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HomeMy WebLinkAbout04-4098 FEDERMAN 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 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET SUITE 100 ORANGE, CA 92868 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 04 - '-ICI1? ci(.J'f,-~ v, CUMBERLAND COUNTY BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, P A 17013 MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, P A 17013 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 TInS 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 #: 58229 File #: 58229 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. 1. Plaintiff is WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET SUITE 100 ORANGE, CA 92868 2. The name(s) and last known addressees) of the Defendant(s) are: BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 MELISSA CARA STOl.LEY 1882 SPRING ROAD CARLISLE,PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 08/22/2000 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERIQUEST MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1635, Page 451. PLAINTIFF is now the legal owner ofthe mortgage and is in the process of formalizing an assignment of same. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 0110112004 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 #: 58229 6. The following amounts are due on the mortgage: Principal Balance Interest 12/01/2003 through 08117/2004 (Per Diem $36.00) Attorney's Fees Cumulative Late Charges 08/2212000 to 08117/2004 Cost of Suit and Title Search Subtotal $120,267.66 9,396,00 1,250.00 30.42 $ 550.00 $ 13 1,494.08 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $ 13 1,494.08 7. 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 attomey's fees will be charged. 8. 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 terminated 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, 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 13 1,494.08, together with interest from 08/17/2004 at the rate of$36.00 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. FEDE N AND PHEL Ntt:rli- By: s/Francis S. Ha inan ~- FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 58229 ~.ALL'THAT CEnTAIN tract of land situate in North Middleton . TQwnship,'CUmber~and County, Pennsylvania, bounded and described as follows: BEGINNING at a ~oint in the center of the state Highway Route No. 34, known'as sterrett's Gap Road, at corner of Lot No. ~1 in the hereinafter mentioned Plan of Lots; thence by the dividing 1ine between Lots NOG. 40 and 41 on the said P1an, West 200 feet to a ~ointi thence by 1and now or formerly oe Lloyd C. Brumbaugh and wife, South 75 feet to a point; thence by.the'oenter of Lot No. 39 in the hereinafter mentioned Plan of~Lot~, East 200 feet to a point in the center of the afore- said stat~ HiqhwaYi thence by the center of the aforesaid '. s~te ~iqhwaYt North 75 feet to a point, the place of . '~:BBGl:NNl:NG. , J': .~. ..(:;.. ~. .~~~G Lo~ No. 40 and the Northern one-half of Lot.No. 39.on .>~e'certain Plan o~ Lots recorded by George E. Henry e~ ux in " ,1:be ;Office of the Recorder of Deeds in and ~or:' CumberJ.and, ' ~'..County,. in' Plan Book 3, Page 93. and having thereon erected a " ..dwel:;LJ..nq hou.... known as, and numl:>ered 1882 Spring Road. . BEING the same pro~erty oonveyed by deed of Joseph B. HoCorke1, dated August 7, 1~86; recorded in the Of~ioe of the Recorder of Oeeds in and for cu~er1and County in Deed Book "e", Vo1ume 32, Page ~~a.. PROPERTY BEING: 1882 SPRING ROAD VERIFICA nON FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in 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. 1~~~ rWl~ Francis S. Hallinan, Esquire Attorney for Plaintiff DATE: R)~ (J /.Q. -,:J ~ ~ ~ q.. . en ...... W () ~ ::! -c.J .J::: b'- P-- Lv Q- ()J ~ ~ +- -f.... .., G SHERIFF'S RETURN - REGULAR CASE NO: 2004-04098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS STOLLEY BRIAN KEITH 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 STOLLEY BRIAN KEITH the DEFENDANT , at 1517:00 HOURS, on the 23rd day of August , 2004 at 1882 SPRING ROAD CARLISLE, PA 17013 BRANDON STOLLEY, 18 YEAR OLD by handing to SON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.70 .00 10.00 .00 31.70 Sworn and Subscribed to before me this I~r day of 1r;,~1/.-<.A- 02. ilO '1 A.D. C 0 {2 M.d~oJ '1 Prothonotary I ~ So Answers: .r~~ R. Thomas Kline 08/24/2004 FEDERMAN & PHA BY:~ Deputy SHERIFF'S RETURN - REGULAR CASE NO: 2004-04098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS STOLLEY BRIAN KEITH 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 STOLLEY MELISSA CARA the DEFENDANT , at 1517:00 HOURS, on the 23rd day of August , 2004 at 1882 SPRING ROAD CARLISLE, PA 17013 by handing to BRANDON STOLLEY, 18 YEAR OLD SON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ,~~"~,,o!<c.d:t!.,:p /' R. Thomas Kline Sworn and Subscribed to before me this lAX day of J-tr;iTi ~ d. cr0.3 A. D . h Q'm.uL ~ Prothonotary . AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WM SPECIALTY MORTGAGE, LLC PJT No. 04-4098 CIVIL DEFENDANT(S) BRIAN KEITH STOLLEY MELISSA CARA STOLLEY AC:CT.#0017835802 SERVE MELISSA CARA STOLLEY AT 1882 SPRING ROAD CARLISLE, PA 17013 Type of Action ~ - Notice of Sheriff's Sale S~1Lle Date: MARCH 2, 2005 SERVED ~~ Served and made known to M't. \ '1'5 S ;;). C~<<.<). s t-o \ \ ~} Defendant, on the I ~ day of VJ Ml u-.~ ,200#;at 7"~ o'clock-fm., at J B 8 ?.. "S(V"~ f'O"',) -K~ . I C::cK \h. \... , Commonwealth of Pennsylvania, in the manner described below: \)Z Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge ofDefendant(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 ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s) 's company. Other: - . ,/ - . \. Description: Age ~ Height S' ? Weight (30 Race IJJ ~ Se:x ~ Other , ~s~5' I, da.vc....c:~ L... c..c\..~ JV., a competent adult, being duly sworn according to law, depose ~nd state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. LUCrLlE NOT~t SEAl. Sworn to an~ subsc~~d ~~~y, = PubIc before me this ~ oay My WItan ExP' New. 1~ of tJh~~~... ,200.1. /:);) - ~. ),2001' Nota~ ~ By:~;I PLEASE ATT~~PT SE~CE AT LEAST 3 TIMES. INDICATE DA ATTEMPTED. ES OF SERVICE NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 2nd Attempt:_ / / Time: 1 st Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - I.D. No. 62205 ~ AFFIDAVIT OF SERVICE PLAINTIFF WM SPECIALTY MORTGAGE, LLC CUMBERLAND COUNTY PIT No. 04-4098 CIVIL DEFENDANT(S) BRIAN KEITH STOLLEY MELISSA CARA STOLLEY ACCT. #0017835802 SERVE BRIAN KEITH STOLLEY AT 1882 SPRING ROAD CARLISLE, PA 17013 Type of Action - Notice of Sherifrs Sale S~lle Date: M~CH 2, 2005 SERVED Served and made known to B'l:rt-> J<'t"~\.... go \ \<:t ' Defendant, on the at 7 " !)~ o'clock -#.m, at / B 8 ;;l.. JO ~) ~~. / 1;Z~ ~v \ \ "') (\ '-- d~Y?f~200_i , Commonwealth of Pennsylvania, in the manner described below: ~ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is W'l ~'- \\ Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. IJ,.,-'t. \:' '5 5 ~ G~::l. <36 ~ 1 Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant( s)' s company. Other: I II Description: Age 3 0- Height 5:" 7 Weight I 30 Race W \,. S{:x L Other )\~SS ~ ~ I, C\a--r ~ ~ ~ ~ t... C... (l \ I ~; ~ompetent adult, being duly sworn according to law, depose ~nd state that I personally handed a true and correct copy of the Nolice of Sheriffs Sale in the forth herein issued in the captioned case on the date and at the address indicated above. NOTARIfL SEAL LUCILlE H. CAAW, Notary PubIc Sworn to and subscriJ:led letterken~y ~owl1shj ,Fra!l'Iklin County befqrr me this ~'aay My Nt>>v. 10 2007 of }J{}\J 1'-"\1c,~", 200!f. /. /) - -..f) Notary~ W/iA-t:") BY~ I' PLEASE ATTEMP{ S~~I~~T LEAST 3 TIMES. INDICATE DAT NOT SERVED On the day of .200-, at o'clock _.m., Defendant NOT FO~ because: Moved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt:_ / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - I.D. No. 62205 '-"1- It ! 'C ':'"1 -<.. () ( - ~ " r-,l C:-:> c::> ..c- c-, r:"1 C-) I CO o "'h "-"~ riif'D .-r'" r~l ::,j C;:.' ~~i3(;; <~'~5 ;:'~ i" J~ ~:;~ -;:1 t...) w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WM SPECIALTY MORTGAGE, LLC ) CIVIL ACTION ) vs, BRIAN KEITH STOLLEY MELISSA CARA STOLLEY ) CIVIL DIVISION ) NO, 04-4098 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) ss: I, FRANK FEDERMAN, ESQUIRE attorney for WM SPECIALTY MORTGAGE. LLC hereby verify that on 11/8/04 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: January 21. 2005 . n 1 , NIEL G. SCHMIEG, ESQUIRE A torney for Plaintiff ",-" ~. €. . z i\ "," ~g, w \ - <ft - ... - <>' "'"" 0; g~ ~ ~. 7i . ;%. .,,~ IJ< 80 \:rI ~j ::1 o. 0: . . ~ o ~ ~ i'& ..~ 1~ !I: 'Z ~ \I, i " o ~ ~'Cg.~;;1 88~\\ . 'q~h ~ ~\\.~. ~ih\ N~""'O :;) :;'Ei'~i~ SI<8~~ Ull~ 5.-:j ..... t;.~ >::l ~ Q 5';;' 00 ~l3>H~~ ~ 'i~~~a r" a~~p~ '"'8i~ ~ ~\\%!'l .:>'\ rn o' ~l'; ~ 5 ':;1' 'it 6- a _./:i. 'S" tU' ",Qn~ a~ ~ i ~.~~as. "..." 00<> ... 1.~~ i ;H:; '" \II g ~ H~. ~H\ ~ lA'~ HOC%: 5.-0'" t\U "'~1~ ~",.", 'St ~ ~.... !. 'J W - N - - - o -0 if' -l ,~102'A'>o, I"~.. -Z-C$j :\~SFOS): 1 _,r\ ;}"<- "I.;, 4 -, C 'C~., / ~ ~~".cmc' o~. 11- $ 01.200 OGOA?;Oi:~71 <:D\iQS 2004 Mf\.\LEO FROM Z\?COOE 19': 0',) '" <ft ... <>' N - r" ~. ~ ~ :z: c 3 g ... Hut ~6~~~ ~8~~~ o;a\:?,?>r. :r. ~ ::I: 0 ; o ~ 9 9 ... VJ, 'q L....'" 0" ~ 0;; >'d en ~ 8g3rQ~~ f",'Zg~ ~~~~\ ~ ~ ?; ~ s ~ ~ ~ " ~ >;l 0 (/l~ ~ 0 ~~~~ @ ~ ~ ~ ~ ;3 :2 ~ tn t; ~ @ ? "" ~ ;~ ~ ~ ~ frl 0 9 '6;$, :~ ttj?;:l :... 0 rJJ t~ ~ ~ ~ ~ ~ 0 ~ ~ '" (/l 0; M ~ '~ p >' ~ " o>,Z ...Po'" we;S :0 '" '" Po"'''' ~ III 6. ",,_0'71 g'. <z; p m ;"'->-..J(tIv ., ""tn i~g~ .f:nQ'!t. ""~::; ::g~~ \D(')<-+r 6.9: ~ ';P. ~o:lcr'Z ;:;;g ~'r-' ~~~t; '"d~(/} ~p..~ ~ 'I o' ... ",::; :.;8 ~ '" .g~ ~ 0 , - -l - o <ft - -l o - <>' ,-> c.;..:;> ~,~:~ c;..\.... ~r~ 1" ","" -1") .....'- ...F'~ f..;'? '-", (';) - .FEDERMAN PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 Atlorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD~ SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET, SillTE 100 ORANGE, CA 92868 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-4098 CIVIL BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendant(s). 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 BRIAN KEITH STOLLEY and MELISSA CARA STOLLEY, 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 Complaint Interest from 8/18/04-1114/04 to 1115/04-312/05 TOTAL $131,494.08 $2,844.00 $134,338.08 I hereby certify that (I) 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. ANIEL G. SCHMIEG, ESQU Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED Ail INDICATED. ~ DATE:Abo 5,:J..tXi-( (!h/J~>~. . PRO PROTHY FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ" Id. No. 12248 LA WRENCE T. PHELAN, ESQ., Id. No, 32227 FRANCIS S, HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71)) )61-7000 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION Vs, : CUMBERLAND COUNTY BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendants : NO. 04-4098 CIVIL TERM TO: BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, P A 17013 FILE COpy DATE OF NOTICE: SEPTF:MRFR 22,21104 THlS 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, IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A TIORNEY 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 MAYBE 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 INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON 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 ASSOClA TION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 ]5~ , FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff CC: PATRICK G, O'CONNOR, ESQUIRE i'EDERMAN 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 (71,) ,61.7000 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION Vs. : CUMBERLAND COUNTY BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendants : NO, 04-4098 CNIL TERM TO: MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 FILE COpy DATE OF NOTICE: SFPTFMRFR 22, 2004 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT lliE 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 DEF AUL T 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 llilS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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 ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 CC: P A TRlCK G. O'CONNOR, ESQUIRE 76~ FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - REGULAR . CASE NO: 2004-04098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS STOLLEY BRIAN KEITH 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 STOLLEY MELISSA CARA the DEFENDANT , at 1517:00 HOURS, on the 23rd day of Auqust 2004 at 1882 SPRING ROAD CARLISLE, PA 17013 by handing to BRANDON STOLLEY, 18 YEAR OLD SON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 .~~-e--.#-< 4'~J , R. Thomas Kline me this day of 08/24/2004 'WE~&~ By: ' ~Deput Sheriff ... Sworn and Subscribed to before A.D. Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004-04098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS STOLLEY BRIAN KEITH 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 STOLLEY BRIAN KEITH the DEFENDANT , at 1517:00 HOURS, on the 23rd day of August , 2004 at 1882 SPRING ROAD CARLISLE, PA 17013 by handing to BRANDON STOLLEY, 18 YEAR OLD SON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31. 70 r~~~ R. Thomas Kline day of 08/24/2004 FEDERMAN ;d,~-v By: . Deputy Sheriff Sworn and Subscribed to before me this A.D. Prothonotary ~~ fl ~ 0: -- w 8 \" ~ ~ :0 ~ Gi cS F \If . () 0- t2. f: J::- C) ,........, 1"'_ ~:::; Cl ..,;.._ -fl ~..,~ (~:3 -;: .C" :~ C) I C') ::'? - FEDERMAN PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC 505 SOUTH MAIN STREET, SIDTE 100 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-4098 CIVIL BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service ofthe 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 BRIAN KEITH STOLLEY is over 18 years of age and resides at, 1882 SPRING ROAD, CARLISLE, PA 17013. (c) that defendant MELISSA CARA STOLLEY is over 18 years of age, and resides at, 1882 SPRING ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~D~ ~~-,k ~ fl'lJ ~ ANIEL G. SCHMIEG,.ESQU Attorney for Plaintiff , 4:.: -.-j -( ,.....:; <:::::;) c.;;::> _l7"" , (I, 17 -"-;~ ,-, '.0 Request for Military Status Page] of I Department of Defense Manpower Data Center NOV-04-200406:37:30 _ Military Status Report ... Pursuant to the Servicemen's Civil Relief Act of 2003 <Last Name First Middle Begin Date Active Duty Status Service/Agency STOLLEY Currently not on Active Military Duty, based on the Social Security Number and last name provided. ' Upon searching the information data banks ofthe 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. ~w~~~ 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. https:/ /www.dmdc.osd.mil/udpdrifowaisscra.prc _Select 11/4/2004 Request for Military Status Page I of I Department of Defense Manpower Data Center NOV-04-200406:37:ll Military Status Report Pursuant to the Servicemen's Civil Relief Act of2003 <Last Name Active Duty Status S~rvice/ Agency First Middle Begin Date STOLLEY 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. ~w~U--~ 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. https:/ /www.dmdc.osd.mil/udpdri/owa/sscra.prc _Select 11/4/2004 FEDERMAN PHELAN, LLP By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE, LLC Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION BRIAN KEITH STOLLEY MELISSA CARA STOLLEY NO. 04-4098 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. ~Ul~ ~~~j'(\Q o~ ANIEL G. SCHMIEG, ESQ Attorney for Plaintiff -, ,." C:~) 532 c.r , :t;~ o .. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WM SPECIALTY MORTGAGE, LLC Plaintiff, v. No. 04-4098 CIVIL ' BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $134,338.08 Interest from 11/5/04- MARCH 2, 2005 (per diem -$22.08) $2,605.44 and Costs TOTAL $136,943.52 fin f1 Q Q 9- ~ ~ ~ fi'{ 0 0 i1 > NIEL G. SCHMIEG, ESQUIRE <J One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the pl~intiff is not present at the sale. ...$ o~ ~~ ~;;.< ....rJl ~z Zz o~ ~~ ~ ~ o~ UZ ...p 00 u ~~ p~ 8~ ~~ ,...~ ~p u .- ",.,..." 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I -ll crl ~ c... l'l ~ ~ 15~ ~ l' -;-- '2 3 J ~ ---t- ~ j ~ - . ~ ALL THAT CERTAIN IracI of I:lnd situate in North Middleton Township, Cumberland Cowuy, Pennsylvania. bounded and described as follows: BEGINNING at a pow in the center of the Slate Highway Route No. 34 known as Sterrell's Gap Road at corner of Lot No. 41 in the hereinafter mentioned Plan of LoIS; thence by the dividing line between Lolli Nos. 40 and 41 on the said Plan West 200 fCeI to a point; thence by land now J)f fonnerly of Lloyd C. Brumbaugh and wife, So\lllt 75 feet to a point; thence by the c<:oll:r of Lot" No, 39 in the b<:reinafter mentioned Plan of I.ots Ea.,1 200 feet to a point in the cenler of the aforesaid Slate Highway; thence by the CCl\leI' of the aforesaid Stale Highway North 75 leet to . pointlhe place of beginning, BEING Lot 40 and the Northern ODe.haIf of Lot No. 39 on lite cenaln Plan of LOIS recorded by George E. Henry et ox in the Office of the Recorder of Deed$ in and for Cumberland Couniy in Plan Book 3 page 93 and havinllthcroon erected a dwelling boose mown"" and IlIl1llhered 1882 Spring Road. TITLE TO SAID PREMISES [S VESTED IN Brian Keith Slolley and Melissa Car. Slolley, his wife by Deed from Joseph 6, McCorkel a1ld Susan J, McCorkel, his wife daled 9/3/1992 and recorded 10/2/1992 in Deed Book 3SX page 491. Tax Parcel #29-17.1585-()(j5 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-4098 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE, LLC., Plaintiff(s) From BRIAN KEITH STOLLEY AND MELISSA CARA STOLLEY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, yon are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $134,338.08 L.L. $.50 Interest FROM 11/5/04 - 3/2/05 (PER DIEM - $22.08) - $2,605.44 AND COSTS Ally's Corum % Due Prothy $1.00 Atty Paid $129.70 Other Costs Plaintiff Paid Date: NOVEMBER 5, 2004 (Seal) CURTIS R. LONG protho~ p ~ '-.Jly: a-,. 17 . '/(A/r,~~ 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 lD No, 62205 .. WM SPECIALTY MORTGAGE, LLC CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS BRIAN KEITH STOLLEY MELISSA CARA STOLLEY CIVIL DIVISION NO. 04-4098 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) WM SPECIALTY MORTGAGE. LLC, 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 .1882 SPRING ROAD. CARLISLE. P A 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if addr\lss cannot be reasonably ascertained, please indicate) BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, P A 17013 2. Name and address ofDefendant(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 Last Known Address (if address cannot be reasonably ascertained, please indicate) CHAMBERSBURG HOSPITAL 112 NORTH 7TH STREET CHAMBERSBURG, PA 17201 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: 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 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: Name Last Known Address (if address cannot be reasonably ascertained, please. indicate) Tenant/Occupant 1882 SPRING ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street ' Carlisle, P A 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 oflS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 4. 2004 DATE ~OrUl~~~~~ ANIEL G. SCHMIEG, ESQU Attorney for Plaintiff 1"'-,) (~C::' e-:':;"> ~,;.- -" 't:<:; ~' ::: \ ()'i ~:J ..-"'''' c::' -- ~ .. , WM SPECIALTY MORTGAGE, LLC Plaintiff, CUMBERLAND COUNTY v. No. 04-4098 CIVIL, BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendant(s). November 4, 2004 TO: BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 "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 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, 1882 SPRING ROAD. CARLISLE. PA 17013, is scheduled to be sold at the Sheriffs Sale on MARCH 2, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of$134.338.08 obtained by WM SPECIALTY MORTGAGE. LLC (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: 1. 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. 2. You may be able to stop the sale by filing a petition asking the, Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See 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 Sheriff's 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 ifthe buyer pays the Sheriff the full amoullt due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe 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 ofthe 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 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 pres~nt 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 . ALL THAT eERT AlN tract of Jand situate in North Middleton Township, Cumberland Coo1ll)l, Pennsylvania, bou.1ded and de.,erilled as follows: BEGlNNINO at a point in the center of tllc Stale Highway Route No. 3o\-lrnown as Sterreu's Gap R<lad at corner of lol No. tl-lln the hereinafter mentioned Plan of Lets; thence hy !he dividing line belween lo", Nos. <lO and 41 On !he said Plan West 200 feet to a point; Iheoce by land now or fOl1llel'ly of Lloyd C, Brumbllugb and wife, Soutll15 feet 1<> a point; thence by the c_r of!,.ot No, 39 in the h.:reinaller m.mtiClned Plan of Lo[S Ea..t 200 feet to a point in the <:eJUer of !he aforesaid StlllC Highway; tnellCe by the center of the afotesllld Slate Highway North 75 leet to a point the place of beginning. BEING Lot 40 and the Nonhernone-half ofLotNQ. 39 on the cet1llln Plllll of Lots recorded by George E. Henry et UJ( in !be Office of the Recorder of Deeds in and for Cumberland County in Plan Book 3 page 93 and !laving thereon erected a dwelling lJouse known as and 1IlIt1Ibef<<l1882 Spring Road.. TITLE TO SAID PREMISES [S VESTED IN Brian Keith St<llley and Melissa Cata Srotley, his wife by Deed from Joseph B. MCCorkel and Susan J. MCCorkel. l1is wife daltd 91311992 and recorded 10/2/1992 in Dew Book 35X page 491. Tax Parcel #29-17-1585-lJ65 ~) -, "'.J c::..) c-:') J;- c..... -\, ---I .1 ~;'\ , en c:: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: ol.j~ '-I 95' I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby ce ify that the Sheriffs Deed in which WM Specialty Mtg LLC is the grantee the same having been sold 0 said grantee on the 2nd day of March A.D" 2005, under and by virtue of a writ Execution issued 0 the 5th day of No v, AD., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2 04 Number 4098, at the suit of WM Specialty Mtg LLC against Brian Keith Stolle & Melissa C a is duly recorded in Sheriffs Deed Book No. 268, Page 292. IN TESTIMONY WHEREOF, I have hereunto se my hand and seal of said office this ;(3 day of 'f''f'I.tV1...{,L ,AD. L"o () ~ t-C'- .::Q:-, ~~~"t~~c:r~:. Recorder f Deeds WM Specialty Mortgage, LLC VS Brian Keith Stolley and Melissa Cara Stolley In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-4098 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 07, 2004 at 5:23 o'clock PM, he served a true copy ofthe withi Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendants, to wit: Brian Keith Stolley and Melissa Cara Stolley, by making known unto Melissa Stolley, personally and adult in charge for Brian Keith Stolley, at 1882 Spring Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the sam , Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2005 at 10:33 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Brian Keith Stolley and Melissa Cara Stolley located at 1882 Spring Road, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Brian Keith Stolley and Melissa Cara Stolley, by regular mail to the' last known address of 1882 Spring Road, Carlisle, P A 17013. These letters were maile under the date of December 29, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 02, 2005 at 10:00 o'clock A.M. He sold the same for t sum of $1.00 to Attorney Daniel Schmieg for WM Specialty Mortgage LLC, without recourse. It being the highest bid and best price received for the same, WM Specialty Mortgage LLC, without recourse of 505 City Parkway West, Suite 100, Orange, CA 92868, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $811.22, it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 15.91 15.00 15,00 30.00 10.00 .50 1.00 7.40 o . ~Jl I. 'l...\ 1.\01 ~J Jf' /\@llo~ Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 6.63 15.00 30.00 242.15 297.40 30.73 25.00 39.50 811.22 Sworn and subscribed to before me This JL..- day of~ 2005, AD. f;;J.; ~ Prothonotary ~ So Answers: r:~r.<< ~--r4 R. Thomas Kline, Sheriff .~ I . / BY, je Real Estate eputy WM SPECIALTY MORTGAGE, LLC CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEA BRIAN KEITH STOLLEY MELISSA CARA STOLLEY CIVIL DIVISION NO. 04-4098 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) WM SPECIALTY MORTGAGE, LLC, Plaintiff in the above action, by its attorney, D SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was following information concerning the real property located at 1882 SPRING ROAD C 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if addryss cannot be reasonably ascertained, please indicate) BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, P A 17013 MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: Same as above IELG. ed the ISLE P A 3. Name and last known address of every judgment creditor whose judgment is a record lien 0 the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please: indicate) CHAMBERSBURG HOSPITAL 112 NORTH 7TH STREET CHAMBERSBURG, PA 17201 , 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot b reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot b reasonably ascertained, please. indicate) None 6. Name and address of every other person who has any record interest in the property and hose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, p lease, indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has an interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please, indicate) Tenant/Occupant 1882 SPRING 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 p rsonal knowledge or information and belief. I understand that false statements herein are made subje t to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 4, 2004 DATE 1orWQ~~ ANIEL G. SCHMIEG, ESQU Attorney for Plaintiff . . , WM SPECIALTY MORTGAGE, LLC Plaintiff, CUMBERLAND COUNTY v. No. 04-4098 CIVIL BRIAN KEITH STOLLEY MELISSA CARA STOLLEY Defendant(s). November 4, 2004 TO: BRIAN KEITH STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 MELISSA CARA STOLLEY 1882 SPRING ROAD CARLISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORM TION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHAR IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTR ED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 1882 SPRING ROAD. CARLISLE. PA 17013. is sched led to be sold at the Sheriffs Sale on MARCH 2, 2005 at 10:00 a.m. in the Cumberland County Court ouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $134,338.08 obta ed by WM SPECIALTY MORTGAGE, LLC (the mortgagee) against you. In the event the sale i continued, an announcement will be made at said sale in compliance with Pa.R,C.P" Rule 31 .3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late c arges, costs and reasonable attorney's fees due, To find out how much you must pay, u may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the. Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court 0 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 ill e 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 OTH R RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidde . 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 gro sly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full aII\oupt due in 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 0 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 th and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceeding you. e sale. To er ofthe Sheriff to evict 6. You may be entitled to a share of the money which was paid for your house. A sc edule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the ale. This schedule will state who will be receiving that money. The money will be paid out in accord ce with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed wit 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, i you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THAVE STED IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It ma no be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must e postponed or stayed in the event that a representative of the plaintiff is not pres~nt at e sale. 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 J3nd situate in North Middleton Township, Cumberland Co Pennsylvania, bOullde4 and dc.~rilled as follows: BEOlNNlNO at a point in the center of tile State Highway Route No. 34 known as Sterrett's Gal' Roa at comer of LoI No. 41 in the hereinafter melllioned Plan of l.ol5; tbcncc by the dividing line bdw Lots No.. 40 and 41 on the said Plan West 200 feet 10 a point; IhellCe by land now or formerly 0 Uoy<l C, Brumbaugh aOO wife, SOulll 75 feel to a poinl; lbcnce by the ei:llleT of ~I No. 39 in hereinafter melllk>ned Plan of I.QIS E:ost 200 fcellO a point in the c.:emer of Ille aforesald SIllIC Highway lIIence by the center of 1be aforesaid Stale Highway North 7S leet to . poiOl tbe pllu:e of beginning. BEING Lot 40 and lIIe Northern one-balf of Lot No. 39 on the certnin Plan of lois "'-Corded by Georg B. Henry et ox in the Office of the Recorder of Deeds io and for Cumberland County in Plan Book 3 page 93 and having Ihereon erected a dwelling b<:lme known as and. IlIUllbered t 882 Sprill8 Road. TITLE TO SAID PREMISES IS VESTED IN Brian Keith S10lley an<I Melissa Cara Stolley, ~ wife by Dw:l [rom Joseph B. McCorkel and Susan J. McCorkel, h.is wife daled 9/3/1992 and lecorlled 10/211992 in Deed Book 35X page 491. Tax Parcel #29-17-1585-065 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL V ANlA) COUNTY OF CUMBERLAND) NO 04-4098 Civil CIVIL ACTION - LA TOTHESHER~FOFCUMBERLANDCOUNTY: To satisfy the debt, interest and costs due WM SPECIALTY MORTGAGE, LLC., Plaintiff ( From BRIAN KEITH STOLLEY AND MELISSA CARA STOLLEY (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 ofthe defendant(s) not levied upon in tbe 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 fr paying any debt to or for the account of the defendant (s) and from delivering any property of the defend nt (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 himlher that helshe has been added as garnishee and is enjoined as above stated. Amount Due $134,338.08 L.L, $.50 Interest FROM 1115/04 - 3/2/05 (PER DIEM - $22.08) - $2,605.44 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $129.70 Otber Costs Plaintiff Paid Date: NOVEMBER 5, 2004 CURTIS R. LONG (Seal) 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 lD No. 62205 Real Estate Sale #11 On November 23, 2004 the Sherifflevied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 1882 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 23, 2004 By<.hdGIJ~ Real Estate Deputy {LBJ c::;:;:u c"-u;] c::::::::a (;:::::\ l".,'j CJ iT;:;;) bZ :/1 'V B- AON nOOl t]E :Zl dV41:A.!HaWintlNVICJ3UH():J .I.:II~S~l .:10 3:J1.:I.:I0 Vj.:l'rMHinsOJ m.V'I!:J]ElHn:J a", 3Hl .:10 3JI.:l.:iO PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor ofthe Cumberland Law Journal, ofthe Count and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland aw Journal, a legal periodical published in the Borough of Carlisle in the County and State afo esaid, 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 regu ly issued weekly in the said County, and that the printed notice or publication attached hereto s exactly the same as was printed in the regular editions and issues of the said Cumberland L w Journal on the following dates, V1Z: Janua 14,21,28,2005 Affiant further deposes that he is authorized to verify this statement by the Cumberl d Law Journal, a legal periodical of general circulation, and that he is not interested in the subj ct matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements 1.S to time, place and character of publication are true. Editor SWORN TO AND SUBSCRIBED before me this 28 day of January, 2005 l:>~1~) ,I '~Jri..U\) Notary REAL ESTATE SALE NO. 11 Writ No. 2004-4098 Civil WM Specialty Mortgage. LLC v.. Brian Keith Stolley and Melissa Cara Stolley Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in North Middleton Town- ship. Cumberland County, Pennsyl- vania. bounded and described as follows: BEGINNING at a point in the cen- ter of the State Highway Route No. 34 known as Sterrett's Gap Road at comer of Lot No. 41 in the herejn- after mentioned Plan of Lots; thence by the dividing line between Lots Nos. 40 and 41 on the said Plan West 200 feet to a point: thence by land now or formerly of Lloyd C. Brumbaugh and wife, South 75 feet to a pOint; thence by the center of Lot No. 39 in the hereinafter men- tioned Plan of Lots East 200 feet to a point in the center of the afore- said State Highway; thence by the center of the aforesaid State High- way North 75 feet to a point the place of beginning. BEING Lot 40 and the Northern one-half of Lot No. 39 on the cer- tain Plan of Lots recorded by George E. Henry et ux in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 3 page 93 and having thereon erected a dwelling house known as and numbered 1882 Spring Road. TITLE TO SAID PREMISES IS VESTED IN Brian Keith Stolley and Melissa Cara Stolley, his wife by Deed from Joseph B, McCorkel and Susan J. McCorkel. his wife dated 9/3/1992 and recorded 10/2/ 1992 in Deed Book 35X page 491. Tax Parcel #29~ 17-1585~065. , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark, being duly sworn according to law, deposes and says: That he is the Accounts Receivable Manager of The Patriot News Co" a corporation organized an existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 0818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of he Patriot-News and The Sunday Patriot-News newspapers of general circnlation, 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 publi ed ever since; lished d the ted lication That the printed notice or publication which is securely attached hereto is exactly as printed and p in their regular daily and/or Sunday/ Metro editions which appeared on the 18th and 25th day(s) of January 1st day(s) of February 2005, That neither he nor said Company is interested in the subject matter of said p , notice or advertising, and that all of the al1egations of this statement as to the time, place and character of p are true; and That he has personal knowledge ofthe facts aforesaid and is duly authorized and empowered to ve 'fy this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously p ssed and adopted severally by the stockholders and board of directors of the said Company and subsequently dul recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book 'M", Volume 14, Page 317. AU.1lIAT~_"IaDd_in - _ TOll1IIIip, CumIJedmj County. ~,I_ ~ooddesaibedlSfollows: _.......in1llo'"'*'..1IIo _ Hi8fnray _ No. l4 toown as _'s Gap Road " """" of Lot No. 4\ in 1110 _meotiOllfd Plan of lois; thence by" divibgline _LoIsN.. 4Oaod41oo 1110 slid Plan West 200feet to.point; thence byland now or formerly of Uoyd C. Brumbaugh am ...e.Soulh15feetto.point;thencebylbereoter P bl' h ' R . t ~ Ad t" C t ofl.otNo,39intltebereinaftermeotionedPlanof U IS er s ecelp lor ver Ismg os Lots East 200 feet to a point in the center oftbe )1isher of The Patriot-News and The Sunday Patriot-News, newspapers of general ~~~ State Highway; tbeoce by 1110 reoter of vledge receipt of the aforesaid notice and publication costs and certifies that the sa ~ 1Il0IeSaJ.d State Highway North 75 feet to a .....Ibe I'bte ofBEGINNlNG. BFJNG Lot 40 aod the Nor\boem _ball of Lot No. 3900 tbecertainPlan of Lots reo.mied. by Ge<n&e E. Hemy et ux in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 3 page 91 aod b1>ing tbereoo erected a dwelliug house known as and ntuDbered 1882 Spring Road. lTILElO SAID ~ is vested in Brian Keitb Stolky aod _ Cara Stolky, !tis wit. by Deed from Joseph B. McCorlteI aod Susan I. McCotte\ !tis wit. dakd 91311992 aod ~ Ill'2Il992 in Deed Book 35X page491. ThxParcel #29-11.1585-065, PUBLICATION COPY SALE#11 REAL ESTATE SALE No. 11 WriI No. 2004-4098 ClvllTenn WM Specially ~;LLC v. Brian KeIth Stolley and Mel.... Cars Stolley Ally: Frank "-rman DESCRlF-noN ~ .........................,.........,..1.....,..1.......,.....,.........,..................,..... L . Sworn!O and su::~before c rd. dayr;~ 2005 A,D lert'! l. Russell. No i~ /' ~ OI'/O\\-IOII\Sb~~piles June. ARYPUBLIC My COrt\rt\ISSlO . "I Nola" ~ ' P $\l\'IlQ.nla Ass"rlMrcottinUSSlOn exptres June 6, 2006 Member, enn 1 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA, 17013 Statement of Advertisiug Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attached hereto on the above stated dates 297.40 e have By....",......",........",......""......"""....., "".",....