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HomeMy WebLinkAbout08-7460r• Pluese, Becker & Saltzman, LLC Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Ste 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorneys for Plaintiff FRANKLIN CREDIT MANAGEMENT CORPORATION V. Plaintiff, NATASCHA THOMAS (MORTGAGOR AND RECORD OWNER) AND JAMES THOMAS (MORTGAGOR ONLY) COURT OF COMMON PLEAS CUMBERLAND COUNTY Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH N THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENT Y (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING THE 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1/800-990-9108 717-249-3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SIUSTEDQUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGWAS SIGUIENTES, USTED TIENE (20) DIAS DE PLAZO A PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APAKIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGADO Y ARCHIVAR EN LA CORTE SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AV1SO 0 NOTIFICACION O POR CUALQIER QUFJA 0 ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO, SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO, VAYAEN PERSONA O LLAMEPOR TELEFONO A LA OFICINA CUYA. ESTA OFICIANA PUEDE PROVEER DE USTED LA rNFORMAc16N SOBRE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PERMITIRSE A LA IRA DE H A LA CAPA, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACI6N SOBRE LAS AGENCIAS QUE PUEDEN OFRECER SERVICIOS JUR(DICOS A LAS CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1/800.990-9108 CIVIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE I • The Plaintiff, Franklin Credit Management Corporation is a corporation having been organized under the laws of the United States of America and having its principal place of business at 101 Hudson Street, 25`'' Floor, Jersey City, NJ 07302. 2. (a) Defendants, Natascha Thomas (mortgagor and record owner) and James Thomas (mortgagor only) are individuals whose last known address is 332 Roxbury Road, Newville, PA 17241 (b) Defendant, Natascha Thomas holds an interest in the subject property as mortgagor and record owner. Defendant, James Thomas holds an interest in the subject property as mortgagor only. (c) If any of the above named Defendants are deceased, this action shall proceed against the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or executors through their estate whether the estate is probated. 3. (a) The subject mortgage (the "Mortgage") is described as follows: Mortgage executed on: August 4, 2006 Mortgage recorded: August 14, 2006 in Mortgage Book 1962, page 1579 Mortgage re-recorded: December 11, 2006 in Mortgage Book 1975 page 4296 County of: Cumberland See Exhibit "A," Note and Mortgage. (b) The Mortgage encumbers property (the "Subject Property") located at: 332 Roxbury Road, Newville, PA 17241. (c) The "legal" description of the Subject Property, expressed in metes and bounds, is incorporated in the Mortgage. See Exhibit "A," Mortgage. 4. The requisite pre-foreclosure Combined "Act" Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". 5. The Mortgage is in default (the "Default") because the Defendant(s) failed to timely tender the monthly payment of $891.53 due and/or to be applied to the payment due May 1, 2007 (the "Default Date"), and thereafter failed to make the monthly payments. 6. Pursuant to the terms of the Mortgage, the secured loan obligation has been accelerated. 7. By reason of the foregoing Default, Plaintiff respectfully requests entry of judgment in rem incorporating the following sums: (a) Outstanding Principal Balance $99,348.93 (b) Interest due and owing at the rate of 8.30% calculated from the Default Date through December 16, 2008. Interest will continue to accrue at the per diem rate of $24.16 through the date of entry of Judgment in rem. $14,295.99 (c) Attorneys' fees $1,250.00 (d) Escrow Only Payment $1,578.86 (e) Title Search $333.00 (f) Release Fee $25.00 (g) Late Charge Payment $609.57 (h) Legal Fees Payment $4,427.24 (i) BPO Fees $249.57 TOTAL IN REM JUDGMENT SOUGHT BY PLAINTIFF $122,118.16 8. The attorneys' 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 or satisfied prior to the Sale, reasonable attorneys' fees will be charged. WHEREFORE, the Plaintiff demands: Entry of Judgment in rem against the Defendants above named in the total amount of $122,118.16 as stated at Paragraph 6, plus all additional interest, additional escrow advances expended, additional late charges and any other costs incurred through the date of entry of Judgment; and Foreclosure of the mortgagors' equity of redemption and that of any persons or entities holding or claiming under them and Sheriffs Sale of the subject mortgaged property. Respectfully Submitted, Pluese, Becker an, LLC. By: R homas, Esquire A t rney for Plaintiff NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT, (the act), 15 U.S.C. SECTION 1601 AS AMENDED To the extent the act may apply, please be advised of the following: 1. The amount of the original debt is stated in paragraph one of the Complaint attached hereto. 2. The Plaintiff who is named in the attached Notice to Plead and Complaint is the Creditor to whom the debt is owed. 3. The debt described in the Complaint attached hereto and evidenced by the copy of the mortgage/note will be assumed to be valid by the Creditor's law firm, unless the Debtor(s), within thirty days after receipt of this notice, disputes, in writing, the validity of-the debt or some portion thereof. 4. If the Debtor notifies the Creditor's law firm in writing within thirty days of the receipt of this notice that the debt or anyportion thereof is disputed, the Creditor's law firm will obtain verification of the debt and a copy of the verification will be mailed to the Debtor by the Creditor's law fine. 5. If the Creditor who is named as Plaintiff in the attached Notice to Plead and Complaint is not the original creditor, and if the Debtor makes written request to the Creditor's law firm within twenty (20) days from the receipt of this Notice, the name and address of the original Creditor will be mailed to the Debtor by the Creditor's law firm. 6. Written request should be addressed to Pluese, Becker & Saltzman, LLC 20000 Horizon Way Suite 900 Mt Laurel, New Jersey 08054.. Attention: Rob Saltzman, Esquire VERIFICATION The undersigned, a representative Franklin Credit Management Corporation, the instant Plaintiff, being authorized to make this Verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATED: 12 2 3 D0 By: U Robert omas, Esquire, a repres ntative of Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. Of Pennsylvania as Attorney in Fact Loan No. (PAge 3 of 67) • • CERTIFIED TRUE COPY Prepped Donald 6albrabth $00 Forest Point Circle, Charlotte, NC 20273 (704)665.3124 Rom Ta r : T EouiFirst Corporation , Attn: Collateral N ,s . 500 Forest Point Circle Charlotte, NC 28273 (000)272.3477 P*Md Nonow.. Minim: 332 Roxbury Road, Newville, PA 17241 A1? A1»N 7UY 1bM M R"6Kalp . MORTGAGE mill 100200100100599717 wads wad io ntdtipte sacdons of Us docent-at are defied below to abx wads an WNW h Sndm 3. 11. 13. 18. 20 ad 21. Caailtt man rgWdiag do =p of wads wed In dds docWm" on do pwri6ml in Ssadon 16. (A) "ieaeRJ 100mimmor mtmme thk dooomM. which is Met August 4. 2005 mpsbar wft in Rid= to thisdooaaeat. M 11urewer"k Nataschs Thomas and James Thomas. rife and husband Bot OTM Wow morow Under Ids Seca ft bmtnaaeu. (C) %M r Is 14w pe Mocoo is Rgbodom Sygoma. lW- MBRS k s Npatasa oapaatiom dxg is acla0 a" n a moldan 0x 1Attder wd l.eder's suoetarws aml = *m. MW b fM notm a ttttdff Wk S=11j bmtrtm•@nL b18R3 k ot- I l and edu miff dta bws of DdoMt and bas w ad&= ad tdapbmms armber of P.0. BU =6. P1hK 1di 48301,2026, td. (950) Mb680:S. 1005997 FWWV&vLvmm • Oro rr"mv • Fmb mwwne` um uMeomM me ra mmr Wtim Nmme ??t o"m rtis J07m1M1 ?.M.rN F011W1 AOy i •IA Wowp>*AwK h- IWCOAI' (Page a o! 67) 0D1'EmuW b EauiFirst Corporation Lsderba Corporation oepNSd and esdrdas under lbs Mws of North Carolina Lmlor'soddromb 500 Forest Point Circle. Charlotte. NC 28273 (4 "NMe" mams &R P Ombmy tv><0 1160011 by IOM WW N d dated AUgost t. 2006 TbcNooesta=*NBorsoerorowasE.adcrone hundred thousand and 001100 Dollars SM. 000.00 ) p1m Wow. 6ot1w¦ree has Pasramt, std b pry die debt 61 fall not ktw d= Augat t 1. promised 0 edit de0t u Psiolxdk M "PtOperty" Swam d0 FIGMY 00 Is das;dbod bdow under the kaft Memi kr of RWU In let Property.' (Q) %mem* Memo tee debt evidenced by me Not. plae klerett. say p Wymew cW"M and 1111 *mW da under tee Mat% and sY mete dae under "a 3mum yr bmu= ot. pia balm M "hairs" a IN Riders b ddb Suorky IDmtremat dW arc mmand by Borrowar, Ybe &Uowiq Riders are m be aaaumd by Bormor lchm r bm a applimblej: A Agnsuhlo Nate Rider Coadsoioiaro Rider Smood Hoow Aida 01110011 Rider no tkk Dem POW Rider 1-4 F1wby Bider VA Rider Smakly Payment Rider 011rer(d ItPOW ARK Floor/ Prepay Rider M "Ap d"Is Lew" morns AN ONtMe1S ttppliNN6 tedae11, sale and local twain, reSela low Otdemaea, lad edmeNWNM 1010, and orders (tort have Ire dfam of law) r w0N a all applieabk Anal. opledom. AwadrNp Aw. Pm. Mad Ammummo• mars all dws. IBM samemeals ad OOW ckmSm rr om or ? sisillr OrS,ai on.sormaer oe or the Properly by a oadoariehm mociadoa. harasowaem (10 'Oamook Plrrde 7YeR*e man mgr u mkr of fiends, ad= due 6 tmmatl1011 arlSirWed by d m:16 dragk or d ft ppr iabamat, wlddl is notGbd tbrmso a domemmie wrmbd. tel¢otio laatrtrt11e . asRIPber. 01 myoetle m11ppe so a m order. Weir et, ar nftdm s ibrtrld iaedweloo d debit OF taut an moors. Such lo m Includes. bat is am Merited to, point-of-sls tnmd11s, Summed Wor IIIIWW U=UdM. 1mRefm Wad by Isl11pi m. who tmmkm, and aammoW daabO=g unsk& (14 "Lento hmn mauns 01016 Ram that an de t%W in Sermon 3. (R4 "Anuddemae l4sseedr" Muni MY N-Pa edion. nail mmd, swod of dsom8es, of pounds paid by say died peat' (steer 11=1 h11a,am proc00. paid under 11111 ounas describedla limsion 5) k1: M dsmye t0. or d01btedoe of. lea Pmpatty. (N) osndamemioe or gow mt3n< of all or my pee of the !!% s . ( aoldi drin Il- of coodcm doo. or (lv) rdue dom of. or Mob" a Ia. the SO Pp bow"er" mrom humames "Oft Lmdw mom on noap,ymma d. or defmit era, Lem (0) "lmidk Peyaed" moat do me rl,dy mWoMed mom due 1br (l1 pdodW sod 101~ ender tb tdose. ON (ii) rq lmoems coder Sretlon s of this Sealrky loanunmt. 1006087 4%41W I6tor P10031116 P10031116 ? Form Me 1191 (Page 5 of 67) Ql "RWA• anise ON RN Rqnkft I Ewa sett)emeal Prosedw Am (12 U.S.C. Seaim 7601 at seq.) god in ?? « blsRionC•al. Pon li0q, as they MW be speeded Itas riots to R att. '1EEEPr III nfaw m dtg=Waft do gown do lose alljeet mWK As used aegrirmtwb sal mwkdnn Net ew bepomd 4 roped 4 de!pe?i d me"" loon' eve* if die Lose does sot pa ify as a Ysdwavy Idaw vow" (Q) 'Stiomsr In LdwM of So - owermoue airy poly due has takes ode to die whedur not tbd puw bee asannmsd bosom's obfisado m unler the Note salvor Ns Sseorhy liw m or TRANSM OF RK*M IN THE PROPERTY 716 $maw ry brbmsent Nona to Lender. (A the of the Lan, nd ell nownds, eatan mu and fAmn rimu•of the NOW ed 01) the PWIWMNM or some mses oovewem ad asepeeenm ender ibis Srar* h arse mt ad do New For dds pwpow, Bwio m does hereby m atgspe, peat sed conic} to MM (Maly N UNIhM fnr Roder sod tender's wooaooes end anises) s d to do Main ota mad Old" of b/FSS. the fdlW*Ulp daalbd property toramd in the County rrM er osm o* Awbildol of Cumberland Sea Attached Exhibit A %Wzb MrMdY hN the sdmw of 332 Roxbury Raid Newville Nn? [cbl.PewnoyMmaia 17241 lZlstaesl rPropwty Address: TOOOMM MM aV the iaoproveoetro am er - Wmmf r wowd on dim ptapsny, and W . and ffstma row or Ae, ft a put of the AU atklkimm nplaommew ad .., a I b_y.* ibis Semrhy baappma. AD of ft is saA' N in We end oenelt Ntam d -Y In IngftsaW4 "So 'd)At, It wen y to nff#-)e0?whltnw' a aasob 1dsRS to t oosi es far Lefler ed t.eudr a Oman ad) bas a rim sm "main =y or ag of don laewaam. Ll* but aft Iheirad to, the d ht Be Mrnkn std sag IM PjaWly and ro ragairad at Ietde, imciadlu[, by ON limited p, tekNiap and awdbg fns SwAty 1005!87 't s "ice w .:+.? t- ram man 1161 <Page 6 of 67) • r BOBB WIM aWENAWM do %nower is hrwhtlly atimd of dt MM haft 0aRWOW d ba tha ftk m MOW Vaal Sod eWw" the ItropaIY sbd that the Pmpeny Is tateatatmbtxad, MOP far ataaa1 mice of maotd. BorwAw wanam std wM ddead pettttmlly do dde to the Property Yd d dsias aad demmk, , a b j e c t lefty g u m o b n o m of rsoord. TMS SOCURM HiMUMEM aomMm uW tem twmmm for nodmA we d wtrvaiform aoveFttatF wkh IhWW rmindm by jorb iadon to coudam a adform =on* bF4nmeat wvaLtp twi pnspwty. . UNl RM AOVI NANTS. Bwrowr ad Cooler cavoraw and ap" at Mom L Psgmaat of Ptbteiplr ItFtWmt, Beam Irtwo, Peapsymeat ptm % ad Lea PharIPL Domms sWl pq vAm dw dta pdn*W of, std banal o% dte debt twileootd by the Note W MW pcq psaaet cWW ad )me dmW due tmder On Note. Dom aw drll to pq hmft for Etemw b m pts>srmt to 8aaioa 3. Pgmaatt dae atria On Naa Sad d6 SecQiq Is ma m " be made iS U.S. mlaaq However. U mw the* or ether iemrteta - tetefwd by Lndw L pymam Wider the Nast w mfa Smmttty hommtt Ia mMnod to Ladar zj*M, Lada m q mom = Fry or all stt6FgWa 10 11n 1 dot adw do Nat mW %U Meowky Uuttamm be made is 0a or mm or the *Marlap R m. m teIwW by L thr W e uh: (b) money order. (c) cwMW dak be* thodt. ftesmrer's do* Of QRMW'F shedh, praMid Fd mq nab first b drawn ape an im kmion whore depoths w h IW d by a hdad apstry, lownw Wily. or aft w (d) Ekctmk Puna Ttm*r. Paymem m damd seta' - by L.eoda? who raodt e/ at pr Wad= dnkpoed m dr NM or at such odor Iseadatt a am be dedwmW by Ladw bt mcmdum wW ft ttatke prowid= In Secllatt 13. Leda mq attFtFS 4 pgytnart or prtw poi U the pe) - or pettf@ payawa4 eta IR=MokM m beftep the Law mateem. Im w may accent a* psymmt or p W p mo m itad &iw a beittp dw Loa arms. women wPtw of tap rlpltet hsraa a of prt jttdiea to iS rW to 10 fe1YtFS Fah p?ymam ar pW W pF3?mea1F in do htm s, bw Latch b as d t*dvd to apply sttdt papadsrw a do dm soh pF{) M ate aoeopmt v Ink Fniodie hyDtam b spptbd m d ks ackoftm da dre. rhea Laadw aced oat PW ietWaM a arppiiad huh. Ltada may had mh as W%d hub =W Darows m" payatatt m bray . the Lm Comm If Barowar don not do so whWo a Mu W period of time. Leo&w tdM d &w apply nrJt hadt ar ramrb tbam to BarrawW. t! aot npplled Fa>var, ttrrJb flsttdF wDl bs applbi Fo the atFtrtdiq ptb>ripd bWrtis wdtar thF Nate irmsdisaly prior m iotmdasme. Ib offset dr cbM w" ft m- tFtW have alter or In the Ibmts Mdut laden reap rWk" BaFaawa hm tssldap pyfomat da n.der the Ntas mtd Ulu S*=* bmu m w or pw farmhtp the awarob and agetmatn sstatrad by dtb Sdomity 7. Afpiks" of Pam or lreceaA, Eno a athanin dattYlbad in Ok $a d= 1. ell ptrytttFatt S oWW fled jWbd by Luder,hall be applied In dr know* or 4w of priority: (a) bm w doe wdW dm Nora: (b) prbdpd doe Wrier du Now (e) ont uou do wAr Std m 3. 3mb payamb &A be Wplied 0 auk Patddla Psymm to the wd w in whkrh k beram da. Aq mdniap MOW" 60 be spout first to lee c mMw Faamd m ny odtar amooots dtt order fhb SMOWI y IaFtstt NW. ad then m ttd»ro As pt bdpd bdaos of de Note. N Lade - Im a poum ft m B= =a hr a doNsWAM Pts9adia Paymmtt wWkb bxh dm a sd kbw am= m pq aq Imo cMW dw dr pytttwt retry to Wohd a the ddhttp m pgrrem and tb Ua tdtsnpt. If more *m dos Pafodic Ps4mem Is wavm ft, lAdwmq Wply my, m I tetwived Mm Daeadwsr m Ibe repaymatt of rift Periodk Popum It, ad to ds eseedt put. a& poymta 100'J48i _ re. ? r u fares 3OJS 1101 (Page 7 of 67) t 3 4 k an be Pais in fell. To the mom do any mom edam after tb payment is Wind a tie ftdl payuem of an or more t4riodle hymcom soft exam may be VOW to amy his AM p due. Holumary M s9m7meme dog be applled Aram say p ngq mur theme ad Maas u dmafbed in *a NMt Apt dpptiallm of p smr^ be- c i poooem I or ldhodlvt PrsoM I a pdadpol dm Leda On MM *A not aslad a poMpae die due due, or rdopp the srtramm, of the Pod§Wk Paywara. I Loeb for lmw Iau. Bonmwer dull pay lo Lefler an the day Plmtodio Paysdo are dux order the Nom. eaeil dt! Nee Is pNd Is tot. a s m me 'ft*') a provide far 1 3 , of now" duo for W am and admmmb and odw itmtm w" art tads pt%* Over this 5eeudq Lebirmw , as no or exm.btamoe on dr PmpW. (b) lnmhdd paytsmtd or ivoimd main a the Plopnryr, If Md: (e) p a dmu hr m W list as imemaa ropivad by Leader under Season S: ad (44 block" bummance prwwoa, 1T new. or ON forms payok by aomrmr a tsmUr is ltau G( &I pomat d l oopp lmstiesoee pranbmu is swordsmen Mich dm provtslomd of Sodom 10. Them Item are aced •Romiew heft* At od@kW m or or my der docirM die was of the taro, Leader may regeim Itat CAammirdq Amo"m Des, Pia. and Amm mm. If say, be ataorwd by Bwv wr, mad much dom. fee surd welaamete dW be an Bmow leer. Boetoerlm? aoa p mmipdy fImmM a Lender all n d= of ammo a be pas NOW ads Smdem, Romm m dug pay Lender dw Ands far Teomw name tiaras Laden wawa Bonoer'm omi,padw to pay the Ands for my or as amen, iomos. Larder soy ware Btrrormr's obliptiw On pay ms Lrdmc Pmads for any or all Pecrour Ideas a mqr tone. Any emct waiver aoq o* be in wrift b die am of of such wdvw. Bonner doll poy dhec*. who and wbw pooK the amounts due der aq Bmermw urea for wbit% payoam or Pwo bur been waived by Lesdm med. lftemder vmvA a, droll Andtft m Lmdw rmodpo oddm ciq mob pynmait Midda act doom priori a Lender mW regoim Borrower's abitpdorn a edm we paiwmrtr and a psevid, rlalpw mall for so p 1.1, be deemed to be a oovemast end yremum comadmod is olds Security Lrrlmmm. $e do pbas; -=mootasd spemaet• b sod to Sectim P. If Botlsmmr Is abtipted a psy Bserar bmm d'iracdy, pure mu a a waiver. and serrowr pals 10 pay da w am are fen sun Exim 11tm. Lander may axodso id tishts odor Bdodw 9 aid py mmoh amount mid Serowe shall that be obKpw under hoodoo 9 a mM a Under aq moth armor. Lm dw aay tmlmbe the waiver ar b Ally or as BMW Jtma at me doe by a aura shme to aoowdara whh Sectim 13 ad. Won no rwocuk& bmum doll pay oc bender all Lamas. Mrs In web mono w dot arm dorm rawbol under OB Section & Lander may. m limy time. Who add I1oldFmds lu an mom (B) Mk mt otr permit Leeds to apptr ft Pardo at to dose mpsdGW vela MWA. ad (b) mot a mmmd ate mmmiormm uttomm a leader cos mgiin moder RIWA. !.uvular atoll endismm do dmomm of Pmmb doe lie do bras of error dm and remeooabto orderer of eapoollom d !atom Bomw Lemur or dhevwia in mocadaroe vkb Applicable Lill. 118 FW* moll be old in to kMlmdoa wham dgrodts us Insured by s ibderd song. YrotmmdmsmUgr, or soap thrbrtbiie Lp1dR. if I.atldes' Y a inodaMia Mboss dspombd sur mo !posed) a od MW larded Home L.am Bak, l mder *A apply dos Poses to p1' do Hesraw boas ma leer thou do time sptdlbd under EWA. Lder dish mot dwp Bortowts for kd tfj end applyhta des Prods, mmnalty astdrataq the anew asoomed. ar vwiWq the aemorr Iem, tinsem Leader pays Borrower m do Fads and Applim" taw prmip [alder in m ft web a oarp. Ual m nh Warrmt b mule in wrimq of Applicable Low se 1.1 , Itrerrx m be pad our to Funds. lamer dim err In sett I a pay ffofs tra sty imbamrt or arafto an die Pads. Borrower ad Leader can dams fa wddra, orwever, Lou b terw 1006987 11??{{?Q,,????yy 4RASIPAJ new r... e.i to rerun Pane 7078 1101 r (Page B of 67) i 41 9 • doll be paid 00 the Pmdt. L miler shall give to Borrower, wkbwA almsyc. m scold =&Ax[ of at Awls me nwdnd by RBSPA. It Sam o a tatphes of pads hdd is escrow, as deRood tender IMPA. Lender shall mom to Dwowr far do caws kvk Is a.mordum with RWA. If dim is • sb=W d Awds bold bo m mw. u I Rued eadw RES'PA, Lander slnll notify Doe vow a nplood by RFSPA, and limmr drll par lo lender des snow somemy to write up eke damp b aRaedsetev with MWA. bst M no wore dos IZ ..eddy pay.eah. U dm is a de&*my ar Pumb hrld M awww, a< delbrd wait EWA. Lsmdw doll SKW Bmw m as nngvirI A by RBSPA, add Bmrwrmm drag pry b 190ft do amain .cancan 10 ruche up toe 4Wkk sy in awwdama wkk RESPA. bent in m won tba 12 ttsmehiy 1 3 m . qm psyntmt iw fdli of on sum aocmt3d by this Seeotity Ituntmte d, Lettda slue pmm" retw to Bmrroaw sat Pwds held by Lads. d. ChUFM Was. Dsnwmr shun pay all taxes, s>swamts, eharlp. Rm. sad k*mldom amihaabla a the Ne"m whklt ea amim prw ft ova two 3e6rky Iasm+oeet, kmdww pay.sMS or pound macs om do Ptttpn . If my. and Ca..wnily Amdadon Dom. Fw, m d Ammmreats, if ss fr. To rite eat. do Mom ills arw Fslrow boom, Barrows shsn pay dram In the mulcts poAM in him 3. HerrtSon o ? powqdy rp mW lieo w" Ms primil over No Saw ky l mtmeat =km to t..tder, bat tttt)y a tawrkir4 lo r{ so Bo de apalm= l is of do etbtipt m aagea 'by dta nom in a amw aeagW* pttrf nft hock sweemut; (b) aoatew do Ilad is Bond Ib Mt by. erd*A& mwbw wdorceoem of arc lke ia, kpl pmoo. is V si" Is Larder's opbda apessne to prewar to srdbeameot of do Bra while *m premmUW wo padioM, bw ady wdl swd, ppaaadbrp an cudedot w (m) sawn fiam the hmldsr or dM Ike aw apeenat s whci ry is Lender mardbttt i ft In Bm no dds St mft kmtrtrmara. N Loader dea.r.ims dam my pan of dw Propssty Is sttldsat to a lkn wW& min priority mw dds Sawritt inrrnanew. Irate: my wive tiarmww a robes idwliftieM do IW& days of do dare as wbkh that mtke Is Slvm. Bonoara dun stdkg Mte Ba or tales an or more of the aedom se Berk ob vs is this Smim 4. udder cloy t Sot rower to pay s ame tim dwp far s seal ewer in vwNladma mUm reporting =via trend by Under In toomotkm with dds Loan. S. h"wly Imwomm Mono. alyd) bog do faprovewm a row Wain or 1> mdw erased .m do Pmp M MmaW W mt loin by fire, bomds krritrded w)toia the tam 'eateaesd w rap.' amd any el ut bosads %skdhtg, bat we Mrs bW to, wr*Valm sad Roods. fwwhiak Lesdor ngtd.a ktrmamm. 71tis inseseswot sorb lm meisdairard in the a uawn (irrektdtmg dwwdmo kvd.) and for the psdods am Luder mqd" . Whe Laden mplm pmww w tM p and ig ommems to MW duff &e .no of do LmmL Mom Immupw cudn ? Ilnwuta shah be elu by Bwrotwr st*jm a 1 oddx's doid m m 9d" l simmer 10 par, IN ooamakn With mis Loan, d dw. (a) as oaa-dme *up p la now i mme drspoleslkt- aleddesdon.sed UdI tlp mnioes; or (b) a owodkns Our hr food a damtnlmaioa sad emdliMM a1 1- ad strbasgrtan ehaBas each dm mmopptap or dons dwwSw aeav wldi tudowabb midst atfset wh ddamhollom or osedliratioa. Sommar shelf dso be mpmmWe fbr too paymsal of say Ibso Wfawl by the: Aederd Bffwp ey Maaspmw Apmsy In eenaselam with do rellm of any Road some delawdoatko mfideg from a objection by Borrows. 1005997 ?iAl/4f woe. erttrc ry, 6 .r is A/ J/ 'Fetes 30= tlav I. r Vage 9 of 67) If Bonewes fiib Ia m11a01io aq of area WOMAN dOM-Wd above. Lm1at may obtain hwtraom oo aqe, at Lades aptlw ad Borewwer's eapeaae. Larder it under no ebUpian to ppraham my Pmt Q'Pt ar loeoea of etwsrap. Theraiere, locb eowuio " win Lefler, bet MI& or mitre, as I ems ltmwer. Dot-mea snotty In Mee Property, or due came, of ft httpaty, sptisw eq dot. hoseld Of "lbillty d mitres p -Ale ireyer at low awenie an west joff omit' M a&CL amt, " wlmmkm*s are the OR of do imunim tmmp lo obtdnod mI& siydftiaady amed the ones of banenms dot Borsowsr ootld lrw obtsimed. Any mtonete dlt AwW by Lunde under No Section S shall beoame Mddotwi debt M 8srreaeI - I, I by tides SaattW INVOMM. Tome mtosats doll beer htlwatt Y die hots use 60110A dent of disbetem ant aid deli be per, whb sock interest. upon notice from Lander m locrowev s nob pqm w. All ihummem polkda taptdsed by Linda sad n ww* of wick policies dolt be mb}xt to ).coda', '1* to diosppanw look poikim del hshde a sedan mar" clause, wed drli nose Larder a srortpptt tedlor ere All 0fadood lose payfr. Lander alW hew do date a held the pdidw ad eloeaal nmswd taint. "newts! obosON COMM 411111 FrOllift lss ep' Ions of ° Linder in mocipts i of paid pra Len sad bwxu= centric, = odo duewlae agaitad by y Leads. for danys to, w l- - -1,a of. die Peepaty, lock polity creel) holade s atadnd maepte doss wed 111111 mom Lender os taotliWe mWar m on additions) fora psyea. 10 VW wen of ICK Barrawwr ftR Silo I , I A ,elks to do inswoo s canter sod ).ender. Leda AW mlr proof of loss N at muds I mtpdy by bonower. Udsa ]wader ad Bonowa cdomse o pm in "r Wei, MW Incomes prank. whWw or at flu uedeA ti I n re a wes taaplGed by Lender. elks)) be sppsied to ratottdm or repair of the PropmQ, if do ramoesdom or repak is emaariaiy lemout tad Latch's smft Is set himeow. Du ft such repair ad MW Elm Paled. Lender sold lave !kt d& to hold seek Imemaea ptaeedde =1 Leader lm had on appwou ty to hmM sods hopaty se mama tot wak Ire bees compio f to Larder's nddm im, prow ldrd that sub bipeedm shall be mdembm praeeA. Leodst may dielsrseptaodeds fordo repairs aid m sorwka is a sl*t paymea or Ins series Of' seIF-- I mM Site sent is mmp le d. Unim m 4ftso a In much in wrehbri or Apptktbie Law mobs huwat q be pall en attdt lomm m proepds. Lady dell not be tegrimd to pay Borrower cry btllydt or com imp m each pmtmds. Not for pAic a4(stm, or other ON psdies, received by BWMm doll tot IN pelf see of eke brmrmos proesda mod Ad be do solo ebl*W n of Borrower. 9 do tosser tic or tspair 11 not dmamic ft itatNle of tender's so" would be hteloed, tM httmtloce p?ooosde 111011 be VOW so the wmlt secured by cols Severity Idomwd, whodw or one lion des, w)ds dad ostde, if NW. POW to Scormer. Such hom mee prank doll be soak is the odes p wMW for in Seethe 2. If Dattoner ahudoos tka Tiopetey. Lender may W w olile end aide any atraflablo imermuce ddm and t0lwdf atsams. If Btrsnuer does as reaped wdtlfn 30 days me a stela Lad Lander do the imeemw cads hm elites! m a@Wa a ddm. tom Linder wry ariodwo red seeds eb ddm. 7M 3D4q unda wrld bells whoa Mee snot Is slvw- In stela ewe, or If Leader mom the Prepm y under 32 - prmWt fa an aeeo rw tamed tlt?eaau exiiiins a Lender tsI eoroomes shim to eg iwmww i' afar! Of OM at at q UM coda the Nets or this Seatrtty, bnommt. wed d8ttnW O S a 004 ((COW me tis idtle htstrwne my tl esrad of irmmd praah>tn pfd by wader Policies m+'alai the Ptepsmq, Minter as such dills we applicable to do 10 paliey of do Pro") r. Lender wry! use do Yrmnaos proaaedt ldw to np* or tatters the Pnp orq or b pr smemaa -i*W w d- do Nee or Ole Smffky hwoomm, wkdw at act: does doe. 1005987 t?'?lPAaraseM Pw1N ?1 , ? tam assn Las *(Page 10 of 67) 6. Oeeer-q- Barsewer shall -up) emmia. aad as drs Ptepesty m Botr wll Fdadpal m1mmee wUhla f0 days after do m meuein of dde SKmW bmamma Lod "ji ooubm to qmW " ?pnty o Smsetwr's Fbm* i oeidum fm at ism om yar der do doe of oeapao) . talpm Lmdar adawsrYe Wm it wtitete, wW Comm Ad not ba wralarmbly wkM eK or adelt manna q chumatsmm aaia w" are brow Soao+wr's sottawi. 7. Prm wn"eu. Mdmtatasroe and Psatae"ets d am MMtyt btpmd"L Botlowm d" ast dasaeoy, datmea er hstpdr tbs Prepslty. Am 61 P "Nly to daarkM m comm* lwtu at the Pro". VAN &w err m Deem over is nekliq is de PropMr Borrower dM assk"k do Pn"v io Oder is ptevmt dr Prro q li m det<eiLrrriof or dmaasiq is vshm Me to Its eandlttoa. Udus Is Is demmimd paramo b Seaton S dnt tapir or =waft k ttm emrsaioaft fYaLBt)a. Borrower dap Pon" repdt do Ptmpaty if damaged to woad Udw dslmtsra m or daLasge. If httrranee or omtdemmdm Wooaadt at pld in aoLroetin WO daattigt a, of ft Oft of, the plonly. Bosom pnrpoaas. ll aft slay Ohm pmemeb Io ik re Lauder it eelrmLed poo so ai tapttra and iesrortdtist la t sit* psyaeta or r In io a s aatlo d at prarms paymaats at dam wmlr is sosepiatad. H ft htsutmas or eoodomniee paameh after sot sef ci tt to impalt at ', - do :optic :aamasioa??• Samoa is ace mtWved of Bormwa'a *NblHmt for Ow eompiatior of nch Or larder or Its seat try vale mateeabls egttiat spat and bggcdsm of dr Ptttpmty. u it bo nemsabie eaaLe. Lmtder NOW htapet the i terim of the breve mss a dm PWWly header doll give Batlowar noose d 4 time of or prior to mb ml - k impeder -1 It I - aaei n aameMs amo. I. So emom Lear Appaatlm. Daiwa doM be In ditk if. to tg eras taco appl@atlos promo. On ve r or am pmteaa or eatitift soft at do dkealms of BOsswa or mA Bmwwa'1 l mWW m eemmr Bne m blly Use. eidmtdlae. or;ntanaa Wbmadea at momarm is I Oder (a Aged le preside Lauder wkb mmerld klummedsO M omwedm wkb the Lom Malmlal mpasmsHmL blehslle, Im: am Am Hudw W, riptaasrrtaoaa mmmruwg Bormvmes oomptocy of do Piopatyy n Dam m a ptioal taddm= 9. Ptets"' 1 et Lsrttre'a iraeratt IN d w PrepaKy tatd BWp yaitr lids SaasBS irdnWAet. If W D C n a laser t0 pallor dis of a mes ad apamarnu mid m oiler Sa mtlty fatarmeal. (b) dt m is a low prooaadtte to M101 ftdku* stkol Lender':lnanat in do Pt"iy aadlm dOm ula dds Smaudly I=mum (seer to a paeeeteae in' , a 4 dlm. Pmlata. fat emdamwar err tatlewsm'a atfinemms of a an %+J& mq malt prkAy over " Semrky htsstrtnsst or a Odom Area or nffidml?). w (d 11a v er gas abmdoosd dte ftwV, tAm Limdsr any do sad }q for whopmr Is ramm" lasttaaaaOL lai*sfta IN a aLmmWs I me is the memel" ?y std ayW mist r "der SWAft ft &Z V" of the Prapasty. and s nasittg adAor sapridsg des Ptopmty. Lendn s netisnt tan bakda. Asa are 0a IkWW m: (s) pq tj eq atnrt seeard by a no wttisb bu ptimlty cow deli etatiy brtrmatt: go Ill earn: sad W Ptl'Aa s tain s saotnei ' fm o ptesea its ' ' - in dw Pnipmy arsYp r-tatdsr itch &Mky fnrmam. iadtabq IN seared pakiou in a bmdovm proossd* Searlae the A"my b dude, gat Is sot Haimd a. "ter plop" to miss, ttlpttet, A&W Leah, tepiaos er betel up time mid wlt*- *do waax er eMer mb vhdneWn or an of off. AAloogk Lm*r new ma wdm mom m • and have t k atn tmda ag day or *Hpdm to do . It Is sgmed do Laadm lm s m doer no we oft do o so t0 en md I, m isAiHty for we taft any or an aetlort attllteaiaad amder this SmBies 9. 1095987 sssm; ®dAl?Ala?oe A,s.a of 1s j 1rw 3021 1101 (Page 11 of. 67) is W • Aap smoaaa 01 - by Lades a.der We Seodw 9 AM boeoras atidldmal deb( of Borrower OWN! by sW be ? wi(p ? ink Wwoft doll bow WWW 9aoaee( upcm ralm ham « LaWw rNW ISM A Bm? 110 dial Of requaitirg U rbb Sapdig latotttmwt is an a lauehels. Dam~ shill cost* wA all do pnwlA to of dte leas. if amlotnr ao FAm fm dds to tl. hopaq. the kwcWW aid dc fie We IM we aa.Be mASM Lsoft geeoc to ft =qw is vrk* IlL Meal - h wmmm ff liatdv rgdr d Mwgrtps Immune a a =M" of mddlt{ do Lows. Dorrowa doll pry the PuMu a s ninel io mafaabt the Margap itmtnpea in dhM If. for lay romm d. IfaetStp irt.aaoe atsaap tttgdtad by Loader txaara io be a+tanabU boa die amrtpp laarrar do ptv , p w b. arob monmot: and Bwnma wm m9dred go olds upaadp diftol l paA &W eW co =TV +abe egeivattttt le do hiorqm bourn" pQ4 bt cosm. at a cosAsmddw agdrdem le 60 mat b so Mom of do Moue Imor nee ptevlsady fe AIC4 for m altatatr1 law wimmid by !aide. u roMunddly agahvim MwIM maa:artoe txraraae is w ae . Senesce dmV madw to acpstmely dedytaaod wom do .rites Ate faasnaee mratap oommld?beeiin smom OW ?? will mumpt. we and ; fie ae k. uooghr*bk I= dw !matt Use LLotm k Ldd is is Stteh )sus MWft ahem he oftwilimmoll" tddaaary pd0 f1111, ml Leodw tler d rltan aot >» mgeitad 0 pay DOn "any br.aa[ a mirvi pi on such hie .ow Lander tsa o b W N"N lose }ice a ifV us rlse?r - covsa op rs dry Daman and for do FRW dst - tsgdws) aapara dadYOae - paymwta toward diepra m s aranafda y cbttt maL ttd L4uIK I I d't.tlnit . Motyage hwtaan. ltl,LAi eaar d ngte lissome as amsdldon d mdda8 die Lon aid Bormrrtr was ragtde I a ago eaparsarly lolled pgmasts teaesd Nti p mmbmn for mor" bwrattoe. 8ottowe I" pay drc ptemfao n .. - fe m*9" mae(?s laasmm is dbc4 or w protAdm a mwttlmW* lost manse, tuaU Laadmr'a agdt>•tsaf ibr ldeelrap flaamaeos aide in ucw atom whh eery luiges ssaatswtt tttdweet?Doe:9sta add Leader prw#WbA far s m* t.mtwtiw or tta ll sodntha b tttgaiaad Law. if *I% is ride Smllos !O dho Datmwa'e oitl*Wmt to pay kmm tram ptaidsi friths Nola mo itlaaa balamm ela.esnee Lender (a mW ndq *m pateAstat des Nam) ft eeraln liana k eermser dooa sot repay rite Lan a "tied, fl iono is wt a parry a the Iftrop ININWAL Maetpp innsaaa sral.r. dtdr mil &k w an aa* Inaraace fs tow hom dos to dws, tsd any Barr iaa artsaas - lank other pttada that alma or modify dWr d*. or wins )Dews. Thaw sp I I - sm a. amts .d oemlNion dim wa aW(ae "to *a mmyap low er and the ama pmq (sr patt1 0 eo - win Mwo ?) !mane m y lnre ivWebk ktdmrde obaia ed Aeeo?Moeroge As a team d flow . Lmder, ally ptty dwer of aite Note. ammdtor ifatsa, siq relwter. my Oder ashy. a aagr marry or the ftoft mq tea ve (diraody or btlhauly) amaw, that d.(w fiva (e ad* be dwaater1 $4 a parries of so vww a psymmis Aar Mwtpp Lse.to I is eaabaaaa far tlareittst or s.difybtn tbm vortpgs Mamm's title. a tedooI lum. !t aft a WI" 1 that as of gho of Loader Wtaa a ahem of d. ioaows A* to mcbmw for i shoe of Wtt pm* ma p* t9 ft faaaoa. rite ar.topemeat is ohm armed •orpdro rdrmraaos. • PueAter W AW sub agewntnar wr oat a?!wt a * asttotatda do Dwrawm Die NNW f. pry fir biaayge s % or ow dbw arim of"Lama. Staab sRwam *0 ad haaaw ffae amwad b wan we, ad ft win ant so ftle fie now m ow nfmL !005981 ?MI?Maar nq.e.ra tour. rwm3 Oa 1191 YBage 12 or 67) t f k • (? ? auseh e?Mwsatf wNl cut edfbet Qe tIpIY Uarrowsr hY • d Mq ' wqb nt?stt q the M4rt?ym baaaass emdr tie I ubmw-n Tt+dmcdm Ad of 1M r mW athr haw. 'flow dou OW faddy dw villa N n--A - avrtais diodaaamm, w ngmd and sewn asoeMalim of the M ))denims b18tmsars ardaagd mdamaYOtdb, taedfr to vralse a mftm7d it my maw" - prumsiona tilt .as wnsaeeed et tM Ihae d sash atsasllmdse er (Emboom 11- K h[eesWsseus lheeeait Pbrfellwrc All Miredbm m Peecesuk are hereby udjnd w sleN be pad w Loader. If dw Pnpesty k duwpd, ash Mieoalnaaue Praamds doN be sled so sauuntlss at repair of dr uly- If d- eaosasefes Of ssormmiesily fasible mod Lender's U=ft le set leaned. DsrGtc oat reysk stall rogoaadoo p101101F Is 1.eadr rl1dN kaw the fillet w sold arch NMM?aieoas >tsoceda ads Glad Irr h" aPPiwodty w it"M 50h hWM is assume the work esr law cna $kW to IasdePS won, pd N" so a" letpentim SMN smduaiss pro,opdy. Leader sway Per for the tupgiea and tosseYioa in s sbds dishraessat r Is a -ho as proyrao as 16s work is Unions ft r Law ltaaeds. Emliff doll a* ? asd kabb fm r? on an =0 hllemseeeom mash lANsslhsosrslraa'ads. atM dr110ratl.re r rr fs mat soosostlntlp fladbk r Lder'o ssatehy world be Iraeaod. the !d<rodiesu hoteede "be ?pp?o? a dbe sate mowrld by fhp S.mreh Iaesurawst. whether or as Ow due. wih do am.-If my. Pd to sorrows. Sack MMxlbseoo Ptocmb 90 bV appNd Is die ceder praMded it is SsVdoa L Is do wem of a 18W uddgd. daMuckn. or Pau th west of tee ftGjwV. the Nbcoleaatb Troeeeds iadl be spplid a do same tsomed by the Soasig lnumsmt, wor rot dws don, whh de a mm. if sq. psld q ssererM In d18 want of a pedal Wde& desuuedon, or km In Was of the Ptaputy he sick do far mast vslae Of 98 RW" Iaaae"- 13 bafow 1118 pattW lift dreboadm or bss he wine is agodt a or tyrer dada dta amemt Of 04 aloes weaned by thin Secully halromaa b medhlufy bdbn 1118 pn W taldq. daeusdiaa, a Pas is wh18, vim swm mr red Lrdr atbeavrita mina bk wathaq, the am 1, by dads $ ME* hadnesdt dual be reduced by Ow awoaat Of de ICAMNOm Treads midpw by so Mb-" fk elm (a) the tool m mm of the amts seamed Imlgedletdy 1e0aes dw psrtlsl dsswrdtioa. se ku in vahx divided by (b) due fair aw - Was of tb po"m imoediasay 1118 patW ltllm& dimusabs. or lot in valm Asy bslaos dai M paid iasoraevow. L the swat of s elda0, dwoucdon, r loss in wee eftie Property is wbid aimfar mdw wh18 Of the Prepeny V 113 btdsae de Potted 111 ft, dmumdos, or lm in vales is Pau dims do swoust of the olds taddt _ --My bdow die petal aMm, dumeadea, or IoM is vase, adds So Oum ad Loader sehdrein *w i• wtWos, de MiStallsommil Paooeeds sM be appded we ths aims aeosrud b dim imumuM wbethr or as the somas an dam due. B sus Iraperry ebaadwd by soeeodrae. or If. d w Baia by Loft to so 00011 that the Owaft Party (n &dud In she am snmmnso Odds q a" a awns w muds a OWN the duffildel. sonaaar fhik q n*W q Lady within SO days mild i dme ths eeft b gm fader M as tl ?It da Misntlasa18 Aoededt elthr q naoladee r rpair of the Poverty or is, do tied tnrss Drtowr 1 as wbatMr r not rhos dY. 'Oppgiss Tatty- oleo dha tlied peaty P c or do rem" w bisessaaoq Prwsds. rrn agolmet wlaw s01ower has • d& ad seems is So OWN "be is ddmik d am aahm or prooesdhds, wear" or aioiosl. b b*a dim. in lader's No" Oedd noit b fOfflhaq of the Prvemv or Odwr tsedutal la4dmes at IAmdoes kwO 6th Ire P$Wmty or dg% ntder dds Scarcity Iastseoae , srtowr an Vail tact s dab& ad. 9 woetseadm has oeeorrad, nissI I on pnwWmd is Sedta It. by mosiag do sdalod r poormdioe to be 1006997 u?ts1?I rwu `"? qer w* a fora aqua 1101 gaga 13 of 67) dhndael with a nditB dwL in LOma'a )Odpmw. brtetnn of to property or other wAwW wwafmomd of dander's bswm in dw Pmpwty or t radar *AF Sworky bmusswoc 7be proweds of err awmd or dda for dim" dot oe aw boop b the impbmrot of fadw,l laeetest is lie pmpaW as hwwy IMEW" N d tdW In pdd W l aedee. All h/bediaaaat ftiesede mil are art applied to mmwWoo of npdr of dte f4eMW fte ba eppiled In dm order provided far in hloemwn L IL as wwrr Nat >Ieleeeeil 70%0 mea By LOW* Not a Wahsr. Bwtar M of flte tiara for pya- o<MdAwtlm d amotmatbo Of Oe wow swmad y dds Mawdty IortnimW !per y Leda I Bar F of my Strww r In Ittmtat of smawar ehdi ow oporme to abus do D*ft of tatvwer w g Brewames V MOM Of Borrower. fatda" ww be ngabad b oammtame ptooee?ap aptat any 3acaamOF b IfnmMal Of BOrrOwar to to refbae to aatad data fa PRU" or *bwwim soft ameematdeto of 00 oar aaaead by this Sma dW laattmm by ante of wW deorM ante by adated ery Strtewttaa b INWW of Baetaarer . Any %* otaoe by Laden is C C d* a" :iM a * ww" »on, Lama's awwwae of Fe)-- 0 boo died proms. or ER lmmam Of a nOwr or in sa9arma lad Lisa do aoamc thes des. Aw oat he a waiver of a pttel06 ft owdo of to ttnoe ay. ML JOIN si !honored +lobfi 4t Co"Aw" at fbeorara and *Mk m Bard. Boralow a"a mofi sad +rraeF tint BaFOwmrs abti fpdiona sad liability rWl be jtdot tied wren!. sawp r. soy Bartrnrar Tft aoyip dds mSWWW y%Wws w bw dw not eaeame the iota N "oadpFer'k (a) b this MW %W W% . M ad M147 dte a«l PWS tmm?tt In In hap" wades dw tmmt mb ltd a4 NoWumat; (b) P?fy oblfplai to paps dw Area amnzad bq fhb Sewthy ltN&i Of Of W S h afQr a od (Owpm thatj,mdvsad dam.rim any wlher Boetowu om atop m wAnnd, modbyy, b-1, or M fwd to the terms of dda logoft bwom w w the Naas wamtc at to the prwhirna of soodoa It. my Smxtmsor in btma t d Eel "In who owtraot Batrawer's cedar rids Setat ky b inrma at in wtkbB, sled b apprew/ Iy Leda, Iii Aide an of b?pYtt ad bawb wdw mtb Saawy Intprtaatt. Brae ww shr>i oot be mtand *M Bartowees aM4oema ad a6 ft Dour fhb Sanity brgtwaw mud Lm*r Woo, to a& ttdltea in naft The oovmomra ad ovum"" of us 8ewity laenanat drp Nod (adept er provided to Saedatt and Iaadk dw AFMM and ardpnr of Lander1d. Ci ups. Lade any drop tfonowr few for aervkas In Oaamedioo via Bonl?wer'a deI I . IN dte p rpaa of ptoa dba Larder's fwtetaar b dl ?lmd rWft wider dds SO" lattmeaay bebodhw, bet not Haked Co. am emp- Gee, ptapwV WWoo a and vatradoo hoL Is need OR m4 stars Gar, dm abaeaa: of axpm saehaFfty b th 8aanky Iermmwat a Oita a ep wit to to Swro d oN nw be commuted s a p10hilki I a the alojiap of Mob fee. l eedn wW sot drwp hol &a LdMWd Apokk* LAW. Ntlr b tm 4111 v vVebmet adlyirlea t fe lkribr iokrprped so List 00 bdnsm or mans dean d&W aoBetaM of b be wbodol IN aOaAamhaa wfdrdw Lane eared the pstaeitm I Bsfm. dtesn (a) Ow ado loan drop doM bo m& W by Ihw atmt•t oeoawty to tetboo de d P b me peenided Bat; MA (W mW some &ady oolltmed film low -I- be ile tataMtd parr.btei !babe ?lq mlbrded a Banana. Lsndw voi r aooaa a loft this twtnd y twdmdeB Waal . owed atdn dM Nob or by twddt a dhaet 1 a3 b Bonewer. If a rotted adoon dr mdaadon wil be bend a a prtbt yrapeymm widwat my pmWymw chop (abedw or trot s MalaDrtt slap is provided far rider ate Note). Bmrotree's of any w* whad made by of wiled wN condom s waives of wiry tilt of acdou Smower md& bow wWW oat LS. NlNltau Ail notlea El- by Harrower or Lamda in amuldoa wffh this SON* harolo t MW be is wM M& Arty w ft to ffo www In Cowacdoa wtmt Lids Seanky houtwew shod (a dsmoad to LOIS917 . earn ?•u?PN wow r.? n w +a ' ?? Fame stab 7tw7 (page 14 of 67) hm boa Siva to Bawer "a( mWod by fim dos well or whaa actually dolivorad to Borso s notice, aYnwsf it ass by odic sane. Mabee b w w are Bort owar chap eowrdou order to ad Borv r radar Applimble Lw atpwedy ngobu otherwise. The modes addwas shall be On hopoly Address Lastder of dsdposd ¦ sobatise soda ad&= by rodeo to Lander. Bee tmm dall pahpdy notify bw?j dkwp du ? addrns. If lewder *dflo a I c, dne tar apm t Batowa'a chop dom. *An Bortowta There my be a* are do4poed retice eddras onirr Ode Swift ? lovowart rt a ?= solos to Ludes loll be tivao by deUvaft B or by mWitlB k'by AN so LddWe address = doe. Any Oft led heroin woks Latdu iwu dsipaed walwr aebbm by sotioe to Borrow. Any odes In asaaedes with No iaaniq Latrwataal 00 wet be dewed to have bum lhvn to lender wstil aeenlly rB' _ by 1 order. It any nodes us4dted by this .Tensity fr strum t Is wise required unit -Appuaible Law oploom will eddy the ooetspotdiwj raga rem own this bormm IL Govestaist Lauri Bararsbi ft Bata of Coish a ilm This Swwiq botrones Shall be Bavaad by bd vid lw ad do low of dos )uriedktim In whlab the hopetq b foaled. All dOW and c? oonrdne I in die Sneaky Isswso ass aw4w to oW roods not and holudss of AppheaV Stu be Slew. diewa? = or bwNdOy Allow dw Pardo to apse mmeaot or It bw ad de avert tat L Is h aqr prvkhta or dame of this Worky lasanseeat by aotantwbW ta Law. sail wodikt *M no able( edat or X loft or coofta; sic New wfiicis ors W & cuen be $Wm atlia wldwo to eafthi ft proviwian?w of ? Socerhy lsa?roers a de N As WO Ib Oft Beet, R) Iu w ww. (a) weeds of do asoalise polar "lean sad Include as sws words or wards of the fa ides nodes, (b) words In die shtpla shall moo aid Iadsds me Owl W4 Woe wan; AN (e:) do W M 'soy- ties eab diandou wiWs.t aq obliSMion to tabs & salon. 17. Bswewu s C1spy. Borrower oiled be $lvan one e" of the ]Vats and of deb SeomiW hwa nmL fil. 'ltsnlfe of at h"way w a Badichd bheawt In %awwwa. As eyed it this Sadao 18. 'INK is ft ftepaty, wsaar raw ko or aenWdd I 1 0 be the Property, behi at, MK riot now m. droa bess ieW knows baseI In a boss for dead. oor - for dead, iutaBwsst do comou of saw asawatt. the brew arwAsidt bl fha uttestkr d fide by Bortnwer a a Name doe * a pwre. h ens manor a lw or tbs Privoly or any Iaast is so hgwty b sold err tramband (err if ft3owae a UMW parson ad a bustled i smat bt Yarower Is sold of nrmfatwd) wlrtos Lsdeei prier Isnleteee IL Plowever. this aption don not he awaahod by Linder if each wdae is by WooModd by Appllable Law. If Leader seenbes ddb spdok Leader shill Siva Butoww rake of sorelsaior. MR aodoe she pro" - par of so hiss dws 30 days Is given is Moardwe w r Winds VA" Bemoans am pay an sums, aee.eed by this tkatri Instrument. V Bummer so 1S than, aster prior to firs 1 -1 of this period. Lender sW nvohe ow erJmeNes pamkw, by 111111 SeffiWiew Lteaae w wbltert fatless slew or dwaed an Harrower. 5. Bhsswou a kltis to =drsats ARer Aaeda>,tisn. tf Bo mm news certain ooalltims. Borrows ahal have the 10 have afaetxsmt of ebb SettW* laartwranl dlaaaattmred a< aq time Pct to the sdiest at (y an dtga bdon ado of the ltwm PNOWU to mil pmra of oils oowfaa+d is Wis lsteMq Losasmt; (b) uoh other period a Applicable tr aitm spec* for tM saaiaaem at Botrows 2 do to niame; or (C) Mary of a Mtdpwats onfadtq Wier Soft iobhaas. Those cordidos w that Bowowa W pays Lewder all'awars which hhm wants be der vada (isle Swift lowww t and the Now n if so acceleration had ooetwrad; (b) otaes shy def" of any other co% w u or 1005981 ataaNAl eras rW1201e //-/ /Yea sm 11M (Page 15 of 67) • i Wommm (9) poi's so apemen ineurem I in aahre ft Wfa Std Add bsaaant, rndndigp, but Imbed m• raaaomable aarmap. has. mrpmim and sleds bcs. No otter an lacarrrd for the pwpm of p uWq LwAses =in arr. Pruprey end d m order this 8eoorby tuts u went: send (4 atom sari ad" a LarOwr any mmon" require to amen rake Lssdw'I edema in dK P+opatr and rWm under Us Saadrby In--m sst, and Borrows ablipdon b py the sums somoed by dds Sedaity Imaaam on . shall condom uaelrnpd. Lmtdw o" nVin dint bummo r pay toO nWANnow so ad consent k .m or am of the blioaims fdrna, a selected by Leader. (m) a* M mama order: (e) atti5sd chick, bank dock. tau mder s check or oahiw's clerk, provided my Inch cheek 4s damn upon by a blend spoey!? Transfer. Upon Mammonism by bornowa, dds? Instnamewslity or : or omwe senor "a rash hl$ efloodw as If mo moderation had o? however, cis rwh rainemm aM not apply to dw one of s mal ation leader Section IL 20. Bide of NMq C map of Luca Sm king Nudes K Csbranea, The Nom or a parM Warms in dm Now (talnhw widt Akio Uorhy lowmnevo can be add on or wore drums ww m prior soft so Borrower. A ark n& mob h a CMW in the aft (be as the 'Lan 3wdme) du =00 Parlodic Paymarm due antler the Nee and Ws Secnaigr I meettmatt ad paefasmm ether =Opp lass servieht ahiitMiona cedar dr Nato, this Sernky ImmouommL and Applicable Law. TLas do mip)rt be an a am m3anapes of an Loan Swvba wuiwu0 b a ads of ton Note. N dm is a etettse of do Lass Seroicer, boeroaar will he Oven wrhmm modee d the champ which sups rile the Inmm mad addram of the mew Loa Sorter. the addrime to whiab poUrmmmm ahodd he meld and my other rdhmmdaa RZSPA mquirea to ammecdom Widen a nodw of uaaehr of aerviokms. If dA Nets is sold end d?meder *a Use is serviced by a Lamm Surber atkec than ft purelanma of In Name, he mwtpp loss wvkbs obiipd m b bwsmwo will marts whb the tam Swvkw or be umbnet to a wnmw Loan Serrioa and we era am®drba Pwdmaar` valm a borwise provided by lbe Note?asmway aonmmened. JoK at be )Woad to may fodkW motion (w sidw as a die _ of a due) do arils Amu do other VaWs males possum to lhk Security Isrumm or *u the odw o has broadmul any pmwWm at. or may day owled by raw" c4 this Seaway Instrument. small such borrow of Lender has od pp W ((wrh ach motion than In amplimmw whb the rmquhwamm of Section IS) of sock ilepd bermhI and dfrnde I do taker pan)' htemas a moo mtble pcdod Moor the oft of sorb modes to take eormetivm shoes. If Audiume Law j;WvAN b- bled wort dopm beams oertmhh shim w be ubm, that time oppmbmtp b are Sire In beemombl pia of tda pmuVq . The mcdbe of acdmm oo and Bouower pn*aasm as bodes 18 stab be in wAW do aabe ke sodus of ... I, d, and opportunity In fth cote e rm aebn prorWea of die Sermon 9o. 21. liaaardsme Smbelarem. As seed b We Sudan 21: W 'lumtaes Substances' Ins those mrbewmea deluded a made or hssrdow wbsmnces, pot umme, or wama by Bmlronmomml Law wA dw b=. vdst* a?wnun , asomids 'N (lI br or male pmiesimrw prime. bode pwbm (b) 'sw4bomm umal t{.nr' amsa hderd I m and Im jovial W, - Whose *0 PProperty is boom no mote b balik aft or avisoaaernd PM= $^, (c') 'Barimemssml Clatmp` btdo" my MWM motion. mondial medom, or amovd action, «ddbd to Bwdvm need law; ad (d) an 'Endrmnnmtd Cand(tbn' Income a eoodlties art can assn, oau dbum is. a otho win &Ww an BwAmmmtemd cwanw• laaspei Iowa m .., u., y , ? n.,M sons date Mage 16 of 67) 0 • 0 0 Honors Ad not tare Of perrok do proaut1 me. diVoW ,toe..e a relraas of aqt• Haardoaa Sttbaa m so thraataa m mlooaa a4 Ilaaatdooa lbtbaattcaa, a ar is ISO l? 17 NdmU oneMar tm do. sot dlow aYose doe q do. a. Ytbkfg RNMEAM the ?q (a) dw is to vbl as d aq hoo.wu) Law. (b) wbtoh tasttm m Favirrmerdd Go Lion, Or (O) WM* die to rho pamame, vw or namae of a Hasudms 21411010% eremo a caod ek s dot odrandy &MM the wlm of the Ro wly. MW p? taro a.almnm doU aot apply to dr w0. or AMW on *A Pte ely of amdt girMiYot' c7 Namdo?r BLbdaattto da>< are iced m Ie rp¢apdfafa t0 nand oWd=M noel ad to ardowoos d do Vail act 7lmilod to. hoibdsm ata un oa ha tomaarr pooducp). 1ar1eata4W pollspb pm Lender wrb a mdoeOf (U my Ir" d" 4111101111, 3aaradl ISM a odor attliott as {ovarmaaotai Or Aaau A- Subsiaow or swiroto??? Of "= =Pat PwPM aid off I" 1do nett , (6) my HaNaaam IN CoOdos. heir ft bat an limittd 10, . api L- dbtbttl0, rdoam at ft m of velon of aay Haaadar fMhataaoe, ad (c) sly eoodlnon eaumd by 04 prumos. as or niew of a Hamden fMtboma" widab adversely anher the vakr of --e Moyer". If so? own lerrsa. or b actIw sago:M"w:aor wah?ortq. or ag leivw INKY, do wy amp?c =mw odw rotttd"M ay Haan w in atadwo0, &Mto a ? abm Ot w ny oanbiipdo0 Y Wks ! -1 t melee lbr a dvilemoaaol t]aawp NOWUMPOW COVINANTS. Borrower and tender fait. OOaeamt and apes w fblmwa s:. Acedawdoat bundts. Landw don dvo aeuoe to bsrrewarpear a aaoiamds. ititBiwt.S smasaur's bomb of aq aamo w w -0eaamei. a lldr SWAIAY &MINI UM (bat rat Misr to secdom as rmda S d im U corks AaoYtab)a Lw pravfdat odwwb* Later tM8 las" oreewr af~ amp altar IYapx ItQ tba bs p) tba oeilaa b cars the drltaltt k) rrisa the 40111110111 Oman INS orb asd (+ Mat IN.. a ew dW s accdseMmt of to now mow - y 11warby koinno.t. foodoatre bY?nor roo and mM of do Property. Laaor dM drdbw tatetst lanwwr of tYe e?kt M ++iootsM allot .oMlststlw ad fie rider to tmsrt 1a the Ieratle.me pro rit non-adtttna of a ddldt or arty olhv adows of rawer is wedrMtsr Orel larO?sw awe V do Mail is not cm as gadISK Ludtr M In dp ft to dNUIN °d Is tUb of oU now ownrod IT dh Ssarly fsabtamsat Towlew roll be mom is u1im all upo pier gr iwao-Nmb p-.-Ad loo atlrOb bw am OW. Ibalmd to. worom, fso and--UMu of tills svideaoe b the rattan }mmiw b22, y APPICA L 1"d. ited- Upon Oaymad Of dl stmt orated by this Swo ty lmamou. thla fieearitY Imtnrmet and dm wane aorwoyed doll aamiaae and bsoo w void. Ahw mck ommroeo, Leader dad dbdwr and sadly d1h 5101047 Grttrt MOO Borrower doll pay tW rmordadm cmr. loodar ntq OW boaowsr a•im for Us lonaity b eaimaat, be Daly if da: he b paid to a ddrd pony far mrviem daMSrad Orel tie [ of rise he b penaitq del uww Apptlmble Lev. 91. . m dr m parminsif An &" I". **voa ad MOM aq orir or do0rots b m aifadse tftb kY bneby wdvao dr hasdlt of AV. pooh Or hoomomad for my of aaocatien, adodoe of Z. nwgdm from a ckl wt, bwy sod mlc. ?S. Hsbrla For" borlwpes dme m room pwINO is a*= 19 Drell emus eo Doe ?? a do oooreroeaetaa of biddrb at a *w Ws on or Other ado pwolon as ft SwA* 7d. Pa dws M-W Marlptpo. U =1 of Wa debt w=M dW Sow" M mteat Is' lot to Borrow 0 acpiro No a tlm Plop". abb 8aoirity houglo t doll bo a pnrabma ataay mom". 27-1 alarsot 7taY After J-*msL Nnwwer spm dot ft furrow ears p y*A ally a bloom to amend as ft Note or bt on action of mor%W fma tame den Y dr rap pay" !tiro doe ro tha Mbf the NOW 10059!7 wYwre 4k~11 Meow ?n. u.r a ?-- , 1'ww aoso 7/01 (ftge 17 of 67) BY Si MG RLOW. Bonow accepts and area to the trims and oomauts weniood In dds Sam* fawuaem aad In MW Rw" Ofto ad by Horramar am roooe W Wkk tt c m& \I.w A - (Saga 8atastha Thomas p,.,.Kr (BUD (saw (Sod) (s°a aNi 7AOmai ,ge,i,e,a, ,ao„? (W (Sean sorrow ems 1805987 ek~AI Iiw hq. +a.r is /ors 8019 IMI (Page 18 of 67) • cOmm0NwULTx or mmnvA,arw (W. ),A J c.eey ¦. On ddo, ft dry of August. 2106 bdme na an edetaissw officer, well Uy a-I ' Netasche Themes ime1 Thommr fly P?A1 W be the PUNKS) whow to am to a me (or eelmowdedged diet l dg*Aky awm d the secs u mm Wm eubserJ6ed do Wtia . wflfiin iro+moext st ad Pmpoip bereim ooauinod. W VMNW WRRUW. I bermft w my load an kid seal. My COMMWoa Eapim. oea+aaesaesi, a f rw,.yn.,r, IIIIIIIINK WINE La MA.t mWp.umWypA1e wtac cow ~ bbulm fto m W IBC, stt. erOlBoa 1. . do hweby eeedfy unt t!e wntot sddteu kbrn oDwd UWSWI Ig P.O. Bca 7016. Flirt. LII Itt7 l.2M 6. Vr"- try band dds 4th day of A punt. 2006 . Apseti(atppa 30059117 4" AWAlaeo* "verse Peenttm tot ?(Page 29 or 67) S 1 In witness Whereof, the said poly ofthe first port bss heratato set his>mwFnd FeFI the dw and parr first above written. 910104 .Fd ndtv«ed IF tu. P.esm?e of w F. Pabn CERTIFICATE OF RESIDENCE I hereby =*, that ft precise rniden of the Oriatee herein is as follows: 333 Roxbury Rand NewvWe, PA I7241 A.r..yrASrs>kds.re FIDELITY CLOSING SEtiYICB, )]C xi K tcmuonto. surman Pm counk M low COMMONWEALTH OF PI KRMVAMA ) COUNTY OF Cu?.y?0?fyt? 56: On tMs, the day of , 2006,1,6 ore mo, i-LNotary Public, the aada:sigood ol6oas, parsowliy WAYNE F. PATERS, Imovm to me (a uds&ooorily psovea) to be the person whose mane is subscribed to the withion iastrmneat, Fad admowte* that be eaaeuted the s for the pnposa tharda corrtsined. IN wnNESS VVf EnW, I set my hand sad oftial seaL t rlFw6fts Mat Nou" PwAk 0 ftoll La & ?Ifmw 4? iiMwa.a s0.sose (Page 20 of 67) %9 SCHEDULE "A" LEGAL DESCRIPTION ALL the M wblp de m*W reel scale OV and being dbwle In LOW MM ToMMI111 , Cdnnbsdand County. " I'mmOmkoft, o Lai No. C more doatibsd (n, aoowdw" WM &Ibd *n Plan I mum I said hel &AiOv Subdwitic ' w" Etne PlaPlmn h110f UM as ban $sPpoMad by to Spp L kmur p pNuthorYln and Is record in CtsdmW4 County Plan Book 79, Pape 143, w follows; BEGINNING at a sel n oad epke In public road SR.0007 (Re*wy Road) at comer of the wldhkh dwadbw pact NO parcel 8 an No above referred to Subdivision Plan; 0 m r ce done Raabhry Road, Naft 40 deprr Al inimules 4111ssoonds East, 0D.00 fret to a point, lo Nm of Nand new or !only d thteyne F. Paters, which lands Ohs w" dowted parcel N bakg added to M a lot uMftn; ftnos along Pelars' ttlnde. 8otlat 40 dWm 20 mbUm 14 swords East. MAD test to e sal Non pK In Nns of hands now or bbrrasrly of Elwood R. and DwW W. Gtrtdralk t mm shore *w of Isnds d Gut wK south as depnes 22 rnirwta 5a aacmw Yvad, 30.13 fed to s set Mon pNr at oorrrsr of Perot 9; t wm a along Nrrs w panel L Noreh 48 degree 20 mlmtes 14 seconds WSK 2111.5O feel to the ed raWcad oft st point owl plats of BEGINNNG. CONTAINING 0.2014 saes, in w=dwos vft to above mkrmd to Subdivision Plan. BEING Para1 No. 154Li.0411.01e. BEtNO the owns prembae which Edgar L Stun and Lois A. Stem, husband and wtk, by deed dated Oseenrbsr 31.2001 and nodded ,kmmy 11.2002 inCumbw1mnd Caunty In Dead Book 249. Pegs 4M5, gran Md snd corrayed un10 Wayrw F. Pslns, a single pomon. UNDER AND Sl1 ECT to b Mrkg eel bm* lkm, dedksted right of way km and o0w nobftw arhd amd kns as shown an the above rchrnhd to SubdMWm Pbm Qou+pe~ooeotYFOVwwosooeel ft (Page 57 of 57) &VUSTABLE RATE NOTE , IaI Iamaolwtttlslhu (LIBOR lades . Rua Cops) TIRE Nara comrARts PRovniONs ALLOVI7NC POR Cumn IN MY AmmuT RATE An MY OMMLY PAYMENT. THIS NOTE LRMM THE AMOUNT MY INf IMIff RASE CAN CRAN(X AT ANY ONE TOME AND THE MAXIMUM AND MINN1 N RATE 1 MUST PAY. August 4, n" Neavme !A [ail) Icily) - (SuW 332 Res?ury Rand. NewWll% PA 17241 ( OMW Abler) 1. BORROWZ" PROMISLTO !AY In tears fora lost *d I Ian renewed, I promise to pay U.S. S UOMM OW WAM IS called kwcK, I* the crAw Naee to die oof do Lender. The Leader is BgdRM Cae}orellm . I will like w chock er mousy or dm 1 ordwsmod ibst lbo Isdrrm ey bansfsr lhir oil Tba Lenir «anyms wbo t+Mey thi. Nob by tr.rrafw and wbo isemiad to teoaive ptryaeraw trader Ids xaa it oaBed tbe'Yfear Acidor." L RVTERZIT low= will be dmpd o. Irepsid pdneipd votil Na foil aaaum ofp n*d Mm bm paid. I -M pry merest at• y mlZ eato of I m % TMs warm rata I w p.y my ,.?..?.. in eeneriNN wo slodoo a a11? NNoolma Mm mkmK rob mWiad by this Section 2 and Seerloe 4 of xoa is &a wr i wift poy bor3 bairo and agar any dofrdt Awar&W is es 7(B) of Ibis Note. 3. PAYNM14U (A) 7Ls..d plees of hysaate low Gopimeber I wql poy prbtcipai and httaaest by ataldag a paymom ereeyatoadt. two t.aMs Ii?iw psywsop °A da lot asy otaoeY aoaA 6?i W 3, 20Of rhorgea iowbad below tW i ovety wwrYh u 11 i hve paid all aRhs /Iloeipct md-' ' and ?M t odw aY ows wedw Ids mm. sub mamddyv will bo appbod as etbe schoduled de. di led will be Mplid io Jmwm before pinolpal. Was Argrst tr SIOf , 1 ou awe moww mdw mil Now. I I will will? ay aoso.?oSegem iinsnfan ooTle dog deg, which if aided the "M.Oority Dm. plm Circle a st difrmt??Distifrgoieedo by Ike Nots HHoklcr. NC 2f271 Faek a(my b dal tsow* psymeur will bD Is the mom efU.S. S 754.7! . This ameaetmay chasm, (C) m*mftpsymntCbgga Opel SM IN trr MMIlliYlsywe t wUl vollect chooses in dra uopald ptla*d ofmy lum sal is me blemsel rate Ibot I sood?.y? The Nolo Holdx will dstmmhm ow am bww im led be ehwoul mood of wry eendh y psymeat it aooardana with Sooticu 4 of"Nora bt.hmftA4WAbl9RmNwA4A rlv4lm EFSISN(LOO) O%ooylvaois Ve k,) Lon!%WAO 100.5917 Paso 1 of4 Iaieiok '(Page 58 of 67) 0 4. ammm (A RATE D MOILY PAYMENT CHANCES ! 1Ae 1a0eare I wdl Pay cry CbWW oa Ampel 1. Mg. and as tW dry every dXlb 2111021d be ft- Each dar an which my 'alma( rate eau mp is celled a "Manse Dab.' Ths Iadac wAlt the IM C loW Due, cry inteeat ab ang be bawd as m)ades Tia'iedve' b the avetaga of i?las6sti rasa for t+ -"8 6 U.S. dollar desamiaalad dapcft is eba La cw nnloat i't.i80R'k as pubWbed is lie WAI ilbwrJbrrsst Thermo team Index Open available a otibe &atbseleas day of the mae1Y imadindy de tnoedt le trhleh tie Clasen Dore oatxra 's ailed Oxc'tflrecst Cede:'. Min We% b se b%W avegow on moic lbww win etas a new index 1Mt is bwedd'yea aompoable htrataw0a. The Afore HeMei will give ma aake or Ode ebohm (C)Cdcaladva If Cbeagev 0 1 m ai ChUP Draex tie Noe Holder will akuiw my new bttaaw m by oddiog 1.798 1010" (3.71A 7i) M tle G1tnsY hdmx.11x0 NOxe Helder will lie!Nord dxe xewk of Oxie eddiliaa b 4r wr?ere moe point Oeyamoestaj t will0faft be my now ixawat swe(0letil the aeon Clangs Dw i7 sled is Section 6dow. We xollnded The Nae'bidet wiD tbea dwrnkbnv da amewd of de sestltly payeeat that wosld he exxii?io&st so mpg sic WWiWd 1 dku 1 ae s paned to owe at da Chop Dos is fill ao do bfintaYy Date at my new bkm fate In lebaballagy eqW payaamsa Tha teal oftits a'aweloe will to the new noaset arty moaft payemL T Lkedte on Interest Raw Chomps . 1 0 unapt ale 1 on ?q tse- oplyU thrust Charge DswwRl act besnow dkes I1-10%ork e ben 8300%. Tbwaaw"WgaW et! 1.:: none be'oua - or tkmesead on asy m*k psepa Dees iy wore then ampw-.-tw wil (I.000Ii) five.dtsrsteotisaa, I6avsben for the asmend. My aaseat raw wA nave ho {tutee don 14J@Q% at Iwo flan do initial et tab ' p for is Section 2 of his (1) Eliaetlvs Hab arCbarga "y new be~ ate wlg beeowe eff"Ve on sack Chmp Dale. I will pry lie comsat of aty new'mondly Pv)vdts last teopltly payweet dace alter (ha C6aega Dab t txo4T she weoaet of wy mostly (P) 14ades arGbmages 7h. Web t4sldr w? deNvsa es'I so wa a nwiee olsey cisoges it ay tntersat tae and the smwet of my ?? eo lee d 6 the GdJwiw doe of nay ehstp The no" will fneixds itbtaadoe ngnied by law b eeleprarc aabrata Porn wio well aatwer say 4seeaon 1 way ha a agrding A BOR20WZR RIGHT TO PREPAY W PnVaypw 1 hove to sisltt b wain paysews a any tias hater they as tire. A of priselpal ten't' k ]asowa r a 'pr9syma r. What I etais a Prepayment. I w81 call the Note 1'otdar in *skkt~?1IMy?? a tieing en S I ealee a paRiatpevpyaoeet, Rats w81 M ao ehenpe le tie des dab a in the awosnt edawtpsed(y txyweat raataa the P"Bmb as B elan the lain Charge to three ? My P? pwromem aq xednew fie awsed of my woz" Dow bW** W pleps) maybe olfhvt by m iwwut my C PraP K "em Or tadktadoa be in my P Mcim (a) Prapayawtt Peasky to the event.dness the Am 2 yaws aAordo saacufiwx of this Nab„ I pals s pespgswu and tiePeep?maetsnaeda lovely petoeet MM) of rho t Wad princissl worst of lie 3otn b pry tsslw (t3W awl peetoe, 1 W11 P.y a I im o> r)is a W-W DOW io ioe i6) s,wedxl vdamoe iswnvt as ra amum ?!4e? wWrL k is assns of CCsidr will sot apes a perlq iAer afthe lee widde the tetslve (tzl peed Wind The Noe die 2ad aashmmy of the doeofecsadeo aftiiNota. Low Number 100!987 Pape 2 of4 W"DEL (Page 59 of 67) 0 0 6.IOAI'( CHARGES p sad which am maximum lose, b {p1Mpl Odo do 1ala0et a Other IOM aoilaoted W a be oollacted O aMSSedon whb this low a>oCasd 11t WllW% am 0) my am toss dwp Shall be seduced IW OK.mwt to duce da charge a 6e pa.Mad Usu: and (b) ^y ass d aady soli aced has mss which exceeded ;.=I= w1 bo wf'W a as TYe Nob Iloidera"ahteae b babe Ors ralbtd by ndoaiu f the pri@KI ovie under hie Noto or by making; a dinet VaYMN b nat. Ifs ssIia I nehmtss prtwspd, the eeducdoe wfl be oeetad asa Pia PaPQ, - 1 7. NORROWIR'S PAHAME TO PAY AS RZQUMKD W Iab =her Overtee Psysevow If ebe Neb it not received alit full swoons army moo* paymm by the osd st 13 cab dsrdsys aM tba dose it 4 ds, t wlt pay a Ira chassis b the NOb Holder [1te etuarrt of Ya chose Ie 3M %of ay ovwdeeyayaaet at and Wawa i wig pay this lose chnga bet only once aw each hoo psymset V t do not laY the full ammst Of each moe&ty paymna ce On dune it is due. I will be in ddm& (C) Noah d Ddeall If I as in dalbsi, the Note boNer may sad we a writ em sodas lolling me flat (fl do cot ppaqy the eeetrws MOW .by a . * * the Nom Holder may sequins w In pay iaaedielelyOts f ri a.soe.t ad pebdpal w;is has and b biapaid ioR 21heio me or dodo ob that amount. Mat don snot be at least 7o dryaafter do atb on which IM byodtsrraML (D) He Walvw dy Hate HNaer Even it,osaflowwhoIasiodshuktheNanHohhsdowsotsequin sab Wood" lybfall u dsaibed above, the Woes Holder will still have the d fbt b do so if f an in defxott at a baser then (9) Pay~ of Nose Hddses Casa and LVenses tf for Istlb Reldsr bra ratpNsed mss b yay b fill eadescribed above the Hots lxo(Ierwill havr thr eidAt b aw ppe? back by ,r 16r all ofia now and an yomes inaafotaiag this t" to do extant no pstddbind by sppic" taw. Than emWensatorbdyforex mple,ramonableattoseyffoot. • GIVING OF NOTICLS Wells aMP&" law _ R Orby M sun nail6t= a it by nt line .ts dl to* oms e a tha atss tharod be plot In teidaN s, Micro apddea?ss /etlwrluNtole it by does n a munt Propeety Ad3sa above ant ditllasm i< glva nomw a sodas of my dlf main admss. Any antics dw ant bs liven a da NonxoWrUnder this Hole will be gives by ddlveft h arty ate ft ltby fhos loss otaq b Oa Nan Holder of the addsws sabd fa Sucdm 3(A) above ar at a dillwmom adios ff l act gives a nodes of that d w*M address. !. OBUG.ATIONS Or MRSONS UMIR TM NOU If aaa OM aw sign Otis Nob, each ptasr Is folly and pearaly ohUgsbd b hop ntlof *a pis wads labia Nate, aebdiag do pmns b pry the FA antowt awed. Any ppaaaaww whoa a aawgorattalravoflbiaNMeisaba6iiigttgdtodothwaOittgs. Any wboatlwowrOota ? ? abNpYeta a?¦ gu?or. asroty arendMaer of tltk Nob. is ahoabRgabd b ?eyall otRa wdr is lbieNotn. The limb Aoida 4 aft w imiots yoder d d. !4m apimrt Inch 3a?vi0adly s sgsiust of of w ee edsr. this marts Ora sty ana of tr soy bs ngoited a se all of bj woautsonad wdrr Ole l0. WArVW I red app caber pasaat who its obkgadons under Ohs Note wain the dgltb of pvessoMard =doe of dislawr.'Awwd.d'ssMS the ''? b repose dr No(a ider b dommul paymrl danmub dra Modena( sasstba tw to regidma ie Note Aolder to per a mda to atbn penor dam abatis dw buns wt bass Mlism Lon No Nwt . _ k j-LDP I.or ba: Itt039g7 hge3 oft Wn'nti+lL' iPage 60 of 67) il. UNtPOM SECURED [t0` This Nob b a e hom irlient w i& limiW v,Wiom in Dom j In addidoa to do probodoss pwa lod o Nob Holder avbrtbb Wove, a Moeiye. Dad of Tnm er Seewlp Deed (dw sacm* bAvuowwj bled Ibs wwe dssa n pia NoM, pwa dr Neb Holder less poerible loerrr wLial aaipit rueak if t do wet keep tee prowien tbal 10" is"Nm The Sw,* IastruraN describes 6rw wad ouder Mat madden Ix" be reaabW toaalm im-diab pryaemt is fun cf all aamuols 1 owe uader this Now Sole aMon comMos s m dune st foilowa: Treader K ba FmpwW ar a sawmftW latetwt is sonswur.lf aV arm" part of Aar Mp[y army lateroM M tes tropggr b sold a traoafenud (a if Baroervr is as a aNral pemoa and a baaefieiefmfruet is Harrower Y meld er ommatm d widwW Laadary prior as comment, Leader ary, at lb opdan ?epahs iarrreeirb m W) wfa- was neteld by rho 3mu ft inebewnra, However, ddt opioa aYai not be vawdaed by i eaderif aotetdea Y pdbited yy MNieabie Intr. I.eadQ aleo dull act eseein ddl optlaa if! (a) Hattotwr cwmos to bar nbadaed b l attde iofomrtDoa te?vire? by trader to evalads tbs invaded Osabeeo ac i &mew [ loon vows bwbD o edo es do beerfirur, wed (b) Lood rwoeab y debnriaw IYet I.aede?e vaeerilr wiN not ugpbW by dear tea eeMlgspdW ere tfist Oa tick ofa brcecJt of aq eoremt or edtseaist b teb Eewtity etWwaceldle ma ?p1161e bI.aader. cesarean b tea loan Did by Applieabir Lev, Lode? may eheuSa o rnooo" fn u a c®dWmn b L*Woru avomrWe b Luder obN?? farae? dfall n va mrsum eru nods ds in tbtot is ad In tldv Setatilr I??MII. Datawin wM coodo e b be der t v ad wad ft mm nabs Isadswdwass 8errower is wdts. ° °d d oundar tlr Hots and tbir Swardy btiamaw If Larder eaw d tea opbw m require iwmad m p Wmm N N14 Lertdar dM tWo Htimrraraotbb of eocelu+Iboa The aatlcs e4W prerids a period of col lean lean 30 days flow Or bb Ids aoeba Y prmr b aeoerdeaas wia sootioe is tri®i Mini, Horrorwr maw ppaayy el Sams aeeared by floe Dewady larameat If BersoesrAie b pay leeae ems prier b the eapsalioa of dw perkd, I.aoder auy iwdx aey rawadies pamiaed by ?+ 3eaadtY Iaewmesar..Imoee Oarreeractive a deuwd oa Hareovva. "W1TNI86 THE HAND(S) AND SEAL(S) OF THE UNDEMICNEW 4ftftamw (SOW) (Selo (Sail -vanes. [ham it (s-0 4 mrww (W) asses ERISN LOW Nowbm 1003997 Per 4 of4 laitiels (Page 61 of 67) • • ADJUSTAOE RATE INTEREST RATE &R & PREPAYMENT PENALTY Addendum to Note not ADJWABLE B1lUM RATE FLOOR a PW PAVMBa PENALTY ADDEND1Ad is made dw 46 day "We in dw 4110W Of U 06AVDA- 6104 6? (sold ?c ? (e) %) URTWM ?on ? •Loo do now dale and firs by ft Pa(s) Is eddhioa to the SVONN rs and p-viW- awdo is dw Nets and do S Inststtett. sad sommusa ft arty Pr vision a 69 mmnry coaYioed in mid Now or do Seewity lratrrmw4 I orb Ibe Bamwer(s) nd &a Loader Rolm wm a bNm: ADAWAX9 INTEREST BATE FLOOR Tab bn hu as lo* M Rate'PMor' wbiab wit hair dts auount the bmw Rfls sets deaeee kq dbs of eq damps Is the isdar, die [wearer Rate drieg dro ram of do ba wiU tsrwr bs Mau tbae the bdt(d Rmwml Raw p avidei far is sectios 2 ohhe Nms. NWAYbMT PENALTY L the swat, deriox the &d 2 years aAer do mewt;m of dds Note, I Babe a pr?r?y?r? sad do FNP" rat smosit 1>wMy tie (f%) of dm 040al pisoyua esteem of the len is ow Iws)ra (M sr? 1 vriu p4 alwysytseat clove It a aeomim owd in sot (6) m oche admwe kierest oo dam etast v-" is is Qotat of ew" I Depot MK)of the arWW peireipal amewd of dw fare wkbis dote - (2) m1k podod. The Note Holder wM apt amen a, p vpvv sot pon{ty agar go bid amivwn, mdse date ox6ttrort a$" NOIL Notm&$ Misuses loom wwvoz" PLUESE, BECKER & SALTZMAN, LLC Attorneys at Law ROB SALTZMAN • RSaltzman ftbslaw.ore SANFORD J. BECKER SBeckeWy6s1aw-6je ROBERT T. PLUESE RPluese(abbslaw.org ROBERT F. THOMAS • RThomas(alpbslaw.orp 20000 HORIZON WAY SUITE 900 MT. LAUREL, NEW JERSEY 080544318 (856) 813-1700 FACSIMILE: (856) 813-1720 PENNSYLVANIA OFFICE: 425 COMMERCE DRIVE, SUITE 100 FORT WASHINGTON, PA. 19034 (215) 546-3205 Please reply to: Mt. Laurel, New Jersey OF COUNSEL: Katz, Ettin & Levine, P.C. ------T-he-Law-Offices-of-Barbara-A Fein; P.C: * - ? PA and NJ Bars Our File #84050 March 6, 2008 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM F ORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and hone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agencv toll free at 1 800 342 2397 (Persons with impaired hearing can call (717) 780-1869)This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney_in your.are?se loci.lea.r_association.m.a_y_he_able_to_help-youu- - find alawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Natascha Thomas and James Thomas PROPERTY ADDRESS:332 Roxbury Road, Newville, PA 17241 LOAN ACCT. NO.: 2375082 ORIGINAL LENDER: Mortgage Electronic Registration Systems Inc. as Nominee for Equifirst Corporation CURRENT SERVICER: Franklin Credit Management Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary _ __ itay_of foreclosure on your mortgage for thirty _(30)_days_from_the_date of Notice. During time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of desi ated consumer credit counselin a encies for the coon in which the ro e is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) --.-___ IH1OW.T0-_CURE YOUR--MORT-GA-GE-DE-FAUI,-T-(B-ring_it-up-to-date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at 332 Roxburv Road Newville PA 17241: IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS of $891.53 since the April 1, 2007, to the present and the following amounts are now past due: $11,589.89. Late Charges: $264.18 Escrow Advance Balance: $242.66 BPO/Inspection/Property Preservation: $95.00 Available/Unapplied Funds: -$40.43 TOTAL AMOUNT PAST DUE: $12,151.30 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 12,151.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Name of Servicer: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) YOU DO NOT CURE THE DEFAULT--If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged propery IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refersyouur case_to i s attorney, b you cure __. _ __ __ _ the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paving the totalamount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing b the lender and b performing any other requirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Franklin Credit Management Corporation Address: 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 Phone Number: 201-604-1800 Fax Number: 201-604-4510 EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or _X_ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortge debtzprovided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED. t 7160 3901 9645 5309 3636 T i4atascha Thomas -332 Roxbury Road Newville, PA 17241 r SENDER: .le REFERENCE: 84050acts t PS Form 3800 January Zoos RETURN POMP --old i RECEIPT SERVICE a Total us P08ta1 SlfVip Receipt for Certified Mail NO Imurarfce CM121 a Provided i Do Not Use for kftmational Mai - fZErU'- 31 t7 ]i -- -(vT ? -a To fames Thomas 332 Roxbury Road Newville, PA 17241 SENDER: Je REFERENCE: 84050acts 313 9?y5 7-P! • POSTMARK OR DATE 31?1? PS Form 3800 32 January 5 q 3b2y 0 y34 y 9a4 ' • ?yb0 39D 0.00 A nn US P ftl Service Receipt for Certified Mail No Inwmnes Connkgo Provided Do Not Use for Inform Tonal Mai POSTMARK OR DATE 3)V)D8- ?-, ? ? ° ? - "V v `?' ` ? (l` ,. \ , (? _ _? `_? s f`3 ? 'y Q ? "` SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-07460 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TENANT/OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 332 ROXBURY ROAD , TENANT/OCCUPANT NOT FOUND , as to NEWVILLE, PA 17241 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 6.00 .00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County .00 21.00 PLUESE BECKER SALTZMAN 01/05/2009 Sworn and Subscribed to before me this day of A. D. c 4. 7= G co d ..y LLJ C C.,. C-4 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TLJnAAA C M7T TT C(UA the DEFENDANT , at 1140:00 HOURS, on the 31st day of December , 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 NATASCHA THOMAS by handing to 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 10.30 .00 ' 10.00 R. Thomas Kline .00 38.30 01/05/2009 PLUESE BECKER SALTZMAN By: day Deputy Sheriff A. D. ci., cn iUC- i.LJ ?? ; SHERIFF'S RETURN - REGULAR CASE NO: 2008-07460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS JAMES the DEFENDANT , at 1140:00 HOURS, on the 31st day of December-, 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 by handing to NATASCHA THOMAS, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE day 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 Subscibed to before me this of So Answers: R. Thomas Kline 01/05/2009 PLUESE BECKER SALTZMAN By: Deputy Sheriff , A. D. r.-T i. - co LL ? 4.L . I Aw Pluese, Becker & Saltzman, LLC. Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorney for Plaintiff 84065 FRANKLIN CREDIT MANAGEMENT CORPORATION v. Plaintiff NATASCHA THOMAS (MORTGAGOR AND RECORD OWNER) AND JAMES THOMAS (MORTGAGOR ONLY) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7460 Civil Term Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification of plaintiff for the verification of Robert F. Thomas, Esquire, Attorney for Plaintiff, pursuant to Pa. R.C.P. 1024. Robert F. Thomas, Esquire Attorney for Plaintiff DATED. JANUARY 10; 2009 V l ? VERIFICATION The undersigned, an officer of Franklin Credit Management Corporation, the instant Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken from the records maintained by said persons supervised by the Plaintiff who maintains the business records of the Mortgage held by the Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa C.S.A. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 17-' 2q' 20006 BY: , Name: DA%JID r+t; n`I Title: WtCp?l. i g Co . Loan No. 2375082 '?? r. .?.?`' ';": ? Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84065 Franklin Credit Management Corporation Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7460 Civil Term PRAECIPE TO ENTER JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter Default Judgment in favor of Plaintiff, Franklin Credit Management Corporation, and against Defendant(s), Natascha Thomas (Mortgagor and Record Owner) and James Thomas (Mortgagor Only), for failure to file an Answer to Plaintiffs Civil Action in Mortgage Foreclosure within the time provided for by applicable law from service thereof. Service was made on the Defendant(s) by Sheriff of Cumberland County as follows: Natascha Thomas (Mortgagor and Record Owner), served on December 31, 2008. James Thomas (Mortgagor Only), served on December 31, 2008. Assess Damages as follows: Total Demand in Complaint $122,118.16 Interest due and owing at the rate of $24.16 per diem from 12/17/08 to 2/3/09 $ 1,183.84 TOTAL JUDGMENT TO BE ENTERED $123,302.00 PLUESE, BECKER & SALTZMAN, LLC By: tzman, Esquire vs for Plaintiff Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84065 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7460 Civil Term CERTIFICATION OF ADDRESSES I, Dawn Killen, Legal Assistant, of the Law Firm of Pluese, Becker & Saltzman, Attorney for Plaintiff, Franklin Credit Management Corporation, hereby certify that the Plaintiffs correct address is 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 and the last known address of each Defendant is as below. Natascha Thomas (Mortgagor and Record Owner), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. Sworn to and Subscribed before O K PLUESE, BECKER & SALTZMAN, LLC me this__(:2?_day of Vr C , 2009. rl4k& M-X" By. Dawn Killen, L al Assistant N :.JERSEY -±, ., .. - .. p5,: Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856/813-1700 Rob Saltzman, Esquire Attorney ID No.: 53957 Attorney for Plaintiff 84065 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7460 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND S.S. I, Rob Saltzman, Esquire, being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained either by or an behalf of the Plaintiff herein named and that such investigations, including inquiry of the U.S. Department of Defense via their website, https://www.dmdc.osd.mil/scra/owa/home, and/or records indicate that the above-named Defendant(s) is/are not in the Military or Naval Service of the United States of America or its Allies as defined by the Servicemembers Civil Relief Act 50 U.S.C. Appx, sec 501, et seq., as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Natascha Thomas (Mortgagor and Record Owner) Age: Over 18 Residence: 332 Roxbury Road, Newville, PA 17241 Employment: Unknown Defendant: James Thomas (Mortgagor Only) Age: Over 18 Residence: 332 Roxbury Road, Newville, PA 17241 Employment: Unknown PLUESE, BECKER & SALTZMAN, LLC By: Sworn to and Subscribed before me this _Qy"'day of '2009. Saltzman, Esquire .nev ID No.: 53957 '10# 222.1929. X11 C4MM1"Slott 6XPiRES 5!9109 I4r 7J r ?{•? _' Pluese, Becker & Saltzman, LLC Attorneys At Law 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Rob Saltzman, Esquire Attorney ID NO.: 53957 856/813-1700 Attorney for Plaintiff 84065 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7460 Civil Term CERTIFICATION OF MAILING I, Dawn Killen, Legal Assistant, of the Law Firm of Pluese, Becker & Saltzman, Attorneys for Plaintiff, hereby certify that I forwarded to the following Defendant(s) on the date(s) listed, by regular mail, a copy of the Notice of Intention to take Default Judgment, Rule 237.1: Natascha Thomas (Mortgagor and Record Owner), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 PLUESE, BECKER SALTZMAN By: Dawn Killen, Legal Assistant Pluese, Becker & Saltzman, LLC. Robert F. Thomas, Esquire Attorney Identification No.: 70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 (856) 813-1700 Attorney for Plaintiff R4n65 FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY V. NATASCHA THOMAS (MORTGAGOR AND RECORD OWNER) AND JAMES THOMAS (MORTGAGOR ONLY) No. 08-7460 Civil Term Defendant(s). NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa. R.C.P. 237.1 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 asserted against you. Unless you act within ten (10) days from the date of this Notice as set forth below, a Judgment may be entered against you without a hearing and you may lose your property or other important rights and may be liable for money damages. You should take this Notice to a 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 32 South Bedford Street Carlisle, PA 17013 1/800-990-9108 717-249-3166 NOTIFICACION IMPORTANTE Usted estd en incumplimiento de su oblicaci6n legal de presentar, ya sea personalmente o por medio de su abogado, una declaraci6n por escrito y por no haber presentado por escrito sus defensas a Jos cargos que se han presentado en su contra. Si usted no toma acci6n dentro de diez (10) dias de la fecha de esta Notificaci6n, se registrara una sentencia en su contra sin audiencia y usted podrd perder su propiedad u otros derechos importantes y podrd ser responsable por ddnos monetarios. Lleve esta demanda a un abogado immediatamente. Si no tiene abogado, vaya en persona o Ilame por telefono a la oficina cuya. Esta oficiana puede proveer de usted la informaci6n sobre emplear a un abogado. Si usted no puede permitirse a la ira de h a la capa, esta oficina puede poder proveer de usted la informaci6n sobre las agencias que pueden ofrecer servicios juridicos a las personas elegibles en un honorario reducido o nngiun honorario. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1/800-990-9108 717-249-3166 Date of Notice: January 21, 2009 PERSONS SERVED: James Thomas 332 Roxbury Road Newville, PA 17241 Natascha Thomas 332 Roxbury Road Newville, PA 17241 PLUESE, BECKER & SALTZMAN, LLC. By: Robert F o as, Esquire Attorne for Plaintiff SHERIFF'S RETURN - REGULAR U m CASE NO: 2008-07460.. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS NATASCHA the DEFENDANT at 1140:00 HOURS, on the 31st day of December 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 by handing to NATASCHA THOMAS 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 18.00 Service 10.30 Affidavit .00 Surcharge 10.00 .00 38.30 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/05/2009 PLUESE BECKER SALTZMAN By: Deputy Sheriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-07460_ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon THOMAS JAMES the DEFENDANT , at 1140:00 HOURS, on the 31st day of December , 2008 at 332 ROXBURY ROAD NEWVILLE, PA 17241 by handing to NATASCHA THOMAS, ADULT IN CHARGE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 .00 00 10.00 R. Thomas Kline .00 16.00 01/05/2009 PLUESE BECKER SALTZMAN By: day Deputy Sheriff A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-0746u P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FRANKLIN CREDIT MANAGEMENT VS THOMAS NATASCHA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TENANT/OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 332 ROXBURY ROAD TENANT/OCCUPANT NOT FOUND , as to NEWVILLE, PA 17241 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 6.00 .00 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County 21.00 PLUESE BECKER SALTZMAN 01/05/2009 Sworn and Subscribed to before me this day of A.D. ?p p -0- W f OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ONE COURTHOUSE SQUARE CARLISLE, PA 17013 CURT LONG, PROTHONOTARY TO: Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas COURT OF COMMON PLEAS CUMBERLAND COUNTY (Mortgagor and Record Owner) NO. 08-7460 Civil Term James Thomas (Mortgagor Only), Defendants NOTICE PURSUANT TO RULE 236 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby no feed that a Judgment has been entered against you in the above-captione4c s iicated below. YZI Curt LMq PffitLiono [XX] Judgment entered by Default IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Rob Saltzman, Esquire, Attorney ID #53957 PLUESE, BECKER & SALTZMAN, LLC 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 856/813-1700 Attorneys for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Franklin Credit Management Corporation Plaintiff V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Defendant(s) To the Prothonotary: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST From 2/4/09 to 6/10/09 @ $20.27 perdiem Total (Costs to be added) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 08-7460 Civil Term $123,302.00 $ 2,574.29 $125,876.29 Date: February 2, 2009 Note: Please attach description of Property. Rob tzman, Esquire A rney for Plaintiff 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 (856) 813-1700 Attorney ID No.: 53957 File tk<File No> o H OW u v 03 rt y co o a W O U w o a o W ? H M U Z a ? y w a d m CAJ 0 o0O000 c-iSi a =o C(P TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester. L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. 453957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. Court of Common Pleas Cumberland County Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendant(s). Docket #08-7460 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Rob Saltzman, Esquire hereby certify that I am the attorney of record for the Plaintiff, Franklin Credit Management Corporation in this action against real property and I further certify that this property is: ( ) FHA - Tenant Occupied or Vacant ( ) Commercial (X) That the Plaintiff has complied in all respects with Section 403 of the HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 which may include but is not limited to: (a) Service of Notice of Defendant(s) (b) Expiration of thirty days since the Service of Notice (c) Defendant's failure to request or to appear at a face-to-face meeting with the Mortgagee or with a Consumer Credit Counseling Agency. (d) Defendant's failure to file an application for financial assistance with the Pennsylvania Housing Finance Agency and/or the denial of such application. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any willfully false material statements given herein. Respectfully submitted, PLUESE, BECKE & SALTZMAN, LLC BY: Mb Saltzman, Esquire Attorney for Plaintiff Our File #«File Nos ('? ? Cam' .°v ???? ? rn ? _? . ? fJ, s ;- ? .. z .. . ^' ? ?.:? ` ? --- ?V '? 3 t _ ? ? -,. =-? --" .?, PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation 7 COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY v. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Docket #08-7460 Civil Term Defendant AFFIDAVIT OF LAST KNOWN ADDRESS I, Rob Saltzman, Esquire, Attorney for Plaintiff, Franklin Credit Management Corporation, hereby certify that the last known address(es) of the Defendant(s) is/are as below: Natascha Thomas (Mortgagor and Record Owner), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. Respectfully submitted, PLUESE, BECKER & SALTZMAN, LLC BY: man, Esquire for Plaintiff Our File #«File No» N ft fl- rri V, PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY V. Natascha Thomas (Mortgagor and Record Owner) Docket #08-7460 Civil Term James Thomas (Mortgagor Only), Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File *(File No)> 5. Name and address of every other person who has any record lien on the property: 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: Cumberland Co. Dept. of Commonwealth of PA Domestic Relations 6`h Floor, Strawberry Square P.O. Box 320 Bureau of Individual Tax Carlisle, PA 17013 Inheritance Tax Division Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept. of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105 Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch 13`h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 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. #4904 relating to unsworn falsification to authorities. February 2, 2009 PLUESE, BECKER & ALTZMAN, LLC Date 1 BY: Ro tzman, Esquire Attorney for Plaintiff Our File #« File No>> te `? r - , _e tr., t s r 71 vo r ..; K . rQ y C - ? PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. Docket #08-7460 Civil Term NOTICE OF SHERIFFS SALE OF REAL ESTATE Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriff's Department to enforce the court judgment of $123,302.00 obtained by Franklin Credit Management Corporation against you. The Sheriffs Sale will be conducted on June 10, 2009, at 10:00 A.M., at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff's Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. 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 sale through other legal proceedings. Our File #oFile Nou 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 below 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 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 Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (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 this 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 Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriff's 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 Distribution sheet is posted. 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File AtFile No» 4 TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7460 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION, Plaintiff (s) From NATASCHA THOMAS (Mortgagor and Record Owner) JAMES THOMAS (Mortgagor only) (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $123,302.00 L.L. $.50 Interest from 2/04/09 to 6/10/09 @ $20.27 per diem -- $2,574.29 Atty's Comm % Due Prothy $2.00 Atty Paid $194.30 Plaintiff Paid Date: 2/04/09 Other Costs Curtis R. Lo , r honotar (Seal) REQUESTING PARTY: Name: ROB SALTZMAN, ESQUIRE Address: PLUESE, BECKER & SALTZMAN LLC 20000 HORIZON WAY, SUITE 900 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 By: Deputy Supreme Court ID No. 53957 FILE-iSr T I'M C3F ?-!E f'' OIVO' 'NARY In the Court of Common Pleas of SEP -4 FM 1: k 4 Cumberland County, Pennsylvania Ft?IvSyL+IAN1A Writ No. 2008-7460 Civil Term Franklin Credit Management Corporation VS Natascha Thomas and James Thomas William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2009 at 2037 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Natascha Thomas and James Thomas, by making known unto James Thomas, personally, at, 332 Roxbury Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 1230 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property Natascha Thomas and James Thomas, located at, 332 Roxbury Road, Newville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit Natascha Thomas and James Thomas, by regular mail to their last known address of, 332 Roxbury Road, Newville, PA 17241. This letter was mailed under the date of April 2, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, per letter of instruction from Attorney Rob Saltzman on August 31, 2009. Sheriff's Costs: Docketing 30.00 Poundage 31.76 Posting Bills 30.00 Advertising 30.00 Law Library .50 Prothonotary 2.00 Milage 27.00 Levy 30.00 Surcharge 40.00 Law Journal 797.00 Patriot News 566.19 Share of Bills 15.43 Post Pone Sale So Answers, R. Thomas Kline, S eriff By Real Estate Coordinator 20.00 1,619.88 AL 9 9 y ,6 "'9-.66 C d IT 5--6 LC, c,k4 -7l6 y,? /L??-3011 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. Docket #08-7460 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File &File Nou 5. Name and address of every other person who has any record lien on the property: 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: Cumberland Co. Dept. of Commonwealth of PA Domestic Relations 6th Floor, Strawberry Square P.O. Box 320 Bureau of Individual Tax Carlisle, PA 17013 Inheritance Tax Division Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept. of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105 Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch 13`h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 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. #4904 relating to unworn falsification to authorities. February 2, 2009 PLUESE, BECKER & ALTZMAN, LLC Date BY: Ro tzman, Esquire Attorney for Plaintiff Our File lk(File Non PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY Docket #08-7460 Civil Term NOTICE OF SHERIFF'S SALE OF REAL ESTATE Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriff's Department to enforce the court judgment of $123,302.00 obtained by Franklin Credit Management Corporation against you. The Sheriff's Sale will be conducted on June 10, 2009, at 10:00 A.M., at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff's Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. 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 sale through other legal proceedings. Our File #((File No)) 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 below 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 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 Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (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 this 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 Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriff's 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 Distribution sheet is posted. 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File H((File No)) TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: .15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 814/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7460 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION, Plaintiff (s) From NATASCHA THOMAS (Mortgagor and Record Owner) JAMES THOMAS (Mortgagor only) (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $123,302.00 L.L. $.50 Interest from 2/04/09 to 6/10/09 @ $20.27 per diem -- $2,574.29 Atty's Comm % Due Prothy $2.00 Atty Paid $194.30 Plaintiff Paid Date: 2/04/09 (Seal) Other Costs I ?4 Curtis R. Lo g, Protho tary By: REQUESTING PARTY: Name: ROB SALTZMAN, ESQUIRE Address: PLUESE, BECKER & SALTZMAN LLC 20000 HORIZON WAY, SUITE 900 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 Supreme Court ID No. 53957 Deputy Real Estate Sale # 42 On February 13, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, PA Known and numbered as 332 Roxbury Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 13, 2009 By: ojaA,- cc?4 ?4 Y PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 1, May 8, and May 15, 2009 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. sa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this day of May, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND J2010 MY Commission Expires Apr 28 REAL ESTATE ME NO. 42 Writ No. 2008-7460 Civil Franklin Credit Management Corporation VS. Natascha Thomas and James Thomas Atty.: Rob Salzman TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Sur- veyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Rox- bury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described par- cel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accor- dance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern comer of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legisla- tive Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 min- utes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legisla- tive Route 21001, North 42 degrees 17 minutes 20 seconds East, a dis- tance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extend- ing Southwardly there from at an even width a distance of two hun- dred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05- 0411-018. TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/ 11 / 2006 in the County of Cumber- land in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. 'The Patriot-News Co. 812 Market St. Harrisburg,- PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/24/09 05/01/09 05/08/09 ............. Sworn to a skscribed before me this 12 day of May, 2009 A.D. Notary Public C MMONWEALTH OF PENNSYLVANIA. Notarial Seal Sherrie L. Kisner, Notary Public N CarnH'eresion Ewe 26, 20111 Member, Pennsyivanla Association of Notaries Real Estate Sale No. 42 Writ No. 2008-7460 Civil Term Franklin Credit Management Corporation VS Natascha Thomas and James Thomas Attorney Rob Salzman LEGAL DESCRIPTION TRACT NO.1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne E Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at comer of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in acc rdance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern comer of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center fine of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TTfLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a marred man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7460 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff (s) From NATASCHA THOMAS, JAMES THOMAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $123,302.00 L.L.: Interest from 2/4/09 to 12/7/2011 at $20.27 per diem - $13,621.44 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $1,836.18 Other Costs: Plaintiff Paid: Date: 8/29/11 .-LZL? David D. Buell, Prothonotary -- (Seal) Deputy REQUESTING PARTY: Name: ROB' SALTZMAN, ESQUIRE Address: PLUESE, BECKER & SALTZMAN, LLC 20000 HORIZON WAY, SUITE 900 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 Supreme Court ID No. 53957 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Franklin Credit Management Corporation Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Defendant(s) To the Prothonotary: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST From 2/4/09 to 12/7/2011 @ $20.27 perdiem Total (Costs to be added) © Date: August 26, 2011 0Ak %1".4 co 39. go 9.F 1 G-o0 11" 91-001111 110.19. se 11 I&SG a 4• oo $4 Note: Please attach description of Property. ail. so ?? 1 File #8x065 Ck *Gtq 3a Ce F- *aU S9T NO : 08-7460 Civil Term= . ?+y A ? =C) pC Q C-a -4 rT: > $123,302.00 $ 13,621.44 $136,923.44 I6b Saltzman, Esquire /Attorney for Plaintiff 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 (856) 813-1700 Attorney ID No.: 53957 Wrtk C6 2? ?LS.stA-ecl R H 0 110 00 0 0 z O~y ?' ? C, p O a? zz o ?7a °' O OW 0 w 9 0 H OO 0 cd i? a A ? ? .0 o W W d V f, U z N z W ? o b x N M M b a? a? w d 0 00 00 W. TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Defendant y '?Tiff N0TAii /ill AUG29 Pry`2: "LIMS"ERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Docket #08-7460 Civil Term AFFIDAVIT OF LAST KNOWN ADDRESS I, Rob Saltzman, Esquire, Attorney for Plaintiff, Franklin Credit Management Corporation, hereby certify that the last known address(es) of the Defendant(s) is/are as below: Natascha Thomas (Mortgagor and Record Owner), 332 Roxbury Road, Newville, PA 17241 James Thomas (Mortgagor Only), 332 Roxbury Road, Newville, PA 17241 I certify that the foregoing information is true and correct to the best of my knowledge, information and belief. Respectfully PLUESE, BI BY: TZMAN, LLC Rob Saltzman, Esquire Attorney for Plaintiff Our File #84065 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendant(s). -? 1. 2J" 1 UG 2 Phi 2: 0' =i CUPIBERLAND COUNTY Court of Common Pleas Cumberland County Docket #08-7460 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Rob Saltzman, Esquire hereby certify that I am the attorney of record for the Plaintiff, Franklin Credit Management Corporation in this action against real property and I further certify that this property is: ( ) FHA - Tenant Occupied or Vacant ( ) Commercial (X) That the Plaintiff has complied in all respects with Section 403 of the HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 which may include but is not limited to: (a) Service of Notice of Defendant(s) (b) Expiration of thirty days since the Service of Notice (c) Defendant's failure to request or to appear at a face-to-face meeting with the Mortgagee or with a Consumer Credit Counseling Agency. (d) Defendant's failure to file an application for financial assistance with the Pennsylvania Housing Finance Agency and/or the denial of such application. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any willfully false material statements given herein. Respectfully submitted, PLUESE, BECKE & SALTZMAN, LLC BY: Rob Saltzman, Esquire Attorney for Plaintiff Our File #84065 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 for Plaintiff T iON0TAR"' J ! I= J! 29 ECM 2:: 4 ?ITIBERLAND COUNT)` PENNSYLVANIA Franklin Credit Management Corporation, Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY Docket #08-7460 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File #84065 5. Name and address of every other person who has any record lien on the property: 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: Cumberland Co. Dept. of Domestic Relations P.O. Box 320 Carlisle, PA 17013 Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept. of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105 Commonwealth of PA 6th Floor, Strawberry Square Bureau of Individual Tax Inheritance Tax Division Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 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. #4904 relating to unsworn falsification to authorities. August 26, 2011 PLUESE, BECKER & SALTZMAN, LLC Date BY: ob altzman, Esquire Attorney for Plaintiff Our File #84065 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation Plaintiff, V. Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Defendant . L; ;EmTy 0N0TAk CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Docket #08-7460 Civil Term NOTICE OF SHERIFF'S SALE OF REAL ESTATE Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the court judgment of $123,302.00 obtained by Franklin Credit Management Corporation against you. The Sheriff s Sale will be conducted on December 7, 2011, at 10:00 A.M., at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff s Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. 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 sale through other legal proceedings. Our File #84065 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 below 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 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 Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (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 this 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 Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriff's 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 Distribution sheet is posted. 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File #84065 TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE; This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFD G 1 HE PRC i 1-10N i ? 2012 MAR 15 PM 3: 09 CUMBERLAND COUNTY PENNSYLVANIA Franklin Credit Management Corporation vs. Natascha Thomas (et al.) Case Number 2008-7460 SHERIFF'S RETURN OF SERVICE 10/11/2011 11:40 AM - Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County. 10/11/2011 11:40 AM - Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Nataschz Thomas at 332 Roxbury Road, Newville, PA 17241, Cumberland County. 10/11/2011 11:37 AM - Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be NATASCHA THOMAS, WIFE, who accepted as "Adult Person in Charge" for James Thomas at 332 Roxbury Road, Newville, PA 17241, Cumberland County. 12/06/2011 As directed by Rob Saltzman, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/7/2012 03/07/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,587.48 SO ANSWERS, March 15, 2012 RON R ANDERSON, SHERIFF AI Z aPag77 ir.1 CoumyStjitr. Shermt, Te!eosofi In::_ r PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. #53957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation, Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only), Defendants. Docket #08-7460 Civil Term AFFIDAVIT PURSUANT TO RULE 3129.1 Franklin Credit Management Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 332 Roxbury Road, Newville, PA 17241, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of owner(s) or reputed owner (s): Natascha Thomas James Thomas (Mortgagor Only) (Record Owner and Mortgagor) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 2. Name and address of defendant(s) in the judgment: SAME AS ABOVE 3. Name and last address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and address of the last recorded holder of every mortgage of record: Franklin Credit Management Corporation (Plaintiff) Our File 494065 1 `Name and address of every other person who has any record lien on the property: 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: Cumberland Co. Dept. of Domestic Relations P.O. Box 320 Carlisle, PA 17013 Commonwealth of PA Dept. of Welfare P.O. Box 2675 Harrisburg, PA 17105 Dept. of Public Welfare T.P.L. Casualty Unit Estate Recovery Program P.O. Box 8486, Willow Oak Building Commonwealth of PA 61h Floor, Strawberry Square Bureau of Individual Tax Inheritance Tax Division Attn: John Murphy, Dept. 280601 Harrisburg, PA 17128 Internal Revenue Service Federal Estate Tax Special Procedure Branch 13`h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Harrisburg, PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property, which may be affected by the sale: Tenant/Occupant 332 Roxbury Road Newville, PA 17241 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. #4904 relating to unworn falsification to authorities. August 26, 2011 PLUESE, BECKER & SALTZMAN, LLC Date 1-111, BY: ob altzman, Esquire Attorney for Plaintiff Our File #84065 PLUESE, BECKER & SALTZMAN, LLC By: Rob Saltzman, Esquire Attorney I.D. 453957 20000 Horizon Way, Suite 900 Mount Laurel, NJ 08054 Phone: 856-813-1700 Attorney for Plaintiff Franklin Credit Management Corporation Plaintiff, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) Defendant Docket #08-7460 Civil Term NOTICE OF SHERIFF'S SALE OF REAL ESTATE Natascha Thomas (Mortgagor and Record Owner) James Thomas (Mortgagor Only) 332 Roxbury Road 332 Roxbury Road Newville, PA 17241 Newville, PA 17241 Your house at 332 Roxbury Road, Newville, PA 17241, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the court judgment of $123,302.00 obtained by Franklin Credit Management Corporation against you. The Sheriff's Sale will be conducted on December 7, 2011, at 10:00 A.M., at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 or, in the alternative, at a location to be determined by the Cumberland County Sheriff's Department. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: 1. The sale will be cancelled if you pay to Plaintiff Mortgagee the back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call Rob Saltzman, Esquire at (215) 546-3205. 2. 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 sale through other legal proceedings. Our File 1!84065 T 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 below 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 Rob Saltzman, Esquire at (215) 546-3205, or by calling the Cumberland County Sheriff's Department at (717) 240-6390 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 Rob Saltzman, Esquire at (215) 546-3205, or by calling the Sheriff's office at (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 this 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 Cumberland County Sheriff on or about thirty (30) days from the date of the Sheriff's 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 Distribution sheet is posted. 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. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Our File #84065 T TRACT NO. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County, Pennsylvania, referred to as Lot No. C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum", prepared by Eric L. Diffenbaugh, Professional Land Surveyor, which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79, Page 145, as follows: BEGINNING at a set railroad spike in public road SR-0997 (Roxbury Road) at corner of the within described parcel and parcel B on the above referred to Subdivision Plan; thence along Roxbury Road, North 48 degrees 51 minutes 49 seconds East, 50.00 feet to a point, in line of land now or formerly of Wayne F. Peters, which lands the within described parcel is being added to as a lot addition; thence along Peter's lands, South 48 degrees 20 minutes 14 seconds East, 249.10 feet to a set iron pin, in line of lands now or formerly of Elwood R. and David W. Gutshall; thence along line of lands of Gutshall, South 33 degrees 22 minutes 56 seconds West, 50.13 feet to a set iron pin at corner of Parcel B; thence along line of parcel B, North 48 degrees 20 minutes 14 seconds West, 262.59 feet to the set railroad spike at point and place of beginning. CONTAINING 0.2914 acres, in accordance with the above referred to Subdivision Plan. TRACT NO. 2: ALL THAT CERTAIN lot of ground situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas A. Neff, on. March 27, 1968, a draft of said survey being attached hereto and incorporated herein by reference, as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G. Wert, which spike at the place of beginning is one thousand three hundred sixty (1,360) feet. West of the center line of Legislative Route 21036; thence from said spike at the place of beginning along said line of land now or formerly of William G. Wert, South 58 degrees 45 minutes East, a distance of two hundred (200) feet to a stake in line of land now or formerly of G. Herbert Richardson; thence along said line of land now or formerly of G. Herbert Richardson, South 42 degrees 17 minutes 20 seconds West, a distance of one hundred (100) feet to a stake in line of land now or formerly of Lester L. Clever; thence along said line of land now or formerly of Lester L. Clever, North 58 degrees 45 minutes West, a distance of two hundred (200) feet to a spike in the center line of Legislative Route 21001; thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East, a distance of one hundred (100) feet to a spike, the place of beginning. CONTAINING one hundred (100) feet in front along the center line of Legislative Route 21001 and extending Southwardly there from at an even width a distance of two hundred (200) feet, comprising an area of forty-five one hundredths (.45) acre, and having thereon erected a one story brick and aluminum siding covered dwelling house. TAX PARCEL NUMBER: 15-05-0411-018 TITLE TO SAID PREMISES IS VESTED IN Natascha Thomas, a married woman by reason of the following: BEING THE SAME premises which Wayne F. Peters, a married man by Deed dated 8/4/2006 and recorded 8/14/2006 in the County of Cumberland in Deed Book 276, Page 773 conveyed unto Natascha Thomas, a married woman. AND ALSO BEING THE SAME premises which Wayne F. Peters, a married man by Corrective Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland in Deed Book 277, Page 4692 conveyed unto Natascha Thomas, a married woman. NOTICE: This Corrective Deed is being done to include Tract No. 2 that was not included with the prior transfer in Deed Book Volume 276 at Page 773, dated August 4, 2006 and recorded August 14, 2006 in Cumberland County. 8Z -.8 d OE onv Hoz WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7460 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff (s) From NATASCHA THOMAS, JAMES THOMAS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $123,302.00 L.L.: Interest from 2/4/09 to 12/7/2011 at $20.27 per diem - $13,621.44 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $1,836.18 Other Costs: Plaintiff Paid: Date: 8/29/11 David D. B 11, Pro not (Seal) Deputy REQUESTING PARTY: Name: ROB SALTZMAN, ESQUIRE Address: PLUESE, BECKER & SALTZMAN, LLC 20000 HORIZON WAY, SUITE 900 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-813-1700 Supreme Court ID No. 53957 On August 30, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, PA, Known and numbered as, 332 Roxbury Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 30, 2011 By: a I 0-tt 66 Real Estate Coordinator Q 8Z :8 d 0E 90V i1oz v d , I { ?' JJI?3HS 31-1,1 PLUESE, BECKER & SALTZMAN, LLC ROBERT F. THOMAS, ESQUIRE Attorney ID #70206 20000 Horizon Way, Suite 900 Mt. Laurel, NJ 08054 Attorneys for Plaintiff 84065 FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff, V. NATASCHA THOMAS(MORTGAGE AND RECORD OWNER) AND JAMES THOMAS(MORTGAGOR ONLY) Defendants TO THE PROTHONOTARY: r; "'EPjgs `°t ?,q 01jPj i COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 08-7460 PRAECIPE TO WITHDRAW AND PRAECIPE TO ENTER APPEARANCE Kindly withdraw attorney, Robert F. Thomas, Esquire of the firm of PLUESE, BECKER & SALTZMAN, LLC as counsel of record and enter the appearance of Tom Federman, Esquire of the firm of FEDERMAN & ASSOCIATES as attorney of record. DATED: JUNE 6, 2012 PLUESE, BECKER & SALTZMAN, LLC By: F. Thomas, Esquire FEDERMAN & ASSOCIATES,LL? By: (Tom Federman, Esquire Y?t tom- r /`.. C5 . ___k y By: FEDERMAN & ASSOCIATES, LLC Thomas M. Federman, Esq., ID No. 64068 Danielle Boyle-Ebersole, Esq., ID No. 81747 305 York Road, Suite 300 Jenkintown, PA 19046 215 572-5095 FRANKLIN CREDIT MANAGEMENT CORPORATION Plaintiff V. NATASCHA THOMAS -4 Cn (MORTGAGOR AND REAL OWNER) JAMES THOMAS (MORTGAGOR ONLY) CUMBERLAND COUNTY Defendant(s) PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P. 2352 TO THE PROTHONOTARY: rV1 r -0 4 x? Kindly substitute Wells Fargo Bank, N.A. as Certificate Trustee no in its individual capacity but solely as Certificate Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 as successor Plaintiff for the originally-named Plaintiff. The material facts upon which the right of succession and substitution are based are as follows: Wells Fargo Bank, N.A. as Certificate Trustee no in its individual capacity but solely as Certificate Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 is the current holder of the Mortgage by virtue of that certain Assignment of Mortgage, which has been recorded 6/23/2011 in the Office of the Recorder of Deeds of Cumberland County as Document #201117716. A true and correct copy of the Assignment to Plaintiff is attached hereto as Exhibit "A." Kindly amend the information on the docket accordingly. r t Date: _ J ATTORNEY FOR PLAINTIEII;' , ? kl_3v COURT OF COMMON PLEAS CIVIL DIVISION c c -D NO. 08-7460 Civil Term N Respectfully submitted, FEDERMAN &. ASSOCIATES, LLC Y\Danielle Boyle-Ebersole, Esq. By: Thomas M. Federman, Esq. Attorney for Plaintiff Pa 2N-a-n4(n2 NI02I?III C PREPARED BY & RETURN TO: M. E. Wileman Orion Financial Group, Inc. 2860 Exchange Blvd. # 100 Southlake, TX 76092 Parcel # 15-05-0411-019 Assignment of Mortgage Send Any Notices To Assignee. +?'"y K. ==LYNN Notary PubMy mOtob?m \gAk--, Notary public, K. L My commission exp L-r 18, 2014 2375082 PA Cumberland FCMC/FL1M1SC ASMTS The Assignee hereby certifies that the precise address of the within named WELLS FARGO BANK N.A., AS CERTIFICATE TRUSTEE NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE, IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 is 9062 OLD ANNAPOLIS ROAD, COLrasa 9 A, MD 21045. For Valuable Consideration, the undersigned, THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A Franklin Credit Management Corporation Attorney In Fact, 7 EASTON OVAL EAE63, COLUMBUS, OH 43219 (Assignor) by time presents does assign, and set over, without recourse, to WELLS FARGO BANK N.A., AS CERTIFICATE TRUSTEE NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE, IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010.2 9062 OLD ANNAPOLIS ROAD, COLUMBIA, MD 21045 (Assignee) the described mortgage with all interest, all liens, any rights due or to become due thereon, executed by NATASCHA THOMAS to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (MERS) SOLELY AS NOMINEE FOR EQUIFIRST CORPORATION. Said mortgage Dated: 81412006 is recorded in the State of PA, County of Cumberland on 12/1112006, as Book 1975 Page 42% AMOUNT: S 100,000.00 Property Address 332 ROXBURY RD., NEWVILLE, PA 17241 IN WITNESS WHEREOF, the undersigned corporation/trust has caused this instrument to be executed by its proper officer. Executed on: June 15, 2011 THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A Franklin Credit Management Corporation Attorney In Fact' B.Y: Nk • kl? 1011MINWIN111 M. Matthews, Vice President THOMAS CAW •110271320 The Power of Attorney was filed in Cumberland County, Pennsylvania on 09124/2010 in INST#M01026814. State of Texas, County of Tarrant On June 15, 2011, before me, the undersigned, personally appeared M. Mathews, who acknowledged that he/she is Vice President ofl Franklin Credit Management Corporation Attorney In Fact for THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A and that he/she executed the foregoing instrument and that such execution was done as the free act and deed of THE HUNTINGTON NATIONAL BANK, AS CERTIFICATE TRUSTEE OF FRANKLIN MORTGAGE ASSET TRUST 2009-A Franklin Credit Management Corporation Anomey In Fact. w ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201117716 Recorded On 6/23/2011 At 11:38:08 AM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 88871 User ID - KW * Mortgagor - THOMAS, NATASCHA * Mortgagee - VNT TRUST SERIES 2010-2 * Customer - ORION FINANCIAL GROUP INC * FEES STATE WRIT TAR $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 I Certify this to be recorded in Cumberland County PA * Total Pages - 2 Certification Page DO NOT DETACH This page is now part of this legal document. RECORDER O D DS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111 FEDERMAN & ASSOCIATES, LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No.81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown,PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DMSION , WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS w s CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED rn M v rn HOLDERS OF VNT TRUST SERIES 2010-2 ;Zr r� oo CD , Plaintiff CUMBERLAND COUNTY z_ ::�j�`2 V. C)' NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO.08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) w3 Defendant(s) AFFIDAVIT OF SERVICE I,Thomas M.Federm E quire, Attorney for the Plaintiff in the within matter, hereby certify that on the J day of ,2013, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s)as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit"A". Copies of the letter and certificates of mailing are also attached hereto, made a part hereof and marked as Exhibit"B". FEDERMAN & ASSOCIATES, LLC 'SkTKOMAS M.FEDERMAN,ESQ. ID#6-T068 ❑DANIELLE BOYLE-EBERSOLE,ESQ. ID#81747 305 York Road, Suite 300 Jenkintown,PA 19046 Attorney for Plaintiff SWO TO AND SUBSftD BE E ME THIS DAY F 2013. l NOTARY P�t 4W=vAmw NOTARIAL SEAL NY ANN o..Mw Y,Noll lown Boro.,MaMpoMy tMrr�iMOn E� ine� MN 4 101 FEDERMAN & ASSOCIATES,LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No.81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown,PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff CUMBERLAND COUNTY V. NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO.08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 The undersigned hereby certifies that he/she is the attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 332 Roxbury Road,Newville,PA 17241,a copy of the description of said property is attached hereto and marked Exhibit"A". 1. Name and address of Owner(s)or Reputed Owner(s): Name Address Natascha Thomas 332 Roxbury Road Newville,PA 17241 James Thomas 332 Roxbury Road Newville,PA 17241 2.Name and address of Defendant(s)in the judgment: Name Address Natascha Thomas 332 Roxbury Road Newville,PA 17241 James Thomas 332 Roxbury Road Newville,PA 17241 3.Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address � � oA I) 4.Name and address of the last recorded holder of every mortgage of record: Name Address 5.Name and address of every other person who has any record lien on the property: Name Address 6.Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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: Tenant(s)/Occupant(s) 332 Roxbury Road Newville,PA 17241 Domestic Relations Office PO Box 320 Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 Commonwealth of PA PO Box 2675 Department of Public Welfare Harrisburg,PA 17105 Commonwealth of PA 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare PO Box 8486 TPL Casualty Unit Estate Willow Oak Building Recovery Program Harrisburg, PA 17105-8486 United States of America United States Post Office& Courthouse c/o United States Attorney 700 Grant Street, Suite 4000 for the Western District of PA Pittsburgh, PA 15219 PA Department of Revenue PO Box 281230 Bureau of Compliance Harrisburg, PA 17128-1230 Commonwealth of PA Department 280946 Department of Revenue Harrisburg,PA 17128-1230 Bureau of Compliance ATTN: Sheriffs Sales Clearance Support 8.Name and address of Attorney of record: Name Address 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. Section 4904 relating to unsworn falsification to authorities: F & CIATES, LLC Date: /5y//-? THO S M.FEDERMAN,ESQ.ID#69)68 DANIELLE BOYLE-EBERSOLE,ESQ. ID#81747 305 York Road, Suite 300 Jenkintown, PA 19046 Attorney for Plaintiff Tract No. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township,Cumberland County, Pennsylvania,referred to as Lot No.C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Sturn",prepared by Eric L.Diffenbaugh,Professional Land Surveyor,which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79,Page 145,as follows: BEGINNING at a set railroad spike in public road SR-0997(Roxbury Road)at corner of the within described parcel and parcel B on the above referred to Subdivision Plan;thence along Roxbury Road,North 48 degrees 51 minutes 49 seconds East,50.00 feet to a point,in line of land now or formerly of Wayne F.Peters,which lands the within described parcel is being added to as a lot addition;thence along Peters'lands,South 48 degrees 20 minutes 14 seconds East,249.10 feet to a set iron pin,in line of lands now or formerly of Elwood R.and David W.Gutshall; thence along line of lands of Gutshall,South 33 degrees 22 minutes 56 seconds West,50.13 feet to a set iron pin at corner of Parcel B;thence along line of Parcel B,North 48 degrees 20 minutes 14 seconds West,262.59 feet to the set railroad spike at point and place of beginning. BEING Parcel No. 15-05-0411-018. Tract No.2: ALL that certain lot of ground situate in Lower Mifflin Township,Cumberland County,Pennsylvania,bounded and described in accordance with survey made by Thomas A.Neff,on March 27, 1968,a draft of said survey being attached hereto and incorporated herein by referenced,as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G.Wert,which spike at the place of beginning is One Thousand Three Hundred Sixty(1,360)feet West of the center line of Legislative Route 21036;thence from said spike at the place of beginning along said line of land now or formerly of William G.Wert,South 58 degrees 45 minutes East,a distance of Two Hundred(200)feet to a stake in line of land now or formerly of G.Herbert Richardson;thence along said line of land now or formerly of G.Herbert Richardson,South 42 degrees 17 minutes 20 seconds West,a distance of One Hundred(100)feet to a stake in line of land now or formerly of Lester L.Clever,thence along said line of land now or formerly of Lester L.Clever,North 58 degrees 45 minutes West,a distance of Two Hundred(200)feet to a spike in the center line of Legislative Route 21001;thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East,a distance of One Hundred(1 00)feet to a spike,the place of beginning. CONTAR41NG One Hundred(100)feet in front along the center line of Legislative Route 21001 and extending Southwardly therefrom at an even width a distance of Two Hundred(200)feet,comprising an area of Forty-five One Hundredths(45)acre,and having thereon erected a one story brick and aluminum siding covered dwelling house. BEING Parcel No. 15-05-0411-018. BEING the same premises that Wayne F.Peters,a married man,by Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland(Book 277 Page 4692)granted and conveyed unto Natascha Thomas,his/her heirs and assigns,in fee. FEDERMAN & ASSOCIATES,LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No.81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown, PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff CUMBERLAND COUNTY V. NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO.08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) Defendant(s) DATE: �3 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S):Natascha Thomas&James Thomas PROPERTY: 332 Roxbury Road,Newville,PA 17241 IMPROVEMENTS: Residential Dwelling The above captioned property is scheduled to be sold at the Sheriffs Sale on June 5,2013 at 11:00 a.m. at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. Our records indicate that you may hold a mortgage, or judgment(s)and lien(s)on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Tract No. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township,Cumberland County, Pennsylvania,referred to as Lot No.C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Sturn',prepared by Eric L.Diffenbaugh,Professional Land Surveyor,which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79,Page 145,as follows: BEGINNING at a set railroad spike in public road SR-0997(Roxbury Road)at corner of the within described parcel and parcel B on the above referred to Subdivision Plan;thence along Roxbury Road,North 48 degrees 51 minutes 49 seconds East,50.00 feet to a point,in line of land now or formerly of Wayne F.Peters,which lands the within described parcel is being added to as a lot addition;thence along Peters'lands,South 48 degrees 20 minutes 14 seconds East,249.10 feet to a set iron pin,in line of lands now or formerly of Elwood R.and David W.Gutshall; thence along line of lands of Gutshall,South 33 degrees 22 minutes 56 seconds West,50.13 feet to a set iron pin at comer of Parcel B;thence along line of Parcel B,North 48 degrees 20 minutes 14 seconds West,262.59 feet to the set railroad spike at point and place of beginning. BEING Parcel No. 15-05-0411-018. Tract No.2: ALL that certain lot of ground situate in Lower Mifflin Township,Cumberland County,Pennsylvania,bounded and described in accordance with survey made by Thomas A.Neff,on March 27, 1968,a draft of said survey being attached hereto and incorporated herein by referenced,as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G.Wert,which spike at the place of beginning is One Thousand Three Hundred Sixty(1,360)feet West of the center line of Legislative Route 21036;thence from said spike at the place of beginning along said line of land now or formerly of William G.Wert,South 58 degrees 45 minutes East,a distance of Two Hundred(200)feet to a stake in line of land now or formerly of G.Herbert Richardson;thence along said line of land now or formerly of G.Herbert Richardson,South 42 degrees 17 minutes 20 seconds West,a distance of One Hundred(100)feet to a stake in line of land now or formerly of Lester L.Clever;thence along said line of land now or formerly of Lester L.Clever,North 58 degrees 45 minutes West,a distance of Two Hundred(200)feet to a spike in the center line of Legislative Route 21001;thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East,a distance of One Hundred(1 00)feet to a spike,the place of beginning. CONTAINING One Hundred(100)feet in front along the center line of Legislative Route 21001 and extending Southwardly therefrom at an even width a distance of Two Hundred(200)feet,comprising an area of Forty-five One Hundredths(.45)acre,and having thereon erected a one story brick and aluminum siding covered dwelling house. BEING Parcel No. 15-05-0411-018. BEING the same premises that Wayne F.Peters,a married man,by Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland(Book 277 Page 4692)granted and conveyed unto Natascha Thomas,his/her heirs and assigns,in fee. FEDERMAN & ASSOCIATES, LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No.81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown,PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff CUMBERLAND COUNTY V. NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO.08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO:Natascha Thomas James Thomas 332 Roxbury Road Newville,PA 17241 Your house(real estate)at 332 Roxbury Road,Newville,PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5,2013 at 11:00 a.m.at the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,PA, 17013 to enforce the court judgment of$123,302.00 obtained by Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to the Plaintiff the back payments,late charges,costs, and reasonable attorney's fees due. To find out how much you must pay,you may call Federman &Associates,LLC, at(215) 572-5095. 2. 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 sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS 1. If the Sheriff's Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling Federman&Associates,LLC,at(215)572-5095. 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 on the sale. To find out if this has happened,you may call Federman&Associates,LLC,at (215)572-5095. 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 a 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 real estate.A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with his schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate 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, 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 REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17103 (717)249-3166 (800) 990-9108 Tract No. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township,Cumberland County, Pennsylvania,referred to as Lot No.C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum",prepared by Eric L.Diffenbaugh,Professional Land Surveyor,which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79,Page 145,as follows: BEGINNING at a set railroad spike in public road SR-0997(Roxbury Road)at corner of the within described parcel and parcel B on the above referred to Subdivision Plan;thence along Roxbury Road,North 48 degrees 51 minutes 49 seconds East,50.00 feet to a point,in line of land now or formerly of Wayne F.Peters,which lands the within described parcel is being added to as a lot addition;thence along Peters'lands,South 48 degrees 20 minutes 14 seconds East,249.10 feet to a set iron pin,in line of lands now or formerly of Elwood R.and David W.Gutshall; thence along line of lands of Gutshall,South 33 degrees 22 minutes 56 seconds West,50.13 feet to a set iron pin at comer of Parcel B;thence along line of Parcel B,North 48 degrees 20 minutes 14 seconds West,262.59 feet to the set railroad spike at point and place of beginning. BEING Parcel No. 15-05-0411-018. Tract No.2: ALL that certain lot of ground situate in Lower Mifflin Township,Cumberland County,Pennsylvania,bounded and described in accordance with survey made by Thomas A.Neff,on March 27, 1968,a draft of said survey being attached hereto and incorporated herein by referenced,as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern comer of land now or formerly of William G.Wert,which spike at the place of beginning is One Thousand Three Hundred Sixty(1,360)feet West of the center line of Legislative Route 21036;thence from said spike at the place of beginning along said line of land now or formerly of William G.Wert,South 58 degrees 45 minutes East,a distance of Two Hundred(200)feet to a stake in line of land now or formerly of G.Herbert Richardson;thence along said line of land now or formerly of G.Herbert Richardson,South 42 degrees 17 minutes 20 seconds West,a distance of One Hundred(100)feet to a stake in line of land now or formerly of Lester L.Clever;thence along said line of land now or formerly of Lester L.Clever,North 58 degrees 45 minutes West,a distance of Two Hundred(200)feet to a spike in the center line of Legislative Route 21001;thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East,a distance of One Hundred(1 00)feet to a spike,the place of beginning. CONTAINING One Hundred(100)feet in front along the center line of Legislative Route 21001 and extending Southwardly therefrom at an even width a distance of Two Hundred(200)feet,comprising an area of Forty-five One Hundredths(.45)acre,and having thereon erected a one story brick and aluminum siding covered dwelling house. BEING Parcel No. 15-05-0411-018. BEING the same premises that Wayne F.Peters,a married man,by Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland(Book 277 Page 4692)granted and conveyed unto Natascha Thomas,his/her heirs and assigns,in fee. ��Ptrrer sowcs Name and Address of Sender Check type of mail or service: Affix Stamp Here 02 1 P 004•720 FEDERMAN &ASSOCIATES, LLC c Certified ice.' Recorded Delivery(International) ;t ofmaAing, a 0001696893 MAR 18 2013 305 Old York Road, Suite 300 = coo orfbraddiliw:W MAILED FROM ZIP CODE 19046 Jenkintown, PA 19046 !ry Delivery Confirmation Return Reoso for Merchandise � / Express Mail 1- Signature Confirmation Postman*aw Insured Date of RBO t Article Number Addressee ffila s,St"K 06' State,&OPCb* Postage Fee Handing AcGrai Yaitre Ir red Due Sender F DC SC SH RD i RR 1 _ _.._ Charge if Registered Vakre if COD Fee Fee Fee Fee , Fee Natascha Thomas _ 332"RbJbUry"Road Newville,PA 17241 E : � J3a3m2...eRs o Thomas o_a.....d.. ......... i f ............... .. .. ...... 2. Newville,PA 17241 ' I 3 Tenant(s)/Occupant(s) T' i 332 Roxbury Road _ 3. Domestic Relations Office Cumberland County Courthouse PO Box 320,13 North Hanover Street _. _ ...._._.._. __..._._ __....__..__.. ._ _—_ _.._...._____ ,.._..t .�___ 4. i Commonwealth of PA '�hJy ..... ..._ .. ... ..... ._.... i Department of Public Welfare i PO Box 2675 ... :...... .......... ... .... arrisburg;PA...17405 ........._ .._..............._._...---.. .................._ ._....._ ;.._.. _.............._ ............................ .. 5. , _.._ _..._ 'AB4 4WXA f S Commonwealth of PA Bureau of Individual Tax Inheritance Tax Division 6 3 ;_.._&th Flog,-Strawber Square._ s _. . ......... _._ __.-_--_ _.._._. _...... __. .._._...._ ....._.__.. 6. Department#280601 i 3 Harrisburg,PA 17128 „ ...................................... ..._._.... ......._. .. ....,.. ...... ... ....._I i i Department of PubHe Welfare E I # f ...... Gasttaipt11nit..__.._. 7. Estate Recovery Program 5 -.3 PO 8ozi38. ... ... ......... ........ ... ...._... ... -Willow Oak Building __ I 3 q ' Harrisburg,..PA.-17105-8486 _ j _............ ...._......._.............._......................._. ........ . .. - .......... ....... t 8. United States of America do United States Attomay __. fdrthls' 'Wm DiStrildarIPA -.. ..., .. ., i United States Ros Gourt Ouse 700 Grant.. Sine 4000. burgh, A l 19 ..................... . . _..... . .. .. ............. Total Number of Pieces u f s Postmas ,Pe N..... .....� Listed by Sender aceived Post Off a See Privacy Act Statement on Reverse PS Form 3$77,Febr any of 2) Co e b ,Ink,t/iR3att PBtt VLYI C,� 1 Name and Address of Sender Check type of mail or service: Affix Stamp Here Certified Recorded Deiiv (N issued as a FEDERMAN &'ASSOCIATES, LLC coo erypntematior�i> cefdNcata�rnaBh+g 305 Old York Road, Suite 300 ' Registered �` � Delivery Confirmation Return Receipt for Merchandise o*ss of dWe bbl) Jenkintown, PA 19046 f M Express Mail `:.` Signature Confirmation Pastmarit and Insured Date of Receipt_ Article Number Addressee(IVarttes,SfeeS 01y,Saf&21P Gbnie) Postage FQ8 Handling Acivai Value insured Due Sander DC SC T SH RD RR Charge i if Registered Vase if CUD Fee , Fee Fee , Fee Fee 1. PA Department of Revenue T �� "Bureau of Compliance -PO Box 281230 Harrisburg,PA 17128-1230 .. f............................_... '......................._ _ ...'............ . .............. 2. Commonwealth of PA Y f E Department of Revenue i 1 Bureau of Compliance Clearance_Suppott Department 280946 ._.- ..�lams>�,PA`17T25-�10 _ .._m.. _.__ _ ___. _ _..__._.______ _ __w_ ATPN:Sheriffs Sales _.__. _........._.. _..,, . ._...._...... ....... ............. _ ___.._.__. ._....._ TE i 4. W I ..... 1 i i ........_ ....... _.......... .. ........... .............. ............ ........ , E i t x : _.._.. .........._ ................. ___........ .............. .. .... ._..........................._.............................................................._...__........._....._._._....................._.... .............................. ...... _..... ........ ...._.... ........_.................. ..._... ._.. _...;.. _.'... ........ s 3 ................................. .. ... r K 3 i __...._. ._ ____ _..__ _._. 6. i < � `. �� sxms t t < s � I .._ _._... _.._... ....__......... _........ __......_....._... .................................. ... .. ............. ...,...,..................... ... .. s _.. r i _.. _...... ...._... ............_............ ...... ............_... _ ._... Ystau s . 8. � 4 < s i _ ......... .. __............ .. . 1......... ........... Total Number of Pieces t1! of Pieces Postmaster, r Name receiving a - oyes) 2 Listed by Sender ecei a o Uf►ice -a See Privacy Act Statement on Reverse ,PS Form 3877,Feb u 02 lPa Co by T Ink,0120al Pert w p<� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r - nr��titr at cuittbe 0 THZ PIRG T HiuNi1 AR'f Jody S Smith r Chief Deputy 2013 SEP —4 KIM 9; S Richard W Stewart NO, C U IBER tA?qD ClM �Y SOtICItOr OFFICE CF THE SHERIFF PCNNSYi.VAtdiA Wells Fargo Bank vs. Case Number Natascha Thomas (et al.) 2008-7460 SHERIFF'S RETURN OF SERVICE 03/26/2013 06:45 PM -Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 332 Roxbury Road, Lower Mifflin -Township, Newville, PA 17241, Cumberland County. 03/26/2013 08:07 PM -Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: James Thomas at 332 Roxbury Road, Newville, PA 17241, Cumberland County. 03/26/2013 08:07 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be JAMES THOMAS-SPOUSE,who accepted as"Adult Person in Charge"for Natascha Thomas at 332 Roxbury Road, Newville, PA 17241, Cumberland County. 06/03/2013 As directed by Thomas M. Federman, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/4/2013 09/03/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $803.26 SO ANSWERS, September 03, 2013 RbNW R ANDERSON, SHERIFF . on, a7_ (c)CournySuite Sheriff,Teieosoff.Inc. F'EDERMAN & ASSOCIATES, LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No. 81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown,PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff CUMBERLAND COUNTY V. NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO. 08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 The undersigned hereby certifies that he/she is the attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 332 Roxbury Road,Newville,PA 17241, a copy of the description of said property is attached hereto and marked Exhibit"A". 1. Name and address of Owner(s)or Reputed Owner(s): Name Address Natascha Thomas 332 Roxbury Road Newville,PA 17241 James Thomas 332 Roxbury Road Newville,PA 17241 2.Name and address of Defendant(s)in the judgment: Name Address Natascha Thomas 332 Roxbury Road Newville,PA 17241 James Thomas 332 Roxbury Road Newville,PA 17241 3.Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address n a L 4.Name and address of the last recorded holder of every mortgage of record: Name Address 5.Name and address of every other person who has any record lien on the property: Name Address 6.Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 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: Tenant(s)/Occupant(s) 332 Roxbury Road Newville,PA 17241 Domestic Relations Office PO Box 320 Cumberland County Courthouse 13 North Hanover Street Carlisle,PA 17013 Commonwealth of PA PO Box 2675 Department of Public Welfare Harrisburg,PA 17105 Commonwealth of PA 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare PO Box 8486 TPL Casualty Unit Estate Willow Oak Building Recovery Program Harrisburg, PA 17105-8486 United States of America United States Post Office& Courthouse c/o United States Attorney 700 Grant Street, Suite 4000 for the Western District of PA Pittsburgh, PA 15219 PA Department of Revenue PO Box 281230 Bureau of Compliance Harrisburg, PA 17128-1230 Commonwealth of PA Department 280946 Department of Revenue Harrisburg, PA 17128-1230 Bureau of Compliance ATTN: Sheriff's Sales Clearance Support 8.Name and address of Attorney of record: Name Address 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. Section 4904 relating to unsworn falsification to authorities: FEDERMAN & ASSOCIATES, LLC Date: (/ - Q�' 2- /— �� OMAS M.FEDERMAN,ESQ.I #64068 F]DANIELLE BOYLE-EBERSOLE, SQ.ID 981747 305 York Road, Suite 300 Jenkintown, PA 19046 Attorney for Plaintiff Tract No. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township,Cumberland County, Pennsylvania,referred to as Lot No.C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Stum",prepared by Eric L.Diffenbaugh,Professional Land Surveyor,which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79,Page 145,as follows: BEGINNING at a set railroad spike in public road SR-0997(Roxbury Road)at corner of the within described parcel and parcel B on the above referred to Subdivision Plan;thence along Roxbury Road,North 48 degrees 51 minutes 49 seconds East,50.00 feet to a point,in line of land now or formerly of Wayne F.Peters,which lands the within described parcel is being added to as a lot addition;thence along Peters'lands,South 48 degrees 20 minutes 14 seconds East,249.10 feet to a set iron pin,in line of lands now or formerly of Elwood R.and David W.Gutshall; thence along line of lands of Gutshall,South 33 degrees 22 minutes 56 seconds West,50.13 feet to a set iron pin at comer of Parcel B;thence along line of Parcel B,North 48 degrees 20 minutes 14 seconds West,262.59 feet to the set railroad spike at point and place of beginning. BEING Parcel No. 15-05-0411-018. Tract No.2: ALL that certain lot of ground situate in Lower Mifflin Township,Cumberland County,Pennsylvania,bounded and described in accordance with survey made by Thomas A.Neff,on March 27, 1968,a draft of said survey being attached hereto and incorporated herein by referenced,as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G.Wert,which spike at the place of beginning is One Thousand Three Hundred Sixty(1,360)feet West of the center line of Legislative Route 21036;thence from said spike at the place of beginning along said line of land now or formerly of William G.Wert, South 58 degrees 45 minutes East,a distance of Two Hundred(200)feet to a stake in line of land now or formerly of G.Herbert Richardson;thence along said line of land now or formerly of G.Herbert Richardson,South 42 degrees 17 minutes 20 seconds West,a distance of One Hundred(100)feet to a stake in line of land now or formerly of Lester L.Clever;thence along said line of land now or formerly of Lester L. Clever,North 58 degrees 45 minutes West,a distance of Two Hundred(200)feet to a spike in the center line of Legislative Route 21001;thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East,a distance of One Hundred(1 00)feet to a spike,the place of beginning. CONTAINING One Hundred(100)feet in front along the center line of Legislative Route 21001 and extending Southwardly therefrom at an even width a distance of Two Hundred(200)feet,comprising an area of Forty-five One Hundredths(.45)acre,and having thereon erected a one story brick and aluminum siding covered dwelling house. BEING Parcel No. 15-05-0411-018. BEING the same premises that Wayne F.Peters,a married man,by Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland(Book 277 Page 4692)granted and conveyed unto Natascha Thomas,his/her heirs and assigns,in fee. FEDERMAN & ASSOCIATES, LLC By:Thomas M.Federman,Esq.,ID No.64068 By:Danielle Boyle-Ebersole,Esq.,ID No. 81747 305 York Road,Suite 300 ATTORNEY FOR PLAINTIFF Jenkintown, PA 19046 (215)572-5095 COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO BANK,N.A.,AS CERTIFICATE TRUSTEE (NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff CUMBERLAND COUNTY V. NATASCHA THOMAS(MORTGAGOR&RECORD OWNER) NO.08-7460 Civil Term JAMES THOMAS(MORTGAGOR ONLY) Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO:Natascha Thomas James Thomas 332 Roxbury Road Newville,PA 17241 Your house(real estate)at 332 Roxbury Road,Newville,PA 17241 is scheduled to be sold at the Sheriff's Sale on June 5,2013 at 11:00 a.m.at the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,PA, 17013 to enforce the court judgment of$123,302.00 obtained by Plaintiff against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to the Plaintiff the back payments,late charges,costs, and reasonable attorney's fees due.To find out how much you must pay,you may call Federman & Associates, LLC, at(215) 572-5095. 2. 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 sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS 1. If the Sheriff's Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling Federman& Associates,LLC,at(215) 572-5095. 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 on the sale. To find out if this has happened,you may call Federman&Associates,LLC, at (215) 572-5095. 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 a 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 real estate.A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money.The money will be paid out in accordance with his schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate 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, 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 REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17103 (717) 249-3166 (800) 990-9108 Tract No. 1: ALL the following described real estate lying and being situate in Lower Mifflin Township,Cumberland County, Pennsylvania,referred to as Lot No.C more particularly described in accordance with Subdivision Plan entitled "Final Subdivision Plan for Edgar Sturn",prepared by Eric L.Diffenbaugh,Professional Land Surveyor,which said Subdivisions Plan has been approved by the appropriate municipal authorities and is recorded in Cumberland County Plan Book 79,Page 145,as follows: BEGINNING at a set railroad spike in public road SR-0997(Roxbury Road)at corner of the within described parcel and parcel B on the above referred to Subdivision Plan;thence along Roxbury Road,North 48 degrees 51 minutes 49 seconds East,50.00 feet to a point,in line of land now or formerly of Wayne F.Peters,which lands the within described parcel is being added to as a lot addition;thence along Peters'lands, South 48 degrees 20 minutes 14 seconds East,249.10 feet to a set iron pin,in line of lands now or formerly of Elwood R.and David W. Gutshall; thence along line of lands of Gutshall,South 33 degrees 22 minutes 56 seconds West,50.13 feet to a set iron pin at corner of Parcel B;thence along line of Parcel B,North 48 degrees 20 minutes 14 seconds West,262.59 feet to the set railroad spike at point and place of beginning. BEING Parcel No. 15-05-0411-018. Tract No.2: ALL that certain lot of ground situate in Lower Mifflin Township,Cumberland County,Pennsylvania,bounded and described in accordance with survey made by Thomas A.Neff,on March 27, 1968,a draft of said survey being attached hereto and incorporated herein by referenced,as follows: BEGINNING at a spike in the center line of a public road known as Legislative Route 21001 at the Northwestern corner of land now or formerly of William G.Wert,which spike at the place of beginning is One Thousand Three Hundred Sixty(1,360)feet West of the center line of Legislative Route 21036;thence from said spike at the place of beginning along said line of land now or formerly of William G.Wert,South 58 degrees 45 minutes East,a distance of Two Hundred(200)feet to a stake in line of land now or formerly of G.Herbert Richardson;thence along said line of land now or formerly of G.Herbert Richardson,South 42 degrees 17 minutes 20 seconds West,a distance of One Hundred(100)feet to a stake in line of land now or formerly of Lester L.Clever;thence along said line of land now or formerly of Lester L.Clever,North 58 degrees 45 minutes West,a distance of Two Hundred(200)feet to a spike in the center line of Legislative Route 21001;thence along the center line of said Legislative Route 21001, North 42 degrees 17 minutes 20 seconds East,a distance of One Hundred(1 00)feet to a spike,the place of beginning. CONTAINING One Hundred(100)feet in front along the center line of Legislative Route 21001 and extending Southwardly therefrom at an even width a distance of Two Hundred(200)feet,comprising an area of Forty-five One Hundredths(.45)acre,and having thereon erected a one story brick and aluminum siding covered dwelling house. BEING Parcel No. 15-05-0411-018. BEING the same premises that Wayne F.Peters,a married man,by Deed dated 12/1/2006 and recorded 12/11/2006 in the County of Cumberland(Book 277 Page 4692)granted and conveyed unto Natascha Thomas,his/her heirs and assigns,in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 08-7460 Civil COUNTY OF CUMBERLAND) CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,NA,AS CERTIFICATE TRUSTEE(NOT IN ITS INDIVIDUAL CAPACITY BUT SOLELY AS CERTIFICATE TRUSTEE),IN TRUST FOR REGISTERED HOLDERS OF VNT TRUST SERIES 2010-2 Plaintiff(s) From NATASCHA THOMAS(MORTGAGOR&RECORD OWNER)JAMES THOMAS (MORTGAGE ONLY) (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $123,302.00 L.L.: Interest from 2/4/09 TO 6/5/13 PLUS$24.16 PER DIEM THEREAFTER-$38,245.28 Atty's Comm: Due Prothy: $2.25 Arty Paid: $3,461.16 Other Costs: Plaintiff Paid: Date: 2/28/2013 David D.Buell,Prothonotary (Sea]) y:— 41 � Deputy REQUESTING PARTY: Name: THOMAS M. FEDERMAN, ESQUIRE Address: FEDERMAN&ASSOCIATES,LLC 305 YORK ROAD,SUITE 300 JENKINTOWN,PA 19046 Attorney for: PLAINTIFF Telephone: TRUE.G'O'B'``F ROM RECURS and In Testimony Wherecf,1 here u grllsie,p a Supreme Court ID No.64068 -al of said Coin at and the�c� ,2 Th'ss�..--o day of Prot o otary On March 11, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, PA, Known and numbered as 332 Roxbury Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference - u- Lnincorporated herein. 7Z_. J,-' &Date: March 11, 2013 4J By: VICE' EC state Coordinator CUMBERLAND LAW JOURNAL Writ No. 2008-7460 Civil WELLS FARGO BANK vs. NATASCHA THOMAS, James Thomas Atty.:Thomas M. Federman DESCRIPTION:ALL the following described real estate lying and being situate in Lower Mifflin Township, Cumberland County,Pennsylvania. LOCATION OF PROPERTY: 332 .Roxbury Road,Newville,PA 17241. PARCEL NO: 15-05-0411-018. THEIMPROVEMENTSTHEREON ARE: Residential Dwelling. SEIZED AND TAKEN IN EXECU- TION AS THE PROPERTY OF: Nata- scha Thomas&James Thomas. REAL DEBT: $123,302.00. 75 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 12, April 19 and April 26, 2013 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. isa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this 26 day of April, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy t4f atr10t1WXfW5 Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/Community Weekly editions which appeared on the date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 2008-7460 Civil 04/16/13 WELLS FARGO BANK Vs. 04123/13 NATASCHA THOMAS 04/30/13 James Thomas Atty: Thomas M.Federman DESCRIPTION: ALL the following . . . " " " . . . . . . . . . . . . . . . . . . described real estate lying and being situate in Lower Mifflin Township, Cumberland County,Pennsylvania. Sworn to and subscribed before me his 13 day of May, 2013 A.D. LOCATION OF PROPERTY: 332 Roxbury Road,Newville,PA 17241 PARCEL NO:15-05-0411-018 aw �_ I THE IMPROVEMENT'S THEREON ARE:Residential Dwelling IIC SEIZED AND TAKEN IN EXECUTION AS THE PROPERTY OF: Natascha Thomas&James Thomas REAL DEBT:$123,302.00 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel,Notary Public Washington Twp.,Dauphin County My Commission Expires Dec.12,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES