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HomeMy WebLinkAbout04-0636FEDERMAN 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 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET SUITE 100 ORANGE, CA 92868 Plaintiff SANDRA MILLS A/K/A SANDRA FOLK ROBERT MiLLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 COURT OF COMMON PLEAS CIVIL DIVISION TERM No. 0% 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 judgrnent 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 yotl. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 87494 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, 1F 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 #: 87494 Plaintiff is WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET SUITE 100 ORANGE, CA 92868 The name(s) and last known address(es) of the Defendant(s) are: SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 05/09/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1812, Page 4778. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2003 and each month thereafter are due as~d 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 all interest due thereon are collectible forthwith. File #: 87494 The following amounts are due on the mortgage: Principal Balance Interest 08/01/2003 through 02/12/2004 (Per Diem $31.95) Attorney's Fees Cumulative Late Charges 05/09/2003 to 02/12/2004 Cost of Suit and Title Search Subtotal $121,080.29 6,262.20 1,250.00 152.86 $ 550.00 $129,295.35 Escrow Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $129,295.35 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. 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 $129,295.35, together with interest from 02/12/2004 at the rate of $31.95 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. FEDERMAI~ AND PHELAN, LLP, / ~' FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FKANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 87494 All that certain lract of land, located in the Camp Hill Borough, Cumberland County, Penns3dvania, mom particularly bounded and described as follows to wit; Beginning at'a point on the Northern side of Fairview Road, at the line of LOt NO. 43 on fl3e plan of lotS hereinafter mentioned; thence along the northern line of I=airview Road, South 42 degrees 44 minutes West, 100 feet to a stake at line of property of G, Frank Zerbe; thence along line of said Zerbe property North 47 degrees 16 minutes West 227.02 feet to a stake at the line of other prope~ now or formerly of E.T. Schimmel; thence along the line of said property North .54 degrees 02 minutes East 101,98 feet to a point on the line of Lot No. 43; thence along said lot, ~uth 47 degrees 16 minutes East 207.04. feet to the place c,f beginning, Property Address: 2824 Falrview Road, Camp hill, PA 17011 Property ID #: 01-19-1594-054 VERIFICATION STEPHEN C. WHITAKER hereby states that she is FORECLOSURE SPECIALIST of AMERIQUEST MORTGAGE COMPANY mortgage servicing agent for Plaintiffin this matter, that she is authorized to ta~e this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hex knowledge, information and belie£ The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. SHERIFF'S RETURN - REGULAR CASE NO: 2004-00626 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLA/~D WM SPECIALTY MORTGAGE LLC VS MILLS SANDP~A ETC ET AL BRYAN WARD Cumberland County, Pennsylvania, who being duly says, the within COMPLAINT - MORT FORE was MILLS SANDRA AKA SANDRA FOLK DEFENDANT , at 1859:00 HOURS, at 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 SANDRA MILLS a true and attested copy of COMPLAINT - MORT FORE , Sheriff or Deputy Sheriff of sworn according to law, served upon the on the 17th day of February , 2004 together with by handing to and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me this ,~3~_ day of · Prothonotary So Answers: R. Thomas Kline 02/18/200A FEDERMAN & PHELAN Deputy ~Sheriff SHERIFF'S RETURN - CASE NO: 2004-00636 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS MILLS SANDRA FTC ET AL REGULAR BRYAN WARD Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 17th day of February by handing to together with says, the within COMPLAINT - MORT FORE MILLS ROBERT DEFENDANT , at 1859:00 HOURS, on the at 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 SANDP~A MILLS, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE 2004 and at the same time directing Her 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 R~3,_ day of So Answers: R. Thomas Kline 02/18/2004 FEDERMAN & PHEL~ Deput~ Sheriff FEDERMAN AND PHELAN, LLP By: FR.~NK 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 WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET, SUITE 100 ORANGE, CA 92868 Plaintiff; SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION NO. 04-636 CIVIL Defendant(s). : 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 SANDRA MILLS A/K/A SANDRA FOLK and ROBERT MILLS, 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 dan~ages as follows: As set forth in Complaint Interest from 2/12/04 to 4/6/04 TOTAL $129,295.35 $1,757.25 $131,052.60 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL1NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?~s) ~6~-7o0o ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC Plaintiff SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS Defendants COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 04-636 CML TO: SANDRA M/LLS A/FdA SANDRA FOLK 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 FILE COFY ' DATE OF NOTICE: MARCH 9. 2004 THIS FIRM 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 RECE1VED 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 MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLETO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNq~ 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 S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?15) 56~-7000 WM SPECIALTY MORTGAGE, LLC Plaintiff Vs. SANDRA MILLS A/FdA SANDRA FOLK ROBERT MILLS Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION : CLrMBERLAND COUNTY : NO. 04-636 CML TO: ROBERT MILLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 DATE OF NOTICE: MARCH 9, 2004 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT 'FIDE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE 1N 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 OK OBSECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 SHERIFF'S RETURN CASE NO: 2004-00636 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAigD WM SPECIALTY MORTGAGE LLC VS MILLS SANDRA ETC ET AL - REGULAR BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE MILLS SANDRAAKA SANDRA FOLK DEFENDANT at 1859:00 HOURS, on the at 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 SANDRA MILLS a true:and attested copy of was served upon the 17th day of February , 2004 by handing to COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.66 --~, Affidavit .00 Surcharge 10.00 R. Thomas Kline 37.66 Sworn and SubSCribed to before me this __ da~ of ~ AiD~ 02/18/2004 FEDERMAN & PHEI~IN Deput~ ~heriff Prothonotary SHERIFF'S RETURN CASE NO: 2004-00636 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS MILLS SANDP~A ETC ET AL REGULAR BRYAN WARD Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE MILLS ROBERT DEFENDANT at 1859;00 HOURS, at 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 SANDRA MILLS, ADULT IN CHARGE a true Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 17th day of February by handing to together with and attested copy of COMPLAINT - MORT FORE 2004 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6 Service Affidavit Surcharge 10 16 O0 O0 O0 O0 O0 O0 Sworn and Subscribed to before me this day of A.Do So Answers: R. Thomas Kline O2/lS/2oo4 FEDERM~N & PHEL~q Peput ~ Sheriff 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 WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET, SUITE 100 Plaintiff, SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-636 CIVIL VERIFICATION OF NON-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 SANDRA MILLS A/FdA SANDRA FOLK is over 18 years of age and resides at, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011. (c) that defendant ROBERT MILLS is over 18 years of age, and resides at, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011. 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 BEGFvlNII~G at a point on ~ {',tOfRI~a skie of Fairvicw Pond at the ~ of line of Lot No. 43 on the plan of 1o~ ~ meatkn~l; ~ along the Nor~m line of Fai~i~w Road, South 42 degrees 44 minutes West, 100 feet to a s~ke at the line of pmlnn~ of Dr. O. Frank Zefbe; tl~ence along the line of sa~d propev~r, North 47 degrees 16 mtatttez West, 227~02 feet to a ~take at the line of propea, ty now or formerly of l~, T. Schimmel; ~en~ aloa~ the IIn~ of said @to~y, Not~ 54 d~ree~ 02 mim~e~ East, 101.98 fee~ 1o a point on 0re I~ne of L~ Ne. 45: thence Mong said lot, Sou~ 47 d~ 1.6 miattte~ F.~t, ;t0'L04 fcct to tl~ place of beginaiag. BEINO Lo~ No. 44 on ~ Phmof Lo~ of E. T. $chimmel and SOaz, aaid Plan of Proper0/I~ing from survey of D. P. ~ger Regtst~ed Sorveyor, dated March 2, 1957. TITLI~ TO SGII~N. CT PREMI~ l,~ VESTI~ IN Ro~rt MI~ sod Samira Mille, biz wi/e, by reason of ~e followiag: BEING ~ SAM~ PRE.kriSES which S~ndra L Mills and Parry L. l{tkicer, Jr.. co-ex~ of the II.ate of Eve W. Dasher, ~, by Deed tinted 5/15/21X]O and moon:led on 5f26/2000 in the County of Ctuubvrland iu D~ Hook ~1, Page 1078 c0uveyM ~amto Sandra L Mills, in fcc, AND A[30 BBINO TI~E SAME P~ which ~ L Mills by Q, dt Clz. im Deed ds.,~ 4/9_.6/2002 and recorded on 8/14/2(X~ in the County of Cumb~antt in ])eM Book 253, Page 701 conv6y~d nn~o Robe~ Mills and Sandra Mills, his wife. PROPERTY ADDRESS: 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011 TAX PARCEL: # 01-19-1594-054 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 WM SPECIALTY MORTGAGE, LLC Plaintiff, SANDRA MILLS A/K]A SANDRA FOLK ROBERT MILLS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-636 CIVIL CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 9l because it is: ) an FHA mortgage ) 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 unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WM SPECIALTY MORTGAGE, LLC Plaintiff, SANDRA MILLS A/FdA SANDRA FOLK ROBERT MILLS Defendant(s). No. 04-636 CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: AmountDue ~terest~om 4/6/04toSEPTEMBER8,2004 (p~ ~em -$21.54) TOTAL $131,052.60 $3,338.70and Costs $134,391.30 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Note: Please attach description of property. No. LEGAL DESCRIPTION BEING Lot No. 44 ou th~ Plan of Lo~s of E. T. SchLqu-'nel and Sons, said PI,mn of PropeiW {xfing from a survey of D. P. Rff~ml~ger Regls~'ed S~'veyor, dated March 2, 19~7. HAVINO thereou er~;ed a dwcHiug house known and uumben~d as 282~ Fairview Road, Country Club Rifts, Car~ Hill Pennsylvania. TITLg qfO $~ PREMISPCq IS VESTI~ IN Robert Mills aud Smmtta Mills, his wife, by rozon of rig followiag: BEING THE SAM~ PREMISES wi.ich 5andta L Mills and Har~ L. Bricket, ?r., co-executors of th~ ~t~t¢ of Eve W. Dasher, deceased, by D~ed datod 5/1512/X10 and recorded on 5/26/2000 in ~ County or' Cumborl~tmd iu Deed Book 221, Pagg 1078 cottveyed ~ Sandrn {, Mitts, in fee, AND ALSO BEING ~,-[E SAME PREM~ES which ~ L Iviilis b'y ~ ~ Deed dated 4/26/2002 aud record~ on 8/14/'2002 in the Counly of Cumbertnud in Dead {~ook 253, lnq~e 701 conv~yed unto Ro{~-~ Mills nnd .qnndra Mi{Is, his wife. PROPERTY ADDRESS: 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011 TAX PARCEL: # 01-19-1594-054 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-636 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE, LLC. Plaintiff (s) From SANDRA MILLS A/K/A SANDRA FOLK AND ROBERT MILLS (1) Youaredirectedtolevyuponthepropertyofthedefendant(s)andtosell SEELEGAL 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 $131,052.60 L.L $.50 Interest FROM 4/6/04 TO 9/8/04 (PER DIEM - $21.54) - $3,338.70 AND COSTS Atty's Comm % Due Prothy $1.00 Arty Paid $135.66 Other Costs Plaintiff Paid Date: APRIL 8, 2004 (Seal) CURTIS R. LONG 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: PLAINITFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Deputy "· WM SPECIALTY MORTGAGE, LLC Plaintiff, SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-636 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WM SPECIALTY MORTGAGE, LLC, 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, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) SANDRA MILLS A/K/A SANDRA FOLK 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 ROBERT MILLS 2824 FAIR¥IEW ROAD CAMP HILL, PA 17011 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: NatTle 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 may be affected by the sale. NaiTle 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 may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 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 information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Aoril 6, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SPECIALTY MORTGAGE, LLC Plaintiff, SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS Defendant(s). TO: SANDRA MILLS A/1OA SANDRA FOLK 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 04-636 CIVIL April 6, 2004 ROBERT MILLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT ,4 DEB T, B UT ONLY ENFOR CEMENT OF A LIEN AGAINST PR OPERTE * * Your house (real estate) at, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011, is scheduled to be sold at the SherifFs Sale on SEPTEMBER 8, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $131,052.60 obtained by WM SPECIALTY MORTGAGE, LLC (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: 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 may be 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 fights. 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. 1. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full 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 yotl. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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) are 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) 249-3106 (800) 990-9108 LEGAL DESCRIPTION ALL T~IAT CERTAIN tract of ~ locat~ h~ ~ l~orough of Camp Hill, Cumberland County, Petmsylwmia, bounded and deser~ as follov~, to wii: BEING Lot No. 44 on ~he Plan of Lots of E. T. Schlnm'tel aad Sore, said Plan of Pl'opeff/being from a surly of D. P. ~ger Registered Surveyor, dalml March 2, 1937. KAVIN(~ thereon crec~d a dwelling house known and lmmbe~ as 28:2.4 Fairvie~ Road, Country Club Hills, Camp H~I1, Pe.~.sylvani~. TITLE TO SUi~I~2Y.r PR~MISI~ IS VI~T~ FN Robert Mi~ aad Saedta Mills, I~ wde, by ~-.a,~n of the followiag: BEING TRE SAM. E PREMISES which Sandra L Mills and I~ L. l~'tcker, Jr., co-ex~..utots of the Esta~ of Eve W. Dasher, deceased, by Deed dated 5/15/2000 and recorded on 5t26/2000 in the Counly of Cumbertat~ in De~l Book 221, Pag~ 1078 conveyed tmto Sandta J, Mills, in fee, AND ALSO I]EING THE $~ PREMISF~ which Sahara L Mills by Quit Claim ~ dated 4/26/2002 and recorded on 8/14/20~ in the County of Cumbertnnd in De~d ~ook 253, Pa~e 701 conveyed umo Rotm~ Mi/Is and Sandta I~fills, hia wife. PROPERTY ADDRESS: 2824 FA1RVIEW ROAD, CAMP HILL, PA 17011 TAX PARCEL: # 01-19-1594-054 PLAINTIFF DEFENDANT(S) AFFIDA~TOFSER~CE WM SPECIALTY MORTGAGE, LLC SANDRAMILLSAfK/ASANDRAFOLK ROBERT M/LLS SERVE SANDRA MILLS A/K/A SANDRA FOLK AT 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 SERVED CUMBERLAND COUNTY PJT No. 04-636 CIVIL ACCT. #0047087424 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 8, 2004 Served and made known to _ gjA~)('~.II~ I~|t..,[..,.~ _, Defendant, onthe_ ~C{'K at o'clock m,_ of Pennsylvania, in the manner described below: ,200~ , Commonwealth Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is ~,Oq5 [~ _Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __.Manager/Clerk of place of lodging in which Defendant(s) reside(s). __ Agent or person in charge of Defendant(s)'s office or usual place of business. __ Other an officer of said Defendant(s)'s company. Description: Age _~(o Height ~ t'~.- Weight ~--~.O Race _~ Sex _~ Other I, ~g 15 ~ ~ ~Sa competent adult, being duly sworn according to law, depose and state t~tI a ~e and co~ect copy of the Notice of Sherifffs, Sal~ in ~e ma .... 2s z:: ~ ~nh herein, issued in ~e canfioned ca personally handed the ad&ess indicated above. - [ ~ ~ ' ~ ~ se on the date and at Sworn to and subscribed / ~~~ [ before me this ~ay [ ~~~ 1 PLEASE ATTEMPT SER~CE AT LEAST 3 TIMES. I~ICATE DATES & TIMES OF SER~CE ATTEMPTED. NOT SER~D On the day of ,200__, at Moved --_ Unknown__ No Answer 1st Attempt:. / / Time: : 3rd Attempt:. / / Time: : Sworn to and subscribed before me this _ day of ,200 _. Notary: By: .A. ttorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 __ o'clock __.n% Defendant NOT FOUND because: __ Vacant 2"d Attempt:_ / / Time: PLAINTIFF DEFENDANT(s) AFFIDAVIT OF SERVICE WM SPECIALTy MORTGAGE, LLC SANDRA MILLs A/K/A SANDRA FOLK ROBERT MILLs SERVE ROBERT MILLs AT 2824 FAIRV/Ew ROAD CAMp HILL, PA 17011 SERVED CUMBERLAND COUNTy No. 04-636 CIVIL ACCT. #~ Type of Action - Notice of SherifFs Sale Sale Date: SEPTEMBER 8, 2004 Served and made known to ' e ae.T ILL5 , -- -, Defendant, on lhe ~ {o ~ day of , Co~onweal& °fPe~sylvania, N the ~Defendant personally served, manner described below-: ~Adult fa~ly member with who~ Defendant(s) reside(s). Relationship is ~Adult in Charge of Defendant(s) s residence who reused to give name or relationship. ~Manager/Clerk &place of lodging in which Defendant(s) reside(s). ~Agent or person in charge ofDefend,-.r-~, ~ mztka] S Orllce or USUal place of business. ~ O~er: ~ an officer of said Defendant(s),s COmpany. Description. A ~t_ ~t~ ~. ge ~ Height ~ W ~ ' eight ~ Rac dune and COgect copy of the Notice ~ff~i~swo? according to law, depose ~d st captmned case on ~e date and at ~e address ind~'erut~ Sale m &e manner ......... ate that Sworn to and subscribed ' ' ~ ~ , PLEASE ATTEMPT -~ ~ A [ PTED ~ o&~E~ & TIMEs OF SERVICE NOT SERVED On the ~_~ day of ~, 200~, at o' ~ clock ~.m., Defendant NOT ~n~rxr~, ~ Mo,e0 ~ Un~o~ ~ No Answer - -~',~ oecanse: Att ~ Vacant 1st empt: / Time. 3rd Attempt:~ / / Time:------L--~ SWorn to and subscribed before me this ~- day of ~, 200 Notary: --' By: ~Att~o_r, ne_., .for Plaintiff Frank Federman, Esquire - I.D. No. 12248 -- _ 2 Attempt: / / ~.. '----~-~ ~llme: PJT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WM SPECIALTY MORTGAGE, LLC VS. SANDRAMILLSA/K/A SANDRA FOLK ROBERT MILLS ) CIVIL ACTION ) ) CIVIL DIVISION ) NO. 04-636 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQU1RE attorney for WM SPECIALTY MORTGAGE~ LLC hereby verify that on April 9~ 2004 h-rte and 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 E ' '"" xhiMt A attached hereto. DATE: August 16, 2004 FRANK FEDEPdVlAN, ESQUIRE Attorney for Plaintiff WM Specialty Mortgage, LLC VS Sandra Mills a/k/a Sandra Folk and Robert Mills In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-636 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 30.00 Poundage 412.08 Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Levy 15.00 Mileage 20.04 Surcharge 30.00 Law Journal 353.75 Patriot News 290.20 Share of Bills 30.40 $1212.95 Sworn and subscribed to before me So Answers: This /5'~dayof ~ ~~f~ R. Thomas Kline, Sheriff Prothonotary Real Eshite Deputy WM SPECIALTY MORTGAGE, LLC , Plaintiff, SANDRA MILLS A/K/A SANDRA FOLK ROBERT MILLS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-636 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WM SPECIALTY MORTGAGE, LLC, 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, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or repined Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) SANDRA MILLS A/K/A SANDRA FOLK 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 ROBERT MILLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 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: maine 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: maine 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 may be affected by the sale. mallqe 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 may be affected by the sale: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 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 information 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. April 6, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff WM SPECIALTY MORTGAGE, LLC : Plaintiff, : SANDRA MILLS A/KJA SANDRA FOLK ROBERT MILLS Defendant(s). TO: SANDRA MILLS A/FdA SANDRA FOLK 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 04-636 CIVIL April 6, 2004 ROBERT MILLS 2824 FAIRVIEW ROAD CAMP HILL, PA 17011 **THIS FIRM1S A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011, is scheduled to be sold at thc Sheriffs Sale on SEPTEMBER 8, 2004 at 10:00 a.m. in thc Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $131,052.60 obtained by WM SPECIALTY MORTGAGE, LLC (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: 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 may be 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. 3. You may also be able to stop the sate 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. 1. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full 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 may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 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) are 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 THAT CERTAIN tra~ of laad locaVed in the Borough of Camp Hill, C~ab~land Penn~lvania, bounded a~l described az follovc~, to ~t: BEGINNING at a point on 1~ Northern skl~ of Pairv'~cw Road at the ~ of lille of Lot No. 43 on the plan of lo~s betctnat~ me~toaed; thence along the Nonhero line of Fairvi~w Road, Sooth 42 degrees 44 mimam West, 100 fret ~o a stake at Om lin~ of ~ of Dr. O. Fonk Zetbe; thence atoag the llae of said properS, No~ 47 degre~ 16 minatas We~t, 227,02 feet to a smtre at th~ li~ of otlaer property now or formerly of E. T. 8ehimnml; gaen~e alo~ L~ iln~ of aaid properly, lg0fl~ ~4 ~l~ll'~es (}R ~in,~e~ East, 101..98 feet m a point on I~ lin~ of Lot No. 4:3: thence ~ng said lot, 8outh 47 BEING Lot No. 44 on th~ Plan of L0~ of E. T. $cYaimmel snd Sons, said Plaxt of Prop~ty I~elng from a sm'vcy of D. P. ~erger Registe~l Surveyor, dated March 2~ 19~7. HAVING ~reou ~ a dwelling house known and r0.tmbered as 2324 Fait'view Road, Country Club Hills, Cantp Hill, Peanaylvania. TrrLE TO SUBJn_CT PREMI~R~ I.~ VESTI:~ IN Ro~rt Mffis and Sandra Mills, iris wife, by reason of fl~e following: B~ING TI~E SAM~ PRF, M]$]~S whigh Sandra $~ Mills nnd Harry L. Brick. er, Jr., co-~eeutora of Ibc Estate of Eve W. Dasher, deceased, by Deed dated 5115/2000 and recorded on Couaty of Cumberland in Deed Book 221, Page 1075 conveyed m~o Snndra J. Ms'lis, in fee. AND ALSO BI]lNG THE SAME ~ which Sandra L Mills by Quit Clabn Deed 4/'26/2002 and recorded on 8/14/2002 tn the County of Cumb~l...-I ia I~d Book 253, Pa~ 701 conv~yed unto Robert Mills and ~andra Mills, his wife. PROPERTY ADDRESS: 2824 FA1RVIEW ROAD, CAMP HILL, PA 17011 TAX PARCEL: # 01-19-1594-054 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-636 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE, LLC. Plaintiff (s) From SANDRA MILLS AJK/A SANDRA FOLK AND ROBERT MILLS (1) You are directed to levy upon the p~operty of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to at~ach 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 $131,052.60 L.L. $.50 Interest FROM 4/6/04 TO 9/8/04 (PER DIEM - $21.54) - $3,338.70 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $135.66 Other Costs Plaintiff Paid Date: APRIL 8, 2004 (Seal) CURTIS R. LONG Prothonota[y Deputy 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: PLAINITFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale #01 On May 12, 2004 the sherifflevied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA Known and numbered as 2824 Fairview Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 12, 2004 By: Real Estflte Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE ~LE NO. I Writ No. 2004-636 Civil IJVM Speciadty Mortgage, LLC Sandra Mills a/k/a Sandra Folk and Robert Mills At[y.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as follows, to wit: I~EGINNING at a point on the Northern side of Fairvlew Road at the line of line of Lot No. 43 on the plan of lots hereinafter mentioned; thence along the Northern line of Fairview Road, South 42 degrees 44 minutes West, 100 feet to a stake at the line of property of Dr. G. ,,~fflv~trie Coyne, E~tor SWORI~'TYO AND SUBSCRIBED before me this 30 .day of JULY 2004 LOIS E. SNYDER, Notmy Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 Writ No. 2004-636 Civil WM Specialty Mortgage, LLC Sandra Mills a/k/a Sandra Folk and Robert Mills Atty.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in the Borough of Camp Hill. Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Fairview Road at the line of line of Lot No, 43 on the plan of lo~s herelnafler mentioned; thence along the Northern line of Fair~lew Road, South 42 degrees 44 minutes West, 100 feet to a stake at the line of property of Dr. G. Frank Zerbe; thence along the line of said property, North 47 degrees I8 minutes West, 227,02 feet to a stake at the line of other property now or formerly of E. T. Schimmel; thence along the line of said prop- erty, North 54 degrees 02 minutes East, 101.98 feet to a point on the line of LOt No. 43; thence along said lot. South 47 degrees 16 minutes East, 207.04 feet to the place of beginning. BEING Lot No, 44 on the Plan of Lots of E. T. Schimmel and Sons. said Plan of property being from a survey of D. P. Raffensperger, Rog- lstered Surveyor, dated March 2. 1957. HAVING thereon erected a dwell- ing house known and numbered as 2824 Fairvlew Road, Country Club Hills, Camp Hill, Pennsylvania. TITLE TO SUBJECT PREMISES IS VESTED IN Robert Mills and Sandra Mills, his wife. by reason of the following: BEING THE SAME PREMISES which Sandra J. Mills and Harry L. Bricker, Jr.. co-executors of the Estate of Eve W. Dasher, deceased. by Deed dated 5/15/2000 and re- corded on 5/26/2000 in the County of Cumberland in Deed Book 221, Page 1078 conveyed unto Sandra J. Mills, In fee, AND ALSO BEING THE SAME PREMISES which Sandra J. Mills by Quit Claim Deed dated 4/26/ 2002 and recorded on 8/14/2002 in the County of Cumberland in Deed Book 253, Page 701 conveyed unto Robert Mills and Sandra Mills, his wife. PROPERTY ADDRESS: 2824 FAIRVIEW ROAD, CAMP HILL, PA 17011. TAX PARCEL: #01-19-1594-054. !bl$1I SWORN'TO AND SUBS( 30 day of JULY LOIS E. SNYDER, NC Carlisle Boro, Cumber My Commission Expires THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 CommouwcalthofPenmylvania, CountyofDanphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Penusylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Peunsylvania, 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/ur Sunday/Metro editiuns which appeared on the 27th day(s) of July and the 3rd and 10th day(s) of August 2004. That neither he nor said Company is interested in the subject matter of s~fid 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 Sv~uta ,o and Y~~d day of August 2004 A.D. ~3ember, penntylvanla Aasoclationol Nolan~OT~Y PUBLIC My commission expires lune 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on thc above stated dates 290.20 Publisher's Receipt for Advertising Cost of The Patrint-News and The Sunday Patriot-News, newspapers of general , nowledge receipt of the aforesaid notice and publication costs and certifies that the same have