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HomeMy WebLinkAbout08-0175IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, vs. Michael F. Moran Plaintiff, Defendants. TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 7255 Baymeadows Wav Jacksonville. FL 32256 AND THE DEFENDANT: 500 Thomas Road Camp Hill. PA 17011 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFE CTED BY THIS LIEN IS 500 Thomas Road Camp Hill PA 17011 Municipality: Wormleyburg scoa a. oieqek ATTORNEY FOR PLAINTIFF ATTY FILE NO.: FCP 95960 CIVIL DIVISION NO.: N - 175 CW I t -Fcrm TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Washington Mutual Bank COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Richard P. Haber, Esquire Pa I.D. #202567 Eric Santos, Esquire Pa. I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: FCP- 95960/ad Zucker, Goldberg & Ackerman, LLC FCP-95960 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC FCP-95960 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, vs. Michael F. Moran Defendants. : NO.: NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC FCP-95960 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, : NO.: vs. Michael F. Moran Defendants. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar action como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC FCP-95960 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, : NO.: 47- /Z5 C4zZI --7;,, vs. Michael F. Moran Defendants CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Washington Mutual Bank, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff, Washington Mutual Bank, which has its principal place of business at 7255 Baymeadows Way Jacksonville, FL 32256. 2. The Defendant, Michael F. Moran, is an individual whose last known address is 500 Thomas Road, Camp Hill, PA 17011. 3. On or about November 15, 2002, Michael F. Moran executed a Note in favor of The Washington Savings Bank, FSB in the original principal amount of $84,550.00. 4. On or about November 15, 2002, as security for payment of the aforesaid Note, Michael F. Moran made, executed and delivered to The Washington Savings Bank, FSB a Mortgage in the original principal amount of $84,550.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on November 22, 2002, in Mortgage Book Volume 1783, Page 3416. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC FCP-95960 The aforesaid Note and Mortgage was assigned by The Washington Savings Bank, FSB to Washington Mutual Bank, FA, plaintiff herein, pursuant to an assignment of mortgage dated November 22, 2002 and recorded on September 19, 2003 in the Office of the Recorder of Deeds for Cumberland County in Assignment Book 701, Page 4598. 6. Defendant is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 8. On or about November 15, 2007, Defendant(s) were mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P. S. §101, et seq. Zucker, Goldberg & Ackerman, LLC FCP-95960 9. The amount due and owing Plaintiff by Defendant is as follows: Principal $ 76,787.09 Interest through 12/18/2007 $ 1,750.34 Attorneys' Fees Title Search & Costs Late Charges Suspense Balance Escrow Pro Rata MIP/PMI Total-Fees $ 1,250.00 $ 2,500.00 $ 25.35 $-418.01 $ 87.15 $ 33.12 $ 57.00 Total $ 82,072.04 plus interest on the principal sum ($76,787.09) from December 18, 2007, at the rate of $12.62 per diem, plus additional late charges, and costs (including additional escrow advances); additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $82,072.04, with interest thereon at the rate of $12.62 per diem from December 18, 2007, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises Zucker, Goldberg & Ackerman, LLC FCP-95960 ZUCKER,GOLDBERG & BY: ? / Scott A. Dietterick, Esquire PA I.D. # 55650 Kimberly A. Bonner, Esquire PA I.D.#89705 Richard P. Haber, Esquire PA I.D.#202567 Attorneys for Plaintiff 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 908-233-8500 FAX 908-233-1390 EXHIBIT A Zucker, Goldberg & Ackerman, LLC FCP-95960 12-19-'07 16:12 FROM-Premier Abstract a? c? ?? SA G3 BUX no ? vuzssow soars 300 Pared Number: tMe t Abw nk lie. Par Roo t a D@Q MORTGAGE DEFT MOMS T-220 P013/043 F-457 JuF DEEDS .NO COUNTY-- 4 ,.'! t2 FB 9 09 Wab need in = *%& sections of ft documettt we dd9eed below and othar words at 4 !g, 21) and 21. Cmft rules regarding the u8sp of words used is this document in also (A) *8WW ey bW1110 rt" eriI ' this d0eXM% whidt is dated W*Veober 35th. Riders to ddis dowtneat. (1) '$ore+oW is ULaMal Ir. Moran Loan ZD 0 pp1204br In Sectiaos 3. It. 13, ed in Section l6. . together wkh all . Borrower Is dw mostSW under this SewdW Inttswtu m . (C) Sandee" Is The Raabloglaa savingn auk, Pas . To ha CORPOUVION k" of TWO =Z= t3=]1M OF Jittil MCA L.cstder's addrea and existing under the is 42oi Mit0*21vii1e stead, Suite 300. Bowie, JW 20716 f ' Soo coder oak Smurky IOetr neat. "lro =08 dw Y rote signed by 190 WVW and dated Neva b e er iBth, sates brat Bouftw OWN 1=* sigbtr four sboueand Five euadtesd rilty 2009 The Note end mo/100. - - - Ddbxa (U.S. S It, 550.00 ) P1e1 k t =L Bo ude lot (iMdxPeodlc Paymnn nd to psy tedebt in it c*w tbn a war hus promised to pay eecuber (R) r4 MWd the P mPUW dW 13 dnaibed below under the heading 'Ttangt f Ist, 2032 i - o (F) "Lena" mum the debt evidewW by list: Now, plus iooem. any pnpaymem charm Note. and ail acme tine mitt this Sextuity TW4runamt ine b gists n die PtopaW. We charges due muter the . p urnt. (Q) "RW=ft mane all Riders to tWs Security IOettuowt that are executed by BorroaKt. T1 be e=etm d b9 Bocnewe' [dxCk b following hiders are to ox u appaubb): D Adjustabk Rate Rider C3 Condominium Rider O Second H Aide? 0 Botiooa RWer Zia Planted Uric Devdgmnt Rldcr O O ? 1-4 Fxgk Rider O Biweekly hya?nnt Rider u>a(s) [ 1Y] 110 ?? ` Io? P121NMVAN14440 , scoot-.Paaate to uMrsddie Mae UNNO04 nvMLTAENT Initials: PA&CM • 922"003 n-1 30D9 1x01 Owe I yls rf? 17 U.s1j31; 16 12-19-'07 16:13 FROM-Premier Abstract T--220 P014/043 F-467 Loan 10 0 pp1309br "Applicable Law" mecca all controlling > $rAbk fcdoW, stage turd local am=, . mmilaines and admWaradva rules and steles (that bave due effect of taw) u well as &0 applicable firm. n appealable judleial opinions. M "Corpatttaky Assocladon Dun. Fete, Aud Aa+<eanw", ,uterus all data. fees, mum and other dwSes drat are imposed on Boaower or the Property by a comdototn m aaswation. haceoaners usoc not sbWlw orgsaiserlon. (J) 811hareak Fun& Traodr" mum soy tnnsfitt of thuds, otlwr rhea a tut nctioll orl ' by ebeck. draft, or sindlar Mw instrurma. wbkb Is initiated timpti an eleawook tsrmiasi, tdepbwk ' , computer. or magnetic taps so u to order. $1strUCS. or sutht ft t frost im ttdolt to titbit or e"t ul woount Suet tarn includes. but is not limited to. poin4of4sk tray b a. autowed tella awid a uviasdions. ue wks ioi by Telephone. wire traullers. and tatrowxw dt@ringbouaa aatrtsfbts. M '29crow items" roues Use It= that are described In Section 3. W mH eellane m ftoeoeds" mem say coonpoantion. wilemoot, award of damues. or paid by any third patty (other tiara insusaaee pmooeds pdd under the coverages dtseribad in Section 3) for: ) dunce to, or desuvetiaa of, the Ptopeny; (11) coodorrmadoa or other taicog of oU at gay part of the PropM; (iii) oat in lieu of coedemudon; or (iv) r duvreseatetiens of, of omissions as era, the value sed/or condidott r rte 8toperty. (NO 'Martpp ltmtreanae mugs iostttaooe protecting Lender against the nospaysaeot of, ddfauk on, the Loan. (Ni) " OW& Paytneat" moos the regularly scboduled now due for (1) pAndpal gad r ruttier the Note, pin M any mot" under section 3 of this Swodgr Ic>tnrmeat. (0) "RMwe memo the Real Emm Sememm proettdtaas Act (12 U.S.C. 12601 at ecq.) its implementing regulation. Regubdon X (]A C.F.R. Put 3300), u They might be amended hum time to , or any addidond or tttteeesaor legislation or regtdation that govermt the amm subject mater. As used in this ty Instrument. "AMA' refers to all requitemew and rekrictiou that no ltaposed In reptd to a "federally tdated gage loan" even it the Lout does not qualify u a "fakrdly related mortgage logs' under RESPA. (p) "Successor ht btawt of EorroMrer" means any puny that h" M)= tide to the Prow V. whether of not that potty hog ssaamed Botrowees obligations turda Se Note m&or this Security Iastlumcni. TRANSFER OF MH"TS IN THE PROP ay Tbis Seem* humurtettt sot:ttres to I,atstle , 0) the repayment of the Loan. and all renew ow afaoa and rnodfllondons of she Note; cod ce the pWkmuM of Borrower's eovttoants and ttgtve®ms under this Semaity Ioatrttmeat and rho Now. For tine purpose, Borrower does hereby rnongage, gruff tnd en-p- My to Lester the foilowing dave abed property located in the county of gaud . Post LEGIAL D1t8CR2PTiow an ?t? Ac= Am mDz A ymm =?Y. "1 PENNSYLVANIA-3109k Family-TOMIc Mewl Sreddie Mre WHFOILM o1STRUMENT PA1CAU - 01=11002 Initials. ??/ ' ? 30M 141 "a q/ 14 yaaarl BKI 7 8Jr'J3J417 12-19-'07 16:13 FROM-Premier Abstract which currently 1133 the address of S00 4ho"M Road, Peuasylvama 17011 ("PropCnY Address"): 13-4I (2tp Cods) TOGE711ER WITH all the hVc0ve2neoq now or Korea Ur et eeted on the property, an aPDvRens'neea. ad futdtea now or bcmlfwr a part of the plop ay. All replatxmeats aed t by tbia SsCurity Instmment. All of the foregodog is ti fernd to in this Se WIW Iastrnnseat I BORROWER COVENANTS that Borrawa is l3wAft s4sed of the cute heresy wav MDM4", israot sad oanvcy ihn Penitrrtr and that dt. AaopasV in nraaaeambeted. atcetre R, Borrower warrants cod will defend Swersily the 4 de to the P again" alt eatcUmbtanees of record. AY sled TH39 SECURl1y INSTRUMENT Con"oes aaiiorm covenmrs for national use and ore WNced variations by jurisdiction to cmdutta a ttaifom security iatrlntrnm covering real p UNIFORM COVENANTS. Borrower and Leader covenant and atree as follows: 1. Paymnat of p1{ocilsok 3nsarcest, Escrow Items, ftepeymmt Charges, and Late pU' when due the prlaeipal of. aAd i t eat out, the debt evidenced by the Note and my M charges due wader the Note. Borrower shalt also pay rands for Escrow hear pursumt to M under the NOW sad thin Seauity Itlawftt wt *0 be Made In U.S. currency. However, if m tocalved by 1&aft es pqom under the Note or tbig 9eeudty Itawtm,mt is returned W Iau soy of an subsequem paya mts due under the Tote and this Security Instrument the following forms, as sdected by ].ceder: (a) cash; (b) money order: (c) certified check, check or cashier's check. provided any such cheek Is drawn upon an InWauioo whore depot agency. ioravmmalky, or eatity; or (d) Ekma* Funds Tmder. Payments are deemed mccived by Leader when received at the location designated In dw loeadon as may be designated by bender in aocordadta with the aoth:o viskm in Section plymm or pmw Payer if dwe WYMI or pa ci d payawts are i?t to bring tae 3a "I mY P"M a 111ni+d P9 iwufllGekat to bring the Lola turret. without waiver PRJUft to Its rl0V to T line such pay= a P1011111 Payments In the future, but Leader is and at the due aKh paymeau ice accepted. if eaccb Periodic Payment is Applied as of Leader is u bdA We Loco y rest on unapplled funds, Lander may hold such unappiled fvode unt f Comet. If Borrower does not do so within a reasonable period of tithe, tends or return them to Borrower. If not applied ether. such funds Will be applied to the Under the Note 1nYnedWely prior to foreclosure. No offset or claim which Borrower ndghl against Leader shall relieve Borrower from making ps!'mmu due under the Note and this WIGn ung the eoveoant3 and sgreencmts xWed s tbts Y Security lsutescri ) 1. APl?ration of Faym ma or Proceeds. Enep as otherwise drscriU AM applied by I.estda slrsll be ed in this e WXk7 ply tae Note; (c) amounts d?e ? to the following order of prkrity: (a) iaurast due den ap order In which it bacaote due. qQ rewxkt maining 3. Such Payments 6? be applied to e ATDOUnts rder In dui under Win SaCu ring amounts shall be applied first to late ebarges, o ry trutflent, and then to reduce the principal bdeno of the PIINlMVAJ0A-3leat. P8mi8y-p'a00k Nrs,", , M., PAMNO . OUNIO7 (liVilrpItM uYMW,,W? T-220 P015/043 F-467 Long = 0 pp1209br Clasp aft ICky) ttU aena, didolntsas=tnell also be covered the 'Aropony.- and 10 the right to HNam= Yf Stud. ads, rubject to any covenants with wrV& Borrower wall tneut Chula and hate on 3. pay== due dock of worn instrun= T unpaid. Leader nay made hi one or spore of iC check, ausurar's are insured by a f edem Note or at stwh other tsD currander my t. +mY MY if nay rights bemuftor at owlipw to apply such a M;bWWed duo date, then Borrower ftkoi pay=at wet shill either apply ad tudiag priaci;W balano:e ro now or in the future dty Ill itua at or 2, all payments accepted r the Note: (b) prinelpat Periodic Payment in tbo pond to any other Initials: _ 9L_ 3&19 'M (putt J iYJI paw ?.t?toaardtBaottnesiynau.eem Bi(I )a 31-U34 18 12-19-'07 16:13 FROM-Premier Abstract T-220 P016/043 F-467 if Leader rrccive, a PaYMM ft Z Bturower for a delinquent 8erWk PAYmant whisk to PAY MY Jan dtttrre doe, the payment may be a 4 l lied to th L"11 ID # W209be a suJtk?ent amount pp g e inqum aymeat is 001st P And the Periodic P rttdittg. Lender arrq? aPDh MY a me d ? e. if fates tbtat are p y nt rec vrd Rota Bornower Periodic PAY== It. and to the nut tW Mb the payraart is applied W tau fbll PaYttM can be paid in 1W1. To *AO pqm m of one at Hare Pai dk p t of the that any e?ooeee estisr: after tt ayment,, ,nei cum charges due Volun Any ApgliVOIUO o ff Ptep?w ,haft be applied Hest to any p0mateat drugs! ad yt?reoeers, iaentenoe Pis or Miecell be applied w any late to as described lathe Note. . uLOOw Prococa to W escnod or poetpaoe the doe date, or change die asnonnt, of des Pedocie pgmv ns. 3. Rods far Jfaaow keow. BtmVW dWl pay to Le d due tinder the Not 691 n er on rho day Periodic until the Now U paid is full. a sow (the *a"-) w ptoVl& for PsYarrnt of ealounts due end other im m whk n i ate due ender tie Noe, tatty ( mu t u aga n Walify over this Security loft== es a lien err leasehold pttyatems or Stouod rents an me l( an Praopeny ( k . (b) tDePtopeay; (b) on y; , c) prnt&nta for stir and alt under Secdon S., and (d) UwWW Itmtranee pooitteer if a b Leader . ny. or the Pent of Matt?q?e In,urmoe ptcminms m txeordatr6e with PW Prof 3ct "Escrow Items." At tilt. visions of Sego CHWARtIOR es eroe to Leader in lieu ailed 7lmse iemt see called u any titga dttrlgp the tarn or the Loan, Lender may Association !)tees. sad Ass , if aey. be: escrowed by Bonawer. end sorb does Fees. mud be an ia ion I alas that h Community and SO s sn ow t te m. !ball Barroww Bo rrower shall PtU' Leader the ponds for grew, all notices of atttamts to be Wtas Lend i k o o er a u adnom shall under No Station. er wa ves Borrowers Seerev [teas,. 12Y Or all Leader nay waive Borrower's obtisedon to pay to Leader Fu d patios to pay ft Rends fbr n s at my time. Any $14h waiver noy only be in writing. In Ore event of such waiver, and where PiYWe, the amounts duo for any Escrow tam t h my of all Y ?? Items !hail pay t fly, when hen or w ich if Leader requires, shall hMM la Leader reeeiptl evi&vft paYroeat of ft* hat pqn" gtdt hi n h o' ' waived by Itpder W s regain. Borrowa l suc rex8 MC vJ4 s ob'Odott 10 Malt VXb POYMIS and to hal eIptt shall for c ll period m Lando mry . a ovenant and agreeanent tontaioed in dtia 9aauit us 9. U Borrower !, obti aced to y lug . as the phrase covUtsant and &WM dlreW be deaoed to be a " Is No to Spetimn ? y, Pmt to a waiver, sled dun for an Escrow hare, Lendop nay rlgbts under Section 9 u d pry such amDo oft for an under Item, q 9 bet i? to pay the amotmt : and Bonowar don thM go items aL ?Y to ?n? any such Mount. Lander mar avoke the Eany date by a entice Sivaq in aooordmtse with Settion i S and. apoa such m Day to Lender all Fund, and "L such ver ere to any or all vc&dojl, Sommer !ball , mum. abet Am tiles required tinder this Section. 3. LeO ?Y, K WY time„ 6611001 and bold Fume in An amount (y tufiidW to emit the tiros speeUied under RESPA, and (b) wx w now the 4YpMUM mom, a leader ego Lender aball estimate the amotau of Fltod d to I" die F trite tamer RESPAunds at , w on. the basin of current data and reasoneble !taus &crow hens! or otherwlae in accordance with Applicable Law of expondituaes of . 71W F Wds dwq be hold to ell ln'd Wl ln'd WRwhose 11905lw eft insured by a federal (?? fir, if Lend is *A inift ion whose dcgoslw ere so insured)o k ? L w ry. or eoNry r eader" apply tbo Funds to pay the Btcrow Item no later ft" the ' WY ante ,palflud tinder charge BotTOwrr for holding and a l in Plotne Lo=a Bamk. PA. Lander g6a11 not pp y g It=. unle,A Leader pays BorrpW lantxit o tilt Fun& acrd Applicable Low ?t • o Unless as Agreement is tmgdc in w i i r verifying the Escrow to make such a char e r t ng or Agplitanbla Law required b Pay Bornower soy interest or g requires Interest to be paid , c the F on the Fuada. Botu wax And Lender can drat interest sbW be sad on W F P . g lrttds, LeDder !hail sot be in writin bo e unds. Lendtw sbalJ i3 eve to Borrower, With OUL CharaO, sn Farads as required by ItFSPA. g. w0ver, aCCO aadtag of the if titer is a nrplut of F rode hold irk oeerew. As d.r?..a.t wsnlw RESPA, Lender shah excess funds to accordance with AWPA. It thane is a shortage of 1Nnds beld in es for We d b° crow. as f a RE itte under RI~SPA, P8N7YMVAhUA Vt41v Famay-Fanny Mugr ads Moe UNIlOtAM WSML nWT PAICM4.aa7 w2 InitiAls. . V7 01! Uel 4Wr4,Fl4y@j*d M?a4Rmaakrajtiyrtanr,too? BK 1 16 ," F,, 3 4 1 9 7 12-19-'07 16;13 FROM-Premier Abstract I wder dull 4Wty Bontrwer a: required by RESPA, and Borrower shall pay to Lender d up the shortage is &=r&m witlt RBSPA, but is ao more No 12 monthly payments. I b eld in escrow. w defated uader RBSPA, Linder droll notify Bormww as required by R1 to Lender dw a lot at necessary n ttoake tub the defkiency in accordance with RESPA, bnl payments. upon Priam In Am of all sums secured by this Security lostntmm, mender shall pr F1mda bold by Lender. 4. Cher"; Ueos. Boerowa shat! pay all tws. asseea wM. charges. flaw, and h Property which can stain Pdorkty over arts Stxahrity laatruinc t, ICaKW psymracs or got any. and C.oraalunity Aftclatioa Dues, Peet. gad Assessirm s, if any. To rho extent drat Borrower &WI pay theta in the usuiaer provided 14 Section 3. Borrower shall promptly dirt barge my ilea wbwh has priority over this Sulu ft Insttt agrees in wridas to the Patient of the abliptioo sw mW by the Sun in a marmcr trccepab m Bomma is De taAing such SEremm; (b) Contttsts the He to good (Sidi by. or defaht Ilea in, legal procoadbW which la Le WWs opioion operate to prevent the eeferCernt>,K of pttlceedmgS are penMag. but aaly uaW =eh paooeediags ate Coodudtdt or (C) seallts food agttxa ennt 3W$fa my to Leader subotdb acing the lien in this Security histiumm. If L= dho itroparry Is SoNmt to a Iku whtob can Sam pouchy over this Security ko ur=4 L= notice Wmt*b* the lies Within 10 days of the data on which dtu native h given, Dorm take ow or clove of the Wk ft Set forth above in Ibis Seetbn 4. leader oWy require Borrower to pay a oche tilae charge for a coal estate tax vetificildw 'used by Leader in connection with this Loan. S. Property 14suimee. Botrawser shall keep tits Improveaxars now =ktina or hm insust d against loss by An, huslitis lnciOO within die term "exttaded Covengs," sod any not limited to, CUlliqualn and floods, for which I goder requires insurance. This insuraoa ulloonis Oncludin deduea'ble levels) and for the periods that Lender mquiraa. What Lando Pmuft swicaces can cbango doles the Term of the Lose. Tae insurance carrier providy chosen, by Borrower soaabl :abject to Landot's right to dhapprove Borrower's choler, which At Y UNder DW requite Borrower to pay, in connection with this Loan, either: I hood zone daenmbtutoa, oorditcadon and tracking servkesl or (b) a onarime vbarge for De cettiFAW10a mvkt n and subsequent charges eseb oar, rerasppiags or sib Im t ulftes oowr of to such daurtpfoation or t den. Borrower sbsl also be nipowtible for the pnymer the Fedbcal Emergency Mausgenuat Agency in meeedon wim the review of taly flood 20ni front as objection by Borrower. If Bosatwer fails to main aW arty of the coverages deuxibed above. I.oe W clay obtain f Lender's option sod Eomrav's expense. Leader is under W obligation to Purchase ally pan cQvenga. Therefore, such coversga shah) cover Leader, but might or might avt protect Boa the Property, or the CO Chas of the Property. against any risk, itanrd or liability and might 1 Coverage than was previoudy in affect. Borrower acknowledges that the cost of the iaaurartc might slgaifkcamly exceed the Cost of lWzm w that Borrower could have obtained. Any amu nodes thb Section S shall becprne additional debt of Borrower secured by this Security Jnsaw bear iaiotmet at 1118 Ness tatu fivu. Lhu Jana of dstruseatcot ana dhau be paysblc. with such b Lender to Borrower requesting payment. PENWYLVANU_9j4& F&M1Y--r&0 b pr'W"Mb IKre INLIFORM IMJIW49NT PAICW . e2=M T-220 P017/043 F-467 Loan Za 0 PP1209br amount necessary to tnab hem Is a defieleaay of Funds PA. aid Borrower shall pay a no mote than 12 mottmhy refund w Harrower any Itioos atpritwtable to the thmta on des Property. if e It=2 ens Escrow hem, trot omen Borrower: (a) to Leader, but ody so load =plots eaf mWe nt of the a lion white these die bolder of the ilea an r deterndaet that any part of x may give Borrower a W :ball satisfy ulna lien or reporting service ter ereceed on the Psnpcny WW haauds iatltdiog, but d WH be vidatabW in the requires pursuant to the 1 she kattrain shall be (toll not be etteocind ) a onetime charge for d was mew noon aad hbkh reasonably haigbl of nay firm imposed by determination resWdog saraage Soverage, at afar type or amount of Wet, sormwer's equity in wide greater or lesser coverage so obtained eats dhbnrsod by Leader ent. nese amounts shall amt. Upon notice from fnitlals: ? 4055, 3039 W1 Oqr J of 14 papa 891763ie'G3420 12-19-'07 15:14 FROM-Premier Abstract AD iasuranee polloia required by Leader acrd temwds of such polieiay OW1 be subja diaepprove awl polities, ahdl imdtwk a sttutdud mortgage don. and shall rime Leads[ additional toss payee, Lender dWi bava the right to hold me policies and reaewal cerd t Bomwet sbalt ptamptly give to Lender all receipts of paid premiums and teaearsl notices. foam of bwouoe coverage, not odm wlw requited by Leader, for damage to. or destruca Policy dM Wchtdt a standard margage dense ad skAU =cc bender as mortgages andia In the event Of Ina. Borrower ehadi give prompt notice to do iasnrance arrler end Lei proof of loss if not mope promptly by Borrower. UYA= Leach and lionower otherwise a Peocceds. whether or got the ursdalylag hares was required by Leads. shall be appiiet the property. If She restoration or nprir Is eeonomiaUy fgsibla send Lender's security Is a repair and restoration perlod, L.esdet.sbaB lure the tight to hold tuck Inane r pmceeds u oPPD"NItY to Inspect sued Ptopegy to cum the work h= beta completed to Larch's sat Impactia n 3WIl be undentato pros aptly. Leader, nW disburse proceeds facer the repairs ad payment or nr a series of progress patymeato a: the work Is Completed. We" an agreemer AppBable Lave requites interest w be paid an each i03uranee proceeds. Leader shut ow be gay h tetwt or Casings on tech proceeds. Fees rem public adjusters, or odta third parties,' not be paid out or the insurance proceeds and a di be the owe obligstion of Dorrawa. U ecomrnically feasnbie or Leader's security world be leteened, the inearance proceeds dhell N=W ? . by this Stxauity Lott rum m, whether or not then due, with the excess, if ray, paid Proceeds shalt be applied in the order provided for In Soctim 2. If Borrower abandons the Property. Lender may f9e, ogadm and setae any avaalabls mattexs. If DorrovW data gut respond within w days w a notice from Lender dun the iasu settle a claim, then Lender may negotiate and seals the dorm, The 30-day period will boo In either event. or If L=der acgWree the Property under Section 22 or otherwise, 9^44ower Borrower's rights to my iotat =ce proceeds in an ta7mouat not to extend the amow.ts unpaid Secutky Lastruraent, and (b) any other of Borrower's rights (other than the right to my n paid by Borrower) under an insuraaoe policlp covering the Property, insofar as such sighs coverage of the Property. Lender my vW the JIM= proceeds either to repair Of restore amoants oapaid wafer the Note or this Security bnttsumm, whetiter or not then due. G. Oecuapt 1147 Borrower "I occupy. establish. and ate the Property as Borrower's 60 days after the exatttiaa of a& Security hNnoem and loth coughm to occupy toe Prop residence for at least one year after the date of occupancy, unless Lender Odtawlao .greet spelt not be ttartasooawy withheld, or unless ettteaaating c1mmstances exist which am bey 7. PmerntI00, Mai numee and Prmeetion of the Propwyt bnspectloas, Drn or impair the property, Allow tt>c Property io deteriorate or commit waste on the Propery. residing in the Pmperty, Borrower sbdl Maintain the Property In order to prevent the P* decreming in value due to its eoWdon. Unless it 10 determined pursuant to Station S mat economically feasible. Borrower' shall promptly repair the Property if dsmagcd to avoid If iaaotuaco or condemnation proceeda we WW in connection with damage to, or the taking shall be mponstble for repairing or reswft tke Property only if Lender hat released p Lander may disburse proceeds for the repairs and restoration in a aingle payment or in a the work is cowplaed. If rho imnraw or condemnation proceeds are not suMcient to repal Dorrowrr is not relieved of Bortowcr'r obligation for the completion or such repair or recta . PMSYLVAMA..SSertt VW AY-Fm h UWF! ft Mae UNIFORM DMIL OWT PAICl tt . e22220K T-220 P018/043 F-467 Loan XD 0 pp1709br w Under's right to s mortgagee sadbr a as a. If Lender mquinos, If Borrower obtain any a of. the Property, such as an addidoaad loss payee. der. Ireoder rosy >value yes In writing. goy b"raaco to restoration or repair of t lesmed. During such,. di Lander has had an Ihetim provided that such restoration In a shtgte is trade in writing or required to pqy Borrower Usined by Borrower abaci t reewtaioa or repair is not t applied to the sums Borrower. Such Inturartee lattrattee chits and rel" NCO eerrw kaa offered to who the notice is gluts. sarsby awigns to Lender (a) rnda the Note or ft d of ltaearned premiums Is applicable m the dw property or to pay Principal residence within M err; borrower's principal writing, which comoot red Borrower's control. a tball not destroy, damage VbOtber or not Btarnwer is y trot. daetiamIRS or lair or restoration is not x deterioration or damage. r, rite Pmperty, Borrower Is ibr such purposes. t of progress payateats as or restore the Prop", Initials; -Iv 303P list 4Medefr4Avtll 6K 1 76'13PG342 1 12-19-'07 16:14 FROM-Premier Abstract T-220 P019/043 F-467 Loan = d pp1209br I.andar or its agent may rake reasonnable entries upon and Inspeetioro of the PropwW. If it bas reasonable ame, I nd rosy inspect the interior of the improvenie nts on the property. Linder AM ghro wer notice at the time of or prior io such an latular Inspection spodtf ft swA maa able tease. 8. Borrowa's Lou Application. Borroveeer shall be in default it, during die Lola llesdon process. Borrower or any persons or eatitibs acting at the direction of Borrower or with Borrower's knowledIV or assent gave macerial)y Ida. misleading. or inaccurate lnfomalatlon or w ame nts so Lender (or failed to provide with e>,ararial iatoraaetloo) in connection with the Loan. Muerid repromations include, but are not to, avasentnloas conoeram Borrower's occupancy of the nip M as Bosco Tees prb oipd nadece. 9. Protection of Lt's latwest is fire lhopatty and Rights Under ibis 8aetuiq t. If (s) Borrower falls to perform the eovetlaons sad agneeaenta eootalsed in this Security , (b) that Is a kph ptoeeedtag that m1& slgniWatly affect Lender's iatesmt $ the property and/or sio* turd this Security Iastruw d (sucb as a prooaft to banitsuptcy. probate, for coadetaudon or forfeiture, for e:Mo of a lien wbie;h may attain pdorlty aces- dds Soontity hunuaaeat or to eotbsoa laws or resnlations), or (e) Borrower abaatbaed the Property, then iatder any do and pay for whatever Is reasonable or egepeoprleeee to protect Leader's ' in the property sad glow under this Security Iastranus, iscl adiag protecting and/or mmiag the valaa of the , ad securing and/or tepaitiag the property. Lender's alas can include. but ace sot l n*W to: (a) pay any sums scented by a ties which has prior* over this Security Iattr> n aac; (b) appewh* iA court: and (c) psyiag attorneys' tees to protect its interest in the property and/or rights under this Security Instrument, ioduding its prsskias In a baulttuptcy pmeodiog. Seuntclag Ow Property includes, but is trot Hissed to, entering the to melee repaln, charge loch. rwim or board up doors fwd window=. drain water !tots plpes. gdianimte bu hag err odw code violations or dangerous conditions. sad have utilities tamed ox oar off. Although Lenda ttta take anion under this Section 9. Lender does riot have to do so and is not wider say dtuy or oblijow to do so, is agreed that Leader imam no &Wlky for sot taking nay or all actions autborized wader this Section 9. Any ammoas dlsbursed by Leader uadta this Section 9 stall beWw additional debt of or secured by this Security Ineuumieat. 'I%m amm m sball bear Interest at the Note race Root the date of dIs and sbdl be pttyebla, witb sub interest. upon Aot)co from Lender to Borrower requesting hu)'MMIC• It Us Security la u mteat is an a lasebold, Borrower shall vow4y with all the of the lease. It Borrower acquires fee We to the Property, the leasehold and the fee title shall tot roefge Leader agrees to the merger In writing, 10. Mortesp Inaarsaw If Lcn*r required Mortgage Insurance as a condition of tea Loan. Borrower shall par she premiums required to mintain the Mortgage Inwratim In effect. If, for my . the Monroe hlsuremoc wverage requited by Leader oenes to be available from the mortgage insurer that ly pre74W s ueh insurum and Borrower was required to nwm wpu&Wy designsed payemmu toward the p for Monger laasncanee. Borrower shall pay the PMzdms required to obtain coverago substgadAy t to the Mortgage Lrunnec previously in effect, at a cost substantially equivalent to the cost to Borrovuw of th Mortgage In=s= previously in effect, froth aft alternate tortgage intoner selected by Lender. If substantially nivak u Mnctgap lmrsmv coverW Is sot avAMIe. Borrower shell coadaae to pay to LoWeir the arm= of up=Wy designated payments that were due when the hnsuranoa coverage ceased to be in effect. Lender will see it, use and retain ama payments as a twn-refaadsbie logs reserve is iku of Mortgage Insurance. Such less rese rvu all ba non-rdundable, notwitbsaodiag the fact that dw Load is uitbu tely paid in full. and Larder shat! not be c qui to pay Borrower any interest or comings on such loss reserve. Leader cyn ao longer require late raerve pay if Mortgage IaJUIM% rove: F (in the amount and for the period that I.ead.r requires) ptov" by an insurer seer by Leather again becomes available, is abulned, and Leader tapims aepuately designaed payraatq toward pr a sums for Mortgage Insurance. If Lsader required Mortgage insurance st a condition of making the Loan and Bo wer was required to r1 Iniierda: ?? FENNSY UMA.-StalinF@tn4•.F.mW b7oU7t*"L.hW tlteMXK W5rRt NIM 6 3M 1101 "7 ofJIpeas) PA1CH7 - 07222002 -- -...-,-_ _---- . - - -- BK l 78'.JFG3422 12-19-'07 16:14 FROM-Premier Abstract T-220 P020/043 F-467 111ek0e y d93rgataM luyatgots toward the pMjWDM for Mort required to maiatain NortM g kaauranceI sotto TOltiraatb i ff L "A ID d 9PI209br Slim! pay the pmmiumt n e tec. Or 10 Pmvlde A MR-Wandabie loss r"WrIVIeat for Mortgage inutr%oe Cad. is arcordenee with my writtan WM =t Providing for suoh Nnn4ntlo4 or =dJ i Lender's , tm =til 61 er grid Lender torm nation is required by Appjkehle TAW llmweet; obligation to VW iotemt At the rate proWded In the Note in this Section 10 aflbcn . h1wifte ia11 relrpbur3es Louder (or goy aft that purcbaoes the Moto) for 8ornower does twe repay the Loan a agreed. B mW is not a party to dte Mortgags M laws it guy tricot it octgW lnSUtm walUW their rota! rlalt on all such iesuraoa in faros from a5 time tot ree0te0ts with abet partkS flat Sham or modify their halt. or reduce braes The . and MV eater loco . se malWona that are lm sfhctory oo the mortgafe itwtrer gad the other per' W111 my requim the mortgage iilia to nuke (or pertleA) to ?S'Att usieg My Soutar of t ad are an tarty and groemmu. Thine h v a bane available (which m4' ladvdo (lads obtabW *M Mortgage lnWraaee prerninate) r o mmtgare iasorar my . As a remit of these ? My PUrdMW of the Not, Mahar giver. or dray 'W "W of gay of the tategolag. my teeojvt (dbudy or I'?ly) araouae that teiasttrer, gay other entity, diaranetimil as) it portioa of Borrower's paytaoota for IKttrtgt?e Imueattce. In eltchaage Mor tgage itrattrar's risk. or tedyuiaa IOIM- If ouch app id re from (a might be sharing or n*di*iag the prov es that So ae3llme of WZWA In mboMp F>trlb for a store of the PspNtaii+ paid 00 the imuret. the a?tAa``9meal reloswa risk WW a abate of the Of= termed t:apth+e (a) Any aueh aQ'"mssta wlp not evict the amounts that Borrwvv has agtyod to lasttraece, or say other terms of the Loos. Web t>At tmuta w1U not lserea eb for Man=age u e ma"lgage hwarance. and they "M tint agNtle Sorrowar to atU' rdund Borrower waq owe for . 04 Any such a$reemaap wig met asssme 8894 00 rlge Borrower bas - if My • w{tts rM under the Bomeawp " ]NOUetlon Act of IM o the MertSytge or a other law. Th re do set" attain dia9loauree, to rep" &W ebtttin castedbrlon of or the !!dart We taeura0ce t *stted aytog'alleafty? wtd/or to reed my ladude the r! 1lM to to have the Mvrt>caae " s rotund or any Mmpge uaearasd at the time of stteh estategetlocc or twadnadoe prouslumta that Nero . 11. Az;*wcW be Paid to Lender. of li[beallaaeeua Praoeedsl be P'orldttrre. All Misedkanems procoeds than hea+eby a13lgot:4 to and if the Property le damaged. Stub Miue(leoeouS hOcads Shall be applied 10 ratorados the restoration or t epeir is CMDQMlptl h' fbedble and Leodcr s accu it ? i fair of the Propery. it r ) s trot lest D Oruina itsxW. Lander Shall haw d, dghr to Sao Stich MlS 113Oetlaneaus Proeeeda ntttil w ioapoct Saab Property to =sure We as U OLD k 1 o tbtrh t? and had an opportuaity wor s has bean t fa to Latch's eia "I be uadaatakaap t Pt'• Low" may pay f" dw repwn ad rattorati i ! p ' OWA that on n a 3105 9 d i PWW= as the *0* is contpkted. We" as agreement is made In writing or interest to bu paid aft such Mlacaflaaenvs proceed: L d a series of or In Is s law r . oa er Shall not be required to pay earnkytgS va 3uch MLn911aneous pmoeo&. if the restorsdoa or repair is not 9oonoraiWy fm • ?° MiseeUaaepua Proceeds Shall be applltd to the sane XCUnd b dd or notD d r iates?st ke Lender's security a reg ue. with rho excess. if any, paid to Borrower. Such MiacdlaMeoua ghat P widW for ID 9CC&A 2. arl Ar F yeuu me?ate whether In the event of a total taloag. destruction, or lots is value of the psopmy. the Misc¢l) at sppliett to the sums WRXW by this &=X'ty lasm n mt. whedw at not than du aor i h procrxdS Jul ba the e. w row9r. t (f W. Paid to In ?Y inttavew ncd the mcdlatoftfq putiat tg. deatructiart, or loss in value of the ProP" is which the f y before the partial taking. destruction, or loss in value is e ual t r market value of the loe o q o or great Chan the A=Uftt Of the PdMii$YLVAMA-Sie;te 13mily Fsuals Af Wiy," Mae UMIr'OItM AMBTRUt?t>.NT Wall: PAIChq.t?03 Foam loose8orJ4 Kr1 BK i 783P 'U'3423 APPANkAW09sym m"M i?1423 12-19-'07 16:15 FROM-Premier Abstract T-220 P021/043 F-467 suasa $=ad by ilia Setatrity Imtrtttaent h amediattly bohn the partial tsWgg, destruction Loafs ID 0 pVU09br or loss is value unless Swower and Lender otherwise agree In writing, the sums secured by dtis Security mount of dw Miscel)aoeotts Promo ouitiplieB by the following fraction: (U die total , dWl be reduced by the of the arum aectnvd imtttediacely before the partial Ukft. destruction, or bas in value divided by (b) the ft value of the Property bn=dhWy beibee tiro pascal taking, doructioa. or toss in value. Any belanco &W be tat Borrower. h rise evetll of a partial Wdag. destruction. or loss in value of the PuVwy in which Property lonedin* Wow the partial Wdag, dettrucdon. or loss In value is [on thin the hir madoet value of the Of the == memo Unmedlately bdbre the partial talft. donedon, or loss in value. uttlas Borrower and writing, the Miscellaneous Proceeds dw be applied to the own swxW by this Saetuity odwr*lw apse in whedw or not the aunts are this due. It she Property is abandoned by Bwroww, or if. after aotlce by Leada to Borrower rite Opposing hM (As detiaed in tba ran VAMN) offal tD m*e An award to settle a claim for daraW. Ws so ugatd to Leader wlil{Ga 30 d w after thn Ame the modea le Eivea, London is avdw iawl w wllw? sad apply h/tsmonnoul Mroceetls oltbor w resWation or repair of the Property or to the am sewtred by this Security whether or not dwen due. 'oppoth:9 Patty" arenas the iltrsd patty that owes Dotrower MisoeUsneous Proceeds BotWWW has A tight of eetiraa in regard to Miscellaneous ProaWs. dw party Against whom Borrower !ball be In dohok if auy action or proceeding. wberber civil or erinol=C is judgment, could M WI in ibrhinue of the Property or other =%-r al impairment of Lt'eda' sera tbat, is Leader's latest in the Property or :11018 under dui: Seeuriry ldstritracnt. Borrower can cure Sueb a defanit and. If aooelerstion oOEt nx4 reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a ruling in Leach's judgtnmt prreludce forfeiture of rise Pro" or other material i of Lender's interest in the Setaniry IasuuflM. The Qrocews of airy award or claim for daroa es that are attrib t bl , WpM or rights under Ibis h i i g a e u Leader's irtunt is due Property are hereby wrigned anti ftD be paid to Leader. t e mpa nueat of All Miscellaneom Proceeds drat au roc applied to restoration or repair of the Propegy a All be applied in the order provided for in Section 2. 12. Sorrowes Not X910054 Forbearance by Lmder Not a waiver. gum"Won of di time for payment or modrficadea of Wanitation of the sums socurod by this Security Inarlrment Scanted by Suottssor in Intt= of Borrower shall not opartdo Ie idCA c the li bili f B ro Boaower or say a ty o ortuwer ur Boffotver. Lender !ball la be rogtt and to coam once prooeWLMz gatnn jay successor it Suemsaots In late= of of Somawer or to NAM to extend time for PWA100t to otherwise modify amortimlon of Um scum nee wW by Security batttmteat by reason of any dtntaurd made by the otiAW Borrower or any Succafsora in lotcreat of BUM . Any >Torrbeuutcc by Leader In eambiug say right or randy itecladlag, whhout h'mitstioa, Lender's acceptance f paym es from third parsons, entices of Su=oaaors in tsterear of Borrower or in Aamum less than the amount th waly" of or pfeelwk the rx=169 of Say right or remed due. shall not be a y. 13. Joint and Several Liability, C .dpkrsl Successors and Assigns Bound. Botrsda Borrower's Oblivious avd HaWy skunk be J*t And se covemu sad agrees that veral. However, any Borrower w hen meat but does nor exmw the Note (a "co-sip a-): (a) is co-signing this Security s this Svcwiry only to rooRtgage grant and convey the co-sigttot''a ioter+eet lit the Property under the terms of this Security personally obligated to pay the sums secured by this Security loatrument: and (c) a ee t . : (b) is not * gr s Borrower can agroo to extend. modify, forbear or make nay accommodations with regard lastruneot or the Note without the cc-sigaer'a ceaaaat. and say other s of this Securit y tm 60ICCI 14 the 1tm WAY1R rho Section Iii, JOY ANooosot is Iaterost of D&,v*r4 wbu sasuu under this Security 1n1tttlam is writing and is a roved b L d h Burtuwer'a obllpdons ' . pp y en er, s all obtain all of B under this 5ecusity Insmimoat. Borrower shall not be releaW fmm Borrowef's obligations wcr a rights and benefits liabillry under Otis PENN$YLVANU-Single PUngy-POaeia hfiefteddk hose ($ WO&M INST41p4 rT F Initials: /' PAtCW-axzseo: SMCnsaa?asi aAaaseo•, 12-19-'07 16;15 FROM-Premier Abstract T-220 P022/043 F-467 Security Inatrament unless Leader ape= to sutb release In writing. The oovetutatd and AS Instrnntent stroll bind (except as provided in Settle$ 20) and benefit rho sttaosaon and ani 1A. Lam Clurgas. Leader auty Cbargo Borrower lea for setvkes potlbtMW in CAN default. for do purpose of prowling Lender's iotereat In the Ptopotty ad rights under that imludke. but not unfired to, auomoys' funs Property iaapatien and valuation fees. is ttl absence of expreu authority in this Snousisy lnuninsat to d1aKV a spe dit Lee to Bomowa prohibition on the charging of such ft. Leader nay not charge fetes that are expressly Pre lurrurnent or by Applicable Law. If the Lola is sW*a to a late wbkb set: maxlmnst loan charges, and that law Is find iRtme or other loan charges Col)eewd or m be collected in ooaaeCtloo with die Loam erect (a) my sub loan Charge shad be mfted by the aswunt sea wry to reduce the oblige to any sums already collated from Borrower Widd atoeaded permitted lbnits will be refnnde eboose to make this refund by tedudng the principal owed tinder the Note or by makieg a if it refund adaoes principal, the n tenon will be uosted as a partial pttpaytttem withott (whether or not a pmpaymew change Is provided for under ebo Note). Borrower's =CM by direct payment to Borrower will coastlanm a waiver of any dgbt of action Borrower sdE Loma Tit 0 pp1209br emeats of this Secudly u of Lender. ctivn with Borrower's Swift Woument. rd to say other fees. the shall not be cons ad as a tbitad by this Security inturprelod so that the die pemnktcd limits, then: r permitted, !bait; and (b) W Borrower'. Lender may no paynteat to Bormwet. 7 PA M dwV e of any such. nfmd made t hm Arising out of such ovackup. 15. Nmtiew. All notices given by Borrower or Lam in c anecdon with this SeCatity trumest mat be in writing. Any notice to Borrower in cooneetion with ibis Socrtrity fasttumcat shall be to hate baA given to Borrowa when stalled by first class nosh or when setually delivered to 8onow es notice irlont by other mesa.. Notke to any one Borrower shall constitotenod= oak Borrowers fatless Applieab Law expressly requires odtetwise. The sake address emalt be the Propeny Address unless Borrower bit des a substitute notim address by mice to Leader. Borrower shall promptly notti)r lender of Borrower's change of If Lauder specifies a procedure for reporting Borrower's chop of address. rhos Borrower shall out, report a of adilmn through that specifkd procedure. Thera tray be only one designated notice address under this Secuuity trameas at any oat iim. Any notice to Lender shalt be given by delivering it or by trailing it by riot class tnsit to 's address stated herein urkss Lender hat daigaated anodes address by nodoc to llotrower. Any notice Art to wxMi with this SMW[y instnasent shalt not be deemed to haw been given to Lender =9 actually received by if any sobs required by this Seenrity Iosaumm is also required tinder Applicable Lsw. the Appltt abh Lawn regal tmot wilt satisfy the tor[ I mpostdlag requIrensent umdor this Security Instrument. 16. Governing Law; Sn aWkyt Ruda of Cona nsaties. This Security Iosuurmomaddat be Vvaned by federal law cod the law of the jurisdiction in which the Property Is located. All tights and obH cWAd fed in this Security fnsurterteat arc subject many taquitetaems and liatitations of Applicable Law. Applicable taltu exp Wtty or Implicitly Slow rho puttee to rtgra by conaTct or Ir might be silent, but sucb silence shall be construed as a prohibition agdat agteemast by contract. In the event tbu say proviviun or clause of this ty btstrnnunt or the Note conflicts with Applicable Law. such conflict shall not affect otter provisions or this ty Iasmuneot or rho Note which can be given effect withotu the conflicting provision. As used In this $murky Instrument: (a) words of the 7asseulise gender shall mm and I ado Corresponding scoter words or words of the fcminine Scoffer. (11) words Io the singular shrill tnUAn and include rite Aural and vies versa: and (c) rho word "may" gives solo div=tton without any obligation to take any action. 17. Borrower's Copy. Bona sluff be given one ropy of the Note and of this Securl y lnstrument. 18. TF*Wer of the Property or a ftnq [eiei Interat in Borrower. As used In Ohs n 19. 'Interest In the Property' mecca any legal or hcneilcial inlemt in the Property. Including. but not limited to those beneficial Interests Iaitiats tr$NN MAraA-SirWe t?amUnwFJ?nerie 11?arrYeddla Mae tIWORM V4MUMENT Tofu 3W JM (pare ?o gJll pease, VA1CUtA • o7=17003 .M0tla8ea8aaldogSYrtd1u.CM BK i 763FUG3425 12-19-'07 16:16 FROM-Premier Abstract T-220 P023/043 F-467 loan Ip 9 pp1209br transferred In a bond for deed, contract for deed, Wtallaxat sales contract of aaerow ag the intent of which Is the ttaaskr of title by Borrower at a fmm date to a purduar. If all or arty pan of the Ptopeity or any Interest In rho property is sold or ttaosfatred ( U Borrower is ant is nature] person and a bm&W Interest is Borrower is sold or trandur4 wkboua Ladder's ' r written OMAN. Lender may iequlre irmnedixt pqrnew In Adl of an am wired by Ibis Seca* However. Ibis option shall not be exaccieed by fader if such exardso Is probihlted by Applicable Law. If Leader ameises this optiaa, I.endoar abaft give Bor wma Wdw of scahrmm. notice shall provide a period of am lea thin 30 days fe[em the date the notion is given In aeoordmm with Seetiost 13 wl which Borrower mnst pay all sines secured by this Sorority Irta nstnect. If Borrower falls ro pay them trims prior to exoration of this period, Letuda trey iuvolltj any rarmdib permitted by this Stxtrrisy iasttats?errt without tlntlier at domed an Borrower. 19. Borrower's Right to Adnew After Ataedustiaa if Borrower mean eesttuist tioae, Borrower shall have the right to bave a torment of this Secusky hamtment disc anted at any there prior to eartiesr of: (a) five days bofere sale of the Properly pu tat, to arty power of sale contained In t!w $ccW*y I ; (b) web abet period as ApplicaMe Law migbi apCdty for the terrairudion of Borrower's right to:eins;og or (e) of a judgroestt wh aiat this Sorority InsMuM. 1UH sni ditiima xrr thsi Borrower: (a) pays Lander all Betas that weeds be due ua" this Security Iusuttmeat and the Note u If no mcdcration had occutced: (b) rota any Clef of any other covanaats or agrexrrns 0; (e) pays all expanses incurred in pafbreing this Security Instrument. kAudi» g, not United to. reasonable elteoroeya' Sees. property inspeetton and vdttatlo t Ilea. and other tots incurred 1br the of protecting loader's imerM in thr Preiterry said rights under thle 6opa ty IgMM&A, NJ (d) te,kw *uuh taalvn t adee my teaaonsnty require to assure that Leader'a interest in the Property sad rights under this Security ins , and Borrower's oblisation to pay the auras secured by this Security Inahutnent, ehaU eondaus uncho gad. may require that Sornowor pay Such rdnstatesom am nerd upwacs; in one or mono of the following forum. selected by Under, (a) cast: (b) mom order; (c) c dfkd cbeclt, beds cheek. treasurer's cbeck at cashices cheek, rOvWed soy wch d=k Is drawn upon an institution whose depod" ere injaW by it federal. atency, fasirumentslity or ty; or (d) Blectrostic Funds Transfix. Upon rolaet mart by Borrow, this Security Instrument ad obligations hereby shall retm(n fully effoaive ss If no acuierstion bad occurred. Hower, this right to rdutaa shall not y in the use of acceleration under Section Is. 20. Sale of Notq Change of Lotto Servleee; Notice of Glrriwattta. The Note or a inert In the Mote (totetha with ells Security Dwrarnear) an be sold an or more times without prior hake t Borrower. A sale might result In a change in the entity (known as the "Loan 8ervieet') that collects Pesiiodk due under the Note and this SO=* iesuutnent and performs other mortgap Ina servicing obllgsdiow tinder the N , deli Security instrunit'At. and Applicable Law. There also alight to one or snore cbsrtgos of the Loan Servieer tmred to a sale of the Now. If them Is a dtaoge of the Loos Servicer, Borrower will be given written notice of the d=V bleb wail time the taame and address of the new Lava Servieer. the Address to whirls paywou should be wade end other infancition R$SPA requires !n oon=dOn with a notice of tmufex of servicing. If the Note is sold and the Lana is serviced by a Loan Servicer other than duo purdwer, of as Note, the toottgage loan servicing obligation Borrower will remain with the Lows Servica or be transferred to a sueoenor Iaan SWAM acrd are mot assumed b the Note puurdw& Won otltowlte provided by the Note ptrrltsser. Neither Borrower nor Lender may cotrmoenaa, join, or be joined to any judicial action ( either an mvidt1d litiguet or the mCtnber of a class) that arises from the: other party's actions pursuant to this So urity Instrument or that alleges thst the ether parry baa breached any provision of, or any duty owed by mum of, th Security Instrument, uutu such Borrower or Leader has notified the outer party (with such notice givea in comntianee %I tit (i,o requircri mm of Section IS) of such aUcged breach ad afforded the other party hereto a reasonable period aft, the giving of such notice to take corrective salon. if Applicable Law provides a time period wbieb must lapse before certain action can be 6K 1 18 J- 6 ialtiale: teE MMIMUMA-ainele FAmit>-?iml? AfteW edW Mu trKEFORK uhl? Form loll IMt 1mr It 4 JOPIVWI 6144%. "- MUM 1Yreemoa?aaetilef&vat"m.eMr 12-19-'07 16:16 FROM-Premier Abstract T-220 P024/043 F-467 Loots in M p91709br uhero. deli limo period will be deemed to be ressoUNG for "oscs of this peregrapft. notice of acwh adoo and apportaeicy to cage given to Bottpwer pttrnraot to Section 22 and tbs notice at gtvea to Gott ewer pttrsuaru to Section 18 shall be doemtd to sadsiy the Donne and opporatt9ty to talcs eorr+c d" salon vision; of this Section 20. 2!. Nuardeus 8nbst was. As and In this Seotioa 21 : (a) 'Humdous Substamcn" tkoae aubsawoes defined as toxic or harstrdorts anbtttasxe. poilntants. or wastes by 1??ironattsrtal Law sad the col h1t arbatamoes: gesaliAe. karossne, other f mmablo or to* pearostatm prvdsota, toxic pestiddes end Iterbkides, v aalveatt. tmmriels containing admus or formal dome, and radiosuive matssiok (b) "EAvirazatintal Law' fedoras knws and laws of the Jurisdiction, whore eke Peonage is soesrwd dW relate to health, safety or cmvironance ptnleetion; (e) 'Baviroor Waj CI=Up' isanlndd nay reaponae at4 0& re WW action, Of tttrtovas action. deflaed in 13wftnmeotel Lew: acid (d) an gHaviromme" Condition" arenas a condition that can cause, contribute to or othetwiee trlggcr eA EoviroontmW Clourup. Smower shall not comae or pm* the psesetroe, list, dispoeal, storage. or release of Hazardous Nbstances, or three= to release lily Haardou Substam, on or in the PYopeny. Borrower shalt not dG , nor allow anyone else to do. any&IRS afl aft the Property (y that is in violation, of any Bnvirommenud Law. (b) w treater on Environmental Condition, or (c) which. date to the presence, use. or r Ie F Of 19011106098 tenm crem a cowicbn that adversely atftem the vows of tic Property. 71ho preceding two seotcnces not apply to the PFWMcC, use, or storage on the property of renall quantities of Hazardous Substattrrs tlat arc recognized to be appoopeino ro AW Mi residential Uses end to awutenaace of the Property (including, but no IbWted uh hsurdow substances In cooaatm w products). Borrower sball pmrnptly give [.otter written notice of (a) any ipvestgatoa, dollar, . lawsnit or other action by any IPVC t><Atal Or negularory egtM or PiVAID patty bWWViag *0 Property afld Wertz Substance or Environmental Law of %W& Borrower Its; K% W lmowkdge. (b) any Envi oam atal Condi inciudiat but act lttmhed to. Arty spilling. k"g, discFaage, release or thtm of release of any Hazardous , arced (c) any c"tion caused by the pmacnee, use or release of a Hsratdous Subnkm vma edvasely is tbo valve of the . Propotty. U Bmnwcr !cams, or is notified by say gavenu sestd or rquIsmy twthorlay, any private pate, that any rt=val or outer ranediadon of arty Hazardoas Substance asserting the property is Smower shall promptly roles an rretessary remedial action in woordanee with Environmental Law. Nothing herein I create any obligation an Leodds for an Lnvlm=anW Cleanup. NON•UNIPORM COVENANT& Borrower and trader further coveaant and agree as s: 22. Attelentioni Raatedtee. Lender *0 gWe notice to Harrower prior to following Bwmwer's breach of eery covetmtt or aprsrment to this Security InstAlmost rout not prior to atioa under SMAWD its Wen Appl40ble Law provides stherwbe). Leader shall notify Borrower or, anions (b) the aetka raqubvd to care the delaWt; (0) when the defoult must be aired= and (d) er ditp: (a) the default; h t Wa h default as apeeMed tney res uk in acceleration of the sums seat red by this Security I a re to care t e ant, toreclosuro by Judicial proceeding and sale of the property. Lander shah further ltdom Borrower of rw to reinstate after eecdentiea and alto right to assort In the t rodoemre proceeding the non-entente of a defense of BaTower to acederadon end foreclosure. It the do&Wt is mot epired as spsel cult or any otbtr ed, Lender nt !'s option mu1 reeluke fa mediate psynirnt in atilt at all wens secured by this Security futiumat mid may foreclose Ibis Security ltua man by JtrdicW proceeding. Lender skali be end Ihout flatbwr demand to cohost an prpasea inw red in pis nWg the raand er provided in this Section. 22, including, but not lienit to, attorneys' too and cuats of title evidomm to the extent permitted by Appslab a Law. 23. Release. Upon payment of all aunts secured by this Security lastmovot, this Seeuri IasL=mt and the estate canve Yw shall mmioate and becorne vold. After such occmame, !.ender sball disCharge an M4? Ws Security P initials: r??! ? U?te5Ytv,?nt Pm • ft=IA-S002 te FamnY-}seas Ma&Troddts Mee LgVVORM tNtrrRlA?szW Tong , ._, 143# 10 OW ISgII4jwra) .afore?eltantde><Srrem?.nm BK 1783PG3427 12-19-'07 16:17 FROM-Premier Abstract T-220 P925/043 F-467 Loan ID M y9190flar tnstrua=. Bomwer shell M any l00a"oa cm:ta. lender may chwle Borrower a fee rWoWaa dib Somsdey hmn meet, but ody it the fee Is pald to a ddrd parry for savices rendered and the of dw fee is peraitiod under Appikibto Last. 24. Woivas. Bonower, to tba extent permitted by Applicable Lew, waive; aed myy erm or defects Ia proscWV to anions t4ie Smusity l ouumem. and hemby waives the bowfit of say or tetuta hwe ptovidtoy ibr tta?y of ataal dM waendea or die, e?ratpptloo from attaclu m. IM sad tale, a? bo paamptioo. 23. Beblahtelpnlt Att+iod. Barowa's time to tskatete previded in Sealaa 19 Wall to oaa boar prior to dw commoneftmt of biddtap u a ahee We sale or oteer aale poiauant to this SwAdry Iaa 26. Pothose Nooay it wgapa. If say of the debt secured by this Soca[iry IagMnM b last W Borrower to acquire dde to The Ptopeny. U Security hon atettt shall be a punhm mosey trq %op. 27. interest Rata After Jsdlewi . Sommot agrees that the interest fate pgsbk a jodSmem is enured on the Kota or in an salon of awtrgage toteeloeure shall be the nest payable from time a time the Note. BY SIilMNt3 SE,0W. 8onower accepts and apm to dte mm aed coveaaau in W, Stxufity bam m m ad In say Rlda W010ed by Borrower sad recorded WM It. WWtsSSa: ?' /' r ? / ? (Seaq ebasl r . 1[o an .&now (seal} -Borrower tSeal) .Borrower -Borrower (Set) -Borrower -- --- fSeail -Borrower VWtNSYLvAM-Shale Faay«-F&M a Weft eMe Mn tJWGRH tNMVM ENT PAICM - o2222ea2 Sormi W1 OWJ3o/14M&ef) BK l 783r?3428 12-19-'07 16:17 FROM-Premier Abstract Cwdfl stet of lksideoee I do cmify drat the ytWu add= of the whhiet-named mar gq= is 4201 900, Bowie, ND 80716 Witness my head tbis 18th day of llov4mbet:, 200py ,?. T-220 P026/043 F-467 Lam ID 0 ppl209br Road, suite of wee ?Sy CORGIGNMALTK OF PIIdMnVANIA Cpyily g; On dds, the ? dth day of 2rayo ber, 200 ,2 ^. before toe. die code ni ofi er. Pwwwdy Appeafcd 1He114el V. Novan known to me (or sati0kWrpy perwaq) to be dte pmun(s) Ww o tieaae(s) is to tlt t . instwwrlmt and ackmowled=t:d do & awaj end do nu for rho pxpuu herein IN Y rEMS VINMOV. I bmetsato set my hW and of l@W scat. 44 My Cotttmiseioet @xpknes: ?N." :?`.,''c ,_• ZI NOTAIiAL WAL jCW x R jCM P. edee?Id*plalrO Oohs Arf? bItIMA K &_ W pYdle , , Nks JYOa 1 AI CA SUN .2000 Tide of Oft a MOMYLVAM-SiWe pamar-ramb 1rtaNrowae uat UIr M M WSTRUMXNT PAicmz - 0ainou Iakitdl: fw/" 1009 LOl 0 1d'V14 BKI783PG3429 VERIFICATION I, 'i e4c- %'a -4"P (title), depose and say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. By: Washington Mu Bank Name: Title: _ A"xq Our File No: Loan No.: Borrower Name: 95960 0609102694 Michael F. Moran Zucker, Goldberg & Ackerman, LLC FCP-95960 00 c;x:a ^I t C_ r ?5 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MORAN MICHAEL F NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORAN MICHAEL F the DEFENDANT , at 1410:00 HOURS, on the 14th day of January , 2008 at 500 THOMAS ROAD CAMP HILL, PA 17011 by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 1/?2l oP gw .00 42.40 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/15/2008 ZUCKER GOLDBERG ACKERMAN By: Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank, Plaintiff CIVIL DIVISION No.: 08-175 ISSUE NUMBER: vs. Michael F. Moran; Defendant(s). TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF: Washington Mutual Bank Plaintiff I Hereby certify that the last known address COUNSEL OF RECORD FOR THIS of Defendant(s) is/are: PARTY: 500 Thomas Road Camp Hill, PA 17011 sanleo1j, Attorney for Plaintiff ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa I.D.# 55650 Kimberly A. Bonner, Esquire Pa I.D. #89705 Richard P. Haber, Esquire Pa I.D. #202567 Eric Santos, Esquire Pa I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: FCP-95960 Zucker, Goldberg & Ackerman, LLC 2 FCP-95960 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank Plaintiff, vs. Michael F. Moran; Defendant(s). CIVIL DIVISION NO.: 08-175 PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Michael F. Moran, in the amount of $81611.86 which is itemized as follows for failure to file an Answer: Principal $76,787.09 Interest through 04/08/08 $3,163.78 Attorneys' Fees $1,250.00 Title Cost $ 525.00 Late Charges $ 126.73 Suspense Balance $-418.01 Escrow $ 87.15 Pro Rata MIP/PMI $ 33.12 Total-Fees $ 57.00 Total $81,611.86 plus interest on the principal sum ($76,787.09) from April 14, 2008, at the rate of $12.62 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sa e mortgaged remises. By: ?--, S A. to , Esquire-PA I.D. #55650 Kimberly A. Bonner, squire; PA I.D. #89705 Richard P. Haber, Esquire; PA I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: FCP-95960 Zucker, Goldberg & Ackerman, LLC FCP-95960 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his/her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. S A. etteri, Esquire Kimberly A. Bonner, Esquire Richard P. Haber, Esquire Eric Santos, Esquire Sworn to and subscribed before me This /l/K day of April, 2008 Notary Public T My Commission Expires: MARIE LINDNER NOTARY PUBLIC OF NEW JERSEY Ccrtrmissw Expires 1Q10011 Zucker, Goldberg & Ackerman, LLC FCP-95960 4 t 6 OS\O t 0 1 ZOIK#3 mw&nMO3 • r SHERIFF'S RE'T'URN - REGULAR CASE NO: 2008-00175 P ?;q w COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS MORAN MICHAEL F NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania; who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORAN MICHAEL F the DEFENDANT at 1410:00 HOURS, on'thell4th day of January 2008 at 500 THOMAS ROAD CAMP HILL, PA 17011 by handing to, MICHAELF MORAN a true and attested copy of COMPLAINT - MORT FORE together with and at.the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 42.40 Sworn and Subscibed to- before.me this -day of , So Answers: Ole R. Thomas Kline 01/15/2008 ZUCKER GOLDBERG ACKERMAN By : ?/?j•..Deputy Sheriff . A.D: v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank vs. Plaintiff, Michael F. Moran Defendant. CIVIL DIVISION NO.: 08-175 IMPORTANT NOTICE TO: Michael F. Moran 500 Thomas Road Camp Hill, PA 17011 DATE OF NOTICE: 2/5/2008 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR B Y 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 MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU D 0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LANNYERREFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990.9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank Vs. Michael F. Moran TO: Michael F. Moran 500 Thomas Road Camp Hill, PA 17011 FECHA DEL AVISO:2/5/2008 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE ]NFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL S'ERNZCE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 ZUCKER, GOLDBERG &ACKERMAN BY: Scatt a. Diettexi& Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 CIVIL DIVISION Plaintiff, : N0.:08.175 Defendant. FIRST CLASS U.S. MAIL, POSTAGE PREPAID 95960 Cz? 404- p 00 00 Q V b f ?'} ry w- cr) J C'? 4 CO f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank CIVIL DIVISION Plaintiff, NO.: 08-175 vs. Michael F. Moran; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Michael F. Moran ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding onf ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $81,611.86 plus interest on the principal sum ($76,787.09) from April 14, 2008, at the rate of $12.62 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC FCP-95960 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION File No. 08-175 WASHINGTON MUTUAL BANK, Amount Due $81,611.86 Plaintiff, ; Interest from 04/08/2008 to date of sale $4,139.36 vs. MICHAEL F. MORAN ; Costs Defendant. TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: April 29, 2008 Signature: Print Nam : Scott A. Dietterick, Esquire Kimberly A. Bonner, Esquire Richard P. Haber, Esquire Attorney Telephone: Supreme Court ID No.: Eric Santos, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 for: Plaintiff 908-233-8500 55650 89705 202567 201493 Zucker, Goldberg & Ackennan, LLC FCP-95960 -f- u po 00 ?O 00 b D Q O 0 O ? d 1 V- cp ?T Cf e W 5n w Exhibit "A" LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE 3057, ID# 47-18-1302-227, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING, AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: IN ACCORDANCE WITH THE AMENDED FINAL SUBDIVISION PLAN NO. 1 ENTITLED "FOXCROFT" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7, 1981, LAST REVISED ON JULY 17, 1984 AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "46", PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOT NO. C-9 SET AT THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8 WHERE SAID DIVIDING LINE INTERSECTS WITH LINE OF LAND DESIGNATED AS F.H.O.A. #2; THENCE ALONG LINE OF F.H.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO A POINT; THENCE CONTINUING ALONG LINE OF LAND DESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 MINUTES, 16 SECONDS EAST A DISTANCE OF 95.03 FEET TO A POINT; THENCE CONTINUING ALONG F.H.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8; THENCE ALONG SAID DIVIDING LINE AND PASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 MINUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD HAVING thereon erected a dwelling house being known and numbered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 Zucker, Goldberg & Ackennan, LLC FCP-95960 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, Plaintiff, vs. MICHAEL F. MORAN Defendant. CIVIL DIVISION NO.: 08-175 AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 500 Thomas Road, Camp Hill, PA 17011. 1. Name and Address of Owner(s) or Reputed Owner(s): MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 2. Name and Address of Defendant(s) in the Judgment: MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WASHINGTON MUTUAL BANK Plaintiff Zucker, Goldberg & Ackennan, LLC FCP-95960 r 419 4. Name and Address of the last record holder of every mortgage of record: WASHINGTON MUTUAL BANK Plaintiff COMMERCE BANK/HARRISBURG, NA 100 Senate Avenue Camp Hill, PA 17011 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 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: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 500 Thomas Road Camp Hill, PA 17011 UNKNOWN SPOUSE 500 Thomas Road Camp Hill, PA 17011 Zucker, Goldberg & Ackennan, LLC FCP-95960 r ,r PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 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 made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: April 29, 2008 BY. Scott . Dietteric , Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-95960 ca cx?° "FT _J cn w 1 r t? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, NO.: 08-175 vs. MICHAEL F. MORAN; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Michael F. Moran 500 Thomas Road Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 09/03/2008 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 500 Thomas Road, Camp Hill, PA, 17011 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 08-175 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Michael F. Moran Zucker, Goldberg & Ackerman, LLC FCP-95960 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 thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. 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. 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. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland 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 a 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 Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs 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 Cumberland County. The petition must be served on the attorney for the creditor Zucker, Goldberg & Ackerman, LLC FCP-95960 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBER & ACKERMAN, LLC Dated: April 29, 2008 BY: SCOW. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-95960 Exhibit "A" LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE 3057, ID# 47-18-1302-227, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING, AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: IN ACCORDANCE WITH THE AMENDED FINAL SUBDIVISION PLAN NO. 1 ENTITLED "FOXCROFT" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7, 1981, LAST REVISED ON JULY 17, 1984 AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "46", PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOT NO. C-9 SET AT THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8 WHERE SAID DIVIDING LINE INTERSECTS WITH LINE OF LAND DESIGNATED AS F.H.O.A. #2; THENCE ALONG LINE OF F.H.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO A POINT; THENCE CONTINUING ALONG LINE OF LAND DESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 MINUTES, 16 SECONDS EAST A DISTANCE OF 95.03 FEET TO A POINT; THENCE CONTINUING ALONG F.H.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8; THENCE ALONG SAID DIVIDING LINE AND PASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 MINUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dwelling house being known and numbered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 Zucker, Goldberg & Ackerman, LLC FCP-95960 Mca C5 -J cn to WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-175 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, (Plaintiff (s) From MICHAEL F. MORAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $81,611.86 L.L.$ 0.50 Interest from 4/08/08 to date of sale - $4,139.36 Atty's Comm % Due Prothy $2.00 Atty Paid $161.40 Other Costs Plaintiff Paid Date: 5/07/08 Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ERIC SANTOS, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 301 MOUNTAINSIDE, NJ 07092 Attorney for: Telephone: 908-233-8500 Supreme Court ID No. 201493 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, NO.: 08-175 VS. MICHAEL F. MORAN; Sheriff Sale #: TYPE OF PLEADING Defendants. Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST CODE: FILED ON BEHALF OF: Washington Mutual Bank COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Richard P. Haber, Esquire- PA I.D. #202567 Eric Santos, Esquire- PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office(cr,zucker olg dber .com File No.: FCP- 95960/ml IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, : NO.: 08-175 vs. MICHAEL F. MORAN Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Marie Lindner, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Washington Mutual Bank, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Michael F. Moran, is the record owner of the real property. 2. On or about 5/9/08, Michael F. Moran was served with Plaintiff's Notice of Sheriff s Sale of Real Property Pursuant to Pa. R.C.P. 3129, via certified mail at the address of the mortgaged premises, being 500 Thomas Road, Camp Hill PA 17011. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about 7/22/08, Plaintiff s counsel served all other parties in interest with Plaintiff s Notice of Sheriff s Sale according to Plaintiffs Affidavit Pursuant to rule 3129. 1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of Zucker, Goldberg & Ackerman, LLC FCP-95960 said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: August 14, 2008 MARIE LINDNER Paralegal Sworn to and subscribed before me this 14th day of August, 2008 Notary Public MY COMMISSION EXPIRES: SARAH J. SPOTWOOD A NOTARY PUBLIC OF NEW JERSEY My Commission Expires 7/19/2009 Zucker, Goldberg & Ackerman, LLC FCP-95960 EXHIBIT A Zucker, Goldberg & Ackerman, LLC FCP-95960 USPS - Track & Confirm tll4ttTSTATES POSIA 5?RVXE-a Track & Confirm Search Results Label/Receipt Number: 7160 3901 9845 5315 5732 Status: Delivered Your item was delivered at 11:29 am on May 09, 2008 in CAMP HILL, PA 17011. A proof of delivery record may be available through your local Post Office for a fee. Additional information for this item is stored in files offline. I Rroae (Jive +PIS> )Ratlmv i'? tf?PBtt Noe > Page 1 of 1 Home I Help Track. & Confi_rrn Truk i!,#t Cotlm Enter Label/Receipt Number. -- Site_map. Gontact..U.s. Forms Cav..t_Seryices Joks PpvaCy Policy T.ecros of Ilse National,. .& Copyright©1999-2007 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA http://trkcnfrm 1.smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do 8/14/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, Plaintiff, vs. MICHAEL F. MORAN; Defendant. CIVIL DIVISION : NO.: 08-175 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Michael F. Moran 500 Thomas Road "HWHREft Camp Hill, PA 17011 7160 3901 9845 5315 5732 TAKE NOTICE: ? . That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 09/03/2008 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 500 Thomas Road, Camp Hill, PA, 17011 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 08-175 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Michael F. Moran Zucker, Goldberg & Ackerman, LLC FCP-95%0 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 thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. 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. 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 Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland 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 a 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 Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs 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 Cumberland County. The petition must be served on the attorney for the creditor Zucker, Goldberg & Ackerman, LLC FCP-95960 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBER & ACKERI LLC Dated: April 29, 2008 BY: " Scot . Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-95960 Exhibit "A" LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE 3057, ID# 47-18-1302-227, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING, AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: IN ACCORDANCE WITH THE AMENDED FINAL SUBDIVISION PLAN NO. 1 ENTITLED "FOXCROFT" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7, 1981, LAST REVISED ON JULY 17, 1984 AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "46", PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOT NO. C-9 SET AT THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8 WHERE SAID DIVIDING LINE INTERSECTS WITH LINE OF LAND DESIGNATED AS F.H.O.A. #2; THENCE ALONG LINE OF F.H.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO A POINT; THENCE CONTINUING ALONG LINE OF LAND DESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 MINUTES, 16 SECONDS EAST A DISTANCE OF 95.03 FEET TO A POINT; THENCE CONTINUING ALONG F.H.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8; THENCE ALONG SAID DIVIDING LINE AND PASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 MINUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dwelling house being known and numbered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 Zucker, Goldberg & Ackennan, LLC FCP-95960 EXHIBIT B Zucker, Goldberg & Ackerman, LLC FCP-95960 0 UNITEDSTATES 'POSTAL SERVICES Thus Certificate of Mailing pmvides cvidmce that mail has been presemed to USPS® for mailing. lb and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Certificate Of O ?ttto ?ataar • ? ® MrNEY BOVYES 02 1M $ 0'1,100 0004253133 JUL22 2008 MAILED FROM ZIPCODE 07092 FCP-95960/pn To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover-Street PO Box 320 Carlisle, PA 17013 PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITEDS /ATES POSTAL SERVIC This Certificate of Mailing provides evKkwe that mail has been presented to USPS® for mailing. This and international mail. From` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Postmark Here ? 1 1 JUL 2 2 20b y6OS?? 4 7 ®O? P"EV BOWES 02 1M $ 01,100 0004253133 JUL22 2008 MAILED FROM ZIP CODE 07092 FCP-95960/pn TO: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Here Dept. 280601 Harrisburg, PA 17128-0601 PS Form 3817, April 2007 PSN 7530-02-000-9065 Certificate Of Mailing JUL 2 2 2008 UNITEDSTATES POSTAL SERVICES This C i icate of Mailing provides evidence that mail has been Puemed to USM for ms and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Certificate Of M.Aina e 49 P err ter. ( 11 d r. 71 -M-L. R4 ® WMEY BOYVFS • 02 --M $ 41.100 0004253133 JUL 22 2008 MAILED FROM ZIP CODE 07092 FCP-95960/pn To: Commerce Bank/Harrisburg, NA Postmark Here 100 Senate Avenue Camp Hill, PA 17011 JUL 2 2 20 PS Fonn 3817, April 2007 PSN 7530-02-000-9065 UNITEDSTATES POSTAL SERVICE, Tllis Certificate of Mailing provides evidence that mail has been preseme+d to USPS® for a and international mail From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LL 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Certificate Of Mailing - • ? ? PfrNEY BUVYES 02 1M $01,10d 0004253133 JUL 22 2008 • MAILED FROM ZIPCODE 07092 FCP-95960/pn TO: CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 JUL 2 2 2006 PS Fonn 3817, April 2007 PSN 7530-02-000-9065 IJMITEE?!'STATES PQST,dI SERVICE This Certificate of Mailing provides evidence that mail has been presented to USPS® f and international maiL Prom' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, L 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Certificate Of Mailiina 9SPQ ?4 at. Z 7 ®Prtner Bow?S 02 1M $ 01.100 0004253133 JUL22 2008 MAILED FROM ZIP CODE 07092 FCP-95960/pn T°` UNKNOWN TENANT OR TENANTS Postmark Here 500 Thomas Road Camp Hill, PA 17011 PS Form 3817, April 2007 PSN 7530-02-000-9065 UNIT1ED,STATES V..?'POSTX SERVICEa This Certificate of Mailing provides evidence that mail has been presented to USPS® and international mail. Front. Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, I 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 Certificate Of Mailing JUL 22 2MB 5')s fir , "? a 7 ® PIMEV BOWES 02 1M $ 01.100 OD04253133 JUL22 2008 MAILED FROM ZIPCODE 07092 FCP-95960/pn T°: UNKNOWN SPOUSE Postmark Here 500 Thomas Road Camp Hill, PA 17011 1y?yS FIELy q PS Form 3817, April 2007 PSN 7530-02-000-9065 JUL 2 2 2008 UNI TED STATES Certificate Of i `TALSERVICE Mailing To fee, _aa? ? rey This Ccn&=e of Maliog pmvidm evidence that mail has been Resented to USPS® for mailing. This form maybe used for domestic v ?V v and international mail. From: Scott A. Dietterick, Esquire JUL 2 2 20? c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 . t? Mountainside, NJ 07092 ran ncncn.i-_._ To* COMMONWEALTH OF PENNSYLVANIA. DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 o _ 4 ? aZA .? 02 1M $01-10 0 0004253133 JUL22 2008 MAILED FROM ZIPCODE 07092 PS Fort 3817, April 2007 PSN 7530-02-000-9065 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, NO.: 08-175 VS. MICHAEL F. MORAN; Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C P 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 UNKNOWN SPOUSE 500 Thomas Road Camp Hill, PA 17011 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 UNKNOWN TENANT OR TENANTS 500 Thomas Road Camp Hill, PA 17011 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 COMMERCE BANK/HARRISBURG, NA 100 Senate Avenue Camp Hill, PA 17011 Zucker, Goldberg & Ackerman, LLC FCP-95960 95960D1004CO7222008P1 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the CUMBERLAND COUNTY COURTHOUSE Carlisle, Pennsylvania 17013-3387 On 09/03/2008 at 10:00am, the following described real estate which Michael F. Moran are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of 500 Thomas Road, Camp Hill, PA 17011 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). Zucker, Goldberg & Ackerman, LLC FCP-95960 95960D1004C07222008P2 The said Writ of Execution has been issued on a judgment in the action of Washington Mutual Bank Plaintiff vs. Michael F. Moran, et al Defendant(s) at EX. NO. 08-175 in the amount of $81611.86 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. ZUCK ER G OLDB ERG & ACK ERMAN LLC Dated: July 22, 2008 BY- Scott A. Dietterick, Esquire; PA I.D. 455650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Richard P. Haber, Esquire; PA I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-95960 95960D1004CO7222008P3 Exhibit "A" LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE 3057, ID# 47-18-1302-227, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING, AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: IN ACCORDANCE WITH THE AMENDED FINAL SUBDIVISION PLAN NO. 1 ENTITLED "FOXCROFT" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7, 1981, LAST REVISED ON JULY 17, 1984 AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "46", PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOT NO. C-9 SET AT THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8 WHERE SAID DIVIDING LINE INTERSECTS WITH LINE OF LAND DESIGNATED AS F.H.O.A. #2; THENCE ALONG LINE OF F.H.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO A POINT; THENCE CONTINUING ALONG LINE OF LAND DESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 MINUTES, 16 SECONDS EAST A DISTANCE OF 95.03 FEET TO A POINT; THENCE CONTINUING ALONG F.H.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8; THENCE ALONG SAID DIVIDING LINE AND PASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 MINUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dwelling house being known and numbered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 Zucker, Goldberg & Ackerman, LLC FCP-95960 ?a S ?? fll rrI Tr, SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-00175 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN JAMES CORNETT III VS AQUILLA BLANK ET AL BRIAN CRAMER , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: KING ISAAC IND. but was unable to locate Him in his bailiwick. He therefore returns the WRIT TO JOIN ADDTL DEF , NOT FOUND , as to the within named DEFENDANT , KING ISAAC IND. 12552 MUNGOL HILL RD SHIPPENSBURG, PA 17257 HASENT BENN WITH BUISNESS FOR 10-15 YEARS DOES NOT LIVE AT SAID ADDRESS Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 BRIAN CRAMER Surcharge .00 DANE M ANTHONY, Sheriff .00 .00 ALBERT H HAJJAR ESQ 08/21/2008 Sworn and subscribed to before me this /-4?k day of Dr- A. D. Notary Washington Mutual Bank VS Michael F. Moran In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2008-175 Civil Term Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2008 at 1115 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Michael F. Moran, by making known unto Michael Moran personally, at 500 Thomas Road, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copies of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 16, 2008 at 1927 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of 500 Thomas Road, Camp Hill located at 500 Thomas Road, Camp Hill, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Michael F. Moran by regular mail to his last known address of 500 Thomas Road, Camp Hill, PA 17011. This letter was mailed under the date of July 14, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Santos. Sheriff s Costs: Docketing 30.00 Poundage 21.99 Posting Handbills 15.00 Advertising 15.00 Auctioneer Law Library .50 Prothonotary 2.00 Milage 30.00 Levy 15.00 Surcharge 20.00 Postpone Sale 20.00 Law Journal 443.00 Patriot News 491.48 Share of Bills 17.64 $1,121.61 ? So Answers: R. Thomas Kline, S enff BY UC(,t,l.pt a Cpl 7-- a Rem] EAMe-?? c? G ? a 58 ass ??? 4 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, Plaintiff, vs. MICHAEL F. MORAN CIVIL DIVISION NO.: 08-175 Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 500 Thomas Road, Camp Hill, PA 17011. 1. Name and Address of Owner(s) or Reputed Owner(s): MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 2. Name and Address of Defendant(s) in the Judgment: MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WASHINGTON MUTUAL BANK Plaintiff Zucker, Goldberg & Ackennan, LLC FCP-95960 ! . 4. Name and Address of the last record holder of every mortgage of record: WASHINGTON MUTUAL BANK Plaintiff COMMERCE BANK/HARRISBURG, NA 100 Senate Avenue Camp Hill, PA 17011 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 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: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 500 Thomas Road Camp Hill, PA 17011 UNKNOWN SPOUSE 500 Thomas Road Camp Hill, PA 17011 Zucker, Goldberg & Ackerman, LLC FCP-95960 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 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 made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: April 29, 2008 BY: Scott . Dietteric , Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-95960 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, CIVIL DIVISION Plaintiff, : NO.: 08-175 VS. MICHAEL F. MORAN; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Michael F. Moran 500 Thomas Road Camp Hill, PA 17011 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 09/03/2008 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description 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 LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 500 Thomas Road, Camp Hill, PA, 17011 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 08-175 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Michael F. Moran Zucker, Goldberg & Ackerman, LLC FCP-95960 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 thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. 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. 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. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland 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 a 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 Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs 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 Cumberland County. The petition must be served on the attorney for the creditor Zucker, Goldberg & Ackerman, LLC FCP-95960 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBER & ACKERMAN, LLC Dated: April 29, 2008 BY' Scot . Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Richard P. Haber, Esquire; PA.I.D. #202567 Eric Santos, Esquire; PA I.D. #201493 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: FCP-95960 (908) 233-8500; (908) 233-1390 FAX VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC FCP-95960 IV Exhibit "A" LEGAL DESCRIPTION ALL THAT PARCEL OF LAND IN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, AS MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE 3057, ID# 47-18-1302-227, BEING KNOWN AND DESIGNATED AS ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING, AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: IN ACCORDANCE WITH THE AMENDED FINAL SUBDIVISION PLAN NO. 1 ENTITLED "FOXCROFT" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7, 1981, LAST REVISED ON JULY 17, 1984 AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK "46", PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOT NO. C-9 SET AT THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8 WHERE SAID DIVIDING LINE INTERSECTS WITH LINE OF LAND DESIGNATED AS F.H.O.A. #2; THENCE ALONG LINE OF F.H.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO A POINT; THENCE CONTINUING ALONG LINE OF LAND DESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 MINUTES, 16 SECONDS EAST A DISTANCE OF 95.03 FEET TO A POINT; THENCE CONTINUING ALONG F.H.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINE BETWEEN LOTS NOS. C-9 AND C-8; THENCE ALONG SAID DIVIDING LINE AND PASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 MINUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dwelling house being known and numbered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 Zucker, Goldberg & Ackerman, LLC FCP-95960 WRIT OF EXECUTION and/or ATTACHMENT CQMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-175 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, Plaintiff (s) From MICHAEL F. MORAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $81,611.86 Interest from 4/08/08 to date of sale - $4,139.36 Atty's Comm % Atty Paid $161.40 Plaintiff Paid Date: 5/07/08 (Seal) REQUESTING PARTY: Name: ERIC SANTOS, ESQUIRE L.L.$ 0.50 Due Prothy $2.00 Other Costs Prothono By: Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 301 MOUNTAINSIDE, NJ 07092 Attorney for: Telephone: 908-233-8500 Deputy Supreme Court ID No. 201493 Real Estate Sale #42 On May 20, 2008 the Sheriff levied upon the defendant's interest in the real property situated in W"mI s g-Bc &, Cumberland qty, PA Known and numbered as 500 Thomas Road, Camp Hill more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 20;;WO t By: Real Es a Sergeant The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE 14t Patriot-dews Now you know CARLISLE PA 17013 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/23/08 Sworn to and .. ...................... ! )re me this 20 ay st 2008 A.D. r Notary Public 07/30/08 08/06/08 CO O MYLVAK 310* L Kbrw, N *Ny pt#* Qyor Ha*am em? 'Aus + p M - 80 Nov 1 +odwm a Noq Real ESWD Sob No. 42 Writ No. 2006.175 Clvll Tenn Whaldn" Mutu d Bank VS Mk*wW F. Moran Attorney Eric Santos LEGAL DESCROMON ALLTHAT PARCEL OF LANDIN BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, STATE OF PENNSYLVANIA, As MORE FULLY DESCRIBED IN DEED BOOK 248, PAGE3057, ID# 47-I8-1302-227, BEING KNOWN ANDDESIGNATED AS .ALInIA.T CERTAIN TRACT OR PARCEL OF LANDANDPREMISES SITUATE, LYING, ANDBEING IN THE, ROAQW4. OF 1 $Y3 __. IN TfS CO[Xff OF 0116 i11LAW OF M110LYMA, MORE PA15XV .AILY DESCRIBED AS FOLLOWS: IN ACCORDANCE.WTTH THE AMENDED FINAL SUBDIVISION PLANNO. 1 ENTITLED "FOXCROFl" PREPARED BY MICHAEL C. D'ANGELO, R.S., DATED AUGUST 7,1981, LAST REVISED ON JULY 17, 1984 ANDRECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN ANDFOR CUMBERLAND COUNTY, PENNSYLVANIA, IN PLANBOOK "46" PAGE 110, AS FOLLOWS: BEGINNING AT A POINT AT THE NORTHWESTERN CORNER OF LOTNO. C- 9 SET AT THE DIVIDING LINEBETWEEN LOTS NOS. C-9 ANDC-8 WHERE SAID DIVIDING LINF.INTERSECTS WITH LINEOF LANDDESIGNATED AS F.H.O.A. #2; THENCE ALONG LINEOF FH.O.A. #2, NORTH 61 DEGREES, 49 MINUTES, 47 SECONDS EAST, A DISTANCE OF 60.26 FEET TO APOINT, THENCE CONTINUING ALONG LINEOF LANDDESIGNATED AS F.H.O.A. #2, SOUTH 09 DEGREES, 26 WNUI'ES,16 SECONDS EASTA DISTANCE OF 95.03 FEET TO A POINT, THENCE CONTINUING ALONG FE.O.A. #2, SOUTH 61 DEGREES, 49 MINUTES, 47 SECONDS WEST, A DISTANCE OF 29.74 FEET TO THE DIVIDING LINEBETWEEN LOTS NOS. C-9 ANDC-8; THENCE ALONG SAID DIVIDING LINEANDPASSING THROUGH A PARTITION WALL, NORTH 28 DEGREES, 10 VIlNUTES, 13 SECONDS WEST, A DISTANCE OF 90 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTNO, C-9 ON THE ABOVE PLANALSO BEING KNOWN ANDNUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dweftg house being known and numbered as 500 Thomas Road, Camp HK PA17011. BEING the same premises which Madellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter aWa Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2,2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto Michael F. Moran. Tax Map No.: 47-18-1302-227 s ?.he Patriot-Mm Now you know P. O. BOX 2265 HARRISBURG, PA 17105 (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL 07/23/08 07/30/08 08/06/08 Of Ad Sheriff Sale 42 11.13 $14.57 $ 162.16 Sheriff Sale 42 11.13 $14.57 $ 162.16 Sheriff Sale 42 11.13 $14.57 $ 162.16 Notary Fee I I I I I 1 1 $5.00 TOTAL DUE FOR THIS SALE: $ 491.48 JLC PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : 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 18, July 25, and August 1, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ?Xsa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 1 day of August, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28. 2010 REAL ESTATE SALE NO. 42 Writ No. 2008-175 Civil Washington Mutual Bank VS. Michael F. Moran Atty.: Eric Santos Exhibit "A" LEGAL DESCRIPTION ALL that parcel of land in Borough of Wormleysburg, Cumberland Coun- ty, State of Pennsylvania, as more fully described in Deed Book 248, Page 3057, ID# 47-18-1302-227, be- ing known and designated as all that certain tract or parcel of land and premises situate, lying, and being in the Borough of Wormlevsburg in the County of Cumberland and Com- monwealth of Pennsylvania, more particularly described as follows: in accordance with the amended final Subdivision Plan No. 1 entitled "Foxcroft" prepared by Michael C. D'Angelo, R. S., dated August 7, 1981, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book "46", Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. C-9 set at the dividing line between Lots Nos. C-9 and C-8 where said divid- ing line intersects with line of land designated as F.H.O.A. #2; thence along line of F.H.O.A. #2, North 61 degrees, 49 minutes, 47 seconds East, a distance of 60.26 feet to a point; thence continuing along line of land designated as F.H.O.A. #2, South 09 degrees, 26 minutes, 16 seconds East a distance of 95.03 feet to a point; thence continuing along F.H.O.A. #2, South 61 degrees, 49 minutes, 47 seconds West, a distance of 29.74 feet to the dividing line be- tween Lots Nos. C-9 and C-8; thence along said dividing line and passing through a partition wall, North 28 degrees, 10 minutes, 13 seconds West, a distance of 90 feet to a point, the place of beginning. BEING LOT NO. C-9 ON THE ABOVE PLAN; ALSO BEING KNOWN AND NUMBERED AS 500 THOMAS ROAD. HAVING thereon erected a dwell- ing house being known and num- bered as 500 Thomas Road, Camp Hill, PA, 17011. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter a/k/a Jane B. Carpenter, Late, by Deed dated September 20, 2001 and recorded October 2, 2001 in and for Cumberland County, Pennsylvania, in Deed Book Volume 248, Page 3057, granted and conveyed unto AN-1-1 Ti lVTnrnn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Washington Mutual Bank, Plaintiff, VS. Michael F. Moran Defendant. CIVIL DIVISION NO.: 08-175 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment filed at the above-captioned term and number satisfied without prejudice. Respectfully submitted: ZUCKER, GOL RG & ACKERMAN, LLC BY: "'7 , y Dated: August 11, 2009 Scott A. ietterick, Esqu• e A I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Eric Santos, Esquire; PA I.D. #201493 Joel A. Ackerman, Esquire; PA I.D. #202729 Attorneys for Plaintiff FCP-95960/ka 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC FCP-95960 OF tt ?n? orARv W MJG 14 PH 1 g2 PSYI