cumberland County, Pennsylvania which Unit is designated in the Declaration o) Condominium of Willow Crossm,. Condominium i the 'Declaration u Condominium") and Declaration Plats and Plan, as recorded in the Office of the Recorder of Deeds of Cumberland County, PennsyNama, ui Miscellaneous Book 386, page 889 and Plan Book 61. page 62 and First Amendment w Declaration of Condominium for Wilkm Crossing, A Condominium tthe Tirsr Amendment to Declaration of Condominium 'I, and Declaration Plats and Plans as recorded jr. the Office of the Recorder of Deedc ut Cumberland County. Pennsylvania it Miscellaneous Book 388, page 412 ail Plan Book 61, page 97. Together with an undivided 2.50% interesr w Common Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans. Together with the right to use the iirnitec common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration of Plats and Plans, and amendment thereto. Being known as 440 Miff Race Road. Under and subject to any and all covenants. conditions, restrictions, rights-0f--way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration, and matters which :., physical inspection and survey of the Unit anr' Common Elements would disclose. Tax Map Parcel Number: 40-22-0485-070 (U66i Being known as: 440 Mill Race Road, Unit 66. ,larlisle, PA 17013 Being, the same premises which Robert f:. Goodling and Judy S. Golding, husband and wife and Pfeifer and Gross, Inc., a Pennsylvania ,'orporation, by deed dated the 1/30/1991, and recorded 21111991 in the office of the Recorder in and for Cumberland County in Deed Bak Y34, page 820, granted and conveyed to Lcwi, E. Williams and Joyce E. Williams. to fee.