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Home My WebLink About03-5509WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) PATRICIA A. WILLIAMS and STEVEN W. VOLLIAMS for failure to plead to the above action within twenty (20) days froITl date of service of the Complaint, and assess PlaintifFs dmnages as follows: Unpaid Principal Balance Interest Per diem of $26.38 From 12/01/2002 To 11/01/2003 Accumulated Late Charges Late Charges ($44.19 per month to 11/01/2003) Escrow Deficit 5% Attorney's Commission TOTAL $128,385.40 $8,837.30 $351.68 $486.09 $192.25 $6,419.27 $144,671.99 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of SherifFs Sale. Harrisburg, PA 17102 (717) 234-4178 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN 12qTEREST TO ttOMESIDE LENDiNG, INC., PLAINTIFF Vs. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVILTERM IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. 1LC.P. 237.1 7[ hereby certify that on March 24, 2004 1 served the Ten Day Notice required by Pa. R.C.P. on the Defendm~t(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. Hallj~A I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5509 CIVIL TERM PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: March 24, 2004 TO: PATRICIA A. WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLVILLE, PA 17846-8841 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 TIlE PURPOSE OF COLLECTING TItE DEBT. IMPORTANT NOTICE YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAILANCE PERSONALLY OR BY ATTORNEY AND FILE 1N 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 O~-IER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALLER LEON P I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 2344178 CC: LAWRENCE G. FRANK, ESQ. 2023 NORTH SECOND STREET HARRISBURG, PA 17102 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5509 CIVIL TERM PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS Defendants CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: March 24, 2004 TO: PATRICIA A. WiLLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLVILLE, PA 17846-8841 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & HALLER LEON P I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 CC: LAWRENCE G. FRANK, ESQ. 2023 NORTH SECOND STREET HARRISBURG, PA 17102 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 03-5509 CIVIL TERM WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) Total Judgment Amount Interest Per diem of $26.38 to sale date 9/8/2004 Late Charges $44.19 per month to sale date 9,/8/2004 Escrow Deficit $144,671.99 $8,177.80 $441.90 $2,O00.00 TOTAL WRIT $155,291.69 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, September 08, 2004 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PI~ECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSItFRE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: June 4, 2004 Attorney lbr Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4l 78 PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO TIlE SHERIFF OF CUMBERLAND COUNTY: To satist~ 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 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241 PROTHONOTARY/CLERK C~'~ DIVISION ALL that certain parcel of land together with improvements thereon situate in West Pennsboro Township, Cumberland Counly, Pennsylvania, bounded and described as follows: BEGINNING at a railroad spike set in the center line of Green Hill Road (T-434) at comer of lands now or formerly of Larry E. Smith; thence along the center line of Green Hill Road South 01 degree 20 minutes 20 seconds East 135.27 feet to a railroad spike; thence along Lot No. 2 of the hereinaf~r stated subdivision plan North 89 degrees 50 minutes 23 seconds West 322.14 feet to an ironpin; thence along lands now or formerly of Marlin H. Miller North 15 degrees 05 minutes 15 seconds East 85.23 feet to an iron pin; thence along lands now or formerly of Marlin H. Miller and lands now or formerly of Larry E. Smith North 80 degrees 03 minutes 17 seconds East 301.32 fe~t to a railroad spike set in the center line of Green Hill Road (T-434), the point and place of BEGINNING. CONTAINING 33,415 square feet and BEING Lot No. 1 on the Land Subdivision for John A. Crider and Melvin Z. Leid recorded in Plan Book 75, Page 141, Cumberland County records. HAVING THEREON ERECTED A DWELLING KNOWN AS 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 BEING THE SAME PREMISES WHICH Deborah A. Townsend, f/kJa Deborah A. Reasner and also f/k/a Deborah A. Mentzer, by deed dated 12/20/01 mad recorded 12/28/01 in Deed Book 249, Page 4024, granted m~d conveyed m~to Seven W. Williams and Patricia A. Williams. TO BE SOLD AS THE PROPERTY OF PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS ON JUDGMENT NO. 03-5509 CIVIL TERM ASSESSMENT NO. 46-08-0589-023 WASHINGTON MUTUAL BANK, FA SUCCESSOR 1N 1NTEREST TO HOMESIDE LENDING, INC. Plaintiff VS. PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CiVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 entefmg 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 2 LIBERTY AVENUE 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 NOTIFICAKIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR KAZON 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL BANK, FA SUCCESSOR 1N INTEREST TO HOMESIDE LENDING, INC., Plaintiff VS. PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : 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 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN 1NTEREST TO HOMESIDE LENDING, 1NC., Plaintiff VS. PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS, Defendants 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~5>~ - ~'~'o~ ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., is a Corporation, with an address of P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53201. Defendant, PATRICIA A. WILLIAMS, is an adult individual, whose last known address is 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241. Defendant, STEVEN W. WILLIAMS, is an adult individual, whose last known address is 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241. On or about, December 26, 2001, the said Defendants, executed and delivered a Mortgage Note in the sum of $129,476.00 payable to HOMESIDE LENDING, INC., which Note is attached hereto and marked Exhibit "A". Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, 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 conveying to original Mortgagee the subject premises. Washington Mutual Bank, FA is Successor in Interest to Homeside Lending, Inc. The Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on January 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $128,385.40 Interest at $26.38 per day From 12/01/2002 To 11/01/2003 ( based on contract rate of 7.500%) $8,837.30 Accumulated Late Charges $351.68 Late Charges $44.19 From 01/01/2003 to 11/01/2003 $486.09 Escrow Balance $192.25 A~omey'sFee~5%ofPrinc~al Baiance TOTAL $6,419.27 $144,671.99 **Together with interest at the per diem rate noted above after November 01, 2003 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 ora 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 balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them 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. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.500% ($26.38 per diem), together with other charges and costs including escrow advances incidental thereto to the ~tl'/t~of Sheriffs Sale and for foreclosure and sale of the property within described. Leon P. Hailer, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) WmhOStnd (1696x2200x2 tiff) [4] I,OAN $: 2]27009 234~ill~ca~,~ewui~e, PA ;7241 ~ t'HOO'~ ~ ~ ~vrd-~.'~ $'r'r AND ***************************** DdJm3 ~.S. $'i29,475.00 ). l~l ieJes~A to the oJder ~'! ,,,m., lme~ wd] ~ cl~,r~cd on ,npid p~.dT4f, t'mm ( 7,$00% )paryurIihbe~un~,am~he~bac.~pm~. WmhOSlnd (1696x2200x2 tiff) [5] WmhOSlnd (1696x2200x2 tiff) [16] COMPANY NAME: mmmas~4 nnmn ~, va su:,',m:~ m 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 crrm~ zs, 2003 Dean LaRocha Title Assr secretary SHERIFF'S RETURN CASE NO: 2003-05509 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND WASHINGTON MUTUAL BANK VS WILLIAMS PATRICIA A ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT WILLIAMS PATRICIA A unable to locate Her COMPL~AINT - MORT FORE ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and in his bailiwick. but was He therefore returns the the within named DEFENDANT 234 GREEN HILL ROAD NEWVILLE, PA 17241 PROPERTY IS VACANT. , NOT FOUND , WILLIAMS PATRICIA A as to Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 6.21 5.00 10.00 .00 39.21 R. 'Thom~f~ Kline Sheriff of Cumberland County PURCELL KRUG HALLER 01/06/2004 Sworn and subscribed to before me this /~ day of ~/ / ProWh~n0tary ' SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-05509 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WILLIAMS PATRICIA A ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT WILLIAMS STEVEN W unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT NOT FOUND , as to , WILLIANS STEVEN W 234 GREEN HILL ROA~D NEWVILLE, PA 17241 PROPERTY IS VACANT. DEFENDANT'S FORWARDING ADDRESS IS 1834 OLD BERWOCK ROAD BLOOMSBURG, PA 17815-3034. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 ~ R. Thomas Kline Sheriff of Cumberland County PURCELL KRUG HALLER 01/06/2004 Sworn and subscribed to before me this J3~ day of ~0~ A.D. honorary ' SHERIFF'S RETURN CASE NO: 2003-05509 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WILLIAMS PATRICIA A ET AL - OUT OF COUNTY R. Thomas Kline duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT WILLIAMS PATRICIA A but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT - Sheriff or Deputy Sheriff who being a diligent search and , to wit: in his bailiwick. County, MORT FORE He therefore Pennsylvania, to On January 6th , 2004 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep York County 71.84 .00 96.84 ol/os/ oo SO answe~<~- [ R~ Thomas Kline~ Sheriff of Cumberland County PURCELL KRUG HALLER Sworn and subscribed to before me this /~ day of ~7 ~? A.D. Prothonotary COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN I PLAiNTIFF/S/ Washington Mutual Bank 3 DEFENDANT/S/ 2. COURT NUMBER Nq-RSNQ ~V~] 4. TYPE OF WRIT OR COMPLAINT Patricia A. Willi~ns et al Notice & Complaint in Mot tq~qe Foreclosure SERVE /' 5 NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TQBE LEVIED. ATrACHED. OR SOLD Patricia Williams 6. ADDRESS (STREET OR RFO W1TH SOX NUMBER, APT. NO., CITY, BORO. TWP., STATE AND ZIP CODE) AT 14 Golf Course Road Dillsburg, PA 17019 7 INDICATE SERVICE: D PERSONAL iii PERSON IN CHARGE ~[DEPUTIZEC~cr~andU RT. IL ~ 1 ST CLASS MAIL [~ POSTED [~ OTHER NOW October 30 ,20 03 I, SHERIFF OF~III~ COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute thi.~L~~~etu~rn th_,~e//,,~, ording to law. This deputization being made at the request and risk of the plaintiff. 7' ---~'~--~___~.~--~- ~ 8 SPECIAL INSTRUCTIONS OR OTHER ~NFORMATION THAT W~LL ASSIST IN EXPEDITING SERVICE: t~mber±and OUT OF COUNTY -CUMBERLA~ ADVANCE FEE PAID BY ATTORNEY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any prope~ under within w~t may leave same without a watchman, in custody of whomever is found in possession, after notifying person of leW or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale the~of. 9, TYPE NAME and ADDRESS of ATFORNEY / ORIGINATOR and SIGNATURE 1 7 I O 2 10 TELEPHONE NUMBER ] 11. DATE FILED Leon P. Haller, Esq. 1719 N. Front St. Harrisburg PA 717-234-4178~10-17-2003 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELO'~Z ('~is area must be completed if notice is to be mailed). 13, I acknowledge receipt of the writ 14. DATE RECEIVED I 15. Expiration/Hearing Date orcomplaintasindicatedabeve, Ronda M. Ahrens ?RAT 10/31/2003 I 11-16-2003 16 HOWSERVED: PERSONAL ( ) RESIDENCE (/ POS~I~O ( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. CI I hereby certify and tatum a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks bek;w.) / Crv ';f~,~ 'v ~,~ota~I~OTARY~ S~na~ofY~ -- 47. DATE 50, I~CK~EDGE RECEIPT OF THE SHERIFF'S SIG~TURE 5t DATE RECEDED WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC. Plaintiff VS. PATR1CIA A. WILLIAMS AND STEVEN W. WILLIAMS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 a~er 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 LAV~/ER 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 2 LIBERTY AVENUE 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 AV1SO. 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 REFERENC1A DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 COPY FROM RECORD Testimony wnereol, I here unto set my hano WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC. Plaintiff VS. PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-5509 CIVIL TERM PRAECIPE TO REINSTATE TO THE PROTHONOTARy: Kindly reinstate the complaint on the above captioned matter. DATE: February 10, 2004 Leo,9~. Haller/J 1719 North Fl~m'f Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 SHERIFF'S RETURN CASE NO: 2003-05509 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WILLIAMS PATRICIA A ET AL - OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , WILLIAMS STEVEN W but was unable to locate Him in his bailiwick. deputized the sheriff of COLUMBIA County, serve the within COMPLAINT - MORT FORE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, to On March 1st , 2004 , this office was in receipt of the attached return from COLUMBIA Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Columbia Co 50.00 .00 87.00 03/01/200~ So answers: .... -~" .~ ~,~ R~:' Chomas Kline Sheriff of Cumberland County PURCELL KRUG HALLER Sworn and subscribed to before me this ~ day of ~ A.D. l~rothonotary ~o'The Court of Common Pleas of Cumberland County, Pennsylvania Washin§ton Mutual Bank VS. Patricia A. Williams et al SERVE: Steven W. Williams No. 03-5509 civil Now, February 18, 2004 hereby deputize the Sheriff of , I, SHERIFF OF CUMBERLAND COUNTY, PA, do Columbia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland Coanty, PA Affidavit of Service within ,20 ., at o'clock M. served the upon at by handing to _ a and made known to copy of the original So answers, the contents thereof. Sheriff of County, PA Sworn and subscribed before me this __. day of ~ 20 COSTS SERVICE MILEAGE AFFIDAVIT WASHINGTON MUTUAL BANK, FA SUCC[;~SSOR IN INTEREST TO HOMESIDE LENDING, 1NC.~ PLAINTIFF PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM 1N MORTGAGEFORECLOSURE 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 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241: 1. Name and address of the Owner(s) or Reputed Owner(s): PATRICIA A. WILLIAMS 14 GOLF COURSE ROAD D1LLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLVILLE, PA 17846-8841 above: SAME Name and address of Defendant(s) in the Judgment, if different from that listed, in (1) 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): 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: Tenants if any... DOMESTIC RELATIONS Cumberland Counly Courthouse 13 North Hanover Street Carlisle, PA 17013 Lawrence G. Frank, Esquire 2023 North Second Street Harrisburg, PA 17102 Tenant/Occupant 234 Green Hill Road Newville, PA 17241 Jane Alexander, Esquire 148 So. Baltimore Street Dillsburg, PA I7019 (In the preceding infon'nation, 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 mad~ subject to the penalties of 18 PA C.S. Section 4904 relating to unswom PalsSfc~ Leon P,,~4~ler PA I.D. #15700 Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 4, 2004 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 0 3-5509 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK FA Plaintiff (s) From PATRICIA A. WILLIAMS, 14 GOLF COURSE ROAD, DILLSBURG, PA 17019 AND STEVEN W. WILLIAMS, 26 MILL ROAD, MILLVILLE, PA 17846-8841 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT: 234 GREEN HILL ROAD, NEWlLLE, PA 17241 (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 garfftshee(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 t~lm/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $144,671.99 L.L..50 Interest Atty's Corem % Due Prothy $1.00 Atty Paid $326.05 Other Costs Plaintiff Paid Date: 6/9/04 (Seal) REQUESTING PARTY: Name LEON P. HALLER, ESQ Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: (717)2344178 Supreme Court ID No. 15700 CURTIS R. LONG Pr~thonota~ WASHINGTON MUTUAL BANK, FA SUCCESSOR iN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGE FORECLOSURE NOTICE OF SHER/FF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sher/ff's Sale of Real Property (real estate) will be held: DATE: Wednesday, September 08, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberlm~d County Courthouse Cra'lisle, Pem~sylvmfia 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 m~y other ma. jot improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth m~d County to: No. 03-5509 CIVIL TERM JUDGMENT AMOUNT $144,671.99 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: PATRICIA A. WILLIAMS and STEVEN W. WILLIAMS 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 Shehff 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 Con. non 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 exemise your fights, YOU MUST ACT PROMPTLY. 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 Comxty 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. Infonnation about the Schedule of Distribution may be obtained from the Sheriff of the Court of Comm,,on 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 fights, 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 2 Liberty Avenue Carlisle, Pem~sylvania 17013 717-249-3166 Legal Services, hrc 8 h'vine Row Cai'lisle, Pem~sylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Con,anon Pleas of the within County to open the judgm~ent 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 Co~rmxon 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 Adlninistrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaimiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL ti'rat certain parcel of land together with improvements thereon situate in West Pcnnsboro Township, Cumberland County, Pennsylvania, bounded and described ~ follows: BEGINNING at a railroad spike set in the center line of G-teen Hill Road (T-434) at comer of lands now or formerly of Larry E. Smith; thenc~ along the c~ntex line of Green Hill Koad South 01 degree 20 minutes 20 seeonds East 135.27 feet to a railroad spike; thence along Lot No. 2 of thc hcreinm~ stated subdivision plan North 89 degrees 50 minul~s 23 seconds West 322.14 feet to au ironpin; thence alonglands now or formerly of Marlin H. Miller North 15 degrees 05 minutes 15 seconds East 85.23 feet to an iron pin; thence along lands now or formerly of Marlin H. Miller and lands now or formerly of Lan'7 E. Smith Nor& g0 degrees 03 minutes 17 seconds East 301.32 feet to a railroad spike set in the center line of Gu~n Hill Road (T-434), the point and place of BEGINNING. CONTAINING 33,415 square feet end BEING Lot No. 1 on the Land Subdivision for John A. Crider and Melvin Z. Leid recorded in Plan Book 75, Page 141, Cumberland County records. HAVING THEREON ERECTED A DWELLING KNOWN AS 234 GREEN HILL RO,~D NEWVILLE, PENNSYLVANIA 17241 BEING THE SAME PREMISES WHICH Deborah A. Townsend, ffk/a Deborah A. Reasner and also f/k/a Deborah A. Mentzer, by deed dated 12/20/01 and recorded 12/28/01 inDeed Book 249, Page 4024, granted mad conveyed unto Seven W. Willim~as and Patricia A. Williams, TO BE SOLD AS THE PROPERTY OF PATRICIA A. WILLIAMS AND STEVEN W, WILLIAMS ON JI_YDGMENT NO, 03-5509 CIVIL TERM ASSESSMENT NO. 46-08-0589-023 WASHINGTON MUTUAL BANK, FA SUCCESSOR iN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGEFORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHiN Personally appcared 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 wbich would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this _, ~No*raCffiblic , ;'iOTARIAL SEAL '] ,:cv,,s- -~x[on Twp,, Daul~hin County brv_'_r,~' Co!r e~,~,;ion Expires Aug. WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMES[DE LENDING, INC., PLAINTIFF VS. PATRICiA A. WILLIAMS STEVEN W. WILLIAMS. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM 1N MORTGAGE FORECLOSURE RELIEF FROM STAY - 9/12/03 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: PATRICIA A. WILLIAMS Debtor WASHINGTON MUTUAL BANK, F.A., SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC. Movant : VS. : PATRICIA A. WILLIAMS and CHARLES : J. DEHART, III, Trustee : Respondents : ORDER BANKRUPTCY NO. 1-03-02794 CHAPTER 13 FILED HARRISBURG PA Clerk, U.S...Bankruptcy Court AND NOW, to wit, this /~a day of ~.p~&~' , 2003, upon consideration of the Motion of Washington Mutual Bank, F.A., Successor in Interest to Homeside Lending, Inc. to Obtain Relief from Stay, the Motion is hereby granted and the automatic stay is terminated as to the Movant relative to property situate at 234 Greenhill Road, Newville, Pennsylvania 17241. BY THE COURT: Mar~]D .~ance BankruPtcy Judge WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMES1DE LENDING, INC., PLAINTIFF PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) tN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGEFORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on against you in the above-captioned matter: the following judgment has been entered $144,671.99 and for the sale and foreclosure of your property located at: 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 Dated: June 4, 2004 Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 PROTHONOTARY 1 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 PATRICIA A. WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLV1LLE, PA 17846-8841 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) PATRICIA A. WILLIAMS and STEVEN W. WILLIAMS 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 Interest Per diem of $26.38 From 12/01/2002 To 11/01/2003 Accumulated Late Charges Late Charges ($44.19 per month to 11/01/2003) Escrow Deficit 5% Attorney's Commission TOTAL $128,385.40 $8,837.30 $351.68 $486.09 $192.25 $6,419.27 $144,671.99 **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 Sher/ff's Sale. PURCELL, KRUG & HALL~ Bye.. ~~-"~/,-/"~--'~ 1L~;~.o~a~l~rronPt~t/I;De;# 15700 Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 0 3-5509 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLANrD COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK FA Plaintiff (s) From PATRICIA A. WILL/AMS, 14 GOLF COURSE ROAD, D/LLSBURG, PA 17019 AND STEVEN W. WILLIAMS, 26 MILL ROAD, MILLVILLE, PA 17846-8841 (1) You are dixected to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT: 234 GREEN HILL ROAD, NEWILLE, PA 17241 (2) You are also directed to attach the properV/of the defendant(s) not levied upon in the possession of GAP, NISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclunent 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 thc 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 $144,671.99 Interest $8,177.80 Atty's Corem % At~ Paid $326.05 Plaintiff Paid Date: 6~9~04 (Seal) REQUESTI2qG PARTY: Name LEON P. HALLER, ESQ Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: (717)234-4178 Supreme Court ID No. 15700 L.L..50 Due Prothy $I.00 Other Costs PER DIEM OF $26.38 TO SALE DATE 9/8/04. LATE CHARGES $441.90. $44.19 PER MONTH TO SALE DATE 9/8/04 ESCROW DEFICET $2,000.00 CURTIS R. LONG Prothonotary WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Ha, rrisburg, Pennsylvania on '7- 2c]'- 0 t/t , a true and correct copy of the Notice of Sal~ of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 2,817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: PATRIC1A A. WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLViLLE, PA 17846-8841 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Lawrence G. Frank, Esquire 2023 North Second Street Harrisburg, PA 17102 Tenant/Occupant 234 Green Hill Road Newville, PA 17241 Jane Alexander, Esquire 148 So. Baltimore Street Dillsburg, PA 17019 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533 3836 IOSEPH NISSLEY (1910-1982) JOHN W. pi JRCELL VALERIE A G[FqNOF COUNSEL PATRICIA A. WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD M1LLVILLE, PA 17846-8841 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Lawrence G. Frank, Esquire 2023 North Second Street Harrisburg, PA 17102 Tenant/Occupant 234 Green Hill Road Newville, PA 17241 Jane Alexander, Esquire 148 So. Baltimore Street Dillsburg, PA 17019 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 21129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. FURTHER NOTIFIED that the lien you hold against the said real estate will be YOU ARE ~ed of divested by the sale and that you have an opportunity to protect your int said Sheriff's Sale. BY~-'~Le-~on p. ~aller PA I.D.15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR 1N INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sherifi?s Sale of Real Property (real estate) will be held: DATE: TIME: Wednesday, September 08, 2004 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: 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 TIlE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 03-5509 CIVIL TERM JUDGMENT AMOUNT $144,671.99 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: PATRICIA A. WILLIAMS and STEVEN W. WILLIAMS 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 thc 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) (lays 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. Infomaation 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. ' T IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMEN 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: Cumberlaud County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, lnc 8 lrvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Conrt 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 SheriWs 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 parcel of land ~gether v~ improvements ther~n situate in West Permsbore Township, Cumberland County, Pennsylvania, boundecl and described as follows: BEGINNING at a railroad spike set in the center line of Green Hill Road (T-434) at comer of lands now or formerly of Larry E. Smith; thence along, the center line of Green Hill Road South 01 degree 20 minutes 20 seconds East: 135.27 feet to a raikoad spike; thence along Lot No. 2 of the hereinafter stated subdivision plan North 89 degrees 50 minutes 23 seconds West 322.14 feet to an iron pin; 'thence along lands now or formerly of Marlin H. Miller North 15 degrees 05 minutes 15 seconds East 85.23 feet to an iron pin; thence along lands now or formerly of Marlin H. Miller and lands now or formerly of Larry E. Smith North 80 degrees 03 minutes 17 seconds East 301.32 feet to a railroad spik~ set in the center line of G-reen Hill Road (T-434), the point and place of BEGINNING. CONTAINING 33,415 square feet and BEING Lot No. 1 on the Land Subdivision for John A. Crider and Melvin Z. Leid recorded in Plan B~cok 75, Page 141, Cumberland County records. HAVING THEREON ERECTED A DWELLING KNOWN AS 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 BEING THE SAME PREMISES WHICH Deborah A. Townsend, f/t~a Deborah A. Reasner and also f/k/a Deborah A. Mentzer, by deed dated 12/20/01 and recorded 12/28/01 m Deed Book 249, Page 4024, granted and conveyed unto Seven W. Williams and Patricia A. Williams. TO BE SOLD AS THE PROPERTY OF PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS ON JUDGMENT NO. 03-5509 CIVIL TERM ASSESSMENT NO. 46-08-0589-023 WASHINGTON MUTUAL BANK. FA v. PATRIC1A A. WILLIAMS STEVEN W. WILLIAMS Cumberland County Sale 9/8/2004 U. S. POSTAL SERVICI~ CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received li'o ir1: Purcell, Krug & Hailer 1719 North Frout Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: PATRiCIA A. WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 Postage: Postmark: Received from: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: STEVEN W. WILLIAMS 26 MILL ROAD MILLVILLE, PA 17846-8841 IJ. S. POSTAL SERVICE. CERTIFICATE OF MAILING tin comPliance with Postal Service Form 3877) Postage: Postmark: U. S. POSTAL SERVICE, CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, P A 17102 One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 Nmlh Hanover Street Carlisle, PA 17013 Postage: Postmark: ...... o: $ 00.900 0004338187 JUL29 2004 MAILED FROM ZIPGODE 17102 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877~ Received !Yom: Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Lawrence G. Frank, Esquire 2023 North Second Street Harrisburg, PA 17102 Postage: Postmark; U. S. POSTAL SERVICE CERTIFICATE OF MAILING. (In compliance with Postal Service Form 3877) Received front: Pm-cell, Krug &Haller 1719 North Frout Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Tenant/Occupant 234 Green Hill Road Newville, PA 17241 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (Ill compliance with Postal Service Form 3877) Received fi-om: Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Jane Alexander, Esquire 148 So. Baltimore Street Dillsburg, PA 17019 Postage: Postmark: $ 00.900 MAILED FROM ZIPCODE 17102 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Washington Mutual Bank F A is the grantee the same having been sold to said grantee on the 8th day of Sept A.D., 2004, under and by virtue of a writ Execution issued on the 9th day of June, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 5509, at the suit of Washington Mutual Bank F A against Patricia A Williams & Steven W is duly recorded in Sheriff's Deed Book No. 265, Page 4654. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ ~:g7 day of ~ , A.I)2004 / ' ~.~~co/~der of Deeds Washington Mutual Bank, FA Successor In The Court of Common Pleas of In Interest to Homeside Lending, Inc. Cumberland C. ounty, Pennsylvania VS Writ No. 2003-5509 Civil Term Patficia A. Williams and Steven W. Williams R. Thomas Kline, Sheriff, who being duly swom ac,:ording to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Patricia A. Williams, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. YORK COUNTY RETURN: And Now, July 9, 2004 served the within Real Estate Writ, Notice of Sale and Description upon the within named defendant, to wit: Patricia A. Williams, by making known unto Patricia Willizans, personally, at 14 Golf Course Road, Dillsburg, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copy of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Steven W. Williams, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Columbia County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. COLUMBIA COUNTY RETURN: And Now, June 25, 2004 served the within Real Estate Writ, Notice of Sale and Description upon the within named defendant, to wit: Steven W. Williams, by making known unto Steven Williams, personally, at 26 Mill Road, Millville, PA 17846-8841, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copy of the same. Ron Kerr, Deputy Sheriff, who being duly sworn according to law, states that on July 14, 2004 at 2:29 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patficia A. Williams and Steven W. Williams located at 234 Green Hill Road, Newville, 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: Patficia A. Williams, by regular mail to her last known address of 14 Golf Course Road, Dillsburg, PA 17019. This letter was mailed under the date of July 26, 2004 and never returned to the Sheriffs Office. 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: Steven W. Williams, by regular mail to his last known address of 26 Mill Road, Millville, PA 17846-8841. This letter was mailed under the date of July 15, 2004 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 September 08, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon Haller for Washington Mutual Bank, FA Successor in Interest to Homeside Lending, Inc. It being the highest bid and best price received for the same, Washington Mutual Bank, FA, Successor in Interest to Homeside Lending, Inc. of P.O. Box 1169, Dept. 2665, Milwaukee, WI 53201, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $920.10. Sheriffs Costs: Docketing $30.00 Poundage 18.04 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.66 Levy 15.00 Surcharge 30.00 Out of County 18.00 Law Journal 307.25 Patriot News 328.66 Share of Bills 30.49 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 920.10 Sworn and subscribed to before me So · This ,2 f ~ day of ~.,T,~.,.~ 2004, A.D. (-~.~.c,.~ /~_ ')"h.,~,/,% R. Thomas Kline,,, Sheriff ~ro~honot~y ~ BY (/~,/// Real-Estal~Deputy WASHINGTON MUTUAL BANK, FA SUCCESSOR 1N INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRICIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBER]LAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5509 CIVIL TERM IN MORTGAGE FORECLOSUR~OO~~ AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Ka'ug &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 234 GREEN HILL ROAD, NEWVILLE, PENNSYLVANIA 17241: 1. Name m~d address of the Owner(s) or Reputed Owner(s): PATRICIA A, WILLIAMS 14 GOLF COURSE ROAD DILLSBURG, PA 17019 STEVEN W. WILLIAMS 26 MILL ROAD MILLVILLE, PA 17846-8841 2. Name and address of Defendant(s) in the Judgment, if different from tl~t?listecLm (i~ ~-}~ above: SAME ;:~ ~_7 ~ ~-:'~ 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): 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: Tenants if m~y... DOMESTIC RELATIONS Cumberlm~d County Courthouse 13 North Hanover Street Carlisle, PA 17013 Lawrence G. Fraa~k, Esquire 2023 North Second Street Harrisburg, PA 17102 Tenant/Occup ant 234 Green Hill Road Newville, PA 17241 Jane Alexander, Esquire 148 So. Baltimore Street Dillsburg, PA 17019 (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 ,'md correct to the best of my personal knowledge, infom~ation m~d belief. I understand that false statements~herein are mad.% subject to the penalties of 18 PA C.S. Section 4904 relating to unswom falsification~ Leon P~5I~ller PA I.D. #15700 Purcell, Krug &Haller 1719 North Front Street Harrisb~nrg, PA 17102 (717) 2't4-4178 DATE:June 4, 2004 WASHINGTON MUTUAL BANK, FA SUCCESSOR IN INTEREST TO HOMESIDE LENDING, INC., PLAINTIFF VS. PATRJCIA A. WILLIAMS STEVEN W. WILLIAMS, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-5:;09 CIVIL TERM IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: Wednesday, September 08, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Can-lisle, Permsylvanfia 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 anld any other major improvements erected on the lanld. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 234 GREEN HILL ROAD NEWVlLLE, PENNSYLVANIA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth an~d County to: No. 03-5509 CIVIL TERM JUDGMENT AMOUNT $144,671.99 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: PATRICIA A. WILLIAMS and STEVEN W. WILLIAMS A SCHEDULE OF DISTRIBUTION, being a list c}f 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. Infonuation about the Schedule of Distribution may be obtained from the Sheriff of the Court of Conunon 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 fights, 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 2 Liberty Avenue Carlisle, Pe~msylvania 17013 717-249-3166 Legal Services, Inc 8 h'vine Row Carlisle, Pem~sylvania 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 c,r 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 retm-n 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 parcel of land together with improvements thereon situate in West Pennsboro Township, Cumberland County, P~msylvania, bounded and described as follows: BEGINNING at a railroad spike set in the center line of Crreen Hill Road (T-434) at comer of lands now or formerly of Larry E. Smith; thence Mo:ag the center line of Green Hill Road South 01 degree 20 minutes 20 seconds El~ 135.27 feet to a railroad spike; thence along Lot No. 2 of the hereinafter stated subdivision plan North 89 degrees 50 minutes 23 seconds West 322.14 feet to an iron pin; thence along lands now or formerly of Marlin H. Miller North 15 degrees 05 minutes 15 seconds East 85.23 feet to an iron pin; thence along lands now or formerly of Marlin H. Miller and lands now or formerly of Larry E. Smith North $0 degrees 03 minutes 17 seconds East 301.32 fe~t to a railroad spike set in the center line of Omen Hill Road (T-434), the point and place of BEOINNING. CONTAINING 33,415 square feet and BEING Lot No. 1 on the Land Subdivision for John A. Crider and Melvin Z. Leid tee, ordeal in Plan Book 75, Page 141, Cumberland County records. HAVING THEREON ERECTED A DWELLING KNOWN AS 234 GREEN HILL ROAD NEWVILLE, PENNSYLVANIA 17241 BEING THE SAME PREMISES WHICH Deborah A. Townsend, ~:/a Deborah A. Reasner and also f/k/a Deborah A. Mentzer, by deed dated 12/20/01 and recorded 12/28/01 in Deed Book 249, Page 4024, granted and conveyed unto Seven W. Williams and Patricia A. Williams. TO BE SOLD AS THE PROPERTY OF PATRICIA A. WILLIAMS AND STEVEN W. WILLIAMS ON JUDGMENT NO. 03-5509 CIVIL TERM ASSESSMENT NO. 46-08-058%023 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 0 3-5509 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK FA Plaintiff (s) From PATRICIA A. WILLIAMS, 14 GOLF COURSE ROAD, DILLSBURG, PA 17019 AND STEVEN W. WILLIAMS, 26 M][LL ROAD, MILLVILLE, PA 17846-8841 (1) You are directed to levy upon the property of the defendant (s)amt to sell REAL ESTATE LOCATED AT: 234 GREEN HILL ROAD, NEWILLE, PA 17241 (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 attaclnnent 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 $144,671.99 Interest $8,177.80 Atty's Comm % Atty Paid $326.05 Plaintiff Paid Date: 6/9/04 (Seal) REQUESTING PARTY: Name LEON P. HALLER, ESQ Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: (717)234-4178 Supreme Court ID No. 15700 L.L..50 Due Prothy $1.00 Other Costs PER I)IEM OF $26.38 TO SALE DATE 9/8/04. LATE CHARGES $441.90. $44.19 PER MONTH TO SALE DATE 9/8/04 ESCROW DEFICET $2,000.00 CURTIS R. LONG Prothonotary Real Estate Sale #56 On June 21, 2004 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA Known and numbered as 234 Green Hill Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 21, 2004 By: Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOUR~NAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE 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 couxts 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: JULY 16, 23, 30, 2004 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. REAL ESTATE 8ALE NO. 56 Writ No. 2003-5509 Civil Washington Mutual Bank, FA Successor in Interest to Homeside Lending, Inc. VS. Patricia A. Williams and Steven W. Williams Atty.: Leon Haller ALL that certain parcel of land together with improvements thereon situate in West Pennsboro Town- ship, Cumberland County, Pennsyl- vania, bounded and described as follows: BEGINNING at a railroad spike set in the center line of Green Hill Road {T-434) at corner of lands now or formerly of Larry E. Smith; thence along the center line of Green Hill Road South 01 degree 20 min- utes 20 seconds East 135.27 feet to a railroad spike; thence along Lot No. 2 of the hereinafter stated sub- -~-~o~ ~l,an lqt~th R.Q de~rees 50 [ ~isa Marie Coyn~/, Editor SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 LOIS E. SNYDER, Notary Public Carlisle Boro, Curnbedand County My Commission [-3(pi~s March ,5, 2005 THE PATRIOT NEWS THE SUNDAY PATRIOT ]NEWS Proof of Publication UnderAct 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 Permsylvania, 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 'E~e Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have beert 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 27th day(s) of July and the 3rd and 10th day(s) of August 2004. That neither he nor said Company is interested in ~ae 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 ....... //./'re'me'l~. , . . Sworn to and subsc'rf6ed before me-this 23rd day of gust 2 4 A D S A L E #56 [ ~,~~ C~E~A~ C(>~Y SHE~FS OFFICE ~ C~E~ CO~TY CO~THOUSE ~~ Statement of Advertising Costs For publis~g ~e notice or pub~cafi~,n a~ached ~~ a a'~ ~ ~'~ ~. hereto on ~e above stated dates 328.66 ~ ~ . ~ ~ ~ Publisher's Receipt br Adve~ising Cost ~ ~ a ~ ~ ~ ~ ~ lishcr of ~e PaYor-News ~d ~e S~y Patriot-News, newspapers of general ~ ~ ~ ,ledge receipt of ~e aforesaid notice and publication cos~ and ce~fies ~t ~e same