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HomeMy WebLinkAbout04-3788FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WASHINGTON MUTUAL HOME LOANS, INC. 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 Plaintiff DEBORAH D. GRAEFF 156 EAST HIGH STREET CARLISLE, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CiVIL DiVISION TERM NO.6C¢- 3 CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 96722 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. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 96722 Plaintiff is WASHINGTON MUTUAL HOME LOANS, 1NC. 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 The name(s) and last known address(es) of the Defendant(s) are: DEBORAH D. GRAEFF 156 EAST HIGH STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 08/27/1986 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to HELL FINANCIAL SAVINGS ASSOCIATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 830, Page 699. By Assignment of Mortgage recorded 6/28/95 the mortgage was assigned to FEDERAL HOME LOAN MORTGAGE CORPORATION which Assignment is recorded in Assignment of Mortgage Book No. 498, Page 989. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 04/01/2004 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. File #: 96722 The following amounts are due on the mortgage: Principal Balance Interest 03/01/2004 through 08/02/2004 (Per Diem $8.13) Attorney's Fees Cumulative Late Charges 08/27/1986 to 08/02/2004 Cost of Suit and Title Search Subtotal $28,958.82 1,260.15 1,225.00 125.64 $ 550.00 $ 32,119.61 ]~scrow Credit - 326.78 Deficit 0.00 Subtotal $- 326.78 TOTAL $ 31,792.83 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terrinnated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 31,792.83, together with interest from 08/02/2004 at the rate of $8.13 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. By: FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQU/RE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 96722 '.: BEZ~ ~he aame p~mise~ ~ch Oa~e W. ~n~er and gve~ H, 156 F.A.~T HIGI{ STREET VERI~ICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiffin this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifications to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S CASE NO: 2004-03788 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERIJkND WASHINGTON MUTUAL HOME LOANS VS GPJtEFF DEBOR3tH D RETURN - REGULAR JODY SMITH , Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon GRAEFF DEBORAH D DEFENDANT , at 1145:00 HOURS, on the 9th day of August at CI/MBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to DEBOP~AH GR3tEFF a Sheriff or Deputy Sheriff of who being duly sworn according to law, the , 2004 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 .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this /~ day of ! 'Prothonotary -- So Answers: R. Thomas Kline 08/09/2004 FEDERM3IN & PHELAN ~Deputy Sheriff FEDERMAN AND PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WASHINGTON MUTUAL HOME LOANS, INC. 11200 WEST PARKLAND AVENUE MILWAUKEE, WI 53224 Plaintiff, DEBORAH D. GRAEFF De~ndam(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2004- 3788 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against DEBORAH D. GRAEFF, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaim Interest from 8/3/04 to 9/13/04 TOTAL $31,792.83 $341.46 $32,134.29 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. IVANIEL G. SCHMIEG, ESQUI~ Attorney for Plaintiff --o DAMAGES ARE HEREBY ASSESSED AS 1NDICA/~jl). , FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 56~-7000 WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff Vs. DEBORAH D. GKAEFF Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 04-3788-CML FILE COPY TO: DEBORAH D. GRAEFF 156 EAST HIGH STREET CARLISLE, PA 17013 DATE OF NOTICE: ~IIGIIST 31, 2004 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE 1S 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 1N 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 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 HILLING 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 FRANK FEDEKN~, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - CASE NO: 2004-03788 P COMMONWEALTH OF PENNSYLV~NIA: COUNTY OF CO%4BERLAND WASHINGTON MUTUAL HOME LOAlqS VS GRAEFF DEBORAH D REGULAR JODY SMITH Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon GRAEFF DEBOP~/q D DEFENDANT , at 1145:00 HOURS, on the 9th day of August at CUMBERt~AND CO SHERIFF'S OFFICE ONE COURTHOUSE-SQUARE CARLISLE, PA 17013 by handing to DEBORAH GRAEFF a true and attested copy of COMPLAINT - MORT FORE Sheriff or Deputy Sheriff of who being duly sworn according to law, the , 2004 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 .00 28.00 Sworn and Subscribed to before me this day of A.D. So Answers: R. Thomas Kline / 08/09/2004 FEDERMAN & PHELAN ~Deputy Sheriff Prothonotary FEDERMAN and PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WASHINGTON MUTUAL HOME LOANS, INC. 11200 WEST PARKLAND AVENUE Plaintiff, DEBORAH D. GRAEFF Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2004- 3788 CIVIL VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHM1EG, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin 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 amended. (b) that defendant DEBORAH D. GRAEFF is over 18 years of age and resides at, 156 EAST HIGIt STREET, CARLISLE, PA 17013, This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. EL G. SCHMIEG, ESQUIR~ ~ Attorney for Plaintiff ,o Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center SEP-10-2004 06:31:1 l Military Status Report ~ursuant to the Servicemen's Civil Relief Act of 2003 Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research will be done. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. .... httP~!//www.dmdc.osd.mil/udpdfi/owa/sscra.prc_Select 9/10/2004 FEDERMAN and PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff, DEBORAH D. GRAEFF Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2004- 3788 CIVIL CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 9l procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. D~NIEL G. SCHMIEG, ESQL~ Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff, DEBORAH D. GRAEFF Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2004- 3788 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WASHINGTON MUTUAL HOME LOANS, INC.. Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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, 156 EAST HIGH STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Last Known Address (if address cannot be reasonably ascertained, please indicate) DEBORAH D. GRAEFF 156 EAST HIGH STREET CARLISLE, PA 17013 2. Name and address of Defandant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Nalne 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 plaintiffhas knowledge who has any interest in the property which may be affected by the sale: NO1Tie Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 156 EAST HIGH STREET 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 1 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 tmswom t~alsification to authorities. September 13, 2004 DATE Dd~NIEL G. SCHMIEG, ESQUII~ Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. : Plaintiff, : DEBORAH D. GRAEFF : Defendant(s). : TO: DEBORAH D. GRAEFF 156 EAST HIGH STREET CARLISLE, PA 17013 CUMBERLAND COUNTY No. 2004- 3788 CIVIL September 13, 2004 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOTAND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINSTPROPERT~ ** Your house (real estate) at, 156 EAST HIGH STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sheriff's Sale on MARCH 2, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $32,134.29 obtained by WASHINGTON MUTUAL HOME LOANS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (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 Sheriff within 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It ma,,, not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL those two (2) ce~ lots of ground situate in the Second Ward of' ~e Borough ,3f Carlisle, (~mbetland County, Pennsylvania, bounded and de.~,cfib~l as ~llows: l,OT NO. I: On fl~e North by Ea~ High Street; on the 'East by I.ot ~w ~ formerly of Rog~ K. 'r~ Helen E, T~d. his wife; ou ff~ ~h by ~ ~w or fo~edy of C~ R. Todd; a~ on the W~ by ~t ~w or fo~erly of C, R~e~ '1'o~ and O~[la D. '!'~, ~ wife. Having a ~oa~ge of ~, ~re or le~, ~ F~ H~h St~t, ~ ~teMing in ~ 171 f~, ~t High LOT NO. 2: BF. g31NNING at a point on the Dine of land now or formerly of Lillie J. Ffouston. which poila is 40 t~et from the D~orthern line of Lihen3' Alley; thence with line of land now or formerly of Lillie 1. lloestoa, North 10 feet to COrDer of lot now or fotnlerly of C. Robert Todd and O/ella D. Todd; thet<:e East with said lot, 24.5 ~t to ~ now or formerly of Charle~ R. Todd; flumce South l0 te~ ~o the corner of lot now or fornl~rly of Roger K. Todd and Helen E. Todd, his wife; thence wid'l I~ $aflle~ West 24.5 t~ to the place of T~ginn!ng. Lot No. I being improved with a brick bo~se; and Lot No, Z being improved with a garage. TOGETHER with the right tn use, iD common with the owners of the houses known as N~. 154, 158 and 160 ~t High Street, the ~ of ground about 35 feet Ir.,, 60 feet in fl~ gear of said properties to provide ingr~ a~ egres~ from Liberty Alley to the above mentioned garage, and for l:]~rking purpo~s in eOnneglJon with the name. /'ax Parcel gO3 21-0318-027~ TITLE TO SAID PREMISES IS VF. STF.~ I~. Dei~otah D. Grdeff by Deed from William }. Bran~, Jr. aid Leslie L. Branch, his wife dated 3f20/1986 and recorded 8/27/1986, in Deed Book 32 Page 251, PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff, DEBORAH D. GRAEFF Defendant(s). : No. 2004- 3788CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/14/04 to3/2/05 (per diem -$5.28) TOTAL $32,134.29 $897.60 and Costs $33,031.89 DANIEL G. SCHMIEG, ESQU~t_¥ One Penn Center at Suburban Sta"ti6n 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property,No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale, The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 0 0 0 ~ o LEGAL DESCRIPTION ALL tlms~ r~-o (2) certain lots of grottnd situate in t.he geo'.md Ward of tile Borough of Cai'lisle, (Mmb¢rland County, Pennsylvan~, bounded and de. scrib=~l as follows: !.O? NO. 1: On tl~ North by East High Street; on the East by Lot now m' formerly of Roger K. 'lb:Id and Helen E. Todd, his wil%; on tl~ Sotuh by la~ now or formerly of Chart~ R. Todd; and on die Wast by Lot now or ~etly of C, Rob=r{ l'ocld and Ozedla D. Todd, his wife. Having a frontage of 15 feet, more or le~, on East High Street, and extendh~g in delxh 172 feet, at~l being Lmy~vn as No, 156 ,F~st High S~eet. LOT NO, 2: BI~GINNING at a point on the ~ of land now or formerly of Lillie $. l-Ioustou, which poilR is ~0 feel frotlI the northern line of Liberty Alley; thence with line of land now or formerly of Lillie 1. Ilo~ston, North lO feet to corner o~ lot now or fo[merly of C, Robert Todd and O-zella D. Todd; thence East with said lot, 24,5 ti:et to [ami now or t~m~erly of C~rles R, T0d~; the. ace So~ath 10 feet to the corner of lot now or forlllea-ly of Roger K. Todd and Helen E, Todd, ~ wife; th~ with t~ same, W~t 24.5 te~ to the phce of beginning. Lot No. I bei~ improved with a brick hour; aad Lot No, 2 being improved with a garage. TOGETHER with the right to use, in common with the owtgrs of the houses known as No'$. 1.54, 158 and 160 ~t High Sara:t, ~e tract of ground about 35 feet by 60 feet in ~e rear of saki properties to provicle ingre$~ ~ egress from Liberty Alley to the above memione*J garage, and for parking purpo,~ in eormecfiou with the same, Tax Parcel ~33 214)318.027. TITLE TO SAID PREMISES IS VF~TED IN. Delmfah D. Gr~ff by Deed from William I. Branch, Jr. and Leslie L. Branch, his wife dated 3/2011986 and recorded 8/27/1986, in Deed Book 32 Page 251. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-3788 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERiFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff (s) From DEBORAH D. GRAEFF (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 tha 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 h/m/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2/05 (PER DIEM - $5.28) - $897.60 AND COSTS Atty's Corem % Due Prothy $1.00 Arty Paid $110.00 Other Costs Plaintiff Paid Date: SEPEMBER 15, 2004 (Seal) CURTIS R. LONG Prothon~ --~ By: ~-f.~ ,O ~. ~ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court 1D No. 62205 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) NO. 04-3911 Civil Term ) Plaintiff ) ) v. ) ) THELMA STEIDLE, ) Defendant ) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf of Target National Bank Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 STEIDLE, THELMA 2050.4322.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) NO. 04-3911 Civil Term ) Plaintiff ) ) v. ) ) THELMA STEIDLE, ) Defendant ) PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiff's complaint. Amount claimed in Complaint Interest from December 31, 2003 Attorney's fees TOTAL $ 8,015.86 $ 732.45 $ 2,000.00 $10,748.31 With continuing interest on the principal amount of$10,748.31, with interest at the legal rate, plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached.  de 21,3 E. M~ & Felix,,A,P.~. C a~egie,/PA 15106 (412)"429-7675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) NO. 04-3911 Civil Term ) Plaimiff ) ) v. ) ) THELMA STEIDLE, ) Defendant ) PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037(b) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS. Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared Gregg L. Morris, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant, Thelma Steidle, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Defa~udgement was mailed rl accordance with Pa.R.C.P, 237.1, as evidenced by the attached copy. (412) 429-7675 Sworn to and subscribed before me this /t~ day of 2004, ~E~I~SA L LEtO My G4aflvni~lofl ExlcY~m Feb II, 2QGS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) ) Plaintiff ) ) v. ) ) THELMA STE1DLE, ) Defendant ) NO, 04-39l I Civil Term IMPORTANT NOTICE Filed on behalf of: Target National Bank Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 East Main Street Carnegie, PA 15106 (412) 429-7675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff THELMA STEIDLE, Defendant ) NO. 04-391l CivilTerm ) ) ) ) ) ) To~ Thelma Steidle 2600 Yale Avenue Camp Hill, Pennsylvania 17011 Date of Notice: September 3, 2004 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 800-990-9108 By: Pat/~de & Felix, A-,P. C. ,/ I l'Gregg[L. ~,,M~-~' Esquire C~eg~e, ~A 15106 (412) 4~675 I, Gregg L Morris, attorney for Plaintiff, Retailers National Bank/Target Financial, hereby certify that a true and correct copy of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: Thelma Steidle 2600 Yale ~enue Hill, Penn~ylv~mia 17011 P~ttenauc[iK& E/~lix, A.P.C. Carnegie, PA 15106 (412) 429-7675 FEDERMAN AND PHELAN, L.L.P. One Penn Center at Suburban Station 1617 John F. Kennedy Suite 1400 Philadelphia, PA 19103-1814 215-563-7000 Main Fax 215-563-5534 Peter J. Tremper Legal Assistant, Ex!. 1481 Representing Lenders in Pennsylvania and New Jersey September 29, 2004 Office of the Sheriff Cumberland County Courthouse I Courthouse Square Carlisle, P A 17013 ATTENTION: JODY FAX: 717-240-6397 Re: WASHINGTON MUTUAL HOME LOANS, INC. v. DEBORAH GRAEFF No. 04-3788 CIVIL Premises: 156 EAST HIGH STREET, CARLISLE, P A 17013 Dear Jody: Please STAY the Sheriff's Sale of the above referenced property, which is scheduled for MARCH 2, 200S, The sum of $6,661.33 was received in consideration for the stay. Please return the original writ of execution to the Prothonotary as soon as possible. Very truly yours, Peter J. Tremper ORIGINl'.L WRIT RETURNED TO THE PROTHONOTARY-"S OFFICE ON NOVEMBER 18, 2004. ORIGINl'.L ADVANCE DEPOSIT CHECK l'.ND COPY OF WRIT RETURNED TO l'.TTORNEY FEDERMAN'S OFFICE ON NOVEMBER 18 2004. CASE NOT DOCKETED IN THE SHERIFF'S OFFICE. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., NO 04-3788 Civil CNIL ACTION - LAW Plaintiff (s) From DEBORAH D. GRAEFF (I) 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) lfproperty 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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2/05 (PER DIEM - $5.28) - $897.60 AND COSTS Atty's Corom % Due Prothy $1.00 Atty Paid $110.00 Other Costs Plaintiff Paid Date: SEPEMBER 15, 2004 CURTIS R. LONG (Seal) Protho~ ,---By: Cl/)." f? ~.I1/7./V. / Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne WASHINGTON MUTUAL HOME LOANS, INC., Plaintiff (s) From DEBORAH D. GRAEFF NO 04-3788 Civil CIVIL ACTION - LAW (I) 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) Ifproperty of the defendant(s) not levied upon an snbject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2/05 (PER DIEM - $5.28) - $897.60 AND COSTS Atty's Comm % Dne Prothy $1.00 Atty Paid $110.00 Other Costs Plaintiff Paid Date: SEPEMBER 15, 2004 (Seal) CURTIS R. LONG prothon~ '-By: 0'" D P .~CV7/'f../ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PillLADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 62205 Tr:'~ ?~ C}"~.~P"<>' rt1t!''\~ (:H~r." ;.0;;;~ .' \\1;.3 :.'~ ," .-.,,-<.-~ ~ .' ~ ,,'-:.,..- ~tt,~ ~ ,.~,'_""., ,__,-. :../.1 In i {:'::; ~ t1fH~ har~ ~~~,~j~~~:t~ ."".,...,,'''1 'lUSNN3d , --', \ , ~.( ." t.'i ":; 8 L I dJS Al~. ~~ ,::LiHL: ,J -' ';J.D WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, ioterest and costs due WASHINGTON MUTUAL HOME LOANS, INC., NO 04-3788 Civil CIVIL ACTION - LAW Plaintiff (s) From DEBORAH D. GRAEFF (I) You are directed to levy upon the property of the defendant (s)and to seH 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 foHows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 enjoioed as above stated. Amount Due $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2/05 (pER DIEM - $5.28) - $897.60 AND COSTS Atty's Corom % Due Prothy $1.00 Atty Paid $110.00 Other Costs PlaiotiffPaid Date: SEPEMBER 15, 2004 (Seal) CURTIS R. LONG prothon~ -...llv: ~ P.7fC!?/1/L_/ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Tn~.!~ "'t...,.",y '-;'?In~" Cirr.O.;:l;"' ~-~ipr~" 1\,,,,;,,,,;01 S'..~ ,.w~,rj ~ ..~,_~"" -, y ~iL' f~ r '~.:hei,~'~'.f 1 I h:~:'3 ~,~~.,};,,! !d~:t m)' han-,j ",I _,-' i"_.,:: ~._'\~> F,t':i ~'.t C;c.r~i~\;fJ. Pa. ~',:, '1" ':::~"1 .~ -,,, 11"';",, ~_'J!.:;'J. WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., NO 04-3788 Civil CIVIL ACTION - LAW Plaintiff (s) From DEBORAH D. GRAEFF (I) 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 ofthe defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) Ifproperty ofthe 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2105 (pER DIEM - $5.28) - $897.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $110.00 Other Costs Plaintiff Paid Date: SEPEMBER 15, 2004 CURTIS R. LONG (Seal) ProthOA ~: t'U>...D _p ~./M./'iIf Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Tnl er:; C....PV r.:"'f"~1I ""~CO""D "'~_'~"'~' ~/" ~ . ~..t".lt~fJ ns::.,., .. n,;.. l~':j i !:{S4? cntu ~et r:.V har~ ..' jyJ;:,}j;~;~~ '!l,~SHHjd .' < t (', c (2 J J3S ;...', ~jillC ii" , . ,,~J ,d.i.) WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., NO 04-3788 Civil CIVIL ACTION - LAW Plaintiff (s) From DEBORAH D. GRAEFF (I) 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) Ifproperty 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 $32,134.29 L.L. $.50 Interest FROM 9/14/04 TO 3/2/05 (PER DIEM - $5.28) - $897.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $110.00 Other Costs Plaintiff Paid Date: SEPEMBER 15,2004 CURTIS R. LONG (Seal) protho~ ,,-Bv: (J"""'- tJ P.~h'/V~/ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PIDLADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 62205 '--- TR' j!: ""P~\f r::"""o 3 \ .J.... ""'" 'L1':~)t~ ~ I,"'r';''',,~i',~ RECORD In . 1 > ;'i"'" [,.pAl '"' ,."..~ ':_ '..." ,",. _,' .. '. .."" "r,,' "'. S i ;::;;.,' r'J r"'J!~;';~""'~ J"'\-..D (:.'. A.I'Y., '.i-i',}n'~):31ry ~.;..l(':: _~::.:i:t_.- ." 1'\StH'3d -.",' f', 'I dl(' U ,~, ) ''';':1,,;11,1) FEDERMAN and PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN ST AnON 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION DEBORAH D. GRAEFF NO. 2004- 3788 CIVIL Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.