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HomeMy WebLinkAbout03-5613GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 -- MELLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Real Owner(s) 110 McAllister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY C1VIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No.O CIVIL ACTION: MO~,4 ~ {.~AGE FORECLQSURE 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. AVIS _0 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. The name(s) and address(es) of the Defendant(s) is/are JEFFREY A. LEHMAN, 145 Goodhart Road, Shippensburg, PA 17257 and STACY L. LEHMAN, 145 Goodhart Road, Shippensburg, PA 17257, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On November 17, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#: 1653 Page: 11. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due July 01, 2003, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest fi.om 06/01/2003 through 10/31/2003 at 8.0000% Per Diem interest rate at $26.42 Attorney's Fee at 5.0% of Principal Balance Late Charges fi.om 07/01/2003 to 10/31/2003 Monthly late charge amount at $45.82 Costs of suit and Title Search Monthly Escrow amount $220.82 $120,558.10 $4,042.26 $6,027.91 $183.28 $900.00 $131,711.55 $131,711.55 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 based on work actually performed. 8. 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. VERIFICATION 1, Michael D. Vestal, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: Michael D. Vestal . COUNTRYWIDE HOME LOANS INC. l.e~al DescrJotJol~: · ~LL THAT CERTAIN TRACT OF LAND, SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN IN THE CENTER OF THE PUBLIC ROAD LEADING FROM MCCALISTER CHURCH TO ELLIOTSON AT LINE OF LANDS NOW OR FORMERLY OF HAROLD S. SNYDER AND DOROTHY I. SNYDER, THF. NCE ALONG THE CENTERLINE OF SAID PUBLIC ROAD, NORTH 21 DEGREES 15 MINUTES WEST 279 FEET TO AN iRON PIN; THENCE STILL ALONG THE SAID CENTER LINE, NORTH 16 DEGREES 50 MINUTES WEST FEET TO ANOTHER iRON PIN; THENCE BY LAND NOW OR FORMERLY OF CLAIR M. ROWERS, SOUTH 63 DEGREES 30 MINUTES WEST 7223 FEET TO A FENCE POST AT LANDS NOW OR FORMERLY HAROLD S. SNYDER AND DOROTIIY !. SNYDER, THENCE ALONG LANDS NOW OR FORMERLY OF HAROLD S. SNYDER AND DOROTHY L SNYDER, SOUTH 84 DEGREES 00 MINUTES EAST 799 FEET TO THE POINT OF BEGINNING. BEING THE SAME PREMISES WHICH JANET L FARRANDS, EXECUTRIX OF THE ESTATE OF DOROTHY I. SNYDER, GRANTED AND CONVEYED TO JEFFREY A. LEHMAN AND STACY L. LEHMAN, HUSBAND AND WIFF~ BORROWERS HEREIN. SHERIFF'S RETURN - CASE NO: 2003-05613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTPJtTI VS LEHMAN JEFFREY A ET AL REGULAR GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, LEHMAN STACY L DEFENDANT , at 1300:00 at 401 W M3tIN STREET WALNUT BOTTOM, PA 17266 STACY L LEHMAN a true and attested copy of the within COMPLAINT - MORT FORE was served upon the HOURS, on the 31st day of October 2003 COMPLAINT - by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments 110 MCALLISTER CHURCH ROAD IS VACANT. Sheriff's Costs: Docketing 6 Service 9 Affidavit Surcharge 10 25 00 66 00 00 00 66 Sworn and Subscribed to before me this L ~--~ day of ~ o~ ~g%3 A.D. honor ary ' So Answers: R. Thomas Kline 11/03/2003 GOLDBECK MCCAFFERTY MCKEEVER Deputy She~j~ff SHERIFF'S RETURN CASE NO: 2003-05613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS LEHMAN JEFFREY A ET AL - REGULAR DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon LEHMAN JEFFREY A DEFENDANT , at 1651:00 HOURS, at 109 WOODVIEW DRIVE MT HOLLY SPRINGS, PA 17065 JEFFREY A LEHMAN a true and attested copy of COMPLAINT the on the 31st day of October by handing to - MORT FORE together with law, , 2003 and at the same time directing His attention to the contents thereof. 110 MCALLISTER CHURCH ROAD IS VACANT. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this ~,~ day of ~_ ~ A.D. rothonota~y ~ J So Answers: R. Thomas Kline 11/03/2003 GOLDBECK MCCAFFERTY MCKEEVER By: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. Plaimiff, JEFFREY A. LEHMAN AND STACY L. LEHMAN, Defendants Docket No. 03-5613 Civil Action SUGGESTION OF BANKRUPTCY Filed on Behalf of De£endant Jeffrey Lehman Counsel for this party: Steven C. Courtney, ['.squire GODFREY & COURTNEY P.O. Box 6280 Harrisburg, Pennsylwtnia 17110 Telephone: 717.540.3900 I.D. # 74669 IN THE COURq[ OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, JEFFREY A. LEHMAN AND STACY L. LEHMAN, Defendants Docket No. 03-5613 Civil Action SUGGESTION OF BANKRUPTCY AND comes now Jeffrey Lehman, the Defendant in the above entitled and styled cause, by and through counsel, Steven C. Courtney, Esquire, and shows unto the Court: 1. On October 31, 2003, the Defendant filed his/her petition for relief under Section 301 of Title 11 of the United States Code in the United States Bankruptcy Court, Middle District of Permsylvania. The Defendant's petition was assigned case number 03- 06475. 2. Section 362 of Title 11 provides, in pertinent part, certain protections from creditors including the commencement or continuation of any process of a judicial, administrative or other action or proceeding against the debtor that was or could have been commenced before the commencement of the case under this Title, or to recover a claim against the debtor that arose before the commencement of the case under the Bankruptcy Court. WHEREFORE, the Defendant respectfully requests that these civil proceedings against him/her be stayed without further hearing or order of t~0urt. 8Veveqy{;,-G~rtney, Esquire GODFREY & COURTNEY P.O. Box 6280 Harrisburg, Pennsylwmia 17110 Telephone: 717.540.3900 I.D. # 74669 CERTIFICATE OF SERVICE AND NOW, this 7th day of November, 2003, I, Steven C. Courmey, Esq., of Godfrey & Courmey, P.C., attomeys for Plaintiff, hereby cexfify that I served the foregoing document this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Joseph A. Goldbeck, Jr., Esquire Suite 5000 Mellon Independence Cemer 701 Market Street Philadelphia, PA 19106 Steven C. Co(1-~fiey, Esquire GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 Term No. 03-56b PRAEC1PE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff SHERIFF'S CASE NO: 2003-05613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTP~ATI VS LEHMAN JEFFREY A ET AL RETURN - REGULAR KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT LEHMAN JEFFREY A DEFENDANT , at 1215:00 at 109 WOODVIEW DRIVE MT HOLLY SPRINGS, PA 17065 TODD LINDSEY, BROTHER IN LAW, a true - MORT FORE was served upon HOURS, on the 29th day of March the , 2004 and attested copy of by handing to ADULT IN CHARGE COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this df~ day of ~ ~2&W~ ~ A.D. rothonotary So Answers: 03/30/2004 GOLDBECK MCCAFFERTY MCKEEVER SHERIFF'S RETURN CASE NO: 2003-05613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS LEHMJ~N JEFFREY A ET AL - REGULAR KENNETH GOSSERT Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE LEHMAN STACY L DEFENDANT , at 1254:00 HOURS, at 401 W MAIN STREET WALNUT BOTTOM, PA 17266 STACY LEHMAN a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 29th day of March , 2004 by handing to 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 6.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 25.66 Sworn and Subscribed to before me this ~ day of  ~2~ A.D. //Prothonotar~ ~ ' So Answers: R. Thomas Kline 03/30/2004 GOLDBECK MCCAFFERTY MCKEEVER By: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #1~132 Suite 500 -The Bourse Bldg. 111 S. Indep.endence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff VS, JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., and against JEFFREY A. LEItMAN and STACY L. LEHMAN for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $138,119.83. Joseph A. Gol~'. ~ Attorney for Plai I hereby certify that the above names are correct and that the preci~ ce address of the judgment c editor ~s MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are JEFFREY A. LEHMAN, 109 Woodview Drive Mt. Holly Springs, PA 17065 and STACY L. LEHMAN, 401 W. Main Street Walnut Bottom, PA 17266; GOLD~AFFERTY & McKEEVER BY: Josep~ ,,.. (~o~dbeck, Jr. Attorney f~la~t'fff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 06/01/2003 through 04/30/2004 Attorney's Fee at 5.0000% of principal balance Late Charges Costs of Suit and Title Search Escrow Balance Deficit $120,558.10 $8,850.70 $6,027.91 $458.20 $900.00 $1,324.92 ($0.00) $138,119.83 GOLDBECK Mc~ BY: Joseph A. G~e'~e Attorney for PlainT ~.TY & McKEEVER AND NOW, this ~4~, . day of '~(~ ~, 2004 damages are assessed as above. Pro Prothy In the Court of Common Pleas of Cumberland County MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75624-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff Defendant(s) OCTOBER 2003 No. 03-5613 CIVIL PRAECIPE FOR JUDGMENT 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. Enter the Judgment in favor of Plaintiff and against JEFFREY A. LEHMAN and STACY L. LEHMAN by default for want of an Answer. Assess damages as follows: $138,119.83 Debt Interest - 06/01/2003 to 04/30/2004 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN TME COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and,_~ 1 ~at~t ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A.~3i l~k~ Jr. Attorney for l~afr~iff~ · I.D.//16132 AND NOW -~AM3~I. 5 , °~O¢ , Judgment is entered in favor of MORTGAGE ELECT_RONIC ~_GISTRATION SYSTEMS, 1NC. and against JEFFREY A. LEHMAN and STACY L. LEHMAN by default for want'fit' an Answer and damages assessed in the sum of $138;119.83 as per the above certification. 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. DATE OF THIS NOTICE: April 19, 2004 TO: STACY L. LEHMAN 10 Cabin Lane Shippensburg, PA 17257-9628 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(~9 TO: STACY L. LEHMAN 10 Cabin Lane Shippensburg, PA 17257-9628 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 JUDG~T 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. 1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFF[CE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Itvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon h~dependence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 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 TIlE DEBT. DATE OF THIS NOTICE: April 19, 2004 TO: JEFFREY A. LEHMAN 10 Cabin Lane Shippensburg, PA 1725%9628 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS, JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 1 l 0 McCallister Church Road Cra'lisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(s) TO: JEFFREY A. LEHMAN 10 Cabin Lane Shippensburg, PA 1725%9628 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 ABOLrl' AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES/NC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libelly Avenue Carl/sle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbcck, Jr., Esq. 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DATE OF THIS NOTICE: April 19, 2004 TO: JEFFREY A. LEI[MAN 401 West Main Street Walnut Bottom, PA 17266 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, iNC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CWIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CWIL Defendant(s) TO: JEFFREY A. LEHMAN 401 West Main Street Walnut Bottom, PA 17266 IMPORTANT NOTICE YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WI~H 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. 1F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H/RING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvlne Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libe~y Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr,, Esq, Aaomey for plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: April 19, 2004 TO: STACY L. LEHMAN 109 Woodview Drive Mt. Holly Spr/ngs, PA 17065 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CiVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(39 TO: STACY L. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 IMPORTANT NOTICE YOU ARE 1N 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 h'vine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDIItECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr,, Esq. Attomey for plaintiff Suite 5000 - Mellon Indq~endence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: April 19, 2004 TO: JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County C1VIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 C1VIL Defendant(s) TO: JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 IMPORTANT NOTICE YOU ARE 1N 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES [NC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Ooldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Maflcet Street PhiladeIphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: April 19, 2004 TO: STACY L. LEHMAN 110 McCallister Church Road Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIV1L Defendant(s) TO: STACY L. LEHMAN 110 McCallister Church Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE 1N 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. 1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 hwine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR AS SOCIATION 2 Libe~y Avenue Carlisle, PA 17013 GOLDBECK M¢CAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Atiomey for Plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: April 19, 2004 TO: JEFFREY A. LEHMAN 110 McCallister Church Road Carlisle, PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CiVIL Defendant(s) TO: JEFFREY A. LEHMAN 110 McCallister Church Road Carlisle, PA 17013 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbcck, Jr,, Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Mmk~t Street Philadelphia, PA 19106 215-627-1322 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 THE DEBT. DATE OF THIS NOTICE: April 19, 2004 TO: JEFFREY A. LEHMAN 145 Goodhart Road Shippensburg, PA 17257 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(s) TO: JEFFREY A. LEHMAN 145 Goodhart Road Shippensburg, PA 17257 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES [NC 8 h'vine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Ooldbeck, Jr., Esq. Aaomey for Plaintiff Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: April 19, 2004 TO: STACY L. LEHMAN 145 Goodhart Road Shippensburg, PA 17257 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Plaintiff In the Court of Common Pleas of Cumberland County CiVIL ACTION - LAW Action of Mortgage Foreclosure OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(s) TO: STACY L. LEHMAN 145 Goodhat~ Road Shippensburg, PA 17257 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 SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. L~GAL SERVICES INC 8 h'vine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCiATION 2 U~befly Avenue Carhsle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldb~ck, Jl% Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JEFFREY A. LEHMAN, is about unknown years of age, that Defendant's last known residence is 109 Woodview Drive, Mt. Holly Springs, PA 17065, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its ~Unendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, STACY L. LEHMAN, is about unknown years of age, that Defendant's last known residence is 401 W. Main Street, Walnut Bottom, PA 17266, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: Rule of Civil Procedure No. 236 - Revised 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff OCTOBER 2003 No. 03-5613 CIVIL JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagors and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU V~ILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Deputy If you have any questions concerning the above, please contact: Joseph A, Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attc-,ney I.D.# 16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS, IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 06/01/2003 to 04/30/2004 at 8.0000% (Costs to be added) $138~119.83 GOLDBEC~ BY: Joseph A. Attorney for P ERTY & '~ l~be~k, Jr. McKEEVER '-rio Le~l Description: ALL THAT CERTAIN TRACT OF LAND, SITUATE IN WEST PEN~SBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN IRON PIN IN THE CENTER OF THE PUBLIC ROAD LEADING FROM MCCALISTER CHURCH TO ELLIOTSON AT LINE OF LANDS NOW OR FORMERLY OF HAROLD S. SNYDER AND DOROTHY'L SNYDER~ THENCE ALONG THE CENTERLINE OF SAID PUBLIC ROAD~ NORTH 21 DEGREES 15 MINUTES WEST 279 FEET TO AN IRON PIN; THENCE STILL ALONG THE SAID CENTER LINE, NORTH 16 DEGREES 50 MINUTES WEST 152 FEET TO ANOTHER IRON PIN; THENCE BY LAND NOW OR FORMERLY OF CLAIR M. BOWERS, SOUTH 63 DEGREES 30 MINUTES WEST 722.~ FEET TO A FENCE POST AT LANDS NOW OR FORMERLY HAROLD $. SNYDER AND DOROTHY L SNYDER, THENCE ALONG LANDS NOW OR FORMERLY OF HAROLD S. SNYI)ER AND DOROTHY L SNYDER, SOUTH 84 DEGREES 00 MINUTES EAST 799 FEET TO THE POINT OF BEGINNING. BEING THE SAME PREMISES WHICH JANET I. FARRANDS, EXECUTRIX OF THE ESTATE OF DOROTHY !. SNYDER, GRANTED AND CONVEYED TO JEFFREY A. LEHMAN AND STACY L. LEHMAN, HUSBAND AND WIFF, BORROWERS HEREIN. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-5613 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff (s) From JEFFREY L. LEHMAN, 109 WOODVIEW DR., MT. HOLLY SPRINGS PA 17065 AND STACY L. LEHMAN, 201 W. MAIN ST., WALNUT BOTTOM PA 17266. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 110 MCCALLISTER CHURCH ROAD, CARLISLE PA 17013 (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 fi.om 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 $138,119.83 Interest 6/1/03 TO 4/30/04 ~ 8.000% Atty's Comm % Atty Paid $197.60 Plaintiff Paid Date: MAY 5, 2004 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQ. Address: STE. 500 - THE BOURSE BLDG 111 S INDEPENDENCE MALL EAST PHILADELPHIA PA 19106 Attorney for: PLA/NTIFF Telephone: (215) 62%1322 Supreme Court ID No. 16132 L.L.$.50 Due Prothy $1.00 Other Costs CURTIS R. LONG By: Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 110 McCallister Church Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 2. Name and address of Defendant(s) in the judgment: JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ASSOCIATES FINANCIAL SERVICES INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. 1NC. 1 VALLEY STREET SUITE 103 CARLISLE, PA 17013 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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/OCCUPANTS 110 McCallister Church Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: May 3, 2004 GOLDBECKI BY: Joseph A. Attorney for Ph & McKEEVER 03-5613 CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 Term No. 03-5613 CIVIL Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WIlL BE USED FOR THAT PURPOSE. TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY LEHMAN, JEFFREY A. JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 Your house at 110 McCallister Church Road, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on Wednesday, September 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enfome the court judgment of $138,119.83 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., the back payments, late charges, costs and reasonable attorney% fees due. To find out how much you must pay call: 215-627-1322 03-5613 CIVIL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the fi~ll amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Sfllte 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHM~a~N STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 Term No. 03-5613 CWIL Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LEHMAN, STACY L.#2 STACY !.. LEHMAN 109 WOODVIEW DRIVE MT. HOLLY SPRINGS, PA 17065 Your house at 110 McCallister Church Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $138,119.83 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. against you. NOTICE OF OVqNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be ccmcelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. * You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the.judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sherifl's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full mount due in the sale. To f'md out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plane, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CiVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 NO. 03-5613 CiVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY 1, Joseph A. Goldbeck, Jr., Esquire hereby certify that 1 am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiffhas complied with all the provisions of the Act. Joseph A..~~c'k, Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN 'DIE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CIVIL CERTIFICATE OF SERVICE PURSUANT TO Pa. ILC.P. 3129,2 (c) {2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by:  Personal Service by the Sheriff's Office/lllllllll/~t (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ) Certified mail by Sheriff's Office. ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to A~torney for Defendant(s) of record (proof of mailing attached). ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. spectfully ~qbmitted,. ~, ': JoSeph A. Goldbeck, Jr.v :orney for Plaintiff 716~ 3901 9848 3829 4408 =['0: LEHMAN, STACY L. STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER April 30, 2004 REFERENCE: LEHMAN, JEFFREY A. / CWD-3055 09/08/04 - Cumberland RETURN RECEIPT SERVICE Return Receipt Fee Total Postage & Fees US Postal Service Receipt for Certified Mail No nsu ance Coverage Provided Do Not Use for Intema iona Mai[ AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST Z'LASS POSTAGE, CERTIFIED FEE, RETURN RECEIP. T FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1 Delach the form 38 1 Domestic relurn receip~ by ' ' lear- mg leg to right across perf Attach to mailpiece by peeling back the adhesive strips and affixin9 to front of mailpiece if space permits. Otherwise affix to back ol mailp ece 2 ff you do not want the receipt postmarked, stick the article # label to the right ol the return add ess date receipt and retain the receipt. 3 If you wan~ this receipt postmarked, slip the 3800 receipt belween the return receipt, and the mailp~ece, and slide the edge of the receipt to the gummed edge o[ adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window (SEE ILLUSTRATtON) 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt 7160 3901 9848 3829 4446 1'O: . LeUU/~S, ST^C') ~.#~ sTAGY L. LEHMAN l0c) WOOD¥IEW DPJM~ MT. HOLLY sPRINGS, PA 17065 GOLDBECK MCCAFFERTY & MCKEEVER SENDER: ^p~130, 2004 REFERENCE: LEiiMAN, JEFFREy A*ICWD'3055 09/08/04 - Cumberland PS Form 3800, June 2000 RECEIPT No ~nsu ance Cove age provided AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST C~.ASS POSTAGE, CERTIFIED FEE, RETURN RECEIP, T FEE AND CHARGES FOR ANy SELECTED OPTIONAL SERVICES. 1 Detach the form 38 t Domestic return receipl by ~ear- mg le~t [o right across per/ Attach ~o mailpiece by peeling back the adhesive strips and a/fixing to front of maJlpiece if space permits Otherwise a/fix to back of mailp~ece article # label to the right of the re~um address, date receipt and retain the receipt. 3 if you want this receipt postmarked, slip [he 3800 receipt between the return rece pi, and the mai~piece, and slide the edge of the receipt to the gummed edge of adhesive, This will ho~d the receipt in place to present to your mailcenter, or pest o/fice service window (SEE ILLUSTRATION) 4 Enter fees for the services requested in the appropgate spaces on the front of this receipt. 7160 3901 9848 3829 4439 145 GOODI-IART ROAD SHIPPENSBURG, PA 1725'7 SENDER: GOLDBECK MCCAFFERTY & McKEEVER April 30, 2004 REFERENCE: LEHMAN, JEFFREY A. lCWD'3055 09/08/04 - Cumberland PS Form 3800, June 2000 Certified Mau No InsU a~ce coverage Provided AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST ~'LASS POSTAGE, CERTIFIED FEE, RETURN RECEIP.T FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES., 1 De~ach the form 38tf, Domestic return receip~ by tear- mg left to right across peri Attach lo mailp~ece l)y peeling back the adhesive strips and affixing to front of mailp~ece if space permits. Otherwise afl-ix to back of mailptece 2. If you do nol want the receipt postmarked, stick the article # label to ~he right of the return address, date receipt and retain the receipt. 3. If you want this receipl postmarked, slip the 3800 receJpl between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive This will hold ~he receipt in place to presenl to your mailcenter or post off-ice service window (SEE ILLUSTRATION) ' 4 Enter fees for the services requested in the appropriate spaces on lhe fron~ of this receipt. 7160 3901 9848 3829 4422 TO: LEHMAN, JEFFREY A. JEFFREY A. LEHMAN 109 WOODVIEW DRIVE MT. HOLLY SPR1NGS, PA 17065 SENDER: GOLDBECK MCCAFFERTY & MC KEEVER April 30, 2004 REFERENCE: LEHMAN, JEFFREY A. / CWD-3055 09/08/04 - Cumberland PS Form 3800, June 2000 RETURN [ Postage RECEIPT Certified Fee / SERVICE Return Receipt F Restricted Deiiw Total Postage & F US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST'dLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES.. 1. Detach the form 3811, Domestic return receipt by leaf- ing left to right across per~. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the adicle # label to the right of the return address, date receipt and retain the receipt. 3. ff you want this receipt postmarked, slip the 3800 receipt be~veen the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive, This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) 4 Enter fees for the services requested in the appropriate spaces on the front of this receipt 5, Save this receipt and present if if you make an inquiry. 7160 3901 9848 9829 4392 TO:. JEFFREY A, LEHMAH 109 Woodview Drive Mt. Holly Springs, PA 17065 GOLDBECKMCCAFFERTY&MCKEEVER SENDER: April30,2004 REFERENCE: LEHMAN, JEFFREY A./C~D-3055 O9/0$/04-Cumb~d PS F RETURN RECEIPT SERVICE Total Postage & F US Postal Service Receipt for Certified Mail No insurance Cove age provided AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST'(~LASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT F. EE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing lefl to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits Otherwise affix to back of mailp~ece. g. (f you do not want the receipt postmarked, sticR the adicle # label to Ihe right of the return address, date receipt and re~ain the receipt. 3. Il'you want ~his receipt Postmarked, slip the 3800 receipt between the return rece pt, and the mailpiece, and slide the edge of the receipl to the gummed edge of adhesive. This will hold the receipt in place to present to your mai/center, or post office service window. (SEE ILLUSTRATION) 4 Enter fees for the services requested in the appropdale spaces on the front of this receipt 5, Save this receipt and preseCd it if you mare an inquiry 7160 3901 9848 3829 4453 TO: I~E.~3,N, S'rAC'~ L STACY L. LEHMAN 10 CABIN LANE SHIPPENSBURG, PA 17257-9628 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER April 30, 2004 REFERENCE: LEHMAN, JEFFREY A. / CWD-3055 09/08/04 - Cum'ocrland PS Form RETURN RECEIPT SERVICE US Postal Service Receipt for Certified Mail No insurance Coverage Provided Do Not Use for I~ternationa~ Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST'~LASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES., 1. Detach the form 38fl, Domestic return receipt by tear* ing left to right across perf. Attach to maJlpiece by peeli~9 back the adhesive strips and affixing ~o front of maiipiece if space permits Otherwise affix to back of mailpiece. 2 It you do not want the receipt postmarked, stick the arlicle # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receip[ postmarked, slip ~he 3800 receipt between the return receipt, and the mailp~ece, and slide the edge of the receipt to the gummed edge of adhesive This will hold the receipt in place to present to your mailcenter, or post off, ce service window. (SEE ILLUSTRATION) 4. Enter fees for the services requesled in the appropriate spaces on the front of this receipt 5, Save this receipt and presefd it if you make an inquiry 7160 3901 9848 3829 4415 TO: , LEHM)~N, JEFFREY A. #2 145 GOODHART ROAD SHIPPENSBURG, PA 17257 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER April 30, 2004 REFERENCE: LEHMAN, JEFFREY A. / CWD-3055 09/08/04 - Cumberland PS Form 3800, June 2000 RETURN / Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST'~LASS ,, POSTAGE, CERTIFIED FEE, RETU~RN RECEIPT, FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES.. 1, Detach the form 3811, Domestic return receipt by tear~ ing leff to right across peri, Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits Otherwise affix to back o¢ mailpiece. 2. If you do not want the receipt postmarked, stick the article ff label to the right of the return address, date receipt and retain the receipt, 3, If you want this receipt postmarked, s]fp the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive, This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION} 4 Enter fees for the services requested in the appropriate spaces on the front of this receipt 5 Save this receipt and present it if you make an inquiry Mortgage Electronic Registration Systems, Inc. VS Jeffrey A. Lehman and Stacy L. Lehman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-.5613 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2004 at 8:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jeffrey A. Lehman, by making known unto Julie Lindsey, adult sister of defendant, at 109 Woodview Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2004 at 8:00 o'clock PM, he served a tree copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Stacy L. Lehman, by making known unto Stacy Lehman, personally, at 401 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said tree and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2004 at 1:43 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 Jeffrey A. Lehman and Stacy L. Lehman located at 110 MeAllister Church Rd., Carlisle, 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: Jeffrey A. Lehman, by regular mail to his last known address of 109 Woodview Drive, Mt. Holly Springs, PA 17065. This letter was mailed under the date of July 13, 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 Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Stacy L. Lehman, by regular mail to her last known address of 401 West Main Street, Walnut Bottom, PA 17266. This letter was mailed under the date of July 13, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me This 2004, A.D. day of Prothonotary R. Thomas Kline, Sheriff Real EstatOOeputy Gol'dbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. # 16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN ~IItE COURT OF COMMON PLEAS of Cumberland County C1VIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CWIL AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the vn-it of execution was filed the following information concerning the real property located at: 110 McCallister Church Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 2. Name and address of Defendant(s) in the judgment: JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 3. Name and last known address of every judgment creditor whose judgment :is a record lien on the proper~j to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bure~[u of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ASSOCIATES FINANCIAL SERVICES INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. 1 VALLEY STREET SUITE 103 CARLISLE, PA 17013 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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/OCCUPANTS 110 McCallister Church Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are Uae and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made suhiect to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: DB~ECK MCCAFFERTY ~ McKEEV Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said Cocmty and State do hereby certify that the Sheriff's Deed in which Secretary of Housing & Urban Dev 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 5th day of May, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 5613, at the suit of Mortgage Electronic Reg Systems Inc against Jeffrey A Lehman & Stacy L is duly recorded in Sheriff's Deed Book No. 265, Page 4658. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this O~ 7 day of ~. , A.D2004 ' ~//~-~orcier of Deeds Mortgage Electronic Registration Systems, Inc. VS Jeffrey A. Lehman and Stacy L. Lehman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003.-5613 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2004 at 8:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Jeffrey A. Lehman, by making known unto Julie Lindsey, adult sister of defendant, at 109 Woodview Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2004 at 8:00 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Stacy L. Lehman, by making known unto Stacy Lehman, personally, at 401 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2004 at 1:43 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 Jeffrey A. and Stacy L. Lehman located at 110 McAllister Church Road, Carlisle, 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: Jeffrey A. Lehman, by regular mail to his last known address of 109 Woodview Drive, Mt. Holly Springs, PA 17065. This letter was mailed under the date of July 13, 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 a~gtion to the within named defendant, to wit: Stacy L. Lehman, by regular mail to her last known address of 401 West Main Street, Walnut Bottom, PA 17266. This letter was mailed under the date of July 13, 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 8, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Secretary of Housing and Urban Development, his successors and assigns. It being the highest bid and best price received for the same, Secretary of Housing and Urban Development, his successors and assigns of 100 Penn Square East, 10th Floor Wanamaker Building, Philadelphia, PA 19106, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $716.53. Sheriffs Costs: Docketing $30.00 Poundage 14.05 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 18.88 Levy 15.00 Surcharge 30.00 Law Journal 209.60 Patriot News 232.51 Share of Bills 30.49 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 716.53 Sworn and subscribed to before me This .d£~day of ~ l~rdthonotary So R. Thomas Kline, Sheriff Real Estate Deputy Goldbecl( McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN (Mortgagor(s) and Record Owner(s)) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 No. 03-5613 CIVIL AFFIDAVIT PURSUANT TO RULE 312'9 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 110 McCallister Church Road Carlisle, PA 17013 l.Name and address of Owner(s) or Reputed Owner(s): JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 2. Name and address of Defendant(s) in the judgment: JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 STACY L. LEHMAN 401 W. Main Street Walnut Bottom, PA 17266 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432' P.O. Box 2675 I Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: ASSOCIATES FINANCIAL SERVICES INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 CITIFINANCIAL MORTGAGE CO. INC. 1 VALLEY STREET SUITE 103 CARLISLE, PA 17013 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge,' who has any record interest in the property which may be affected by the sale. 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/OCCUPANTS 110 McCallister Church Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 3, 2004 ~ ~ GOLDBECK .~TY & McKEEVER BY: Joseph A. ~14 , J~., Esq. Attorney for Pla~'nfl GOLDBECK McCAFFERTY & McKEEVER BY: Josaph A. Goldbeck, Jr. Attorney I.D.# 16132 Su/te 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 Term No. 03-5613 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LEHMAN, STACY L.#2 STACY L. LEHMAN 109 WOODVIEW DRIVE MT. HOLLY SPRINGS, PA 17065 Your house at 110 McCallister Church Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2004, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $138,119.83 obtained by IvIORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. · You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an m~omey). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full mount due in the sale. To £md out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you adll remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount Clue is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff ~xty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. ~llae money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market S~eet Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff 03-5613 CIVIL MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. JEFFREY A. LEHMAN STACY L. LEHMAN Mortgagor(s) and Record Owner(s) 110 McCallister Church Road Carlisle, PA 17013 Defendant(s~ IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE OCTOBER 2003 Term No. 03-5613 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN ~4aN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LEHMAN, JEFFREY A. JEFFREY A. LEHMAN 109 Woodview Drive Mt. Holly Springs, PA 17065 Your house at 110 McCallister Church Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2004, at 10:00 AM, in Commissioners Heating Rm 2nd FL Courthouse to enforce the court judgment of $138,119.83 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, iNC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 03-5613 CIVIL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU ttAVE OTHER RIGIITS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fred out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full mount due in the sale. To fred out if this has happened, you may call the Sheriff of 717~240-6390. 4. If the amount due fi.om the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is fii~d. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. lSF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 110 McCallister Church Road Carlisle, PA 17013 SOLD as the property of JEFFREY A. LEHMAN and STACY L. LEHMAN TAX PARCEL #46-08-0583-054 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) · NO 03-5613 Civil COI.7NTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff (s) From JEFFREY L. LEHMAN, 109 WOODVIEW DR., MT. HOLLY SPRINGS PA 17065 AND STACY L. LEHMAN, 201 W. MAIN ST., WALNUT BOTTOM PA 17266. (1) You are directed to levy upon the property of the defendant 00and to sell REAL ESTATE LOCATED AT 110 MCCALLISTER CHURCH ROAD, CARLISLE PA 17013 (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 deliw;ring 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 $138,119.83 Interest 6/1/03 TO 4/30/04 ~ 8.000% Atty's Comm % Arty Paid $197.60 Plaintiff Paid Date: MAY 5, 2004 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQ. Address: STE. 500 - THE BOURSE BLDG 111 S INDEPENDENCE MALL EAST PHILADELPHIA PA 19106 Attorney for: PLAINTIFF Telephone: (215) 62%1322 Supreme Court ID No. 16132 L.L.$.50 Due Prothy $1.00 Other Costs CURTIS R. LONG DeptJy (j Real Estate Sale #38 On June 15, 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 110 McAllister Church Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. ~,~: J= ,~, ~.oo~ ~y: j,~'~ Real Estate'S' Deputy · II I THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, pri~ted and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in the/r 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 the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are tree; and That he has personal knowledge of the facts aforesaid and is duly a~athorized 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 SALE#38 Sworn to and subscribed before me~s 23rd day of~flgust/2~ A.D. N0 tA' I Q~ of ~arns~urg. ~upnin ~my .~ .... [ My Commis~on ~pir~ ~ 6. 2006~t,~ ~ ru~ ~amb,r. penn~ylvaniaAsSo~iali~~ssio~ e~kes J~e 6. 2006 CUMBERLAND COIZgTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs. To THE PATRIOT-NEWS CO. For publishing the notice or publication atlached hereto on the above stated dates 232.51 Publisher's Receipt for Advertising .Cost ublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ~wledge receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (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 courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: 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 E~TATE ~LE NO. 38 Writ No. 2003-5613 Civil Mortgage Electronic Registration Systems, Inc. VS. Jeffrey A. Lehman and Stacy L. Lehman Atty.: Joseph Goldbeck ALL THAT CERTAIN tract of land, situate in West Pennsboro Township, Cumberland County, Pennsylvania. bounded and de- scribed as follows: BEGINNING at an iron pin in the center of the public road leading from McCalister Church to Elliotson at line of lands now or formerly of Harold S. Snyder and Dorothy I. Snyder, thence along the centerline of said public road, North 21 de- grees 15 minutes West 279 feet to an iron pin; thence still along the said center line, North 16 degrees SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission ExpCes March 5, 2005