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Home My WebLink About01-4820FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 Plaintiff JEFFREY L. FUHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERIVl CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE 1N BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 lhrther 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:306764324 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 The name(s) and last known address(es) of the Defendant(s) are: JEFFREY L. FUHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 8/27/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1569, Page 479. By Assignment of Mortgage dated 5/8/00 the mortgage was assigned to PLAiNTIFF which Assignment is recorded in Assignment of Mortgage Book No. 647, Page 629. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." The following amounts are due on the mortgage: Principal Balance Interest 2/1/01 through 8/1/01 (Per Diem $29.76) Attorney's Fees Cumulative Late Charges 8/27/99 to 8/1/01 Cost of Suit and Title Search Subtotal $127,788.57 5,416.32 4,000.00 39.38 750.00 $137,994.27 Escrow Credit 0.00 Deficit 196.98 Subtotal $196.98 TOTAL $138,191.25 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined 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 "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $138,191.25, together with interest from 8/1/01 at the rate of $29.76 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Firs( Morlg~c [oon Scrvicih~ San Diego CA 92186-5071 3451 Han~mond Ave PO Box 780 Waterl0o IA 50704-0780 Date: J'ano 12, 2002 AC I' 91 NOTICE 'I'AKE AC I'ION 3'O SAVE FORI<;CI ,OS[JI 'E This is ;m official ~io(;cc that El~c morq~agc mi your home i~ hi dcfiml(, ami tl, c Icl Ic~ ,~ lc o~ ( fm cci ~;;. ,Specific i~fformation about Ibc oalure ortho dcfaol~ is prov{d¢tl in Iht allachct( lmgC;, Thc IlOMI,:OWNI';II'S MORT(;A(iE ASSISTANCE IqI()(;RAM (III';MAP) may bc able to help to ~avc your home. This Notice explalos how the program works. To see if IIEMAI' can help, you mu,~t MEET WIT]I A CONSUMER CREI)IT COUNSEl,IN(; A(;ENCY WI'IlliN 30 DAYS OI.' Till,; IlA'l E O1; 'l'lll~*; NOTICI,;. Take this Noilce with ,~ou ~l~c}~ '.ou mt-ri _Counseling Agency. Thc name, at dress and phooe numl,cr of Consumcr Crcd}l Counseling Age~ cies serviog your Comity arc listed al thc cod ofthls Notice. If you have a~y questions, you m: y call the Pem~sylva~ia llousiog Fioa}~cc ,3gency toll free at 1-800-342-2397. (Persoos with impalecd hcariol~ can call (717) 780-1869). This Not,cc cootMns impoeta}d legal in formaliom If you have any qocstion.~, rcl)rc~c}ltatlvcs at thc Coosumcr. area, The Ioc:~l bar assoeiatJm, may bc able to help you fiod a lawyer. I ,\ NOl Il l( ACIOX I,;N /xl)J UN lO I,',$, I)1,: ,SIIMA IMI'OIt'I'AN(/IA, I'UES; AIcI,;C'I'A SI.] CON'I INUAR VI\'IENI)O EN SU CASA. SI NO COMI'ltENI)E EL CONTENII)O I)E ESTA XO'l IlqC,~.CION Oll'l'l,;N(;A UNA TRAI)UCCION IMMEI)IATAMENTE I,I,AMANI)O ES'IA A(;ENCIA (I'ENNSYI.VANIA }I()USIN(; FINANCE A(;ENC¥) SIN CAR(sOS Al, NUMERO MENCIONAI)O Al{RI IL,\. I'UI,'DI,;.q 531,;1,' I,'3 ,E(;IBI ,E PARA lin I'RI.;STA).IO POi,' I,;I, ('RO(;ltAM,'~ I,I ,AM,~.I)O "ilOMI,;O\VNF, R'S EMER(;ENCY ),IOI~.T(;A(;E ASSISTANCE PRO(SRAM" El, CI`JAI, fUEl)l,; SAI,VAR SU (;ASA I)1", I,A PI,;RI)II)A DEl, I)EREC}IO A REI)IMIR Stl IIII'OTECA 11() M l::O\\'N 1.;1,"~ I'ROI'I,;R'I Y AI)I)RESS: 1 ()AN ACC'I, NO,: ORI(;INAI,I CUBRF, N1 1 ,I~;N I ) E R/S F,l{ VI C F,R: 306V6~324 N/A G~AC ~orLqago CorporaL5on EXHIBIT A PO Box 85071 3451 tlarmnond Ave PO Box 780 Waterloo IA 50704-0780 Date: Sune 12, 2001 ACT' 91 NOTICE ri'At(l<; AC'I'ION 7'0 SAVE ¥OUk' 1105,/I.1<; IcROM FORECI,OSURE 'l'hi; is an offlc~:d ]mi;cc Ihal thc morigage on your home i; h, del;ri)Il aod ihe Ic}idcr ' Spee~lR' hHb}'maiion abou( II,e .ah)re af (},c dcfin)R is provided h, thc Thc H()MI<()WNI<I.",t; MOR'I'(;A(;E ASSI,q'I'ANCE J'ROGRAM 011<MAP) may be MAc Io help to ~;ivc ;our To ~ec if II I,;MAI' cao help, you mu~t MI,;ET WITll A CONSUMER CREI)IT COUNSEIAN(; A(;ENCY ~,VITIIIN 30 DAYS OF TIlE I)A']'I~ OF 'I'}IIS NOTICE. Take thi~ Notice with ~'ou who. you meet with the _Cou.~eling Agency. Thc name. addrcs~ a.d phone number of Conxumcr Credit Coonxellog Age; clc~ ~erviog your ComHy are ixtct at t w cod oftlilx Notice. If you have any quc~;llons, yoo may call the Pemi;ylvaoia llou~ing Finance Agency toll fi'cc al 1-800-342-2397. (Pcrsoos with impaired heatlog can call ('/17) 780-1869). 'l'hi~ Notkw cantahts imporlarH legal i.fin'mal;on, If }'ou have any qucstloas, rcprescolal;vcs al the Consumer (: : I Coun;elh, g Agc.ey may be al,lc to help cxplalo iL You may al~o wa.I to co.iacl a. ailor.cy i. your I,A NOTIIqCACION EN AD JUNTO l,',S DE SUMA IMI'OI{'I ANCIA, PUES AIq,iCTA SU DERECIlO A CONTINUAR VIVII,iNDO EN gU CASA. gl NO COMI'RI,',NDE El, CONTF. NI])O I)E ESTA NOTII,'ICACION OBTEN(;A UNA TRADUCCION IMMEDIATAMENTE I J,AMANDO F, STA A(;ENCIA (PI<NN~YI V.kNIA IIONSIN(; FINANCE A(;ENCY) SIN CAR(;OS Al, NUMERO MI,;NCIONADO ARI}I ILk. PUEDES SI,iR EI,},;(;I 1~1.1,; }'ARA UN }qIES'I'AMO fOR El, PROGRAMA 1A.AMA1)O "IIOMI<()WNI<R'S I<MI<R(;I,iNCY MOR'I (;AGE ASSIS'I ANCE I'II()(;RAM" 1<1. (?ibM. }'UEI)I6 SAIA' kl{ SU CASA DI< I~A I'ERDII)A I)EI~ }IOME()WNI~;R'S NAME(S): I'l~.O I'EI.'I Y LAUF,]i< A. p'JI]R~4AN 43C CROSSROADS SC}IOOh Ri} CAkNI,ql,N, PA 1'/013 I,OAN ACC'I. NO,: ORIGINAl. 1,ENI)ER: (I',}{ I.' I,;N'I I .ENI)ER/SI,;RVICI<R: 306'164324 N/A GMAC Hortgage Corporation EXHIBIT A II()MF, O~VNI".IUS, I<M}' }~(;I')NC¥ M()R~I (;h(;l< ASSI~,'I AN(I< MAY BI< F,I,I(;}Ill ,II'. FOR FINANCIAl, ASSIS~I ANCF, ~VIIIC}I CAN SAVE YOUR IIOMF lrORll~(] DSUI,III' AND liE] ,1' YOU MAKlq I,'UTURll; MOI~T(;A(;I,', P,\YMll;N] S IF YOU (OMI'I Y 'WI'I'll TIll,; )'I{OVISIONS O1,' 'IIIE }IOMI,;O\~ NI<I,"S I,;M I,',I,'(;I<N( Y 5101,' I (;A(;I,; ANNIS'I ANCI~; ACT O1,' 198:3 (T}IE "ACT"), YOU MAY BE EI,](;t}II,E FOR I<MI*;I,t(;I,;NCY MOI~IT(;ACI", ASSIS'I ANCI~;: IF YOUR I}E}.'AUI,T }lAS BEEN CAUS}.;I) }IY CIRCUSIS'I ANCES YOUR CONTROl,, IF YOU }IAVI.; A REASONABI J~; }'ROSI'ECT ()1.' III,'JIN(; ABI J.; TO }'AY YOUR 3,1()RT(;A(;I~; PAYMENTS, AN]) IF YOU MEF, T ()'1 }II,;R 1<1,1(;11111 J'l Y REQU] RI,;MENTS E,qTA};I JS}I I,;I) BY 'l'll}~ }'I(NNSYI A'ANIA II()USIN(; FINANCE A(;F~NCY. 11, MI'O},~ '~IIY S'IAY O1,' FORECI DSURF, -- Undc~ thc Act, you a~c entitled to a tcmpormy stay of tbrcclosm'c m~ yom n~o~tgagc fo~ lhhiy (30) days fi'om thc date of this Notice. l)urmg thai time you must arrange and attend a "ih['c 1o Iht c" ;netting with one of thc constm~cr credit com~sclmg agencies listed at thc end of this Notice. IBIS 5lEE'lIN(; MUST OCCUR h~;l'l'lllN Till,; NI<XT (30) DAYS. IF YOU DO NO'I APPI Y I"OR MOR'I (i AGI( ASSIS'I AN('I'. YOU MUS'I BR1X(; YOUR M()R'I (;A(;I( 1 'P '10 I)A'I I'L '1111' }'AR'I O1' '1] 11~ N()'I ICl CAI J Jq)"]lOW '10 CUR}( YOUR M()R'I (iA(il( ])I(];AUI/1", I',X}'I ,AINS ]IOW '10 BRIN(i YO[ :R M()]<'I (L.X(i}( lip 'lO ]),,VI I,,. CON~UM},',R CRF, lllT COUNS]~',I ,lNG A(;F, NCIES ]f'you mecl with one of thc consmncr c~edJt cotmsc]mg }~gynck's listed a~ thc cml of this m~t/cc, thc Icndc~ may NO'I take actkm ;~gamst you lln tlmiy (t0) da~s ~llc~ thc of this mcctmg.] hc names, addresses and telephone nmnbcrs of dcs/gnalcd consmncr clcdit counseling, agencies thc com~ty m which thc property is located arc set tb~h at thc cBd of this Notice. It is only necessary to schedule one thcc-to-lhce meeting. Advise your lender ~mmedJately of your inten6ons. Al'fi ,ICA] ION FOR M()IIT(;A(;E ASSISTANCE -- Your mortgage is m dcthu]t tk)~ thc ~casons set ~k~rth latc~ in dfis Notice (sec lb]lowing pages Ibr specific information about the nature of your del\ult.) If you have tried and are un;~blc to resolve this problem with thc lender, you have thc right to apply for financial assistance from thc }lomcox~ncr's Fmcrgcncy Mo~gage Assistance Program. ]b do so, yon must fill oul, sign and file a completed llomcowncr's I(mcrgcncy Assistance Program Applica6on with one of thc designated consumer c~cdit com~sclin[. agcncics listed at thc end of this Notice. Only consmncr credit cmmscling agencies have applications tk)r the l)mg~an~ and they will assist you m sobmilting a complete application to thc Pem~sylvania Housing ]:mance Agency. Yom application MI ;ST bc tilcd or postmarked within thirty (30) days of you Gcc-to-Gce meeting. YOU MUSl I, II,F YOUR ,kPI'I.ICA~I ION I'R(}511"I I~Y. IICYOU FAII~ TO 1)O SO OR IFYOU DO I~()lJ ,()~ lB I,: O'1111<R '11511~' I'l,;l{}OI)S S}(] I.'()R'I Il IN THIS l J(I"I'I.;R, ]?()}{}<CI,OSIJR}.; MAY }'l(OCl~lq) ~(;[1NS'I YOIIR IIOM},~ IMMI,])IATFJ,Y ,~NI) Y()UI~ A}'I'I.ICA'IION }vOR ASSISI AN(if; ~hll,]. BI,; ])I<NI]';]). A(;I<N( Y AC'I ION ..\xailablc lhnds lk~l cl,,clgcl)cy moligagc assistam:c a}c \cry limited Ibc5 will bc disbmscd bx thc AUcncy undc~ thc eligibility c~itc~ia cstablis]ncd hy thc Act, Thc Pem~sylvani~ ]]ousmL, ]qn:~c c Apcncv hi~s s~xt~ (60) days to make ;i decision algol it rccci~cs yo~ll a])plic*~tion. I)ming thai tm~c, no lk~cclosu)c ])mcccdm~s will bc pu~s~c,d ;~gamst you il'you have mcr thc tm~c mquircn/cJ/Is sci lk*~]l above. You will bc notilicd dncctly by thc ])c)ms5 ]v;mi;~ ]](mslng ]:in;moo ~X~,cncy ot'its dccisk>n on your applica~l(>n. EXHIBIT A NO'If: IF YOU ARK CIIRRI,;NTI .Y I'ROTECTI 1,;11115' THE I,'11 ,IN(; O1,' A 1'ISTITION IN BANKRIJI"I CY, '1 Ill, 14)1 .I ,OXVING PART O1,' 'l'}llg NOTIC}q IS FOR INI,'ORMATION }'URI'OSF, S ON1 .Y ANI) SIIOUI.I) N()'I BIg CONSII)ERI,;I) AS AN A'ITI,;NII"I '10 (If yuu Imvc filed bankruptcy you cnn ~till :q~ply IIOW IO CUI,tI,~ YOUR ),lOl(rl'(;A(; E ])EI,'AUI il' (l'h'hi~ i( up lo da(c). NA.I UI.'I( O1, '1 Ill:; I)I,;I,'Alll ,T 'Ihs MOK'l(i,5,(il debt held by thc above Icndcl is o~ yom pmlWll5 k~.alcd :il' YOV }l,\Vt( NO'I M ,\Iii( MONTI l] .h' MOR'I GA(ii{ I'AYMI(N'I S tbr thc tblloxx mg monlhs and thc ].alc C]/algcs 39 . 38 NSF 0.00 Inspections 0.00 Other 5USl/Cnsc b42.95 TOTAl. AMOUNT ]*AST I)UE: 3, 984 . 71 B. YOU l L,\ V],i ],Ail .1'3) '10 'lAKE 'lllh I'Ol 3.0\VING .,\CTION (lie not usc if not applicable): tI()~,V TO CURl,; TI! I~; I)lCFAIII ,T-- You may cure the default within q'HIWI'Y (30) DAYS of thc date of this notice BY }'AYIN(; 'ItlE TO'I Al. AMOIJN'I:I'AST lille TO Till,; I](NI)ER, WIIIC}I IS $ 3,984. '/] , P],['S ANY M()R'I(iAG], I'AYMI(NTS AN]) I,A'J']{ ([]IAR(]]'S Will(Il BI,.(]OM],~ lit:l, I)1 RING l}ll, ']}IIR 1 Y (30) I)AY PI,,R]OD. Payments must bc made cilhcr by cash, cashier's check, ccmflcd chctk (n n/easy ordc~ lnadc payable and sc]il to: GMAC Mortgage Corporation PO Box 780 Waterloo, lA 50'/04-0780 You can cms anx off/el dcfimli by taking thc tbllowinl3 action v,'ilhill '1 }/IR'I Y (30) I),\YS of thc datc oftl~is Ictlcl: (])o not usc if riel applk:ablc.) Not App] 5 cab3 o Il,' YOU lie NOT (;URIC T}I E I)I,;I,'AUI.'I -- If you do not cm'c thc dcfault within T]I]R'I Y (30) I)AYS of thc date of this Notice, thc lender h~lc.ds lo exercise ils rlghl~ Io acceleraic ll~e morlgage debt, This mcans that thc cmHc outslandm~ b~Jancc of this debt will bc considered duc immediately and you may lose thc chance to pay thc mo]i~,agc in monll~lv installments. Ifil,Il paymc]~t of thc total amount past duc is not made within THIRTY (30) DAYS, thc lender also inlends to instruct its attorneys to start legal action to foreclose upon your morig~*gcd properS3. Il,' I111~ MOR'I (iA(i K IS I,'ORI,;CI A)SI,3) UI'ON Thc mortgaged pmpc~ly will bc sold by thc Shcriffto pay off' ach~allx ~c'm~cd, up t(~ S5000 ]~(m c~'cn if legal lnOcccdings a~e started against against you, you will have to pay all ]f~ou cu~'c d,c t!cfi*~ll ~Gth;,~ thc rI'IIIRT¥ (30} I)AYN per;od, you ~GII not be required Io pa~ at{or.er% fees, EXHIBIT A 0'111FR t F,X})]Cl~. RFMI{DII'~ r ~ ~C icl,der may also suc you personally tb~ thc Unlmd p~h~cqm] balance and all othc~ sum~ duc m~dc~ thc mm RI(;II'I TO Ct}RI'; '111E DF, FAUI/l' PRIOR TO SIlI'iRIFIr'S SA1J'; -- if you have not cured the ddhult wHm-~ thc '1] IIR'I Y (30) 1),XY perked and th~cclosm'c pmcccdinp bavc bcgun~ you st~ll have thc r~ghl k~ cmo thc dcfimh am1 p~ cxcnl ti\' sale at any trow up to one hour bcJb~c thc ShcriWs Sale. You may do so by paymB thc mini ammm[ ~hcn past duc, plus any Mc or other c]mrhcs tl~c~ duc, masonaNc atlorncy's fccs and costs connected wil]~ thc t~cclosu~c sale ami a'nv other costs cmmcctcd wifl~ thc Shcrifl~s Sale as spccificd m wntinp by thc Ic~dn and by peri\mtn? any otbcr r4quircmcnts under thc mortgap, c. Cmq.g your dchml~ F. ARI 3],;S I POSSIBI J,; \II ERIIq;'S SAI.E I)ATIq ]t is estimated that thc earliest date thai such a ShcritPs Sale notk:c oflh~' r~cmal d;Hc c;fthc Sbcrift's Sale will Nc scm to you bclbrc thc sale. ()l'coursc, thc ammmt nccdcd 110\\' IO C()NI A('I 'Jill~ I.ENI)ER: Addre ~ ?,: GMAC gortgago Corporatio}~ 401 Mile of Car~ Way (800) 850-4622 (619) Col]ocLion Departmc:ht I,;FI"E(:T OF SIIERIIq"'S SAI.E You should realize that a ShcriWs Sale will c~]d yom' ownership of thc mmtgagcd pmpc]'iy and your right to occupy it. If you col~tinue to live in thc property after thc ShcrilPs Sale, a lawsuil to remove you and your thmHm~gs and other bclongings could be started by the lcnder at any timc. ASSUM I"l I ON OF MORTG AGE -- You may or may .et sell or transtar your home to a buyer or tmnsl~rcc who ,,,,'ill assmnc thc mold. ga p. gc debt, provided that all tile outstanding payments, cha~es and atlomcy's fees and costs arc paid prior to or al thc sale and that thc othcr requirements of thc mortgage arc satisfied. YOU MAY Al,SO HAVE TIlE RI(;-HT: ri() S}'] I rill}' I'}~'OPI']{ I Y i O OB'I '\IN MONI'Y 'IO }'AY OF}' 'llll'; M()]{'I(b\G]': ])kll'l ()R '10 BOP'RO\V MONI'Y I']{OM ANOT}II']{ ],]',NI)IN(; INSTI'I U'IION '10 ]'AY O1"1; '1 Ills ])]'l/'I. 'lO }]:\',.'t' 'lilts ])],),,.\l.~],'j ('/'RI',D BY ANY TIIIRI) PA]{'I \' .,\CI'IN(~ ON YOUR BI,,IIA] ,l,. '10 ]IAV]': T}ll MOR'I (b\(i]' R],S'IO}~I',I) 'lO TIll', SAMI' POSITION .,\S 11,' NO ])I,],,,\UI/I HAl) O('('/~']{RIq), ]1' Y()l~ ('1.1]. 'llll' ])lq,,,\/fl 1. (]IO\VI',Vh](, YO[ ])O XO'l 1],\\']' Ill1\ Rl(i}l'l '10 CURl, YOI, iR I)H :\1 I/1 5,1()1~.1' 'I}IAN 'l]lRk}' 'llMI{S ]N ANY (?Al JtNI)A]~. io .,\SS],R'I 'l lip NON]'XIS'i I,NC] Ot' ,,\ 1)I.,I, Al. '1 ,'1 IN ANY ].O}(]{(i1 ,()SI '}tit PRO(tI'I)IN(i OR ,\Nh Orllll R I ,\\VF,[ Il ]NY/lll["lll)l'Nl)l]4 II Il' \I()R'/(; \(;1 I)O('l \l] N"IS l() ASS},,RI \>,Y O'I}I}'.R I)]g'}NS}' 5'O[ B}} il,V}, 'fOI, MAY ll..\VI l() IOSI]'K I'ROII'(-iION[ NI)hR'lHl' F],l)]!l(:\] B,,XNKI{1.1q('YI,AW. CONSUMER CRI,;IIIT COUNSI'll JN(; A(;ENCII{S SERVIN(; YOUR COUNTY IS F, NCI~()SEI) EXHIBIT A PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTONCOUNTY COLUMBIA COLTCCY CRAWFORD COL'NTY Lvcoming-Clinton Counties Commmon for Communim. Action (STEP) 2138 Lincoln S~zeet P O Box i328 WilliamsporL PA 17703 (570) 326-0537 FAX (570) 322-2197 CCCS of Northeastern PA 20[ Basin Street Wiiliarnsport, PA [7703 (570) 323-6627 FAX (570) 323-6626 31 W Market Street POB I [27 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportumt2:' of Luzeme County. 163 Araber Lane Wilkes-Barre. PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665~Call Before Foxing) (570) 455-!.994 Hazeltown F,AX (570) 455-563 t~Call Before Foxing) (570) 836-4090 Tunkharmock Booker T Washington Center 1720 Hollzald Center Erie, PA 16503 (814) 453-5744 F,~X (814) 5749 John F Kennedy Center, [nc 202[ East 20~ Street Erie, PA 16510 (8 [ 4) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, [nc 2000 Linglestov, n Road Harrisburg, PA [ 7102 (717) 541-1757 Urban League of Metropolitan Hannsburg N 6* Street Harrisburg, PA 1710[ (717) 234-5925 F:LX (717) 234-9459 Community, Action Corem of the Capital Region 15 I4 Deft7 Sh-eet Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CUMBERLAND COL~TY CCCS of Nor'daeastem PA 1631 South Atherlon St., Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 1400 Abin~on Executive Park Suite I Clar~ Summit. PA 18411 (870) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Greater Erie Communit': Action Committee 18 West 9m Sa-eot Erie, PA 16501 (814) 4594581 FAX (814) 456-016I Shenango Valley Urban League, [nc 601 Indiana Avenue Fen'ell, PA 16121 (412) 981-53 I0 Financial Counseling Services of Frankhn 31 West 3'd Street Wa`wcsboro, PA 17268 (717) 762-3288 YWCA of C~rIisle 301 "O" Street Carlisle, PA 17013 .. (717) 243-3818 F:LX (717) 731-9589 Adams County. Housing AuthoriV: 139-I43 CarlisIe St. Gettysburg, PA 17325 (717)334-1518 F:LX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23, J~,ONE 5, 1999 EXHIBIT A Pmmsboro Tawnshlp, Cumbel!and County, Pennsylvania, more ~uUy coundcd end desc:ibcd accordance with a plan prepared by Rodncy Lee Decker. R,P L.S, dated januao' 22. 1993 and recorded in ~he OF~ce of the Recorder of Deeds t~r Cumberland Count7 m 9lan Be:ok f6, 104, as thl[uws: BEGINNING at a point on southern right-of-way ld'.c oF Cross Road acm ~ ~ ko.~, T- West 353.9f lbet to a point; ihence along Phase 3 of Cross Road Schoot Road Estates, Norm degrees 04 minutes 45 seconds West I I2,05 feel lo a point in southe:'n edge oF Watson thence Mong southern edge or' Wutstm Drive by a cur'.'c to thc loft ha~ h~g ;~ radk~s of 20[),,30 [gut _ _~, ...... n .d,,~ of Watson Drive by curve 1o the right ha~ing a radius of 150.00 and an arc distancg of 191.63 5et to a i:~m~: thence still along Watson Drive North 49 degrees 05 minutes 05 seconds East 332. to a poir, t a curve to the righl having a radius of 25.00 'feet and an arc distance of 38.51 feet m a point m AND the said Grantor hereby covenant and agree thai it wiU wan'ant specially property hereby conveyed Ttt E Grantor doth hereby constitme and apl)Olnl John H. Fox al/d }-iasr) ii, F )x, J t. lo its attorney tbr it, and in hs name and as and lbr its CO,lmrate act and deed to acknowlcdgc this Deed bclbre any person having authority by thc taws of the Commonwealth of Pennsylvania to take such acknowledgment, to the intent that the same may be duly recorded, *d th~s Deed to be siancd m IN WITNESS WI-IEREOI:, Ibc said G~anto s has cause - cou>orate names by its president and has caused ~o be affixed hereunto lhe common corpm~te seal of the said coqmrafions, attested by its Secretau, thc day and year ~h's; ~bovc PREMISES: 430 CROSSROADS SCHOOL ROAD VERIFICATION KRISTINE-WILSON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements nmde in the foregoing Civil Action in Mortgage Foreclosure are tree and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: SHERIFF'S RETURN - ~ASE~NO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET AL REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon FUHRMAN JEFFREY L the DEFENDANT , at 2108:00 HOURS, on the 21st day of August at 430 CROSSROADS SCHOOL ROAD , 2001 CARLISLE, PA 17013 LAURIE FUHRMAN a true and attested copy of COMPLAINT - by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.20 Affidavit .00 Surcharge 10.00 .00 33.20 Sworn and Subscribed to before me this ~0 ~ day of f~.. ~, ..~,t~ ,~ / A.D. /Pz/ot honor ary So Answers: R. Thomas Kline 08/21/2001 FEDERMAiq & PHELAN /~ BY:~_ D~/ J SHERIFF'S RETURN - REGULAR CASE NO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN LAURIE A the DEFENDANT at 430 CROSSROADS SCHOOL ROAD , at 2108:00 HOURS, on the 20th day of August , 2001 CARLISLE, PA 17013 LAURIE FUHRMAN 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 6 00 00 00 10 00 00 16 00 Sworn and Subscribed to before me this Jo ~ day of ~/ A.D. Prothonotary t ! So Answers: R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN ,~ ,~ Deputy~ZSheriff ~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE, P.O. BOX 78O WATERLOO, IA 50704 Plaintiff VS. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Defendant(s) Attorney for Plaintiff : CUMBERLAND COUNTY : : COURT OF COMMON PLEAS : : CIVIL DIVISION : : NO. 01-4820 CIVIL : ._ : : : PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against JEFFREY L. FUHRMAN and LAURIE A. FUItRMA~., Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days fxom service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 8/1/01-9/28/01 $138,191.25 $1~755.84 TOTAL $139,947.09 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FP,~x!K FEDEI~MAN, ESQUIRE Attorney for Plaintiff DATE:DAMAGES~IARE HEREBY ASSESSED AS INDICATED.{/~,~ ~PR~OO~O~TO~/') **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATYEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** FEDERMANAND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff vs. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 01-4820 CIVIL De fendant (s) TO: JEFFREY L. FUHP/~=N 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 FILl COPY DATE OF NOTICE: SEPTEMBER 11.20Q~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMANAND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff VS. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY JEFFREY L. FUHRMAN LAURIE A. FUHRMAN : NO.01-4820 CIVIL Defendant TO: LAURIE A. FI/HRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 FILE COPY DATE OF NOTICE: SEPTEMBER 11.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTIC~ You are in default because you have failed 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman,Esquir~ Attorney for Plaintiff SHERIFF'S ~ASE NO: 2001-04820 P COMMON-WEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUNRMAN JEFFREY L ET AL ZTURN - REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN JEFFREY L the DEFENDANT , at 2108:00 HOURS, on the 21st day of August at 430 cRoSSROADS SCHOOL ROAD , 2001 CARLISLE, PA 17013 by handing to LAURIE FUHRMAN 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 5.20 Affidavit .00 Surcharge 10.00 .00 33.20 Sworn and Subscribed to before me this day of Prothonotary So Answers: R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN Depu~%-f-y~4qeriff SHERIFF'S RETURN - REGULAR CASE NO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being dulY sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN LAURIE A the DEFENDANT , at 2108:00 HOURS, on the 20th day of August at 430 CROSSROADS SCHOOL ROAD , 2001 CARLISLE, PA 17013 LAURIE FUHRMAN 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN '~ f Deputy~Sheriff h FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No, 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION VS. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Attorney for Plaintiff : CUMBERLAND COUNTY .. Plaintiff : Court of Common Pleas : : CIVIL DIVISION : : NO. 01-4820 CIVIL .. : Defendant(s) : VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as mended (b) that defendant JEFFREY L. FUHRMAN is over 18 years of age and resides at 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013. (c) that defendant LAURIE A. FUHRMAN is over 18 years of age, and resides at 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FR)kNK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) GMAC MORTGAGE CORPORATION VS. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN : CUMBERLAND COUNTY : Plaintiff : Court of Common Pleas : : CIVIL DIVISION : : NO. 01-4820 CIVIL : : Defendant(s) : ._ Notice is given that a Judgment in the above captioned matter has been entered against you on OCTOBER ,-,Q ,2001. If you have any questions conceming this matter, please contact: FRANK FEDERMAN, ESQUIRE Attomey for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TI-HS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE GMAC MORTGAGE CORPORATION . JEFFREY L. FUHRMAN LAURIE A. FUHRMAN CUMBERLAND COUNTY No. 01-4820 ACCT. #306764324 SERVE LAURIE A. FUHRMAN AT 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 6, 2002 SERVED Served and made kaown to !~ti ~ '~ tO_. ~.'~x ¥~f ~'"~6h. Defendant, on the ~ q~'- day of. '~-c~Bt//3(~, 20~, of Pennsylvania, in the manner described below: Defendant personally served. DU-.Adult fa=ly =tuber with whom Defendant(s)resides>. Relationship is a,'d -- 48: r q L. __ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Dcfendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age/-{0 ' ~ Height ~_[ Weight { ¢~ Race [~)_._ Sex ~_ Other l, ~. d lC ~0 tt~ ~, ~ ~ ,a co~etent adul, ~g du~ sworn accord~g to law, ~ose =d state ~tI perso=lly h=ded a ~e ~d-co~ect copy of ~e Nofic~ of ShefiWs Sale ~ ~e ~er as set fo~ here~, ~sued ~ ~e captioned case on ~e ~te ~d at the ad.ess indicated above. before me ~s ~ ~y of ,200_. Nota~: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. NOT SERVED On the day of ,200_, at __ o'clock __.n% Defendant NOT FOUND because: __ Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this [ '~ day of~.~=~, 200 .~ I Notarial Seal Nogl~-~x(.4~9~ ~//~ Bykisa M. Greason, Notary Public ~ /"f/ ~ Y 1~ ~ I Carlisle Boro, Cumberland County ~e; fo/Plai~ff ~ [?y Commission ~x~ire~ Sept. 9. 2002 Frank F~erm~ Es~ - I~. No. 12248 One Peon Center at ~urban Station 1617 John F. Kenn~y Bo~evard, Suite 1400 Phfladelp~a, PA 19103-1814 (215) 563-7000 AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION DEFENDANT(S) JEFFREY L. FUHRMAN LAURIE A. FUHRMAN SERVE JEFFREY L. FUHRMAN AT 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 CUMBERLAND COUNTY No. 01-4820 ACCT. #306764324 Type of Actioo - Notice of Sheriff's Sale Sale Date: MARCH 6, 2002 SERVED Served and made known tO ,~'~l~Cg C~,..~ L~. ~--L(~ ¢~4~3'%Defendant, on the of Pennsylvania, in the manner described below: Defendant personally served. Adult family racmber with whom Defendant(s) reside(s). Relationship is __Adult hi charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. __ Other: Description: Age ~ Heigh~e~' [ [ Weight ~ Race ~ Sex ~ Other I, !J. U i~Ol{~o~Ce-----d~t~JfO"~,acompetentadult, being duly swom according to law, depose and state thatlpersonally handcd a ~'ue and correct copy of the N~tice of Sheriff's Sal~ in the manner as set forth herein, issued in the captioned case on the date and the address indicated above, at Sworn to and subscribed ~, ~ before me this day of ,200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. NOTSERVED On the . day of_ ,200__, at __ Moved Unknown No Answer Other: o'clock __.rs, Defendant NOT FOUND because: Vacant Sworn to and subscribed before me this .}Q day ~ .... of~.JQtrl_~, 200 ~ ! ~ N~tar al Seal One P~n Center ~uburban Station 1617 John F. Kenn~y Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE CORPORATION No.: 01-4820 VS. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SAI,E February 27, 2002 Plaintiffin 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: 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 1701 '~. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff, JEFFREY L. FUItRMAN LAURIE A. FUHRMAN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 01-4820 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION, Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~430 CROSSROADS SCHOOL ROAD. CARLISLE~ PA 17013. 1. Name and address of Owner(s) or r~puted Owner(s): Name Last Known Address (if address cannot be · reasonably ascertained, please indicate) JEFFREY L. FUHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nanle None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest the property which may be affected by the sale: Name Tenant/Occupant Last Known Address (if address cannot be reasonably ascertained, please indicate) 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree 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. See. 4904 relating to unswom falsification to authorities. December 7 2001 ,~ ~.~ ~ DATE FRANK FEDERMAN, E~QUIRE Attorney for Plaintiff DATE: TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) JEFFREY L. FUHRMAN LAURIE A. FUHRMAN PROPERTY: 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002, at 10:00 a.m. in Cumberland County Courthouse~ South Hanover Street~ Carlisle~ PA. Our records indicate that you may hold a mortgage or judgment on the property, which may 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 not 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. LH ATTORNEY F!LE C. OPY · PLEASE RETURN SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE CORPORATION No.: 01-4820 VS. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiffin 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: 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ,~ .....,,, ~, , ,,~ ~'~TI. ~ ~0¢?}[~ .~ :;:_e .,,,ar ;~ Attorney for Plaintiff February 27, 2002 PLEASE RE"i'UF{ixi ~ GMAC Mortgage Corporation VS Jeffrey L. Fuhrman and Laurie A. Fuhrman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4820 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 24.20 Mileage 10.40 Levy 15.00 Advertising 15.00 Certified Mail 2.32 Poundage 16.58 Law Journal 386.30 Patriot News 299.10 $ 845.40 paid by attorney 3-08-02 Sworn and subscribed to before me So Answers: This /q~dayof ~ ~;;~"~~'~.o,,..e~Sh~r~f...~ R. Thomas Kline, 2002, A.D. (~,,,,_ tO. ~n~t~ ~ Prothonot~ Real Estate Deputy GMAC M~)RTGAGE CORPORATION Plaintiff, V. JEFFREY L. FUI~MAN LAURIE A. FUItRMAN Defendant(s). CI~MBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4820 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~430 CROSSROADS SCHOOL ROAD, CARLISLE~ PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nallle Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: NalI1C Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Nalile Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. December 7, 2001 DATE FRANK FEDERMAN, E~QUIRE Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff, V. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Defendant(s). TO: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 CUMBERLAND COUNTY No. 01-4820 December 7, 2001 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORblA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 430 CROSSROADS SCHOOL ROAD~ CARLISLE~ PA 17013~ is scheduled to be sold at the Sheriff's Sale on MARCH 6~ 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $139~947.09 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the SherifFs sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attomey.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling {215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Pennsboro Township, Cumberland County, Pennsylvania, more fully bounded and described in accordance with a plan prepared by Rodney Lee Decker, R.P.L.S., dated lanuary 22, 1993 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 66, Page 104, as follows: BEGhNNING at a point on southern right-of-way line of Cross Road School Road, T-438 at line of Lot No. 52; thence along Lot No. 52, South 32 degrees 50 minutes 00 seconds West 353.91 feet to a point; thence along Phase 3 of Cross Road School Road Estates, North 67 degrees 04 minutes 45 seconds West 112.05 feet to a point in southern edge of Watson Drive: thence along southern edge of Watson Drive by a curve to the left having a radius of 200.00 feet and an arc distance of 99.02 feet to a point; thence still along southern edge of Watson Drive by a curve to the ri-,~ht having a radius of 150.00 and an arc distance of 191.63 feet to a point thence still along Watson Drive North 49 degrees 05 mihutes 05 seconds East 332 to a point creating the intersection of Watson Drive and Cross Road School Road; thence along said intersection of Watson Drive and Cross Road School Road; thence alon,~ said intersection by a curve to the ri*~ht having a radius of 25.00 feet and an arc distance of 38.5t ~eet to a point in western edge of Cross Road School Road; thence along western edge of Cross Road School Road by a curve to the left having a radius of 1,166.00 and an arc distance of 149.68 feet to a point: thence still along western edge of Cross Road School Road T-438, South 51 degrees 15 minutes 00 seconds East 50.28 feet to a point, the place of beginning. CONTAINING 2.014 acres and desi~ated as Lot 19 on Plan for Cross Road School Read Estates. Tax Parcel #46-08-0587-093 ~Z. TLE TO SAID PREMISES IS VESTED IN Jeffrey L. Fuh,'man and Laurie A. Fuh,man, his wife by Deed from Harmon Graves Company and Kimba Lc. dated 7/29/98, and recorded 10/21/98 in Record Book t87, Page 613. BEING KNOWN AS: 430 CROSSROADS SCHOOL ROAD, P. ARLISI_,E, PA 17013 WRIT OF EXECUTIO~N.and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-4820 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interesl and costs due GMAC Mortgage Corportion ...... PLAINTIFF(S) from Jeffrey L. & Laurie A. Fuhrman, 430 Crossroads School Road, Carlisle PA 17013. DEFENDANT(S) (1) Youaredirectedtolevyuponthepropedyofthedefendant(s) andtosell Real estate located at 430 Crossroads School Road, Carlisle PA 17013. (See attached legal description.) (2) You are also directed to atlach 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/are enjoined from paying any debt to or Ior 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/he r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $139,947.09 L.L $. 50 9/29/01 to 3/6/02 $3,657.00 Interes~,~_~_ ($23.00 t:~r dim,) Alty's Comm % Atly Paid $121.20 Plaintiff Paid Due Prothy $1.00 Other Costs CURTIS R. LONG Date: December 11, 2001 REQUESTING PARTY: Name Frank Federman, Esq. Address: 1617 JFK Blvd., Ste 1400 Philadelphia PA Attorney for: Plaintiff Telephone:. (215) 563 7000 SupremeCourtlDNo. 12248 19103 1814 Prothon~tary~ Civil Division Deputy REAL' ESTATE SALE No. ~}5 On December 12, 2001, the sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, known and numbered as 430 Crossroads School Road, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12, 2001 By: Real L:Vstate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. 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 29th day(s) of January and the 5th and 12th day(s) of February 2002. 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 o~Book "M", Volume 14, Page 317. PUBLICATION COPY Sworn to and subscribed be~ore~me this 22nd da..y of February 2002 A.D. S A L E #45 Notadal S~ "'*~ ~*'*-~. /~ /~' _ T~ L. nu~, ~ P~ ~~~~~ Ha~, ~ ~ 1 ~ ~ E~S, ~ N~TARY PUBLIC I 'M~r, P~nsyNanla A~ N~ My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 297.60 $ 1.50 $ 299.90 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, 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 thc 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 thc following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 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. NO. 45 Writ No. 2001-4820 Civil GMAC Mortgage Corporation VS. Jeffrey L. Fulu-man and Atty.: Frank Federman ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Pennsboro Township, Cumberland County, Pennsylvania, more fully bounded and described in accordance with a plan prepared by Rodney Lee Decker, R~P.L.S., dated January 22, 1993 and recorded in the Office of the Recorder of Deeds for Cumber- land County in Plan Book 66, Page 104, as follows: BEGINNING at a point on south- em right-of-way line of Cross Road School Road, T-438 at line of Lot No. 52; thence along Lot No. 52, South .32 .d__eg~_ee_s__50_ .ini.nu_te~ 0_0.. SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002 l