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Home My WebLink About04-0120FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WASHINGTON MUTUAL BANK, F.A. 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 v. Plaintiff JOHN G.FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 BETH A.FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION TERM No.Oy-IaDC~,v~ ~ CUMBERLAND COUNTY Defendant(s) CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the court without further nofice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIltE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 File #: 85730 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. File #: 85730 Plaintiff is WASHINGTON MUTUAL BANK, F.A. 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 2. The name(s) and last known address(es) of the Defendant(s) are: JOHN G. FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 BETH A.FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/12/2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1735, Page 4122. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and al] interest due thereon are collectible forthwith. File #: 85730 6. The following amounts aze due on the mortgage: Principal Balance $79,343.67 Interest 2,847.71 06/O1/2003through 01/09/2004 (Per Diem $12.77) Attorney's Fees 1,250.00 Cumulative Late Charges 95.84 10/12/2001 to 01/09/2004 Cost of Suit and Title Search 550,00 Subtotal $ 84,087,22 Escrow Credit 0.00 Deficit 696.80 Subtotal 696.80 TOTAL $ 84,784.02 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 84,784.02, together with interest from 01/09/2004 at the rate of $12.77 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDE~ AND PHELAN, LLP ~~/'i'~/~`.(/J ~' 1~--- By: /s rands S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 85730 ALL THAT CERTAIN lot of land atad the improvements situated and erected thereon, situate at 56 Broad Stttxt, Borough of Newville, Cumberland County, Pennsylvania, more particulazly bounded and described as follows: ON THE SOLI by said Broad Street; an the West by property now or formerly of _. Clair Sollenbe:rger, on the North by an alley; and on the East by property now or formerly of Glenn Moha - HAVING a frontage on said Broad Street of Sixty (60) feet and extending in defah at an even width One Hundred Highly (180) feet to said alley on the Noctlt. BEIK'G improved with a two aad one-half story brick dwelling house and outer improvements. BEING iho same premises which Lois M. Mitten, Executor of the Last 'Will and Testament oflsabcl L. McElbaney, by her Deed dated May 15, 1992 and recorded PREMISES BEINGS 56 BROAD STREET VERIFICATION FRANCES S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 (c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure aze based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifications to authorities. /~~"'~ n Francis S. Hallman, Esquire Attorney for Plaintiff DATE: , h (b '`~ v ~ .. .' ~ J ' +~ t C„ '-1 ~ ~ ~_; ~~ i ~~ ~ ~ ?; ~ p W -, s- ~ ~; C~ ~ O W ~1 3 SHERIFF'S RETURN - REGULAR CASE N0: 2004-00120 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS FETTERHOFF JOHN G ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FETTERHOFF JOHN G the DEFENDANT at 1721:00 HOURS, on the 16th day of January 2004 at 56 BROAD STREET NEWVILLE, PA 17241 by handing to JOHN FETTERHOFF 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 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this ,~02 nom- day of ~~2 tiu.... ~ ~ Pty ~( A . D . / Prothonotary So Answers ~ .~ R. Thomas Kline 01/20/2004 FEDERMAN & PHELAN By ~ ~` I,~.--, Dep y Sheriff SHERIFF'S RETURN - REGULAR CASE N0: 2004-00120 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS FETTERHOFF JOHN G ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FETTERHOFF BETH A the DEFENDANT at 1721:00 HOURS, on the 16th day of January 2004 at 56 BROAD STREET NEWVILLE, PA 17241 by handing to JOHN FETTERHOFF, ADULT IN CHARGE 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this .72n„cl day of '1 L /. , ~ 7'12c211i~. ~~r~G` ~ rothonotary So Answers: ,w .~ ~'" R. Thomas Kline 01/20/2004 FEDERMAN & PHELAN By . ~~ ~eputy Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WASHINGTON MUTUAL BANK, F.A. 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. JOHN G.FETTERHOFF BETH A. FETTERHOFF Defendant(s). CIVIL DIVISION NO. 2004-00120 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against JOHN G. FETTERHOFF and BETH A. FETTERHOFF, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/9/04 to 3/3/04 TOTAL $84,784.02 $702.35 $85,486.37 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~,/l~YM ~a~L-t2n.e..~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ ~~ _ s, .~.c~vy ~~~--~, ~ - ~ PRO PROTHY FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 ~~ls~ s63-7nno WASHINGTON MUTUAL BANK, F.A. Plaintiff Vs. JOHN G. FETTERHOFF BETH A. FETTERHOFF Defendants TO: JOHN G. FETTERHOFF 56 BROAD STREET NEWVILLE,PA 17241 DATE OF NOTICE: FERRIIARY 6, 2004 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION CUMBERLAND COUNTY NO. 2004-00120 FItE COSY THIS FIltM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A 7UDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ, Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS 5. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (915) Sfi9-7000 WASHINGTON MUTUAL BANK, F.A. Plaintiff Vs. JOHN G. FETTERHOFF SETH A. FETTERHOFF Defendants TO: BETH A. FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 DATE OF NOTICE: FERRIiARY 6, 2004 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION CUMBERLAND COUNTY NO. 2004-00120 THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVH)E YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plainril SHERIFF'S RETURN - REGULAR ,.CASE NO: 2004-00120 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS FETTERHOFF JOHN G ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FETTERHOFF JOHN G the DEFENDANT at 1721:00 HOURS, on the 16th day of January 2004 at 56 BROAD STREET NEWVILLE, PA 17241 by handing to JOHN FETTERHOFF 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: So Answers: Docketing 18.00 ,,,, Service 8 . 28 :~`! Affidavit . 0 0 ~ ~ ~""""'~" Surcharge 10.00 R. Thomas Kline .00 36.28 01/20/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: J /'jam me this day of /Dept' y Sheriff A.D. Prothonotary FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. 11200 WE5T PARKLAND AVENUE Plaintiff, v. JOHN G. FETTERHOFF BETH A. FETTERHOFF Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.2004-00120 VERIFICATION OFNON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JOHN G. FETTERHOFF is over 18 years of age and resides at , 56 BROAD STREET, NEWVILLE, PA 17241 . (c) that defendant BETH A. FETTERHOFF is over 18 years of age, and resides at , 56 BROAD STREET, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL TIIAT CERTAIN lot of land and the improvements situated and erected thereon, situate as S6 Broad StrCCt, Borough of Newville, t~raberlan! County, Pennsylvania, mare particularly bounded wind described as (allows: ON THE SOUTH by said Broad Streit; as the West by property mw m fannerly of Clair Sollemherger, an the North by an alley; and on the Fast by property now w formerly of Ciitno Mohn. HAVING a frontage on said Brno Street of sixty (tS0) feet and extendh»g iu de{rth at as eves width sae bandied eighty (180} fed to said alley as bse Natdt. BEING improved with a two anus one-half stray brick dwelling house and other improvements, T[Tt,E 1'f} 3AID PRIMISfiS iS YES7'EU IN John G. Fettcrhoff and Beth A. Fetterhoff, his wife by Deed flnm Harold D. Saylor sad Tenna K. Sayler, his wife, dared 10(12(2041 and recorded 14f16/2401 in Record Back 248, .Page 3g2A. PROPERTY ADDRESS: 56 BROAD STREET, NEWVILLE, PA 17241 TAX PARCEL: # 28-21-0361-040 (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW WASHINGTON MUTUAL BANK, F.A. 11200 WEST PARKLAND AVENUE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. JOIIN G.FETTERHOFF BETH A.FETTERHOFF Defendant(s). CIVIL DIVISION NO. 2004-00120 Notice is given that a Judgment in the above-captioned matter has been entered against you on ~/ n~~s' 200/. DEPUTY L If you have any questions concerning this matter, please contact: 3 ~, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHII.ADELPHIA, PA 19103-1814 (215)563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** O N ~_ ~ ~ ~ ~ ~ b ~ ~ ~' W .~ c ~ -:,~~~ w f v -;, ~, v, ~ , ~ ~ t~ v /~ .. ~ i \ - FEDERMAN aad PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 WASHINGTON MUTUAL BANK, F.A. Plaintiff, v. JOHN G.FETTERHOFF BETH A. FETTERHOFF Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2004-00120 CERTIFICATION FRANK FEDE1tMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage O non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERIVIAN, ESQUIRE Attorney for Plaintiff n ~ ~~ -„ ... =*`- . f.~ t ~~ ~~ ~' ~ ~~ .` ) ~l •. ^~i ~~ ~::~ Mi PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WASHINGTON Mi1TUAL BANI{, F.A. Plaintiff, v. No. 2004-00120 JOHN G.FETTERHOFF BETH A. FETTERHOFF Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $85,486.37 Interest from 3/3/04 to JUNE 9, 2004 $1,376.90 and Costs (per diem -$14.05) TOTAL $86,863.27 ~./uir,,~2 FRANK FEDERMAN, ESQUIItE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description ofproperty.No. Q O~ a~ a~ zz z ~a OH ~z 00 as U H ~ ~~ U ~ N t'-~=' ' 7 ~,y,.:-: r f V h- i. ,o ,, _ ~._. ~ c. .n C~ ~~ ~ J , ~y !w r ~~ + CJ N d w 0 mod' ~a~ H H ~~ c~ ~ ~W O~ O H c~ .. ~~ w= Vi w~ O ~, H ~ ~w 3 °' w~ U ~ ~ ~ \'1 v ~ ~ ~ ~ A_} ,~/ q~ C7 7C ~,, Q (''~y '~4 ~ j^ ~ - U `~MJO N/J J ~a ~° ~~ ~° ~¢ w V~ Y U `~, ~ ~ ~~ ~~ N N ~ r ., r, d' d P. 0. W W ~ a ~ ~ zz ~~ mn as ~~ '~ d b ,~ 3 _^~J\ V ~M _/ ~f t¢ <Y C-- CJ N LEGAL DESCRIPTION AI.L THAT CERTAIN !at of land and the improvements situated and erected thereon, situate as 36 Broad SttCCt, Borough of Newvitle, Cumberhind County, Permaytvania, more particularly bounded and described as follows: ON TiIE SOUTH by said Broad Street; nn the West by property trarv or formerly of Clair SoBemherger, on the Norflr by an alley; and on the Fast by property now ar formerly of Glean Mohn. HAYING a frontage on said Rraad Street of aizty (64) feet and extending in depth at as eves widdt one hundred eighty (180} feat to said alley On dte Nottt-. BEING improved with a taro and atu-half story brick dwelling house atgi other improvesneats. T[TLE 1'O SACD PREMISES TS VES7TsD IPl John G. Ferterhoff and Beta A. Pctterixiff, his wife by Deed from Harold 17. Snyder and Tenna K. Snyder, his wife, dared 14!12/2041 anti recorded 10/18/2001 io Record Soak 2d8, Page 3924. PROPERTY ADDRESS: 56 BROAD STREET, NEWVILLE, PA 17241 TAX PARCEL: # 28-21-0361-040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-120 Civil CNIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, F.A., Plaintiff (s} From JOHN G. FETTERHOFF AND BETH A. FETTERHOFF (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 gamishee(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 $85,486.37 L.L. $.50 Interest FROM 3/3/04 TO 6/9/04 (PER DIEM - $14.05) - $1,376.90 AND COSTS Atty's Comm Atty Paid $134.28 Plaintiff Paid Date: MARCH 5, 2004 (Seal) Due Prothy $1.00 Other Costs CURTIS R. LONG Prothono/t~ary G,,, ,, `BY: ~j1n~1 ~. ///~L1.rlC Deputy LC REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 - WASHINGTON MUTUAL BANK, F.A. Plaintiff, v. JOHN G.FETTERHOFF BETH A. FETTERHOFF Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.2004-00120 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) WASHINGTON MUTUAL BANK, F.A., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,56 BROAD STREET, NEWVILLE, PA 17241 . 1. Name and address of Owner(s) or reputed Owner(s): Name JOHN G.FETTERHOFF BETH A. FETTERHOFF Last Known Address (if address cannot be reasonably ascertained, please indicate) 56 BROAD STREET NEWVILLE, PA 17241 56 BROAD STREET NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 56 BROAD STREET NE W MLLE, PA 17241 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 3, 2004 ~,/Laln,~ ~~~vme..-i DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff c7 ^~ ~~ c_~ i- -ri - ~ _ ~.7 _ -1 _ (+' i' ~ `r-~ •~ ". V ~ S G• , i~' .. --, ~, _..' --I -` WASHINGTON MUTUAL BANK, F.A. Plaintiff, v. JOHN G. FETTERHOFF BETH A.FETTERHOFF Defendant(s). CUMBERLAND COUNTY No. 2004-00120 Mazch 3, 2004 TO: JOHN G. FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 BETH A. FETTERHOFF 56 BROAD STREET NEWVILLE, PA 17241 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE (N BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. Your house (real estate) at , 56 BROAD STREET, NEWVILLE, PA 17241, is scheduled to be sold at the Sheriffs Sale on JUNE 9, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $85,486.37 obtained by WASHINGTON MUTUAL BANK, F.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. L If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2151563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL TUAT CE12TA[N lot of land and thetmproremertts situated aml erected therenn, situate as 56 Broad Street, Borough of Newville, Cutaberland Cuttnty, Pennsylvania, more particularly botmded and described as follows: ON THE SOUTH by said Broad Street; on the Wcst by progterty oow or ftxmerly of Cbtir Sullen:herger, nn the North by an alley; and on the Fast by property ttow or formerly of Gier+n Mahn. IIAVING a frontage on said Rmad Street of sixty (60) feet and extending in dgyth at as eves width one hu~tdred eighty (180) feet to said alley 4s the North, BEl NG itnptnved with a two and ottC-half story brick dvvclling imuse and other isnpruveutents. TITLE 1'O SAID PREMISFS TS VE:s'['6p IN John G. Feuerhoff and Beth A. Fetterhoff, his wife by Deed from Harold D. Snyder artd Tenna K. Snyder, his wife, dated 10112/ZUDS antl recordal 1011tit2001 In Record 8nok 248, Page 3920. PROPERTY ADDRESS: 56 BROAD STREET, NEWVILLE, PA 17241 TAX PARCEL: # 28-21-0361-040 .-, ~~ ~ rn ~1 '11 } l ~ -tl ' ' ...V ~~ ( Y17 ~~: . ';fel ~ ~') 1 (_i =r, -.~~ i'. ;i rl .. ~:~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON vs. JOHN G. FETTERHOFF BETH A.FETTERHOFF BANK, F.A. ) CNIL ACTION CIVIL DIVISION NO. 2004-00120 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for WASHINGTON MUTUAL BANK, F.A. hereby verify that on March 10, 2004 true andl correct copies of the Notice of Sheriff s sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Anri130, 2004 l C .G~,Q1 t.YE~N1 FRANK FEDE,RMAN, ESQUIRE Attorney for Plaintiff b .~ c r 5 ~. ~n A ., w N O ~ 0O J ~ ~' A w N ~ H a m, ~~ y ~ a ~ z c 3 c ~° O ~ ..--77 to O O 3 ~ ~ d ~ z h~ a ~ ~~ ~, ~ I o ~ ~ ~ . A ' R~ ~ ~ r ? ~ r O O O ~ ~ ran ~ O s ' ~ A ~.a" ~ ` ~ ~ ~ t ~ N ~ ~ Y y lTj ro ~ ~ 5550 ~ C ~ ~ z : a w ti 88~~~ a ~ O ~ ^R ~ I Y J N ~. . d ~ m W~ g- p r aa.~ ~.a e v~ ~ o 'yLn r ~ ^ r °°'~°d 3 R] ro C R Q~ ga ~~R^c O v' "~ °n"ga N o ~' ~ c a ~ h7 ^ ~ °~ ~ o .. n ~ x ~ ~~A a ~ C" c'3~8 h7 _~°n °a~~ a o ~. c Sm ~'"' '--' J w 9 ~ ° 6 m ~ _ ~ ° =9g _ =a - _. ~ _. ~ ~ d ~. ~ P y pS ~T4 ~ A~~ n .~, o Cm ~.• >~ ~ Oy "' 3 o a u~ ~ . ~. ~NI~ 8 ~ 0~~.41Q~~ ~' ]~ ~ 9 . . al; MAi( t , g . D FROAii Z,; d_ ~ 9 ~ ~ N.9 P_ C d ^ o~z »,aw ag A A a~7 =' a 7~~m rn d G. ~ .,y tr1 ~~~~ ro Y ~ :° m rn °~cx w_ ~ p~~ A .p ~i (/~ " A a~.r ~ ~ ~ ro A ~ 'O O y O /~°~ ~/ ti~ 6- INi:V 89 yyF5 d~.9O~ A~?p ?nn~ :ODE 1g?03 1 () o ~7 La ~_ O r 'ii~~ ?;t~; S ~i i r; _ ~ =<c, _. ~ ~ a Q ry ._; ~ ~ ::may'-; y ..,,. ~C or~i ~ c a . Washington Mutual Bank, F.A. VS John G. Fetterhoff and Beth A. Fetterhoff In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-120 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Frank Federman. Sheriff's Costs Docketing Poundage Posting Handbills Advertising Mileage Levy Surchazge Law Journal Patriot News Share of Bills Law Library Prothonotary 30.00 11.50 15.00 15.00 17.56 15.00 30.00 209.60 213.28 29.26 .50 1.00 $587.70 paid by attorney 06/07/04 Sworn and subscribed to before me This /ofP day of~~,,,,~, 2004, A.D. ~ ~ a . n h l c¢Qc... ~y, Prothonotary S~ s e%i~ R. Thomas Kline, Sheriff BYE le Real Es a Deputy ~~sv ~ yLoS-p 4~..., l5 2 ~° Real Estate Sale #63 On March 09, 2004 the sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA Known and numbered as 56 Broad Street, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 09, 2004 BY:~J~ :!4'i-~.1.'~'1 Real Estatd'Deputy i;a ~~~. 1; C, u;tti !, i `- ~. ~ ~dck.IR_ .....,_ y ._~. ~~~ ~C~' ,~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael 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 Tag 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 27th day(s) of April and the 4th and 11th day(s) of May 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are 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 Dau hin i iscellaneous Book "M", Volume 14, Page 317. PUBLICATION .........................~ ........ ....................................................... COPY SALE#63 . q '`~ w d, ~, .k, ~ r „ ~i~~i w 5 > .. , t +' . x ~r. . s ,> ~~-,~;.4~~.~a. ., . Sworn to and subscribed efore i 2828fth day o a 04 A.D. NOTARIAL SEAL ~i `~/ ~~'~ Terry L Russell, Notary Public NOTARY PUBLIC qty of Harrisburg, Dauphin County commission ex Tres June 6, 2006 MY ~anmisslon Fxplres June 6, 200 P Member,P~nn~~Iv~NBERLANDCOU,fNNSHERIFFSOFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 213.28 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have By .................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyue, 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 regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chazacter of publication are true. REAL E8TATE BALE NO. 89 Wrtt No. 2004-120 Civll Washington Mutual Bank, F.A. vs. John G. Fetterhoff and Beth A Fetterhoff qtly.: F7enk Federman LEGAL DESCRIPTION ALL THAT CERTAIN lot of land and the improvements eftuated and erected thereon, situate as 56 Broad Street. Borough of Newville, Cumber- land County, Pennsylvania, more particularly bounded and described as follows: ON THE SOUTH by said Broad Street; on the West by property now or formerly of Clair Sollemberger, on the North by an alley; and on the East by property now or formerly of Glenn Mohn. HAVING a frontage on said Broad Street of sixty (60) feet and extend- ing in depth at an even width one ~- 'sa Mane Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004 TUnta~r NOTARIAL SEAL LOTS E. SNYDER, Notary Public Cadisle Boro, Cumbedand County My Commission Expires March 5, 2005 I i i ~~ ALL ltu.i ..,~_-- and the improvements situated and erected thereon. situate as 56 Broad Street, Burough of Newville, Cumber- land County, Pennsylvania, more particulaz]y bounded and described as follows: ON THE SOUTH by said Broad Street; on the West by property now or formerly of Clair Soliemberger, on the North by an alleys and on the East by property now or formerly of Glenn Mohn. HAVING a frontage on said Broad Street of sixty (60) feet and extend- Sng in depth at an even width one hundred eighty (1SOi feet to said alley on the North. BEING improved with a two and one-half story brick dwelling house and other improvements. TITLE TO SAID PREMISES IS VESTED IN John G. Fetterhoff and Beth A. Fetterhoff, his wife, by Deed from Harold D. Snyder and Tenna K. Snyder, his wife, dated 10/12/ 2007 and recorded 10/16/2001 in Record Book 248, Page 3920. PROPERTY ADDRESS: 56 BROAD STREET, NEWVILLE, PA 17241. TAX PARCEL: ft 26-21-0361-040. r`7 Nntaryry Q N07'ARIAL SEAL LOTS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2045 PHELAN HALLINAN £~ SCHMIEG, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id No. One Penn Center at Suburban Station 1617 john F. Kennedy Boulevard, Suite 1400 Philadelphia,, PA 19103-1814 X215)563-7000 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, F.A. Plaintiff vs John G. Fetterhoff Beth A. Fetterhoff ~ Court of Common Pleas I Civil Division Cumberland County No. 2004-00120 PHS# 85730 Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the above referenced case Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. Please mark Judgments satisfied and the Action settled, discontinued and ended. X Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. i Date: Ma 2 2007 ~`-' ~ ~-X..-~' ~ _. Francis Hallinan Attorney for Plaintiff -ra C~ 'O ~' ~ d `~ J ~O ~ ~ o ~ W ~ ~' -~- `,~; ° :- ~~-~ ~:. ~. ~~ ~ ~ -~ ~]