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Home My WebLink About09-6707 Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street @ 6(/ Harrisburg, PA 17102 717.234.4178 mtg@pkh.com MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JILL RICHARDSON ACTION OF MORTGAGE FORECLOSURE Defendant THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MIDFIRST BANK, vs. JILL RICHARDSON, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff MIDFIRST BANK, Plaintiff vs. JILL RICHARDSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0 4- (-,76,7 ION - LAW CIVIL ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. The Plaintiff is MIDFIRST BANK, a corporation whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. The Defendant, JILL RICHARDSON, is an adult individual whose last known address is 31 MARKET STREET WORMLEYSBURG, PA 17043. 3. On or about, October 19, 2000, the Defendant executed and delivered a Mortgage Note in the sum of $61,660.00 payable to EQUITY ONE, INCORPORATED, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, the Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth on October 23, 2000 in Mortgage Book 1646, Page 804 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and was recorded on October 23, 2000 in the aforesaid County in Mortgage Book 657, Page 1109. The Mortgage was subsequently assigned to MIDFIRST BANK and was recorded in the aforesaid County on January 22, 2003 in Mortgage Book 693, Page 3266. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 31 MARKET STREET WORMLEYSBURG, PA 17043 and is more particularly described in Exhibit "B" attached hereto. 6. The Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that the Mortgagor has failed to pay the installment due on April 01, 2009 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $62,771.87 Interest at $13.76 per day $3,371.20 From 03/01/2009 To 11/01/2009 ( based on contract rate of 8.0000%) Accumulated Late Charges $274.27 Late Charges $24.12 $168.84 From 04/01/2009 to 11/01/2009 Escrow Deficit $460.00 Attorney's Fee at 5% of Principal Balance $3,138.59 TOTAL $70,184.77 "Together with interest at the per diem rate noted above after November 01, 2009 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and to accelerate the loan balance was sent to the Defendant by letter dated August 17, 2009 as required by Pennsylvania Act No. 6 of 1974, as amended. A copy of the August 17, 2009 Act 6 Notice is attached hereto and marked Exhibit "C". 10. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 11. The Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.0000% ($13.76 per diem), together with other charges and costs including escrow advances incidental thereto to the dat f Sh riff s Sale and for foreclosure and sale of the property within described. By: PURCELL, KRUG & HA LER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Multistate ORIGNALNOTE FHA Cue No. LN# 00240407 441-6381967 , October 19, 2000 DDate] 31 Market Street,Wormleysburg,PA 17043 MOPOM Addmul 1. PARTIES "Borrower' means each person arguing at the end of this Note, and the person's succenors and assigns. 'Lender' means Equity One, Incorporated, a Pennsylvania Corporation and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a luau received from Lender. Borrower promises to pay the principal stun of 'Sixty One Thousand Six Hundred Sixty and no/100 Dollars (lt..s. a 61,660. 00 ),'plus rest, to the order of Leader. Interest will be 06%od on unpaid principal, from the date of disbursement of the loan proceeds by Leader, at the to of Eight perceltt ( ; 8.D000 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is datad the same date as this Note and called the "Security instmment.' The Security Inst ument proW= the Lander from losses which udght result If Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall mare a payment of principal and interest to Leader on the fast day of each month beginning on December .1 , 2000 . Any principal and interest remaining on the fu* day of November 2030 , will be due on that date, which is called the "Maturity Date." (B) place Payment shall be made at 400 Lippincott Drive, Marlton, NJ 08053 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 452.44 This amount will be part of a larger monthly payment required by the Security Instrument. that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) ABonge to this Note for payment ad[ustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the Congo shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ?Graduated Payment Allonge []Growing Equity Auonge ?Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender stall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Leader and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Leader agrees in writing to those changes. FSA Mdtlaate Used Rate NOW -10195 1R iN011.o1 4V VMP MORTOAOe PORMS - W 01421.7201 Pp" 1 e1 2 MW 01M.01 lnkwc N1111111 rqt ked i 4W 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments . If Lender has not received the fall monthly payment required by the security Instrument, as described in Paragraph 4(C) of this Nome, by the end of fifteen calendar days after the payment is due. Lender may collar a late charge in the amount of Four patent ( 4.0000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in hill any monthly payment, then leader may, except as lhnited by regulations of the Secretary In the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Leader may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumetsam regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when mot permitted by HUD regulations. As used in this Note, 'Secretary' means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' few for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who bas obligations under this Note waive the rights of presentment and notice of dishonor. 'presentment' means the right to require Lender to dmtand payment of amounts due. 'Notice of dishonor' means the tight to require Leader to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unleas applicable law requires a different method, any notice that rarer be given to Borrower under this Now will be given by delivering it or by mailing it by frost class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's diffaew address. Any notice that must be given to Lender under this Note will be given by first class nail to Leader at the address stated in Paragraph 4(B) or at a different address if Borrower Is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER TMS NOTE If more than one person signs this Not;, each person Is frilly and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who tubes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to beep all of the promises made in this Note. Lander may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note (Seal) -D w Ji Richardson .> `ewer (seal) (Scal) Borrower -Borrower (scat) (mot) -Borrower -Borrower (seat) (Seat) -Borrower -Borrower VMOUP RECOURSE PAY TO MM ORDER OF: BOMESIDE LENDING. INC. ?' Y?Y TO 'PILE ;? I OB:. EQUITY ONE, IIVCORpO1ZATBD WITliJ00T FF BRMA P-!.. RZ1mL>C Stall 1311>gIOR YICIe PBICSIDUT Asabutartt Vita IPreddalt ALL THAT CERTAIN TRACT, OF LAND SITUATE IN THE BOROUGH OF WORMLEYSBURG, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A SURVEY OF MICHAEL C. D' A GEELO RS. DATED APRIL 27. 1991, AS FOLLOWS, To WIT, BEGINNING AT A POINT ON THE SOUTHERN LINE OF MARKET STREET, SAID POINT BEING MEASURED BY SAME IN A SOUTHWESTERLY DIRECTION A DISTANCE OF 71.54 FEET FROM SECOND STREET, THENCE SOUTH 41 DEGREES 36 A DUMS 00 SECONDS EAST BEING ALONG AND THROUGH A PARTITION WALL AND BEYOND A DISTANCE OF 57.99 FEET TO A POINT, THENCE SOUTH 48 DEGREES 24 MINUTES 00 SECONDS WEST A DISTANCE OF 14.66 FEET TO A POINT, THENCE NORTH 45 DEGRES- 25 MINUTES 00 SECONDS WEST ALONG THE NORTHEASTERN LINE OF AN UNOPONED ALLEY A DISTANCE OF 58.12 FEET TO A POINT ON THE SOUTHERN LINE OF MARKET STREET AFORESAID; THENCE ALONG SAID SOUTHERN LINE OF MARKET STREET, NORTH 48 DEGREES 24 MINUTES 00 SECONDS EAST, A DISTANCE OF 18.53 FEET TO A POINT AND PLACE OF BEGINNING. BEING KNOWN AND NUMBERED AS 31 MARKET STREET. UNDER AND SUBJECT. NEVERTIiLESS, TO ALL OTHER CONDITIONS AND RESTRICTIONS OF RECORD, IF ANY, AS THEY MAY APPEAR, 'A 'b Sep-28-09 02:11pm Front-MIDLAND MORTGAGE REFERRAL T-006 P.01/02 F-966 Midland Mort~ Co. "Innlglency1stanl?ce Center P.O. 11M 08/17/09 -RE:v°4.41" sfl.L. RICHARDSON 31 MARKET ST WORMLEYSBURG PA 17043-1673 RE' 31 MARKET ST WORMLE:YSE3URG PA 17043-1573 Loan Number 0046967134 Dear Mortgagor. Midland Mortgage Co. is the nolder of a Mortgage and a Note on the above promMes. Or is the mort0age- servicing agent for such holder. As of the date of this notice, THE MORTGAGE IS IN DEFAULT STATUS because of non-payment of the following: payments, late charges, and advances from 04/0109 through 08/01/09 The total amount now required to cure the default (or to other words, to get caught up on your payments) is $5141.25. All payments referred to in this notice must be in the form of Cashiers or Cartified Check made payable to Midla l Mortgage Co. and must be received at the expedited payment processing address on your coupon book not later than the dates and times specified herein. In the event that payment (as specified in the proceeding paragraph) is not made WITHIN THIRTY (30) DAYS from the date of this letter, it is the intention of the holder of the mgrtgW, through this company. to amalerate (declare qua and payable immediately the entire Ipan) the mortgage obiotion and all other lawful charges and instruct our attomey to institute MORTGAGE FORECLOSURE PROCEEDING (A) If you wish to CURE THE DEFAULT within thirty (30) days from the date of this letter, you must pay the TOTAL AMOUNT DUE: stated above, plus an adattioonal monthly installment if payment is made after the 1" day of the next month, plus an additional late charge 9 due at time of payment and not included above. A LATE CHARGE: is due with each mortgage payment that is paid more than fifteen (15) days after the due date. Your current monthly installment is $603.08. (&) Fif payrnent is ORECLOSURE PROCEED PROCEEDING THIRTY W3 been started. the amount you wig have to pay will also inC tide the regular monthly installments and tare Marges men due, plus, if incurred. any ATTORNEY'S FEE OF NOT MORE THAN $50.00 and any fife report costs, which amount can be obtained by contacting Midland Mortgage Co. at 1-800-552-3000, extension 1799. AFTER FORECLOSURE PROCEEDING HAS BEEN STARTER. you have the right to STOP the foreclosure action at any time up to ONE (1) HOUR BEFORE the commencement of the SHERIFF'S 'If you flaw reMV64 a pankruptcy 40cnarye of go 46Dt Sooa 0 py on MarigpgoOs d of Tryst or you are Lurre011Y In 4111M lptcY under the fl V"Mon of Va aytornW stay, #" WW os n" an attempt to colleen 00 dahi. put any 40lcat wet nee4 10 06 QK It W avoid foreeWsure If Y" Wan was in 4011111yR ar ins bye Mlc" NQ&n se VAq 4 wo you have not fim baftWicy or started a da charge of tie 4ept spmow py Vte 1A«teaille4 of Trust. we of* "No"re4 to advise ywa plat W46 owmM racawn la ft" a data asos?or, Vus is an WOMpt 10 collet[ 4 dept. and any alforalatwn optaul A wO 139 4140 ibf 11" P"T"O C 1-1- A I Sep-26-09 02:11pm From-MIDLAND MORTGAGE REFERRAL T-006 P.02/02 F-966 Midland IIA Me CO- PDelinueen-mil to ?a Center SAS-E by paying the entire amount dus at the time (which shall include all delinquent pmstallments and unpaid late charges, together with REASONABLE LEGAL FEIIS ACTUALLY INCURRED, costs and other sums related to the foreclosure action, and which amount can be obtainea by oontaating Midland Mortgage Co. at 1-800-552-3000). Should you FAIL to reinstate the loan as outlined above, pie mortgage promises will be SOW AT SHERIFF'S SALE. which will take place approatimately seven (7) to eleven (11) weeks following SERVICE of the Complaint in Mortgage Foreclosure, at which time your OWNERSHIP interest to the mortgaged promises will be TERMINATED, and thereafter, if occupied, proceedings will be taken to OBTAIN POSSESSION of the real estate. You have the right to REFINANCE THE LOAN with another lending institution or TRANSFER THE PROPERTY to another person, under and subject to the existing mortgage. That person will have the SAME RIGHT TO CURE THE DEFAULT as you have, subject to the some limitations and requirentertts. You may CURE DEFAULTS up to three (3) Was in any calemar year. upon cure of a default yQw will be in the same position as if there had been NO DEFAULT. A default may be caged by ANYONE on your behalf. It is important that you call our office so soon as possible to discuss the Options available to you. Our wan Counselors may to reaoned toll-free at 1-800-552-3000. Monday Mmugn Friday. 8:00 a.m. to 9.40 p.m. (Cenral rune). Sincerely, Delinquency Assistance Center Mraland Mortgage Co. Loan Number 0046967134 .If you have n mmm a =WupWy 0scrrarye of the dept w9wrea oy the Mw paVW0"4 of Trust or you are carmay in hanlt NPrcy under the propt?+ira?1 of tna ouprrimc stay, the letter w not an at0 NMX In GOMM 414 dept: put any del" an# nea4 m tie erred t6 avow foraidos?ue Ir your men was in aemun at the lane Mrrtland usher se imM it &M you (cave not filed ow*JwPicy or ramveq a drsaharye of the data secured by tits (+tortgapP DwO of Trust. we ale ragw9ed t4 movwa you than dps mmmurueatwn a from a debt coiiemr, this rs an attempt M conoct a oats. am any attNrnstron obmne4 will 00 uaea for that pu?pasa COMPANY NAME: MIDFIRST BANK VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 5 2 Dated Z06% By Title Vice President FIE 01F =f i'E- - :0TARY 20.9 CC1 -B A-N 10: 20 CL "1 1 1V Sheriffs Office of Cumberland County R Thomas Kline F1(EQ__'-`:'Z;?'? Sheriff Q7= 71 != 7ARY Ronny R Anderson Chief Deputy , ? 2099 OCT 15 All a: 11 K Jody S Smith Civil Process Sergeant OFF ,',-E 1E E RIFF Edward L Schorpp - Solicitor Midfirst Bank vs. I Case Number Jill Richardson 2009-6707 SHERIFF'S RETURN OF SERVICE 10/09/2009 05:17 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 9 2009 at 1717 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jill Richardson, by making known unto herself personally, at 31 Market Street Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 October 13, 2009 SO ANSWERS, ?0010ae?? -'e?? R THOMAS KLINE, SHERIFF Deput Sheriff w MIDFIRST BANK, JILL RICHARDSON, PLAINTIFF VS. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-6707 MORTGAGE FORECLOSURE PR AECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) JILL RICHARDSON for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per diem of $13.76 From 03/01/2009 To 11/01/2009 Accumulated Late Charges Late Charges ($24.12 per month to 11/01/2009) Escrow Deficit 5% Attorney's Commission TOTAL $62,771.87 $3,371.20 $274.27 $168.84 $460.00 $3,138.59 $70,184.77 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriffs Sale. PURCELL, KRUG & HALL Leon P. Haller PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 .w t MIDFIRST BANK, Vs. JILL RICHARDSON, PLAINTIFF DEFENDANT(S) NO. 09-6707 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on November 3, 2009 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW '4 MIDFIRST BANK, Plaintiff VS. JILL RICHARDSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6707 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: November 3, 2009 TO: JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & H LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION LAW NO. 09-6707 JILL RICHARDSON, DEFENDANT IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this /? day of 20_q otar ublic ,::i,,1,k4WEALTH OF i+[ N r l ?r„v . NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Aug. S, 2010 LEON P. illkLLER, ESQUIRE RLEC-OrFtCE OF THE PRM CNIOTARY 2009 NOY 18 AM 10: 16 CUM = U I "juMY ENNSYC%jkkjjA ?I //,dO /d &I?j Pirl -,f el/*C -jrC/- c k, # 15-36d6 ; ,?- 33 703 lva ?)e C At ldl-d 01 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 09-6707 TOTAL WRIT $74,416.51 *Plus additional interest, late charges and other costs to date of sheriffs sale. SALE DATE: Wednesday, March 03, 2010 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE MIDFIRST BANK, Total Judgment Amount $70,184.77 PLAINTIFF Interest $1,651.20 Per diem of $13.76 to sale vs. date 3/3/2010 Late Charges $72.36 JILL RICHARDSON, $24.12 per month to sale DEFENDANT(S) date 3/3/2010 Escrow Deficit $2,508.18 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: November 11, 2009 ,'?z Attorney for Plaintiff / 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA . SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 31 MARKET STREET WORMLEYSBURG, PA 17043 / ) Date: y P OTHONOT LE CIVIL DIVISION BY DEPUTY All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael C. D'Angelo, R. S. dated April 27, 1991, as follows, to wit; Beginning at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes 00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a point; thence South 48 degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45 degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance of 58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of Market Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and place of beginning. Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they may appear. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 09-6707 ASSESSMENT NO. 47-20-1858-157 ALE)-OFFICE 4F THE FROTH NOTARY 1009 NOV 18 AM 10: 19 CUM??-k' i. +'dU Goul TY PEi NSYLVANfA I _4 MIDFIRST BANK, PLAINTIFF VS. JILL RICHARDSON, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 09-6707 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 31 MARKET STREET WORMLEYSBURG, PA 17043: 1. Name and address of the Owner(s) or Reputed Owner(s): JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN Wormleysburg Borough 20 Market Street Wormleysburg, PA 17043 Wormleysburg Borough Manager Gary W. Berresford 20 Market Street Wormleysburg, PA 17043 Citifinancial Inc. 3401 Hartzdale Drive - Suite 126 Camp Hill, PA 17011 Citifinancial Inc. P.O. Box 17170 Baltimore, MD 21203 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller P I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE:November 11, 2009 kir THEPPC)Tfir t,ay 2009 NOY 18 AM 10: 19 PENIN'SYLVANA, MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. JILL RICHARDSON, DEFENDANT(S) TAKE NOTICE: CIVIL ACTION LAW NO. 09-6707 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 03, 2010 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 31 MARKET STREET WORMLEYSBURG, PA 17043 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-6707 JUDGMENT AMOUNT $70,184.77 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILL RICHARDSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of m the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael C. D'Angelo, R.S. dated April 27, 1991, as follows, to wit; Beginning at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes 00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a point; thence South 48 degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45 degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance of 58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of Market Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and place of beginning. Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they may appear. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT NO. 09-6707 ASSESSMENT NO. 47-20-1858-157 FILED-OFFICE OF THE PROTHONOTARY 2009 NOV 18 AM 10: 17 G-UNTY PENNSYLVANA x l-/, v Q PA- ,ALK rk At j<-3606 X33703 77-. y?. qo ?r ? , y D b r. r- 1--L s WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-6707 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK Plaintiff (s) From JILL RICHARDSON (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$70,184.77 L.L.$.50 Interest PER DIEM OF $13.76 TO SALE DATE 3/3/2010 - $ 1,651.20 Atty's Comm % Atty Paid $161.40 MONTH TO SALE DATE 3/3/2010 - $72.36 Plaintiff Paid Date: November 18, 2009 (Seal) Due Prothy $2.00 Other CostsLATE CHARGES $24.12 PER ESCROW DEFICIT - $2,508.18 zz 6.?F? C Lon , Pr tary By: Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: PURCELL, KRUG & HALLER, 1719 NORTH FRONT STREET, HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. DEFENDANT(S) CIVIL ACTION LAW NO. 09-6707 JILL RICHARDSON, IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 1~~~~(~q , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 Wormleysburg Borough 20 Market Street Wormleysburg, PA 17043 Worrnleysburg Borough Manager Gary W. Berresford 20 Market Street Wormleysburg, PA 17043 Citifinancial Inc. 3401 Hartzdale Drive -Suite 126 Camp Hill, PA 17011 Citifinancial Inc. P.O. Box 17170 Baltimore, MD 21203 n ~ _~ G b rT ~ c-°? -+~ ~ --~ - ~ w r ? r ,v ~ ~ _.. .._ ~_.:` tc:~ K cp a.-~~~~" PURCELL, KRUG & HILLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STACEY O'GORMAN JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 Wormleysburg Borough 20 Market Street Wormleysburg, PA 17043 Wormleysburg Borough Manager Gary W. Berresford 20 Market Street Wormleysburg, PA 17043 Citifinancial Inc. 3401 Hartzdale Drive -Suite 126 Camp Hill, PA 17011 Citifinancial Inc. P.O. Box 17170 Baltimore, MD 21203 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533-3836 JOSEPH NISSLEY (1910-1982) JOHN W.PURCELL VALERIE A. GUNNOF COUNSEL NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by bein d of said Sheriffs Sale. Leon P. aller PA I.D.15700 Attorney for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. JILL RICHARDSON, DEFENDANT(S) CIVIL ACTION LAW NO. 09-6707 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will beheld: DATE: Wednesday, March 03, 2010 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 31 MARKET STREET WORMLEYSBURG, PA 17043 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 09-6707 JUDGMENT AMOUNT $70,184.77 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: JILL RICHARDSON A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office -Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KR.UG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 All that certain tract, of land situate in the Borough of Wormleysburg, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey of Michael C. D'Angelo, R.S. dated Apri127, 1991, as follows, to wit; Beginning at a point on the southern line of Market Street, said point being measured by same in a southwesterly direction a distance of 71.50 feet from Second Street; thence South 41 degrees 36 minutes 00 seconds East being along and through a partition wall and beyond a distance of 57.99 feet to a point; thence South 48 degrees 24 minutes 00 seconds West a distance of 14.66 feet to a point; thence North 45 degrees 25 minutes 00 seconds West along the Northeastern line of an unopened alley a distance of 58.12 feet to a point on the Southern line Market Street aforesaid; thence along said Southern line of Market Street, North 48 degrees 24 minutes 00 seconds East, a distance of 18.53 feet to a point and place of beginning. Under and subject, nevertheless, to all other conditions and restrictions of record, if any, as they may appear. HAVING THEREON ERECTED A DWELLING KNOWN AS 31 MARKET STREET WORMLEYSBURG, PA 17043 BEING THE SAME PREMISES WHICH Guy A. Berry, Jr. and Virginia A. Berry, by deed dated 10/10/00 and recorded 10/23/00 in Cumberland County Record Book 232, Page 7, granted and conveyed unto Jill Richardson. TO BE SOLD AS THE PROPERTY OF JILL RICHARDSON ON JUDGMENT N0.09-6707 ASSESSMENT NO. 47-20-1858-157 7160 3401 9b4b 5421 1793 TO: JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 SENDER: NOS 03/03/10 REFERENCE: MIDFIRST/RICHARDSON RETURN Postage RECEIPT Certrfied Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail POSTMARK OR DATE Jf.C ' ~~ F~ MIDLAND MORTGAGE COMPANY v. JILL RICHARDSON Cumberland County Sale 3/3/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: JILL RICHARDSON 31 MARKET STREET WORMLEYSBURG, PA 17043 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comuliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Wormleysburg Borough 20 Market Street Wormleysburg, PA 17043 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Wormleysburg Borough Manager Gary W. Berresford 20 Market Street Wormleysburg, PA 17043 ~~ ~ ~ Dv•.:~ SEPSES Fp~~ f` ~p F . ? ~ ~ °~/ PITNEY 60WE5 02 1M ~ $ 01.15° } 0004284324 DEC04 2009 MAILED FROM ZIP CODE 1 710 2 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comaliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Citifinancial Inc. 3401 Hartzdale Drive -Suite 126 Camp Hill, PA 17011 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comaliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Citifinancial Inc. P.O. Box 17170 Baltimore, MD 21203 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comaliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 Postmark: .~°°`~: ! ~~k?. ,~pZE' ~'T,~ ~~~~ "~~ PITNEY BOW1ES5 ~ 00042134324 pEOC~q 200° MAI IED~ FRaM Z!P CODE ? ? 10 2 ~_ ~ . MIDLAND MORTGAGE COMPANY v. JILL RICHARDSON Cumberland County Sale 3/3/2010 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: TENANT/OCCUPANT 31 MARKET STREET WORMLEYSBURG, PA 17043 Postmark: ~r ,,.. ~ ... ..x #~~ i~~. ,• . ~ T~1• ~. -~ ~~~ GSQjES P~~ O z~~` PITNEY BOWES oz 1M $01.15° 00()4284324 DEG04 2009 MAILED FRdM ZIP CODE 1 710 2 ~ ~ f~L~T3-i.~=-~;f c3~ THE P~^3~~~~.~~=~RRY 2Q10 FLAY 13 A~ 8~ 21 i'~Nt~~~Y~V,.~~IA PURCELL, By Leon P. Haller ID 5700 Attorney for Plai iff Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhallerC~nkh. com MIDFIRST BANK, Plaintiff vs. JILL RICHARDSON, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-6707 IN MORTGAGE FORECLOSURE P R A E C I P 8 Please mark the judgment entered in the above case satisfied of record, because the Mortgage has been reinstated and the default cured. Date: April 27, 2010 #8. oo P~ ~'7r~( e~~ r~ s~+g ~ a~i9~