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Home My WebLink About09-8463A McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company 961 Weigel Drive Elmhurst, Illinois 60126 V. Lisa A. Kepes 356 Park Avenue New Cumberland, Pennsylvania 17070 and Louis R. Kepes 356 Park Avenue New Cumberland, Pennsylvania 17070 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number Oq - 8g4A 0'iwi I -" CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 w CIVIL ACTIONIMORTGAGE FORECLOSURE 1. Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Lisa A. Kepes, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 356 Park Avenue, New Cumberland, Pennsylvania 17070. 3. The Defendant is Louis R. Kepes, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 356 Park Avenue, New Cumberland, Pennsylvania 17070. 4. On July 17, 2007, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 2000, Page 2343. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 356 Park Avenue, New Cumberland, Pennsylvania 17070. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due May 23, 2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest through December 4, 2009 (Plus $44.95 per diem thereafter) Attorney's Fee Late Charges Corporate Advance Escrow Advance NSF Fees $ 157,754.98 $ 10,113.75 $ 1,250.00 $ 849.18 $ 1,377.61 $ 3,420.64 $ 39.99 GRAND TOTAL $ 174,806.15 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $174,806.15, together with interest at the rate of $44.95 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBE AND CONWAY,P.C. BY: Attys for aintiff TERRENCE J. McCABE, QUIRE MARC S. WEISBERG, ESQ EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEIWRG AND CONWAY,P.C. BY: Plaintiff TERRENCE J. McCABE, ES WI MARC S. WEISBERG, ES IRI EDWARD D. CONWAY, ESQU MARGARET GAIRO, ESQUIRE EXHIBIT A ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PARK AVENUE 212.4 FEET NORTH OF THE NORTHEASTERN CORNER OF PARK AVENUE AND OAK LANE, AT THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93 AS SHOWN ON THE HEREAINFTER.MEN7IONED PLAN OF LOTS; THENCE NORTHWARDLY BY THE EASTERN LfNE OF PARK AVENUE 50 FEET TO LOT NO. 94 ON SAID PLAN THENCE EASTWARDLY ALONG THE DIVIDING LINE BETWEEN LOT NOS. 93 AND 94 AND 249.5 FEET TO A WIDE ALLEY; THENCE SOUTHWARDLY BY THE WESTWARDLY LINE OF SAID ALLEY, 70.6 FEET TO LOT NO. 92 ON SAID PLAN AND THENCE WESTWARDLY BY THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93, 193.8 FEET TO THE EASTERLY LINE OF PARK AVENUE, THE PLACE OF BEGINNING. BEING LOT NO. 93 ON PLAN "A" AMENDING OF "SEVEN MAPLES NO. 1", AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE IN PLAN BOOK 2, PAGE 9-1/2. BEING THE SAME PREMISES WHICH NICHOLAS E. EDWARDS BY DEED DATED DECEMBER 19, 2000 AND RECORDED JANUARY 2, 2001 OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA GRANTED AND CONVEYED UNTO ALBA L. BOTTS, III GRANTOR HEREIN. TAX MAP OR PARCEL ID NO.: 26-24-0811-069 ADDRESS: 356 PARK AVENUE; NEW CUMBERLAND, PA 17070-1338 r:xx .. i 0 FILE?c=?;E OF THE FF- TH(NOTAR 2M9 DEC -8 AM 6: 11 O$ABEF'L,??p COUNTY -*ga.oo N A-rrr W 8479 q W a34cous SHERIFFS OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 0MCF'F-.._ ` U --0**7!CE t vi._P 10 PM 12= 50 tiUrr? ? a .:,LIMY PENNS (LVAM Household Finance Consumer Discount Co Case Number vs. Lisa A Kepes (et al.) 2009-8463 SHERIFF'S RETURN OF SERVICE 04/06/2010 06:07 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1805 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Lisa A. and Louis R. Kepes, located at, 356 Park Avenue, New Cumberland, Cumberland County, Pennsylvania according to law. 04/06/2010 06:07 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1805 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit:, by making known unto, Louis R. Kepes, personally, at, 356 Park Avenue, New Cumberland, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same 04/06/2010 06:07 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1805 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Lisa A. Kepes, by making known unto, Lisa A. Kepes, personally, at, 356 Park Avenue, New Cumberland, Cumberland County, Pennsylvania its content: and at the same time handing to her personally the said true and correct copy of the same. 06/02/2010 Property sale postponed to 9/8/2010. 09/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Terrance McCabe SHERIFF COST: $848.09 September 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF .,:?. 06) e o" . Co, M c-L 19d, cl cylea1r, ?C, Cou T"Suite She,W, feieosotl hic.. M V s .1 MCCCABE, WI:ISBERG AND CONWAY, P.C. BY: TERRENCE ,I. MCCABE, ESQUIRE - 1D # 16496 MARC S. WEISBERG, ESQUIRE - 11) # 17616 EDWARD 1). CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - 11) # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 1.9109 (215) 790-1010 I lousehoid Finance Consumer Discount Company Plaintiff V. Lisa A. Kepes and Louis R. Kepes Defendants Attorneys for Plaintiff CUMFIFIRLAND COUN-TV COURT OF COMMON PLEAS NO: 09-8463 Civil 't'erm AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Lxecution was filed the following information concerning the real property located at: 356 Park Avenue, New Cumberland, Pennsylvania 17070, a copy of the description of said property being; attached hereto and marked Exhibit "A." 1. Name and address oi'Owncrs or Reputed Owners Name Address Lisa A. Kepes 356 Park Avenue New Cumberland, PA 17070 Louis R. Kepes 356 Park Avenue New Cumberland, PA 17070 2. Name and address of Defendants in the judgnnent: Name Address Lisa A. Kepes 356 Park Avenue New Cumberland, Pennsylvania 17070 Louis R. Kepes 356 Park Avenue New Cumberland, Pennsylvania 17070 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 plaintiff herein. 41. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 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 NONE 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by file sale: Name Address Tenants/Occupants 356 Park Avenue New Cumberland, Pennsylvania 1.7070 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual 'Tax Inheritance Tax Divkion 1:)epartment of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue. Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United Stages ot'America Domestic Relations Cumberland County United States ofAmerica Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 110 North 8"' Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Deparmlea31 #280601 I larrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg!, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 171281230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, I'A 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA 235 North Washington Street Scranton, PA 18503 and Federal Buildino 228 Walnut Street P.O, Box 11754 Harrisburg, PA 17108 Name and address of Attorney of record: Name Address NONE. I verity that the statements made in this Affidavit are true and correct to the best o1'rny personal knowledge or information and belief'. I understand that false statements herein are made subject to (lie penalties of 18 l'a.C.S. Section 4904 relating to unsworn falsification to authorities. February 28, 2010 TER.RENCE,). MCCABE, ESQUIRE DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GA1RO, ESQUIRE Attorneys for Plaintiff LEGAL DESCRIPTION ALL, THAT CERTAIN LOT OF LAND SI'TUAT'E IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PARK AVENUE 212.4 FEET NORTH OF THE NORTHEASTERN CORNER OF PARK AVENUE AND OAK LANE, AT THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93 AS SHOWN ON THE HEREAINFTER MENTIONED PLAN OF LOTS; THENCE NORTHWARDLY BY THE EASTERN LINE OF PARK AVENUE 50 FEET TO LOT NO, 94 ON SAID PLAN THENCE WASTWARDLY ALONG THE DIVIDING LINE BETWEEN LOT NOS. 93 AND 99 AND 249.5 FEET TO A WIDE ALLEY; THENCE SOUTHWARDLY BY THE WESTWARDLY LINE OF SAID ALLEY, '70.6 FEET TO LOT NO. 92 ON SAID PLAN AND THENCE WESTWARDLY BY THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93, 193.8 F'EE'T TO THE EASTERLY LINE OF PARK AVENUE, THE PLACE OF BEGINNING. BEING LOT NO. 93 ON PLAN "A" AMENDING OF "SEVEN MAPLES NO, 111, AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE IN PLAN BOOK 2, PAGE 9-1/2. BEING THE SAME PREMISES WHICH NICHOLAS E. EDWARDS BY DEED DATED DECEMBER 19, 2000 AND RECORDED JANUARY 2, 2001 OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA GRANTED AND CONVEYED UNTO ALBA L. BOTTS, III GRANTOR HEREIN. Being Known As 356 Park Avenue, New Cumberland, Pennsylvania 17070. BEING the same premises which AL.,BA L., BOTTS, III by deed dated March 10, 2005 and recorded March 11, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 267, Page 4416, granted and conveyed to Lisa A. Kepes and Louis R. Kepes, in fec. "TAX MAP PARCEL, NUMBER: 26-24-0811-049 0 BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW McCABE, WEISBERG AND CONWAY, I'.C household Finance ('onsumer f)iseount Company ! COUR.-F OFCOMMON PI-F.AS V. Lisa A. Kepes and LOUIS ]t. Kepes CUMBERLAND COUNTY Number 09-8463 Civil Term NOTICE OF SHERIFF'S SAI..E OF RL:AL PROPhRTY To: I-isa A. Kepes Louis R. Kepes 356 Park Avenue 356 Park Avenue New Cumberland, Pennsylvania 17070 New Cumberland, Pennsylvania 17070 Your house (real estate) at 356 Parlc Avenue, New Cumberland, Pennsylvania 17070 is scheduled to be sold at Sheriffs Sale oil June 2, 2010 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of'the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $176,918.80 obtained by Household Finance Consumer Discount Company 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: The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney%s fees due. To find out flow much you must pay, you may call McCabe, Weisberg and Conway, P,C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment., if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, 'file sooner you contact one, the more chance you will have of' stopping the sale. (See the followin?o notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFFS SALE DOES TAKE PLACE 1. 11' tile Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bird by calling McCabe, R%eisbera and Conway, P,C,, Esquire m(215) 790-1010. 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. fhe sale will go through only if the buyer pays the Sheriff the. full amount due on the sale. To land out ifthis has happened; you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4lf'the anuHnlt 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 nlay 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 this 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 1'0 OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE, CAN PROVIDE YOU WITH INFORMATION A13OUT 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue. Carlisle, Pennsylvania 17013 (800) 990-9108 I LEGAL DESCRIPTION ALL, THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PARK AVENUE 212.4 FEET NORTH OF THE NORTHEASTERN CORNER OF PARK AVENUE AND OAK LANE, AT THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93 AS SHOWN ON THE HEREAINFTER MENTIONED PLAN OF LOTS; THENCE NORTHWARDLY BY THE EASTERN LINE OF PARK AVENUE 50 FEET TO LOT NO. 94 ON SAID PLAN THENCE EASTWARDLY ALONG THE DIVIDING LINE BE'T'WEEN LOT NOS. 93 AND 94 AND 24 9 . 5 FEET O A WIDE ALLEY; THENCE: SOUTHWARDLY BY THE WESTWARDLY LINE OF SAID ALLEY, '70.6 FEET TO LOT NO. 92 ON SAID PLAN AND THENCE WESTWARDLY BY THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93, 193.8 F'EE'T TO THE EASTERLY LINE OF PARK AVENUE, THE PLACE OF BEGINNING. BEING LOT NO. 93 ON PLAN "A" AMENDING OF "SEVEN MAPLES NO. 1", AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE IN PLAN BOOK 2, PAGE 9-1/2. BEING THE SAME PREMISES WHICH NICHOLAS E. EDWARDS BY DEED DATED DECEMBER 19, 2000 AND RECORDED JANUARY 2, 2001 OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA GRANTED AND CONVEYED UNTO ALBA L. BOTTS, III GRANTOR HEREIN. Being Known As 356 Park Avenue, New Cumberland, Pennsylvania 17070. BEING the same premises which ALBA L. BOOTS, III by deed dated March 10, 2005 and recorded March 11, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 267, Page 44) 6, granted and conveyed to Lisa A. Kepes and Louis R. Kepes, in fee. TAX MAP PARCEL, NUMBER: 26-24-0811-049 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8463 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From LISA A. KEPES and LOUIS R. KEPES (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 $176,918.80 L.L. $.50 Interest from 1/21/10 to 6/2/10 at $29.08 -- $3,867.64 Atty's Comm % Due Prothy $2.00 Atty Paid $191.80 Other Costs Date: 3/5/10 David D. Bue I, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 U- OncMarch 22, 2010 the Sheriff levied upon the defRndant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Kown and numbered, 356 Park Avenue, New Cumberland, N more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 225 2010 By: Ls?K?-C0.?Yke?Yr Real Estate Coordinator 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 16, April 23, and April 30, 2010 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 30 C-Z-2 day of April, 2010 J Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Writ ilo. 2009-6463 Civic Household Finance Consumer Discount Co. vs. Lisa A. Kepes Louis R. Kepes Atty: Terrence McCabe ALL THAT CERTAIN lot of land situate in the Borough of New Cum- berland, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point on the eastern line of Park Avenue 212.4 feet north of the northeastern corner of Park Avenue and Oak Lane, at the dividing line between Lots Nos. 92 and 93 as shown on the hereainfter mentioned plan of lots; THENCE northwardly by the eastern line of Park Avenue 50 feet to Lot No. 94 on said plan thence eastwardly along the dividing line between Lot Nos. 93 and 94 and 249.5 feet to a wide alley; thence southwardly by the westwardly line of said alley, 70.6 feet to Lot No. 92 on said plan and thence westwardly by the dividing line between Lots Nos. 92 and 93, 193.8 feet to the easterly line of Park Avenue, the place of BE- GINNING. BEING Lot No. 93 on Plan "A" amending of "Seven Maples No. 1°, as recorded in the Cumberland County Recorders Office in Plan Book 2, Pale 9-1/2. BEING the same premises which Nicholas E. Edwards by deed dated December 19, 2000 and recorded January 2, 2001 Office of the Re- corder of Deeds in and for Cumber- land County, Pennsylvania granted and conveyed unto Alba L. Botts, III grantor herein. Being Known As 356 Park Avenue, New Cumberland, Pennsylvania 17070. BEING the same premises which ALBA L. BOTTS, III by deed dated March 10, 2005 and recorded March 11, 2005 in the office of the Recorder in and for Cumberland County in Deed Book 267, Page 4416, granted and conveyed to Lisa A. Kepes and Louis R. Kepes, in fee. TAX MAP PARCEL NUMBER: 26- 24-0$11-049. Writ No. 2009-8463 Civil Term Household Finance Consumer Discount Co Vs. Lisa A Kepes Louis R Kepes Atty: Terrence McCabe f 11-THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND. COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE EASTERN LINE OF PARK AVENUE 212.4 FEET NORTH OF THE NORTHEASTERN CORNER OF PARK AVENUE AND OAK LANE, AT THE AVIDING LINE BETWEEN LOTS NOS. 92 4ND 93 AS SHOWN ON THE HEREAL* TER vIENTIONED PLAN OF LOTS; THENCE NORTHWARDLY BY THE EASTERN LINE OF PARK AVENUE 50 FEET TO LOT NO. 94 ON SAID PLAN THENCE EASTWARDLY ALONG THE DIVIDING LINE BETWEEN LOT NOS. 93 AND 94 AND 249.5 FEET TO A WIDE ALLEY; THENCE SOUT14WARDLY BY THE WESTWARDLY LINE OF SAID ALLEY, 70.6 FEET TO LOT NO. 92 ON SAID PLAN' AND THENCE WESTWARDLY BY THE DIVIDING LINE BETWEEN LOTS NOS. 92 AND 93, 193.8 FEET TO THE EASTERLY LINE OF PARK AVENUE, THE PLACE OF BEGINNING. BEING LOT NO, 93 ON PLAN "A" AMENDING OF "SEVEN MAPLES NO. I", AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE IN PLAN BOOK 2, PAGE 9-112. BEING THE SAME, PREMISES WHICH NICHOLAS E. EDWARDS BY DEED DATED DECEMBER 19. 2000 AND RECORDED JANUARY 2. 2001 OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA GRANTED AND CONVEYED UNTO ALBA L. BOTTS, III GRANTOR HEREIN. BEING Known As 356 Park Avenue, New Cumberland. Pennsylvania 17070. BEING the same premises which ALBA L. BOTTS, II] by deed dated March 10. 2005 and recorded March 11. 2005 in the office of the Recorder in and for Cumberland County in Deed Book 267, Page 4416, granted and conveyed to Lisa A. Kepes and Louis R. Kepes, in fee. TAX MAP PARCEL NUMBER. 26-24-0811- (W9 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICr CUMBERLAND COUNTY ('rOURT HOUSE- CARLISLE The Patr1*otAXrws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication under Act No 587.. Approved May 16, 1929 ;omrnonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says, That she is a Staff Accountant of he Patriot News Cc . 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 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: 04/16/10 04/23/10 Sworn to and subscribed before me this 18 day of May, 2010 A.D Notary Public COMMONWEALTH OF PENNSYLVANIA_ _ Nobviel Seal Sherrie L Kisr)er, Not._" ;;UtAL rawer Paxton Twp., 0,iuphin County Fly Commission Expires Nov. tv, 2r1: 04/30/10 Member, Pennsylvania AssvCiation of NC!?rip-s