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Home My WebLink About03-5399 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 MORTGAGEELECTRONlC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. ~ - S3Ct't (]/~ ~( I~ v. CUMBERLAND COUNTY GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, P A 17013 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 COUNfY CUMBERLAND COUNfY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 File #: 80755 File #: 80755 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME, FURTHERMORE, NO ro:QUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: AURORA LOAN SERVICES, INC. 601 5TH AVENUE SCOTISBLUF, NE 69361 2. The name(s) and last known addressees) ofthe Defendant(s) are: GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, P A 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 06/06/2000 mortgagor(s) made, executed and deliver,ed a mortgage upon the premises hereinafter described to NATIONAL CITY MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1617, Page 773. By Assignment of Mortgage record,ed 7/29/2003 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 699, Page 4681. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 80755 6. The following amounts are due on the mortgage: Principal Balance Interest 05/01/2003 through 10/10/2003 (per Diem $16.00) Attorney's Fees Cumulative Late Charges 06/06/2000 to 10/10/2003 Cost of Suit and Title Search Subtotal $67,762.29 2,608.00 1,250.00 94.05 $ 550.00 $ 72,264.34 Escrow Credit Deficit Subtotal 0.00 1,493.77 $ 1.493.77 TOTAL $ 73,758.11 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 73,758.11, together with interest from 10/10/2003 at the rate of$16.00 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PHELA)J, IJ/!. . 'A--~.J~ By: iI/Francis S. Hallman FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 80755 AU. \bat .""Aln 10: of around in lI1c BOltMJIh ofCarllsle, CUmberland Caunty. """.","",1.. being comlKded Gt Lot:Z and 1..Dl3 of I.... PtdiminarylF'..... Subdivision PloD far I". Rcdc'/<:1~1 AUlhoc\Iy Gt CUmhedlnd Caunl~ cIaIcd June 14.1999, and ICllOIde4IR 'I1xl orace of II'" Ra:conlCr of Dcods in ud for Oombcllud Co\InIy. ~_.. in P\III BooI; 79. pqc S6, being _ particu10rly boIIolcIcd and deIcribcd · fol1_; BeGINNING ala FoIal at tI1c Soulhcm rijlhl ofV/1'11inc ofl.'.'11IiI A""DUUI 1\5 iIIIeocotian wIIh Nodh PiU SIIec:Ii ~ C<lIIIimwlaIlou& 1I1c......... ript or way linear North Pill SIIee& Soa\b IS dol'"!'" 00 mi.\l~ 00 IlICoado Weat<42.3 tccIlD. JlOI!lIII& 1I1c d1vld1na JinI: bel- Loll ;1 ind 4 of dle.rc-1IicI SIIbdi'tbioa Pillll: tIICl1CIl.-llnldn& IIong ......, South 74 dep" 30 mitlllleS:Z IllllOlId4 Eaa. 8U1C!i feel 10 IlIIds I10W ur famtel'ly or the Ro:doWlopnClll AlIlbaritJ of'1I1c CautIly of 0lmbaiInd: lIleace cantlllUilla aIong_ North IS depots S mbl111es 08 _ds &Sta dis\lUICc of 41.36 fee.110 n point at a,. SQUlllCIII rigtll of wo:y Ii"" of l.OCU5l 10._0' \hoQCI! contlnuinlllllon8l1l1mc Soulll ~ deg_ 10 mlIl\1ltS 3 SCIXlno" 1!a5196 reel 10 a poinl. (he pin... of lIelinning. BEll'lG Lols 2 oad ,. of the Il'CJfCSoid Stabclivisioll P\8n IIIld knOWn u 126 Nonh PiuSt. TOa811IEIl willi tho rl&hI& IIlld I!I'!vIJe&cI tor pe4aIrion - vehlcblar i,npIS 111<1 0'- rMI Lot 1 of Ihc ...oid Subdivision !'1M, u I1UII1l ~1IIody otI (olIh 111 an a.menl ^~daJaI.1u1y 19. 1999.1IIlll ncoaIcd mIlle om... oflhe RcconIu of Deeds iund fOl'Ollubcr1Bt:4 Coullly. Pcnnsyl....~. in Mis<:. Boak 619. pap 7112. BEI\'lG . ~ of the aame pI~ RcdevcIopntOlll AutIlorlly of die Coo,"y of cUlllbcl'laild ptlu:4 ud """""7"d lIIdo Cllr\lSIo Rau&inl OppoI:1Uniw" COI'pOI'illiOll. a ~ pmnt C<1IlJOI'Illion. by dood daled AugustS. 1999. nnd R!COtdcd in IhI: CUlllbCdand Olllllb" Rccotdcr of Deeds Off'"", in Deed Book:lDS page 423- PREMISES BEING: 126 NORTH PITT STREET VERIFICATION Richard T. Martin hereby states that she is SENIOR VICE PRESIDENT of AURORA LOAN SERVICES mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The Wldersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ ~ Sf'" --:> i. . Richard T. Martin DATE: ,,/7In Sr. Vice President (:) ~ B }J i # ~ c' 0 D 0 (J) -n ~ C >::) , ~ --, -;:, C,J ..... -Ue} -< ' ,-- ">t:: ~ ~F' ;"-1 ; r:J II-' 6"- (N .1rh IN - S2: ~ tN -p - ~ !<'.. ~ C) ~ ~;!: - (.-)'11"'1 ...:.,.{- 0;:..;,.. " 5J -t:- :;:J ,,) -< SHERIFF'S RETURN - REGULAR CASE NO: 2003-05399 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS JOHNSON GWENDOLYN P JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JOHNSON GWENDOLYN P the DEFENDANT , at 2105:00 HOURS, on the 22nd day of October ,2003 at 126 NORTH PITT STEET CARLISLE, PA 17013 by handing to GWENDOLYN JOHNSON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 _.---~/'~7///' /. r ;;::;r~"",_-"",.",< p&-~ ~-:-f1' R. Thomas Kline - 10/23/2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: {Yp~riff me this I.. e.- day of fL()1,u~J.<.-< _ J IJO.3 A . D . ('1, Q.lhJJ,.. JEi: '1"f' Prothonotart J PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PffiLADELPffiA, PA 19103-1814 (215) 563-7000 o /--! J 30 7 c;.) o. . MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 03-5399 GWENDOLYN P. JOHNSON Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against GWENDOLYN P. JOHNSON and, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 10111103 to 4113/06 TOTAL $73,758.11 $14,656.00 $88,414,11 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: '{ /1 ~~ PRO PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F, KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 03-5399 GWENDOLYN P. JOHNSON Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant GWENDOLYN P. JOHNSON is over 18 years of age and resides at, 126 NORTH PITT STREET, CARLISLE, PA 17013 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,f1~ Jj-1~~ DANIEL G. SCHMIEG, ESQ Attomey for Plaintiff . . PHELAN HALLINAN & SCHMIEG, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq. l.D. No.6220S One Penn Center Plaza. Suite 1400 Philadelphia, Pa 19103 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Attorney For Plaintiff : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY GWENDOLYN P, JOHNSON Defendants : NO. 03-5399 TO: GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, PA 17013 DATE OF NOTICE: MARCH 24, 2006 fILE GOPY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.lF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORT ANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HA VE 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 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 INFORMA nON 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 ':fA. S-. lJal~ FRANCIS S. HALLINAN. ESQUIRE Attorneys for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO, 03-5399 GWENDOLYN P. JOHNSON Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on AfT I f7 2000' B~ d 4bA'~ / EPUTY' () If you have any questions concerning this matter, please contact: ~~ Jj --R~ DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ..THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY,.' ~ <;:) .....,.j~^ ",,;-'0 '''-Jt::>) t:-- '. 'r--~ - A-. d ~ .s-, ~.J ,...\:'-., ~ 0'\ ;s ~' 0{:;. ""'\ ~ \ -.;. -.l ~ " , ,I .1 >:- c:, C"- UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA lNRE: Gwendolyn Pamela Johnson alkJa Gwendolyn P. Johnson BANKRUPTCY NO. I 03-bk-06664 MDF Debtor CHAPTER 13 Mortgage Electronic Registration Systems, Inc. Movant Jl03-53f1 ~ v. Gwendolyn Pamela Johnson alkJa Gwendolyn P. Johnson Respondent ORDER MODIFYING SECTION 362 AlrrOMA TIC STAY Upon Consideration of the Motion of Mortgage Electronic Registration Systems, Inc. (Movant), and after Notice of Default and the filing of a Certification of Default, it is: ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided by 11 U,S.c. 362 is modified with respect to premises, 126 North Pitt Street, Carlisle, PA 17013, as more fully set forth in the legal description attacbed to said mortgage, as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal or consensual action for enforcement of its right to possession of, or title to, said premises; and it is further ORDERED AND DECREED THAT: Rule 4001 (a)(3) is not applicable and Mortgage Electronic Registration Systems, Inc. may immediately enforce and implement this Order granting Relief from the Automatic Stay. By tIlt Cow1:, ~~~~ Dated: March 14,2006 ThiS electronic order is signed and filed on the same date. -J! (. G' --< (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C,P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, Plaintiff, v. No. 03-5399 GWENDOLYN P. JOHNSON Defendant( s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $88,414.11 Interest from 4/13/06 to SEPTEMBER 6, 2006 (per diem -$14.53) $2,121.3 8 and Costs TOTAL $90,535.49 YFwwJ Jj -.J~ DANIEL G. SCHMIEG, E DIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ~ g "'" ... .t. p.o. ~ ~ I.) ~ ~~ ~ ~ ~ ~ "i ~~ rJ ~ ~ ~ I.)'!l ~'e ~ <ft ~ (/) .~ ~ p.o.(/) %t ~ \01~ ~~ ~1 p:. p.o. ~ tt 0 ~t ~ l~~ ... \~ \ ~ ~~ .;. ~ 'e 0 e~ ~ ~~ ~ p. ~~ ~, l ....0 '-i~ \ ~ ~ 01.) ~i %~ ~~ ~ ~ II) ~l-" 0 ~ :% ea o~ ~ 1 ~ ~~ ..... ~~ ~ ~% '!lG ~~ ct r.::!l ' ...J~~"'~ (1 \j c:..> t ()v. G ~ l..i1-.:. -t;;:('<) .".. 0" ~- ~.... c' s\~ y.,t.(.~..... -:. ::.:.i' i- ''''.~i , :':~j . -".- -:-::, cD '~',: N ~ e:::: .~: :.;:2llt c__ \"l..l ~~ g;t ..:].0- tJ- cg 5 o ~ (,,) ~ - - - - - J-:5 () ';J () 'V\ l \ () :::; (J lA :) G, ~d-C) V> 'Z" N, -- - - ~~ "---' ~ Vl J1 -r ~ -d, /'\ "' - \ - -i\ r{J ( '" <v,) <J- ("(, <J- ~ cr-- t- ~ - 1L li <;j WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-5399 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From GWENDOLYN P. JOHNSON (I) 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 fromdehvering 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 narned garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $88,414.11 L.L. $.50 Interest FROM 4/13/06 TO 9/6/06 (pER DIEM - $14.53) - $2,121.38 AND COSTS Arty's Cornrn % Due Prothy $1.00 Arty Paid $113.45 Other Costs Plaintiff Paid Date: APRIL 28, 2006 e.~ (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 62205 PHELAN HALLINAN AND SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIllLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION GWENDOLYN P. JOHNSON NO. 03-5399 Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ J1--2~ DANIEL G. SCHMIEG, ES UIRE Attorney for Plaintiff F'~ "'" ~;;? 0-' ~, -;;:; l'-' dJ c~.~.-.:) c.~~ :.:c\ _~ .....0 r'" ._, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GWENDOLYN P. JOHNSON NO. 03-5399 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., Plaintiff in the above action, by its attomey, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .126 NORTH PITT STREET. CARLISLE. PA 17013. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ... '. . 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CARLISLE HOUSING OPPORTUNITIES 60 WEST PENN STREET CARLISLE, P A 17013 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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 Last Known Address (if address cannot be Teasonably ascertained, please indicate) Tenant/Occupant 126 NORTH PITT STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ADril26,2006 DATE JJ~ JjI~ DANIEL G. SCHMIEG, E QUIRE Attorney for Plaintiff ::~;y~ o c:: r-~ c:;.,-;> c:::;;, CfO ?~ :;::-J 1".) CO .' . ... C) -n .-\ -C-('"l n"1p:: j!.' :~ .~ - 1 ?::: "-x~, ~~~A ;::::, ;,0 -<. .SJ "" f MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. CUMBERLAND COUNTY Plaintiff, No. 03-5399 v, GWENDOLYN P. JOHNSON Defendant(s). April 26, 2006 TO: GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at .126 NORTH PITT STREET. CARLISLE. PA 17013. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 6. 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $88.414.11 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. Yon 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. . . I You may need an attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe 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 in the sale. To find out if this has happened, you may call (717) 240-6390. 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It mav not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 . , , DESCRIPfION ALL THAT CERTAIN lot of ground in the Borough of Carlisle, Cumberland County, Pennsylvania, being composed of Lot 2 and Lot 3 of the Preliminary/Final Subdivision Plan for the Redevelopment Authority of Cumberland County dated June 14, 1999, and recorded in The Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 79 Page 56, being more particulllrly bounded and described as follows: BEGINNING at a point at the Southern right of way line of Locust A venue at its intersection with North Pitt Street; thence continuing along the Western right of way line of North Pitt Street South 15 degrees 00 minutes 00 seconds West 42.3 feet to a point at the dividing line between Lots 3 and 4 of the aforesaid Subdivison Plan; thence continuing along same South 74 degrees 30 minutes 2 seconds East 81.06 feet to lands now or formerly of the Redevelopment Authority of the County of Cumberland; thence continuing along same North 15 degrees 5 minutes 08 seconds East a distance of 41.36 feet to a point at the Southern right of way line of Locust Avenue; thence continuing along same South 75 degrees 10 minutes 3 seconds East % feet to a point, the place of beginning. BEING Lots 2 and 3 of the aforesaid Subdivision Plan and known as 126 North Pitt Street. TOGETHER with the rights and privileges for pedestrian and vehicular ingress and egress over Lot 1 of the aforesaid Subdivision Plan, as more particularly set forth in an Easement Agreement dated July 19, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Misc. Book 619 Page 782. TAX PARCEL #05-21-0,320-078 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Gwendolyn P. Johnson, single person by Corrective Deed from Carlisle Housing Opportunities Corporation dated 7/612000 and recorded 7/1912000 in Deed Book 225 Page 626. PREMISES BEING: 126 NORTH PITT STREET, CARLISLE, PA 17013 ",--,,--,-.,.,-,-':, o (- r-' c-) c.::'> 0.... :V'~ --() :,:.;J r--~' aO) 3 '1J, .-' ::: ..,"", l~~.!~~_ '- , Z? .J -'"" '," ".,;'-6. ~:'.\, -~ - ...0 DESCRIPTION ALL THAT CERTAIN lot of ground in the Borough of Carlisle, Cwnberland County, Pennsylvania, being composed of Lot 2 and Lot 3 of the Preliminary/Final Subdivision Plan for the Redevelopment Authority of Cumberland County dated June 14, 1999, and recorded in The Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 79 Page 56, being more particuhlrly bounded and described as follows: BEGINNING at a point at the Southern right of way line of Locust A venue at its intersection with North Pitt Street; thence continuing along the Western right of way line of North Pitt Street South 15 degrees ()() minutes ()() seconds West 42.3 feet to a point at the dividing line between Lots 3 and 4 of the aforesaid Subdivison Plan; thence continuing along same South 74 degrees 30 minutes 2 seconds East 81.06 feet to lands now or formerly of the Redevelopment Authority of the County of Cumberland; thence continuing along same North 15 degrees 5 minutes 08 seconds East a distance of 41.36 feet to a point at the Southern right of way line of Locust Avenue; thence continuing along same South 75 degrees 10 minutes 3 seconds East 96 feet to a point, the place of beginning. BEING Lots 2 and 3 of the aforesaid Subdivision Plan and known as 126 North Pitt Street. TOGETHER with the rights and privileges for pedestrian and vehicular ingress and egress over Lot I of the aforesaid Subdivision Plan, as more particularly set forth in an Easement Agreement dated July 19, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Misc. Book 619 Page 782. TAX PARCEL #05-21-0320-078 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Gwendolyn P. Johnson, single person by Corrective Deed from Carlisle Housing Opportunities Corporation dated 7/6/2000 and recorded 7/19/2000 in Deed Book 225 Page 626. PREMISES BEING: 126 NORTH PITT STREET, CARLISLE, PA 17013 ~ PHELAN HALLINAN & SCHMIEG, LLP BY: FRANCIS S. HALLINAN, ESQUIRE Identification No. 62695 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Mortgage Electronic Registration Systems, Inc. ATTORNEY FOR PLAINTIFF Court of Common Pleas Plaintiff Civil Division vs. Cumberland County Gwendolyn P. Johnson Defendant( s) No. 03-5399 PRAECIPE TO THE PROTHONOTARY: _Please mark the above referenced case Discontinued and Ended without prejudice. _Please mark the above referenced case Settled, Discontinued and Ended. X Please mark Judgments satisfied and the Action settled, discontinued and ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: cP~4Jt ~L1/1!lj f&/A Francis S. Hallinan, Esquire Attorney for Plaintiff PHS # 80755 " ..!--- - Mortgage Electronic Registration Systems, Inc. VS Gwendolyn P. Johnson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-5399 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Daniel Schmieg. Sheriffs Costs: Docketing Surcharge Advertising Prothonotary Law Library Posting Hand Bills Mileage Poundage Share of Bills Levy 30.00 20.00 15.00 1.00 .50 15.00 8.80 1,672.71 19.31 15.00 Total: $1797.32 v ~ 7./?o(, So Answers: r~~A. R. Thomas Kline, Sheriff ByJ~SlllGR Real Estate Sergeant I. 'J'O (:;k.. 5 'f ~ 1 (,.. ~ IS/) 3'f1( ,.. t MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GWENDOLYN P. JOHNSON NO. 03-5399 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .126 NORTH PITT STREET. CARLISLE. P A 17013 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ,. ~ 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CARLISLE HOUSING OPPORTUNITIES 60 WEST PENN STREET CARLISLE, P A 17013 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 126 NORTH PITT STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 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. Sec. 4904 relating to unsworn falsification to authorities, April 26. 2006 DATE 'J5wv4 ~J~ DANIEL G. SCHMIEG, E QUIRE Attorney for Plaintiff ~ ~. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff, No. 03-5399 v. GWENDOLYN P. JOHNSON Defendant(s ). April 26, 2006 TO: GWENDOLYN P. JOHNSON 126 NORTH PITT STREET CARLISLE, P A 17013 **THIS FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at .126 NORTH PITT STREET. CARLISLE. PA 17013. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 6. 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $88.414.11 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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 cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (lIS) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings, ." You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two 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 (215) 563-7000. 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 in the sale. To find out if this has happened, you may call (717) 240-6390, 4. Ifthe 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 DESCR1PrION ALL THAT CERTAIN lot of ground in the Borough of Carlisle, Cumberland County, Pennsylvania, being composed of Lot 2 and Lot 3 of the Preliminary/Final Subdivision Plan for the Redevelopment Authority of Cumberland County dated June 14, 1999, and recorded in The Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 79 Page 56, being more particuhuly bounded and described as follows: BEGINNING at a point at the Southern right of way line of Locust A venue at its intersection with North Pitt Street; thence continuing along the Western right of way line of North Pitt Street South 15 degrees 00 minutes 00 seconds West 42.3 feet to a point at the dividing line between Lots 3 and 4 of the aforesaid Subdivison Plan; thence continuing along same South 74 degrees 30 minutes 2 seconds East 81.06 feet to lands now or formerly of the Redevelopment Authority of the County of Cumberland; thence continuing along same North 15 degrees 5 minutes 08 seconds East a distance of 41.36 feet to a point at the Southern right of way line of Locust A venue; thence continuing along same South 75 degrees 10 minutes 3 seconds East 96 feet to a point, the place of beginning. BEING Lots 2 and 3 of the aforesaid Subdivision Plan and known as 126 North Pitt Street. TOGETHER with the rights and privileges for pedestrian and vehicular ingress and egress over Lot 1 of the aforesaid Subdivision Plan, as more particularly set forth in an Easement Agreement dated July 19, 1999, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Misc. Book 619 Page 782. TAX PARCEL #05-21-Q320-078 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Gwendolyn P. Johnson, single person by Corrective Deed from Carlisle Housing Opportunities Corporation dated 7/6/2000 and recorded 7/19/2000 in Deed Book 225 Page 626. PREMISES BEING: 126 NORTH PITT STREET, CARLISLE, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-5399 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From GWENDOLYN P. JOHNSON (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 gamishee(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 $88,414.11 L.L. $.50 Interest FROM 4/13/06 TO 9/6/06 (pER DIEM - $14.53) - $2,121.38 AND COSTS Arty's Comm % Due Prothy $1.00 Arty Paid $113.45 Other Costs Plaintiff Paid Date: APRIL 28, 2006 2~ (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PIDLADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale # 56 On May 31, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 126 North Pitt Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 31, 2006 By: (.Jorl uJ~ Real E;t~\e Sergeant Clf :b '\! S- AVYl qOOZ . 1 J 1 ,"", ' , ;'.: ','.; ", ,'~ ,j .';, \: i ;.,1 I ',; t 'j \/(1 ;\lr\I\U,~.J \.';1'. '.J !u.,,~ul~l~v ,j.:H(j3HS 3Hl JO 33l.:l.:l0 ~