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HomeMy WebLinkAbout04-1426McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Realty Corporation P,O. Box 8604 Elmhurst, IL 60126 V. Jeffrey Bumbaugh a/Wa Jeffrey L. Bumbaugh 499 Newville Road Newburg, PA 17240 and Roxanne Bumbaugh a/k/a Roxanne S. Bumbaugh 499 Newville Road Newburg, PA 17240 Attorney for Plaintiff 0 41_ /,9.4 6 Cumberland County Court of Common Pleas Number CIVIL ACTION/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 may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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 Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar una con parencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la carte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes Para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. S1 USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. S1 USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO M NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Realty Corporation Cumberland County P.O. Box 8604 Court of Common Pleas Elmhurst, IL 60126 V. Jeffrey Bumbaugh a/k/a Jeffrey L. Bumbaugh 499 Newville Road Newburg, PA 17240 and Roxanne Bumbaugh a/k/a Roxanne S. Bumbaugh Number 499 Newville Road Newburg, PA 17240 CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is Household Realty Corporation, a corporation duly organized under the laws of Delaware and doing business at the above captioned address. 2. The Defendant is Jeffrey Bumbaugh a/k/a Jeffrey L. Bumbaugh, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 499 Newville Road, Newburg, PA 17240. 3. The Defendant is Roxanne Bumbaugh a/k/a Roxanne S. Bumbaugh, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 499 Newville Road, Newburg, PA 17240. 4. On 08/16/2001, mortgagors made, executed and delivered a mortgage upon the premises hereinafter descri bed to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1731, Page 293. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 499 Newville Road, Newburg, PA 17240. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/16/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance $ 58,828.88 Interest through 03/30/2004 $ 8,405.66 (Plus $ 19.93 per diem thereafter) Attorney's Fee $ 2,941.44 Cost of Suit $ 225.00 Appraisal Fee $ 125.00 Title Search $ 200.00 GRAND TOTAL $ 70,725.98 8. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with certificate of mailing. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $70,725.98, together with interest at the rate of $19.93 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. 4AWOIC TERRENCE J. ABE, ESQUIIt Attorney for Plaintiff VERIFICATION The undersigned, Jennifer DeMaio, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, `?U?? } ??``jc ? 11A Yn \ , and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. 1 I;? I , ? 1 I ?? Jenjer e aio d 5„ a r? ROBERT P. ZI'EGLER •RECOtDER OF DEEDS, CUMBERLAND COUNTY-PA, 713303 ! MORTGAGE 111106 20 RN 3 •1,4 a IF BOX IS CHECKED, THIS MORTGAGE IS AN OPEN-END MORTGAGE AND SECURES FUTURE ADVANCES. THIS MORTGAGE is made this day 16TH of AUGUST 2001 , between the Mortgagor, ROXANNE S. BUMBAUGH AND JEFFREY L. SUMBAUGH, (herein "Borrower') and Mortgagee HOUSEHOLD REALTY CORPORATION a corporation organized and existing under the laws of DELAWARE , whose address is 25 GATEWAY DRIVE, GATEWAY SQUARE/SUITE 107, MECHAN 1 CSBURG, PA 17055 (herein "Lender"). The following paragraph preceded by a checked box is applicable. X WHEREAS, Borrower is indebted to Lender in the principal sum of $ 60,616.23 evidenced by Borrower's Loan Repayment and Security Agreement or Secondary Mortgage Loan Agreement dated AUGUST 16, 2001 and any extensions or renewals thereof (herein "Note"), providing for monthly installments of principal and interest, including any adjustments to the amount of payments or the contract rate if that rate is variable, with the balance of the indebtedness, if not sooner paid, due and payable on AUGUST 16, 2031 O WHEREAS, Borrower is indebted to Lender in the principal sum of $ or so much thereof as may be advanced pursuant to Borrower's Revolving Loan Agreement dated and extensions and renewals thereof (herein "Note"), providing for monthly installments, and interest at the rate and under the terms specified in the Note, including any adjustments in the interest rate if that rate is variable, and providing for a credit limit stated in the principal sum above and an initial advance of $ TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2) future advances under any Revolving Loan Agreement; (3) the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4) the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the following described property located in the County of CUMBERLAND Commonwealth of Pennsylvania: ALL THAT CERTAIN PROPERTY SITUATED IN THETOWNSHIP OF HOPEWELL IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 08/26/1993 AND RECORDED 08/31/1993, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME 36 M OJT ?aTG-E 736. TAX MAP OR PARCEL ID NO.: 11-08-0599-008 PA0012A1 ?I¦II???AA?I?I???I¦?IUI?IIII???IN?1911UI??9??WI "aP76CP751587MTG9000PA0012A10""BUABAUGH . BK 173 1 PG0293 ¦ " ORIGINAL Exhibit A -3- is otherwise acquired by Lender, Lender shall apply, no later than immediately prior to the sale of the Property or its acquisition by Lender, any Funds held by Lender at the time of application as a credit against the sums secured by this Mortgage. 3. Application of Payments. Except for loans made pursuant to the Pennsylvania Consumer Discount Company Act, all payments received by Lender under the Note and paragraphs I and-2 hereof shall be applied by Lender first in payment of amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest, and then to the principal. 4. Prior Mortgages and Deed of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, including Borrower's covenants to make payments when due. Borrower shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions attributable to the Property which-may attain a priority over this Mortgage, and leasehold payments or ground rents, if any. 5. Hazard Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended coverage," and such other hazards as Lender may require. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a standard mortgage clause in favor of and in a form acceptable to Lender. Lender shall have the right to hold the policies and renewals thereof, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and shall comply with the provisions of any lease if this Mortgage is on a leasehold. If this Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents. 7. Protection of Lender's Security. If Borrower fails to perform the covenants and agreements contained in this Mortgage, or if any action or proceeding is commenced which materially affects Lender's interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary to protect Lender's interest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of Borrower secured by this Mortgage, Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Lender to Borrower requesting payment thereof. Nothing contained in this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 03-01-01 MTG PAO012A3 IIIII 11 1011III 111I 011INNINN11 "OP76CP751607MTG9000PA0012A30•"a0M0AUGH " OR I GIML ; BK 17 PG02951 -4- 8. Inspection. Lender may take or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonable cause therefor related to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Lender, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted by Lender to any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original Borrower and Borrower's successors in interest. Lender shall not be required to commence proceedings against such successor or refuse to extend time for-payment or otherwise modify amortization-of the sums - secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's successors in interest. Any forbearance by Lender i n exercising any right or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of anysuch right or remedy. 11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements herein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Lender under the terms of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Lender and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accommodations with regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasing that Borrower or modifying this Mortgage as to that Borrower's interest in the Property. 12. Notice. Except for any notice required under applicable law to be given in another manner, (a) any notice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Lender as provided herein, and (b) any notice to Lender shall be given by certified mail to Lender's address stated herein or to such other address as Lender may designate by notice to Borrower as provided herein. Any notice provided for in this Mortgage shall be deemed to have been given to Borrower or Lender when given in the manner designated herein. 13. Governing Law; Severability. The state and local laws applicable to this Mortgage shall be the laws of, the jurisdiction in which the Property is located. The foregoing sentence shall not limit the applicability of Federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this end the provisions of'this Mortgage and the Note are declared to be severable. As used herein, "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under any home rehabilitation, improvement, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender's option, may require Borrower to execute and deliver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property. 03-01-01 MTG ? a PA0012A4 11101M 01111111 01111111 Ell "BP76CP751687MTG9000PAOO 12A40"RBLWAUGH • ORIGIM4l 8K 17 31 PG 0 2,9.6 v -5- 16. Transfer of the Property. If Borrower sells or transfers all or any part of the Property or an interest therein, excluding (a) the creation of a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold interest of three years or less not containing an option to purchase, (d) the creation of a purchase money security interest for household appliances, (e) a transfer to a relative resulting from the death of a Borrower, (f) a transfer where the spouse or children of the Borrower become an owner of the property, (g) a transfer resulting from a decree of dissolution of marriage, legal separation agreement, or from an incidental property settlement agreemeht, by which the spouse of the Borrower becomes an owner of the property, (h) a transfer into an inter vivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or (i) any other transfer or disposition described in regulations prescribed by the Federal-Home Loan Bank Board, Borrower shall cause to be submitted information required by Lender to evaluate the transferee as if a new loan were being made to the transferee. Borrower will continue to be obligated under the Note and this Mortgage unless Lender releases Borrower in writing. If Lender does not agree to such sale or transfer, Lender may declare all.of the sums secured by this Mortgage to be immediately due and payable. If Lender exercises such option to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 days from the date the notice is mailed or delivered within which Borrower may pay the sums declared due. If Borrower fails to pay such sums prior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NONUNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Acceleration; Remedies. Except as provided in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying: (1) the breach; (2) the action required to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, by which such breach most be cured; and (4) that failure to cure such breach on or before the date specified in the notice may result in acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The notice shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure. If the breach is not cured on or before the date specified in the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to collect in such proceeding all expenses of foreclosure, including, but not limited to, reasonable attorneys' fees and costs of documentary evidence, abstracts and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums by this Mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then due under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or 03-01-01 MTG IIII?I?01 Ifilp??WO®??®®IAINIIIAflll glllllp?®IIO Ip111I11 N? MOP16CP751687NTG9ODOPA0012ASOMMOLUBAUGH . ORIGINAL PADD12A5 8?1731PG:0:297 :::(? -6- agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants and agreements of Borrower contained in this Mortgage, and in enforcing Lender's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action as Lender may reasonably require to assure that the lien of this Mortgage, Lender's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage and the obligations secured hereby shall remain in full force and effect as if no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrower hereby assigns to Lender the rents of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and retain such rents as they become due and payable. - . - - - - Upon acceleration under paragraph 7 hereof or abandonment of the Property, Lender shall be entitled to have a receiver appointed by a court to enter upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver shall be applied first to payment of the costs of management of the Property and collection of rents, including, but not limited to, receiver's fees, premiums on receiver's bonds and reasonable attorneys' fees, and then to the sums secured by this Mortgage. The receiver shall be liable to account only for those rents actually received.' 20. Release. Upon payment of all sums secured by this Mortgage, Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21. Waiver of Homestead. Borrower hereby waives all right of homestead exemption in the Property under state or Federal law. 22. Interest Rate After Judgment. Borrower agrees the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. 03-01-01 WrG 'BP76CP751687MTG9000PA0012A60""alA1aA" • Oa IG IKk PA0012A6 8K 17 3 1 PG'0.2 9 8 _ -7 REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of trust or other encumbrance with a lien which has priority over this Mortgage to give Notice to Lender, at Lender's address set forth on page one of this Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action. RO A NE;S BUMBAUG Borrower JEF,,L BUMBTIUGH-Borrower I hereby certify that the precise address of the Lender (Mortgagee) is: HOUSEHOLD FINANCE 25 GATEWAY DRIVE, MECHANICSBURG. PA 17050 On behalf of the Lender. By: ETHAN P FOGLE Title-.BRANCH MANArER COMMONWEALTH OF PENNSYLVANIA, LANCASTER County as: I, ETHAN P FOGLE a Notary Public in and for said county and state, do hereby certify that ROXANNE S BUMBAUGH & JEFFREY L BUMBAUGH personally known to me to be the same person(s) whose name(s) are subscribed to the foregoing instrument, appeared before me this day in person, and acknowledge that they signed and delivered the said instrument as their free voluntary act, for the uses and purposes therein set forth. Given under my hand and official seal, this 16th daY of A u q u s t 20 01 My Commission expires: ((( tart' Public Notarfal Seal Ethan P. Pogo New pUblIC Lancestar Canc?ter Lbunry This instrument was prepared by: MY Qomm"on Expires Apr. 5. 2004 MOLD F CORPORATION tEwvaY DrW, Suite 107 (Space Below This Line Reserved For Lender and Recorder) Return To: Records Processing Services 03-01-01 MTG 577 Lamont Road PA0012A7 Elmhurst, IL 60176 98P7 6W75 1681MT09000PA0012A70aaB1lABAUGH "l l,erGMAb tl ly this to 1: recorded In Cumberlant' ;ounty PA BK 173 1 PG0299? ?i V\?? . rr?.....to V` II\-1 ry u C/ SHERIFF'S RETURN - REGULAR CASE NO: 2004-01426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORPORATION VS BUMBAUGH JEFFREY ET AL CPL. KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BUMBAUGH JEFFREY A/K/A JEFFREY L BUMBAUGH the DEFENDANT , at 0910:00 HOURS, on the 8th day of April 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to JEFFREY BUMBAUGH 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 .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this IS d" day of 01 ?oyA. D. s+othonot? ary So Answers R. Thomas Kline 04/08/2004 MCCABE WEISBERG CONWAY By' ??- eputy Slriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-01426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD REALTY CORPORATION VS BUMBAUGH JEFFREY ET AL JODY SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BUMBAUGH ROXANNE A/K/A ROXANNE S BUMBAUGH the DEFENDANT , at 1129:00 HOURS, on the 6th day of April 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to ROXANNE BUMBAUGH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 1,5? day of Cjr,:- WCa /?? A. D U no- ?Lt,l0,. r thonotary So Answers: 701- R. Thomas Kline 04/08/2004 MCCABE WEISBERG CONWAY By. JC 0( JVuu - , De ty Sheriff Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor C)y - /41azip CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573