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Home My WebLink About04-0282MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOT1FICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : ACTION OF MORTGAGE FORECLOSURE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., herein after referred to as MERS, is the owner of legal title to the Mortgage subject to the Mortgage to this action and nominee for Washington Mutual Bank, FA, which is the owner of the entire beneficial interest in the Mortgage, with an address of P.O. Box 1169, Milwaukee, Wisconsin 53224. Defendant, MARY E. FEDORKO, is an adult individual, whose last known address is 246 INDIAN CREEK DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. Defendant, LAWRENCE J. FEDORKO, is an adult individual, whose last known address is 246 iNDIAN CREEK DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. On or about, August 15, 1996, the said Defendants, executed and delivered a Mortgage Note in the sum of $146,250.00 payable to NORTH AMERICAN MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1337, Page 938 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and recorded in the aforesaid County in Mortgage Book 639, Page 36. Mortgage Electronic Registration Systems, Inc. is acting solely as nominee for Washington Mutual Bank, FA its Successors and Assigns. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 246 INDIAN CREEK DRIVE, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on August 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $23.84 per day From 07/01/2003 To 02/01/2004 ( based on contract rate of 6.000%) Accumulated Late Charges Late Charges $48.35 From 08/01/2003 to 02/01/2004 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $145,074.14 $5,125.60 $96.70 $338.45 $1,841.08 $7,253.71 $159,729.68 **Together with interest at the per diem rate noted above after February 01, 2004 and other charges and costs to date of SherifFs Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at SheriWs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WItEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.000% ($23.84 per diem), together with other charges and costs including escrow advances incidental thereto to the da~-o~.~l)eriff's Sale and for foreclosure and sale of the property within descrihed.By!~., RC~EL~~,~U~& H~~~LER Leon P. Hailer, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) J. BORROWER'S PROMISE TO PAY In return for o lest~ that I tm~e recei~. I l~*omise to ]:ny LI.'~. S 14~,~$0.00 (~ ~t b ~ 2. [~ER~ Mt~ will ~ ~r~ ~ ~M ~{~ ~til ~ f~l ~o~t ~ ~ ~ ~ ~id. l will PAYMENTs iA) Time and Pl~e (4' Puymeata [ will pay ~inMpa~ aad ~ by ~ ~rm~tl ~r ~th. [ wi11 m m F m~thl r ~ym~a ~ t~ FIRST ~y M ~ m~ ~ ~ (B} Amo~l ~ ~tbly Paymen~ 4. BORROWER'S RIOIIT TO PREPAY 1 har~ th~ right to make Mymmlt$ ~ ~in~ip.l at any tim befo~ they are d~. A paymm~t off ~ineil~ ~y is $. LOAN CHARGES ~ ~ I~ ~r~ ~l~t~ or m ~ ~l~ in ~ti~ ~th th~ I~ e~ ~ ~tt~/imi~ th~: (i) ~y s~ I~ ~ s~{ ~ ~ by t~ m~t ~y to ~ t~ ~r~ to t~ ~mitt~ limit: ~ c~ to make ~i~ r~ by ~ing ~ ~i~ ] o~ ~ ~is ~te ~ by ~i~ a di~ ~y~t to me. If 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charles for Ov~rdu~ fr t~ Note ~r ~ FIFTEEN ~1~ ~ys ~t~ t~ ~e it ~ dtw. 1 viii ~y. lam ~ lO t~ [~e ~. ~y tMs late ~rp ~1~ ~ ~y ~ ~ ~ Imm ~y~t, (B) · t_-',Zhi 'A IIIIIIIl J IIIIIIII (C) Noti~ of Del, mU If ! am in default, the Note Holder a~y send me · writtefl notice tolli~ me t~t il I ~ ~ ~y t~ o~ a~l by ! ~min ~te. ~ N~e HoI~ may ~ me to ~y imm~is~ely t~ f~l a~t ~ ~i~i~ ~ch on ~hlch ~e ~i~ is ~i~ ~ ma~ (o me. [DJ No ~raiet by Note ~ol~t E~n ~f, at a t~ ~n Z m in ~a~t, the Note H~ ~ ~ ~ulre me to ~y impurely in full d~ a~e. ~ N~ ~1~ ~1 ~ill ~ve t~ ri~t m ~ ~ i~ X am ~ ~sult at a la~ time. (E} Paymenl of ~ote HoiSt's C~ts and If the No~e H~d~ ~ ~t~ ~ ~o ~y imm~t~y in ~ull as ~i~ ~. ~ N~ ~l~r w~l ~ the 7, GIVIN~ OF ~OT[C~ Unl~ a~i~e law ~eir~ n di~t m~ nny ~t~ t~ m~t ~ ~ m gi~n by ~i~ it or by ~ it by fi~t elm ~il ~o me ~t t~ ~rty A~s a~ ~ at a differ ~ if I ~ve t~ Note ~ol~r a ~i~ ~ my d~e~t mall to ~ Note E~ at ~e ~ s~ ~ ~ti~ 3(A} ~ ~ st a d~t ~ if t am ~ a ~ti~ 8. OBLIOATIONS OF P~ONS UND~ ~S m~ in th~ N~. ~l~i~ t~ ~ to ~y t~ ~1 ~t ~ Any ~ ~ tMs ~, ~ Note H~ may ~f~ its H~ls ~ ~is N~e ~i~ ~ ~ ~ivid~ly ~ t~t~. ~is m~ iht ~y ~ ~ m my ~ ~ m ~y all ~ t~ mo~ts ow~ ~ thb Nm. ' ~. W~VGRS I ~ ~y ~ ~ ~ ~ ~i~ ~ this ~e w~ ~ ~ ~ I0. U~RM SBCURED ~s Note b a ~m i~t with I~l~ ~ri~{~ ~ ~e ~i~. ~ ~ ~ ~t kKp ~ ~mim whi~ i ma~ ~ t~ Nme. ~t ~ity ~t ~i~ ~iti~ I may ~ r~ui~ m ~ im~iaM ~ymm ~ ~1 ~ all ~ [ owe t~ ~{ti~s a~ ~ti~ u f~: Tra~fer ~ tbe ~tly or a ~ield lnte~st ~ ~wet. ~ ~1 ~y ~ ~y ml~ ~ il ~ ~d ~ t~fK~ (~ ~ n ~ei~ in~t ~ ~ b ~d ~ rosy. at ils ~{~ ~u~e im~bte ~ym~t in hH ~ ~1 sss ~ by t~ ~ity f~M law ~ ~ t~ ~ ~ ~is ~utlty ~r~t. shall ~ a ~ ~ ~ lm l~ ~ ~ys from t~ ~ tb ~t~ is ~li~ ~ mail~ within ~ B~er m~t ~y ~1 ~ ~ by t~s ~{ty ~mmt. If ~ fails to ~y t~ sss ~ to t~ ~t~ ~ thb ~i~. ~ may inv~e ~mitt~ by thi~ ~urit7 l~tr~ wi{~ f~ ~i~ ~ ~m~ ~ ~s~r, AND SL~I~S) OP TI-IR UNDBRSIGN~D. · WITHOUT RECOURSE PAY TO · THE ORDER OF · COI~ANYe · .: .. · . · · r. / · ALL THAT C~IN lot or t~t of land ~o~ ~d 'J , PI~ No. 5 of l~i~ ~k ~ pre~r~ by D. P. Raff~rf~ Regls~ Sure.r. da~ Seplem~r 10, 19~, ~d fil~ in the R~ of D~s Of~ in Cum~J~d County ~n D~m~ 3, 1971 in P{~ ~k 22, Page 140. BEGINNING at a ~nt ~n ~e ~ line of I~ C~ DH~, at ~e dividing line b~w~ ~u ~28 ~d {29, s~d ~t ~idg 339.95 f~ ~uth of ~ ~ut~ lin~ of Shasa Way ~d~; ~ by ~ ~8, No~h ~ deg~ 28 m~u~ ~st, a dis~ of 192.0 f~t ~int ~ ~e Con~ogui~ C~k; th~ by rome, S~ 12 d~ 32 minut~ ~, a dis~ce -. of95.0 f~ m a ~t ~t ~ 1~; ~ by ~e, S~ ~ d~ 28 ~nu~ W~t, a dis~ of 192.0 f~ ~. a ~int at ~e ~ Hne of I~ C~ d~ 32 ~u~ W~t, a di~ of 95.0 f~ ~ ~e pl~ of BEG~G. B~NG subj~ m a 20 f~t ~ ~t, ~e of ~e ~ line of l~i~ C~ D~ve ~d ~dtng ~e ~1 wid~ of ~ I~. HAVING thereon erected a brick a~d aluminum two-sto~y dwe{ling house known and numbered u 246 lndin~ Cr~.k Drive, Mechani~bu~, l~.nnsylvanla. ~ BEING lot No. 29, Bl~.'.k ".f", Plan No. 5, Indian Creek, Hampden Tovmsl~p, Cumberland County, Pennsylvania. COMPANY NAME: VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Datedam~ 16, 20o4 SHERIFF'S RETURN - CASE NO: 2004-00282 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTP~ATI VS FEDORKO MARY E ET AL REGULAR SHANNON SHERTZER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE FEDORKO MARY E DEFENDAiqT at 1007:00 HOURS, at 246 INDIAN CREEK DRIVE MECHAiqICSBURG, PA 17055 LAWRENCE J PEDORKO, a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 23rd day of January by handing to ADULT IN CHARGE together with 2004 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 J[~ day of Pt ~Y A.D. honorary ~ ' So Answers: R. Thomas Kline 01/26/2004 PURCELL KRUG HALLER t/Deputy Sheriff +-~'=~ SHERIFF'S RETURN CASE NO: 2004-00282 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS FEDORKO MARY E ET AL REGULAR SHANNON SHERTZER , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FEDORKO LAWRENCE J DEFENDANT , at 1007:00 HOURS, at 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 LAWRENCE J FEDORKO a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, FORE was served upon the on the 23rd day of January 2004 by handing to - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers Docketing 6.00 Service Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 01/26/2004 PURCELL KRUG Sworn and Subscribed to before me this ~ day of 0 ~ ~g A.D. ~grothonotary MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-282 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiffand against Defendant(s) MARY E. FEDORKO AND LAWRENCE J. FEDORKO for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest Per diem of $23.84 From 07/01/2003 To 01/01/2004 Accumulated Late Charges Late Charges ($48.35 per month to 01/01/2004) Escrow Deficit $145,074.14 $5,125.59 $96.7O $338.45 $1,841.08 5% A~omey'sCommission TOTAL $7,253.71 $159,729.68 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & HALLE~ (717) 234-4178 ., a?.,/E. F~u n~OAs~l}) ~~ ._~,~,~a~:',~'c'~' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bm~k, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO Defendants 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 20O4-282 CWIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: February 20, 2004 TO: MARY E. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 LAWRENCE J. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANTNO~CE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 1719 N. Front St., HartSsburg, PA 17102 (717) 2344178 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-282 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF DAUPHiN : Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ~ay 20 Notary Public COMMONWEALTH OF PENNSYLVANIA Trad M. Colin, No~ Public _My Commi~si~ Ex,bites Aug. 21, 2007 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2004-282 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT(S) Total Judgment Amount $159,729.68 Interest $3,051.52 Per diem of $23.84 to sale date 6/9/2004 Late Charges $193.40 $48.35 per month to sale date 6/9/2004 Escrow Deficit $2,500.00 TOTAL WRIT $165,474.60 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, June 09, 2004 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: March 9, 2004 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION-MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judginent, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ~UMa~aLAND Coul~rrY ON DEcEsmr~a 3, 1971, iN ~ BOOK 22, PAGE 1~. ~ ~'~ ~ A D~CE OF 192.0 ~ ~ A ~ AT ~ CONO~ C~ ~NCE ~ ~ W~ a Ol~ OF 9~ ~ ~ ~ ~CE OF B~INNING. BEinG LOT NO. 29, BLOCK '$*, PLAN NO. S, lm)J.5~ Ca~:F.K, H,qMPD~ Tow~stm,, COUNTy, PE~NSYLYAN~ HAVING THEREON ERECTED A DWELLiNG KNOWN AS 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING THE SAME PREMISES WHICH John F, Romberger and Kathloeen E. Romberger~ by Deed dated 8/15/96 and recorded 8/26/96 in Cumberland County Deed Book 144, Page 95l, granted and conveyed unto Larry J. Fedorko and Mary Ellen Fedorko. TO BE SOLD AS THE PROPERTY OF MARY E. FEDORKO ANT) LAWRENCE J. FEDORKO ON JUDGMENT NO. 2004-282 ASSESSMENT NO. 10-20-1846-050 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-282 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. C/O WASHINGTON MUTUAL BANK, FA, Plaintiff (s) From MARY E. FEDORKO AND LAWRENCE J. FEDORKO (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. AmountDue $159,729.68 L.L. $.50 Interest PER DIEM OF $23.84 TO SALE DATE 6/9/04 - $3,051.52 Atty's Comm % Due Prothy $1.00 Atty Paid $134.28 Other Costs LATE CHARGES $48.35 PER MONTH TO SALE DATE 6/9/04 - $193.40 --- ESCROW DEFICIT $2,500.00 Plaintiff Paid Date: MARCH 10, 2004 (Seal) REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 71%234-4178 Supreme Court ID No. 15700 CURTIS R. LONG Prothonot~,~ Deputy MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-282 IN MORTGAGEFORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Hailer, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055: 1. Name and address of the Ovmer(s) or Reputed Owner(s): MARY E. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 LAWRENCE J. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the Judgment, if different from that listed, in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Grandview Surgery & Laser Center 205 Grandview Avenue Camp Hill, PA 17011 Brigid Q. Alford, Esquire 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify' that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unswom falsificat~~ -beo!~. ~A I.D. #15700 Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:March 9, 2004 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,/NC, c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-282 /NMORTGAGEFORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 09, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting ora statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-282 JUDGMENT AMOUNT $159,729.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MARY E. FEDORKO AND LAWRENCE & FEDORKO 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 Sheriffof this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Petmsylvania 17013 717-249~3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware ora 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 o,f the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 COUNTY ON DECEM~F~ 3, lg71, ~ ~ BOOK 22, P*O~ 140. '" B/~L,~iG LOT No. 29, BLOCK "J', PLAN NO. S, INVIAN CIT~EK, HAAfl~ TOWNSHIP, CLrM]SER~,ND COUNTt', PENNSa~VAlqEA t-tAVING THEREON ERECTED A DWELLING KNOWN AS 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 BEING TffE SAME PREMISES WHICH John F. Romberger and Kathloeen E. Romberger, by Deed dated 8/15/96 and recorded 8/26/96 in Cumberland County Deed Book 144, Page 951, granted and conveyed unto Larry J. Fedorko and Mary Ellen Fedorko. TO BE SOLD AS THE PROPERTY OF MARY E. FEDORKO AND LAWRENCE J. FEDORKO ON JUDGMENT NO. 2004-282 ASSESS1V~NT NO. 10-20-1846-050 Mortgage Electronic Registration Systems, Inc. c/o Washington Mutual Bank, FA VS Mary E. Fedorko and Lawrence J. Fedorko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-282 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Leon P. Hailer. Sheriff's Costs: Docketing 30.00 Poundage 10.51 Posting Handbills 15.00 Advertising 15.00 Mileage 16.56 Levy 15.00 Surcharge 30.00 Law Journal 293.30 Patriot News 78.67 Share of Bills 29.26 Law Library .50 Prothonotary 1.00 $534.80 paid by attorney 05/25/04 Sworn and subscribed to before me S%Ang~wers: This ,~ ~/'~day of ~ ~~ ~~ R. Thomas Kline, Sheriff Prothonotary Real EsYate Deputy MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE FEDORKO, DEFENDANT(S) 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-282 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): MARY E. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURO, PA 17055 LAWRENCE J. FEDORKO 246 INDIAN CREEK DRIVE MECHANICSBURG, PA 17055 2. Name and ad&ess of Defendant(s) in the Judgment, if different from that listed, in (1) above: SAME 3. Name and ad&ess of every judgment creditor whose judgment is a record lien on the real property to be sold: Gmndview Surgery & Laser Center 205 Grandview Avenue CampHill, PA 17011 Brigid Q. Alford, Esquire 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Nmne and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unswom falsification to anthorities.~ Purcell, Krug &Haller ( 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:March 9, 2004 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. c/o Washington Mutual Bank, FA, PLAINTIFF VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO, 2004-282 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 09, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting ora statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 246 INDIAN CREEK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-282 JUDGMENT AMOUNT $159,729.68 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: MARY E. FEDORKO AND LAWRENCE J. FEDORKO A SCHEDULE OF DISTRIBUTION, being a list of the persons an&or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein, THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these ri~ts. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS P~APER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sherifr,s Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 i.a..~ j · ~ rqO. ~ OF INDIAN Cas~tr~C AS PI~EpAJa~'~ mv n Fo ~ ~ ~e.,z.,.,..~... m,~ , · ~D~u vuuarx O~ uECEMBER .1, 1971, I~ ~ BOOK 22, PAGE 140. LOT No. 29, BLOCK 'J', PI.4~ No. $, l~rmAN Ca,rF.K, HAMPO~ TowNsm~, HAVING THEREON ERECTED A DWELLING KNOWN AS 246 INDIAN CREEK DRIVE MECHANICSBURG, PENrNSYLVANIA 17055 BEING THE SAME PREMISES WHICH John F. Romberger and Kathloeen E. Romberger, by Deed dated 8/15/96 and recorded 8/26/96 in Cumberland County Deed Book 144, Page 95 I, granted and conveyed unto Larry J. Fedorko and Mary Ellen Fedorko. TO BE SOLD AS THE PROPERTY OF MARY E. FEDORKO AND LAWRENCE J. FEDORKO ON JUDGMENT NO. 2004-282 ASSESSMENT NO. 10-20-1846-050 Real Estate Sale #73 On March 10, 2004 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 246 Indian Creek Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 10, 2004 By: 0['/,J~/~m Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND: SS, Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of thc 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 Cariisle 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 ail 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: 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 character of publication are tree. RF~L F-~TATE $ALR NO. 73 Wilt No, 2004-282 Civil Mortgage Electronic ReglstraUon Systems, Inc, c/o Washingten Mutuai Break, FA VS. Mary E. Fedorko and Lawrence J. Fedorko Atty.: Leon P. Hailer ALL THAT CERTAIN lot or tract of land known and designated as Lot NO. 29, Block 'J', Plan No, 5, of Indian Creek as prepared by D.P. Raffensperger, Registered Surveyor, dated September 10, 1969, and filed in the Recorder of Deeds Of- tice of Cumberland County on De- cember 3. 1971, in Plan Book 22, Page 140. BEGINNING at a point on the east- em line of Indian Creek Drive, at the dividing line beizween lorn #28 and #29, said point being 339.95 feet south of the SouCaern line of Shasta 'q/ay extended; thence by Lot #28 bxie Coyn 'tot SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004 LOtS E. SNYDER, Nota~j Public Ca~lisle Bom, Cumberland Counly My Commission E~pires Mar~h 5, 2005 Indian Creek as prepared by Raffensperger, Registered Surveyor, dated September 10, 1969, and rice of Cumberland County on De- Page 140. south of the Southern line of Shasta by same South 12 degrees 32 at the eastern line of Indian Creek of 95.0 feet to the place of beg/nning. ship, Cumberland County, Permsyl- BEING 'THE SAME PREMISES WHICH John F. Romberger and Kath- loeen E. Romberger. by Deed dated 8/15/96 and recorded 8/26/96 in Cumberland County Deed Book 144, Page 951, granted and conveyed unto Fedorko. TO BE SOLD as the property of Mary E. Fedorko and Lawrence d. 050 NOTARIAL SEAL LOIS E. SNYDER, Nota~j Carlisle Bom, Cumberland My Commiss{on Expires Marcf ilSge lgatriot- qetn5 P.O. Box 2265 HARRISBURG, PA 17105 (717) 255~8100 DUPLICATE BILL CUMBERLkND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ACCOUNT ~:CUMB020 RUN DATE SIZE RATE AMOUNT TAGLINE 4127/04 6.00 12.82 $ 76.92 SALE ~ 73 NOTARY 1.75 $ 1.75 SALE ~ 73 TOTAL: $ 78.67 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAc~ No. 587, Approved May 16, 1929 Commonwealth of Pecnsyivania, 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 The Sunday Patriot-Nev~s 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 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 subsequent{y duly recorded in the office for the Recording of Deeds in and for said Cou~aneous Book Volume 14, Page 317. PUBLICATION , /~yCommlssio~ ~P o i My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND (~)UNTY 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 $ 7 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunde,.v Patriot-News, newspapers of circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the st been duly paid. Leon P. Haller Purcell, Krug &Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller@pkh.com MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., c/o Washington Mutual Bank, FA, Plaintiff VS. MARY E. FEDORKO AND LAWRENCE J. FEDORKO, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2004 - 282 IN MORTGAGE FORECLOSURE P RA E C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendant satisfied of record, because the mortgage has been reinstated and the default cured. DATE: November 3, 2004 PURCELL, KRUG HALLER Leon P. Haller ID #15700 Attorney for Plaintiff