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Home My WebLink About07-6837 Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JILL RICHARDSON ACTION OF MORTGAGE FORECLOSURE Defendant 07 - taP3 7 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. JILL RICHARDSON, Defendant CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JILL RICHARDSON, ACTION OF MORTGAGE FORECLOSURE /Z - Defendant -1,7 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is MIDFIRST BANK, a corporation whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. Defendant, JILL RICHARDSON, is an adult individual whose last known address is 31 MARKET STREET WORMLEYSBURG, PA 17043. 3. On or about, October 19, 2000, the said Defendant executed and delivered a Mortgage Note in the sum of $61,660.00 payable to EQUITY ONE, INCORPORATED, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1646, Page 804 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and was recorded in the aforesaid County in Mortgage Book 657, Page 1109. The Mortgage was subsequently assigned to MIDFIRST BANK and was recorded in the aforesaid County in Mortgage Book 693, Page 3266. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 31 MARKET STREET WORMLEYSBURG, PA 17043 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on May 01, 2007 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $12.59 per day From 04/01/2007 To 12/01/2007 ( based on contract rate of 8.0000%) Accumulated Late Charges Late Charges $24.24 From 05/01/2007 to 12/01/2007 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $57,452.79 $3,071.96 $299.43 $169.68 $489.51 $2,872.64 $64,356.01 "Together with interest at the per diem rate noted above after December 01, 2007 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 12. Prior to the commencement of this foreclosure action, Plaintiff sent to Defendant written notice dated July 18, 2007, notifying her of the fact of default, amount needed to cure the delinquency and that if the account was not timely reinstated, a foreclosure action would be filed. A copy of the July 18, 2007 notice is attached hereto and marked Exhibit "C". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.0000% ($12.59 per diem), together with other charges and costs including escrow advances incidental thereto. to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: PURCELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Generated by Tal]PDF.NET Evaluation ;r sM %ad 13Lv-t ff wq ORIGMALNOTE Flt/? Cue No. Multistate LN# 00240407 441-6381961 October 19, 2000 WWI 31 Market Street,Wormleysburg.PA 17043 n"t" Ad&Ml 1. PARTIES "Borrower" means each person signing at the end of this Note, ad the persom's successors and assigns. 'Lender" mum Equity One, Incorporated, a Pennsylvania Corporation and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; EgTEREST In remm for a loan received from Lender. Borrower promises to pay the principal sum of Sixty One Thousand Six Hundred Sixty and no/100 Dollars (U.S. 5 61.660, 00 )1 'plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Eight percent( : 8 . A000 %) per yeff until the IVU amount of principal has boon paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of must or similar security instrument that is dated the same date as this Now and called the "Security lastrument. I The Security hiammeat protects the Lender from lasses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Mate Borrower shall make a payment of principal and interest to Leader on the fast day of each month beghudng on December.1 , 2000 . Any principall and ineereat remaining on the faw day of November 2030 , will be due on that date, which is called the "Maturity Date." (B) Payftwe atentshalibernadeat 400 Lippincott Drive. Marlton. NJ 08053 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly paymem of principal and lnt and will be in the amount of U.S. $452.44 This amount will be part of a larger monthly payment mitrired by the Sam ft Inetrtmnent, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) AUonge to"Note for payment a4ustmsents If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the sponge shall be incorporated into aced shall amend and supplement the covenants of this Note as if the allonge were a pan of this Note. [Check applicable box) ?GOduated payment Alionge []Growing Equity Anouge Other (Specify) 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, In whole or in part, without charge or penalty, on the first day of any month. Leader shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower undoes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless lender agrees in writing to those changes. FRA Aodtleatt Flaed Batt Nets -10/45 ?r111? -7R wto11.01 vW MORTGAGE FORMS -100019.21.7211 Pop 1 012 MW Guam N , N t. Click here to unlock TaIIPDF.NET (YYYYII t , Generated by TaIIPDF.NET Evaluation f?r t r ' 1 1i/ 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments S If Lender has not received the fall monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.0000 %) Of the overdue amount of each payment. (B) Default If Borrower defaults by Miling to pay In }till any monthly payment, then Leader may, except as limited by regulations of the Secretary in the case of payment defw[ts, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose tot to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Leader Ia rights to require immediate payment in full in the can of payment defatlts. This Note does not suthoft acceleration when not permitted by HUI) regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Leader may require Borrower to pay coats and expenses including reasonable and customary anomeys' toes for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear Interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the tight to require Leader to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have no been paid. 8. GPANG OF NOTICES Unless applicable law requires a different method, any notice that mist be given to-Borrower under this Note will be given by delivering ri or by mailing It by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's dif trout address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragrapb 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If mDre than one person signs this Nosq., each person is fully and personally obligated to keep ail of the promises made in this Note. including the promise to pay the full amount oared, Any person who Is a guarantor, surety or endorser of this Note is also obligated to do time things. Any person who take over these obligations, Including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signstorieB together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms ad covenants contained in this Note. _ (Seal) -Borrower -(Seal) -Harrower _ (Seal) -Harrower _ (Seal) -Borrower Y\ (Seat) J Richardson -T -Borrowsr (seal) -BMMW r _ (Seal) -normww fSCRIl -Borrower (MV1q awn.0+ hw x d s VrMOM RECOURSE PAY TO Tim ORDER OP BOMSIDE LENDING. INC. ( PiY TO TH>C;OHD>CR OY.• SQrfITY ONE, INCORPORBED 4ic'ii t? ?t.tY}j,.? BRIMDL r.;.b Stall SMOR vies M31DIMT Aasbnarrt Vlor tnaldastt - . Click here to unlock TallPDF.NET ALL THAT CERTAIN tract of lend situate In ft Borough of WortnbysW% Cocudy of Cumberland and Commonwealth of Penns*enkk mom particularly bounded and described in accedence with a survey of Michael C. VAngelo, R.S., dated Aprl 27,1991, as follows, to wit BEGINNING at a point on the soutirerrr fine of Market $44 said point being measured by same In a saftisterly direction a distance of 71.50 feet from Second Street; tlarnce wA 41 degrees 36 minutes 00 seconds ad being along and through a pa tMm wad and beyond a distance of 57.99 feet to a point; thence soulh 48 degrees 24 minutes 00 seconds west a distance of 14.66 feet to a?t ow north 46 degrees 25 minutes 00 seconds west along the no sm rsie of an unopened alley a of 58.12 feet to a point on the a Aorn line of Market Street dwweid, trence along said =&w tine of Market Street, north 48 degrees 24 minutes 00 seconds east, a distance d 18.53 feet to a point and place of BEGINNING. BEING known and numbered a5 W Market Street. UNDER AND SUBJECT, nevertheless, to all other conditions and restrictions of record, 5 any, as they may OPPOW. Nov-05-O7 07:42am From-MIDLAND MORTGAGE REFERRAL MidlanI 999 N.W. G; Oklahoma C jY2ezPjL9m*.j4Q5)426- weapm=y. j* 18, 2DD7 COL 111-L RtCHA=SON 31 MARKET ST WORMLEYSSURG r T-386 P.01/02 3 a F-086 Rl:: Lou 0 46957134 Dear Mortgagor(s): Midland Mortgage Co. is the holder of a Mortgage and a Note on the above premises, or is the mortgage servicing agent for such holder. As of the date of this notice, TR8 WORTGAGE IS IM DZr&ULT STATUS because of nonpayment of the following: Payments, late charges, and advances from 5/1=7 through 711&2o07. The total amount now required to cure the default, or in other words get caught up in your payments, is *2,117.59 - All payments referred to in this notice must be in the form of cashier's or certified check made payable to Midland Mortgage Co., and must be received at P-0. Sox 268888, Oklahoma City, OK 73126-8888, not later than the dates and times specified herein. In the event payment, as specified in the proceeding paragraph, is riot made WTTUIM THIRTY (30) DAYS from the date of this letter, it is the intention of the holder of the mortgage, through this company, to accelerate (declare due and payable immediately the entire loan) the mortgage obligation and all other lawful charges and instruct our attorney to institute WORTGAGE WOUICI.OSURE PROCE$DING. s i i i i PA 17043-1673 CO I* [ k1c (I Nov-05-07 07:42am From-MIDLAND MORTGAGE REFERRAL T-366 P.02/02 F-096 (a) :Cf you wish to CWX Ta DIW&MT within thirty (30) days from the daze of this letter, you must pay the TOTU AMODHT AUR stated above. plus an additional monthly installment if payment is made after the lot day of the next mouth, plus an additional laze charge if due at time of payment and not included above. A LATE CNN= is due with each mortgage payment paid more than fifteen (15) days after the due date. Your current monthly installmenr is $5oe.00 . (b) it payment is made AYTBR TXZRTY (30) PAYR from the date of this letter, but RRFOR8 FO1XCLOSUR1 PROC89PING has been started. the amount you will have to pay will also include the regular monthly installments and late c4argea then due. plus, if incurred, any ATTORART' N FBR OF NOT MORE TRAIT 550.00 and any title report costs, which amount can be obtained by contacting Midland Mortgage Co. at 1-800-552-3000. AFTER FORBCLOSURS PROCRBDZWCv R&S RX28 STARTUP- you have the right to STOP the foreclosure action any time up to OWN (Z) NOUR ARTOXX rho cammonoement of rho 98=R2lP 1 S -gALA by payinQr ttie entire amount due at the time, which shall include all delinquent installments and unpaid late charges, together with R39ASONA91.3 LRG7?L FRSS ACTUALLY IITCURRIta. cost and other sums related to trie foreclosure action, which amount can be obtained by contacting Midland Mortgage Co. at 1-800-552-3000. Should you BAIT, to reinstate the loan as outlined above, the mortgage premises will be SOLD AT SURIB913 0A&E, which will take place approximately seven (7) to eleven (11) weeks following SBRVICR of the Complaint in Mortgage Foreclosure, at which time your OWNSIO8IP interest in mortgage premises will be T3JXIIIATZV, and thereafter, if occupied, proceedings will be taken to o8TAIW POSB$3SIOW of the real estate. You have the right to I RYWANCE TUR LOAN with another lending institution or TRAXSFBR To$ PROPRRTY to another person, under and oubject to the existing mortgage. That peroon will have the 3AIi8 RIGHT TO CURB THE DEFAULT as you have, subject to the same limitation and requirements. You may CURB ABFAULTB up to three (3) times in any calendar year. Upon cure of a default you will be in the same position as if there had been NO DEFAULT- A default may be cured by ANYONE on your behalf- please note that if the loan was in default at the time Midland began servicing it, we are required to advise you that this communication is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. Sincerely, Midland Mortgage Co. Collection Department 46967734 COMPANY NAME: MIDFIRST BANK VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated NOV 0 5 2007 Title Mee President N T, 0I W 14, -lz w cz ct? SHERIFF'S RETURN - REGULAR CASE NO: 2007-06837 P s COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS RICHARDSON JILL DAWN KELL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RICHARDSON JILL the DEFENDANT , at 1813:00 HOURS, on the 26th day of November-, 2007 at 31 MARKET STREET WORMLEYSBURG, PA 17043 by handing to JILL RICHARDSON 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 Sworn and Subscibed to 18.00 15.36 .00 10.00 .00 43.36 before me this day So Answers: X?Z- 11 R. Thomas Kline 11/27/2007 PURCELL KRUG & HALLER By: ?) ? Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CAS*E NO: 2007-06837 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS RICHARDSON JILL DAWN KELL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TENANTS/OCCUPANTS the DEFENDANT at 1813:00 HOURS, on the 26th day of November , 2007 at 31 MARKET STREET WORMLEYSBURG, PA 17043 by handing to JILL RICHARDSON 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: So Answers: Docketing Service 6.00 .00 Affidavit .00 Surcharge b 10.00 R. Thomas Kline ? `a` .00 16.00 11/27/2007 PURCELL KRUG & HALLER Sworn and Subscibed to By: Z? 6 1- before me this day Deputy Sheriff of A.D. MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA JILL RICHARDSON, VS. DEFENDANT(S) CIVIL ACTION LAW NO. 07-6837 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) JILL RICHARDSON for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance $57,452.79 Interest $3,071.96 Per diem of $12.59 From 04/01/2007 To 12/01/2007 Accumulated Late Charges $299.43 Late Charges $169.68 ($24.24 per month to 12/01/2007) Escrow Deficit $489.51 5% Attorney's Commission $2,872.64 TOTAL $64,356.01 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & Leon P er PA I.D. # 15700 17 orth Front Street Harrisburg, PA 17102 (717) 234-4178 MIDFIRST BANK, Vs. JILL RICHARDSON, PLAINTIFF DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-6837 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on January 9, 2008 1 served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. Hall-w'PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 ? w f MIDFIRST BANK, VS. JILL RICHARDSON Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6837 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: January 9, 2008 TO: JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE 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 717-249-3166 PURCELL, KRUG & HALLER LEON P. HALL, ttorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 W 4. MIDFIRST BANK, VS. PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-6837 JILL RICHARDSON, DEFENDANT IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before m thi / ?) day 20 LEON P.1 ,?&LER, ESQUIRE r 1 11VL-? OF PENrvsYLVANI, N'OTAI?I-L SEAL ?. NO K. F'RRETr' Notary Public ?'` xton Two;., Da .pt, n County Expires $. 2010 4A v , Tarr ? .?? 91 03 niT L 1 ? f f .3 `-G W. MIDFIRST BANK, VS. JILL RICHARDSON, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-6837 DEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on a .I D the following judgment has been entered against you in the above-captioned matter: $64,356.01 and for the sale and foreclosure of your property located at: 31 MARKET STREET WORMLEYSBURG, PA 17043 Dated: February 20, 2008 Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 ?_ ?71'060? ?v'111-lz ?C&W'r_r ,FROTH R I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236 JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 -. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW AT NO. 07-6837 MIDFIRST BANK, Total Judgment Amount $64,356.01 PLAINTIFF Interest $2,417.28 Per diem of $12.59 to sale vs. date 6/11/2008 Late Charges $145.44 JILL RICHARDSON, $24.24 per month to sale DEFENDANT(S) date 6/11/2008 Escrow Deficit $1,995.80 TOTAL WRIT $68,914.53 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, June 11, 2008 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned Date: February 20, 2008 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leo . Haller P I.D. # 15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 31 MARKET STREET WORMLEYSBURG, PA 17043 Date: PROTHO OTARY? JKKII VI L DIVISION BY DEPUTY 00 W s ?64 O O C) to ov 'b V D i '6+. 00 t11 0 fJ) O W ? O O p 0 6 0 D w N CI Ur I O ALL THAT CERTAIN tract of land situate in the Borough of Wormleysburg, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael D. D'Angelo, R.S., dated April 27, 1991, as follows, to wit: BEGINNING at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence south 41 degrees 36 minutes 00 seconds east being along and through a partition wall and beyond, a distance of 57.99 feet to a point; thence south 48 degrees 24 minutes 00 seconds west a distance of 14.66 feet to a point; thence north 45 degrees 25 minutes 00 seconds west along the northeastern line of an unopened alley a distance of 58.12 feet to a point on the southern line of Market Street aforesaid; thence along said southern line of Market Street north 48 degrees 24 minutes 00 seconds east a distance of 18.53 feet to a point and place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 07-6837 ASSESSMENT NO. 47-20-1858-157 MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. JILL RICHARDSON, DEFENDANT(S) CIVIL ACTION LAW NO. 07-6837 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 31 MARKET STREET WORMLEYSBURG, PA 17043: Name and address of the Owner(s) or Reputed Owner(s): JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): CitiFinancial, Inc. 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are ma ubject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities Leo aller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 20, 2008 (`? rt, r ?-'? <.:? O ? f'`r .,? -_ ?.? 7 ?`]- ? `? - -= ?? t ?°,? : ? r ?' _ c_?r . ,?_.. A MIDFIRST BANK, PLAINTIFF VS. JILL RICHARDSON, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-6837 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 11, 2008 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 31 MARKET STREET WORMLEYSBURG, PA 17043 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 07-6837 JUDGMENT AMOUNT $64,356.01 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILL RICHARDSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT'AGAINST YOU. - IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: L You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land situate in the Borough of Wormleysburg, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael D. D'Angelo, R.S., dated April 27, 1991, as follows, to wit: BEGINNING at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence south 41 degrees 36 minutes 00 seconds east being along and through a partition wall and beyond, a distance of 57.99 feet to a point; thence south 48 degrees 24 minutes 00 seconds west a distance of 14.66 feet to a point; thence north 45 degrees 25 minutes 00 seconds west along the northeastern line of an unopened alley a distance of 58.12 feet to a point on the southern line of Market Street aforesaid; thence along said southern line of Market Street north 48 degrees 24 minutes 00 seconds east a distance of 18.53 feet to a point and place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 07-6837 ASSESSMENT NO. 47-20-1858-157 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6837 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s) From JILL RICHARDSON (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 $64,356.01 L.L.$ 0.50 Interest per diem of $12.59 to sale date 6/11/08 - $2,417.28 Atty's Comm % Due Prothy $2.00 Arty Paid $178.36 Plaintiff Paid Date: 2/22/08 (Seal) REQUESTING PARTY: Other Costs : Late charges - $24.24 per month to sale date 6/11/08 - $145.44 Escrow Deficit - $1,995.80 Deputy Name LEON P. HALLER, ESQURIE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Prothonotary 7 By: Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 Midfirst Bank VS Jill Richardson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-6837 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Leon Haller. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Levy Surcharge 30.00 1.94 15.00 .50 2.00 14.40 15.00 20.00 $ 98.84 ,-' .7/xgo8 -LRn So Answers: R. Thomas Kline, Sheriff J Real Estat0 ergeant ?'2 . sd K:zt `.?q3b Rte' c&136 MIDFIRST BANK, PLAINTIFF VS. JILL RICHARDSON, DEFENDANT(S) IN THE COURT OF COMMON ?• CUMBERLAND COUNTY, PE SY 'VANIA CIVIL ACTION LAW NO. 07-6837 C? - IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 31 MARKET STREET WORMLEYSBURG, PA 17043: Name and address of the Owner(s) or Reputed Owner(s): JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): CitiFinancial, Inc. 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are ma ubject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities Leo alter PA I.D. 415700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 20, 2008 MIDFIRST BANK, PLAINTIFF VS. JILL RICHARDSON, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-6837 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 11, 2008 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 31 MARKET STREET WORMLEYSBURG, PA 17043 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 07-6837 JUDGMENT AMOUNT $64,356.01 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILL RICHARDSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's. Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land situate in the Borough of Wormleysburg, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael D. D'Angelo, R.S., dated April 27, 1991, as follows, to wit: BEGINNING at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence south 41 degrees 36 minutes 00 seconds east being along and through a partition wall and beyond, a distance of 57.99 feet to a point; thence south 48 degrees 24 minutes 00 seconds west a distance of 14.66 feet to a point; thence north 45 degrees 25 minutes 00 seconds west along the northeastern line of an unopened alley a distance of 58.12 feet to a point on the southern line of Market Street aforesaid; thence along said southern line of Market Street north 48 degrees 24 minutes 00 seconds east a distance of 18.53 feet to a point and place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 07-6837 ASSESSMENT NO. 47-20-1858-157 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6837 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s) From JILL RICHARDSON (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 $64,356.01 L.L.$ 0.50 Interest per diem of $12.59 to sale date 6/11/08 - $2,417.28 Atty's Comm % Due Prothy $2.00 Atty Paid $178.36 Other Costs : Late charges - $24.24 per month to sale date 6/11/08 - $145.44 Escrow Deficit - $1,995.80 Plaintiff Paid Date: 2/22/08 D Prothonotary (Seal) By: REQUESTING PARTY: Name LEON P. HALLER, ESQURIE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Deputy Supreme Court ID No. 15700 Real Estate Sale # 55 On March 6, 2008 the Sheriff levied upon the defendant's interest in the real property situated in the Borough of Wormleysburg, Cumberland County, PA Known and numbered as 31 Market Street, Wormleysburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 6, 2008 S? --0! V L Z a3 j 8001 By:, ( ' nt?t, Real Estate Sergeant Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 IhallerOpkh.com MIDFIRST BANK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. JILL RICHARDSON, TO THE PROTHONOTARY: PRAECIPE Please mark the judgment entered in the above captioned matter satisfied of record, because the Mortgage has been reinstated and the default cured. PURCELL, KRUG AL Leon P. Haller ID #15700 Attorney for Plaintiff NO. 2007 -6837 Civil Defendant IN MORTGAGE FORECLOSURE Date: April 24, 2008 r,A o w ? o h ? N Q 4?"'Cfl °"P7 r_iv 0