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HomeMy WebLinkAbout02-0361FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY 8120 NATIONS WAY BUILDING 100 JACKSONVILLE, FL 32256 Plaintiff V. PATRICIA A. WOLL 750 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 Defendant(s) TERM NO. 6a - .?L+ CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Loan #: 317177 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY 8120 NATIONS WAY BUILDING 100 JACKSONVILLE, FL 32256 2. The name(s) and last known address(es) of the Defendant(s) are: PATRICIA A. WOLL 750 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 9/15/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to YORK FEDERAL SAVINGS AND LOAN ASSOCIATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1282, Page 372. By Assignment of Mortgage recorded 7/27/01 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 679, Page 3897. 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 3/1/01 and each month thereafter are due and unpaid, and by the-terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $76,441.72 Interest 5,63 8.05 2/1/01 through 1/1/02 (Per Diem $16.83) Attorney's Fees 1,225.00 Cumulative Late Charges 299.40 9/15/95 to 1/1/02 Cost of Suit and Title Search 550.00 Subtotal $84,154.17 Escrow Credit 0.00 Deficit 883.20 Subtotal 883.20 TOTAL $85,037.37 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. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $85,037.37, together with interest from 1/1/02 at the rate of $16.83 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ rank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff n C'.';'.L' : Or(}c rUS COUNTY- '95 SEv xd mn 10 22 115 ?V? ?. r?1a.>,,?t-,d?,t.e,.t- . Lel.?o-.?-- P (3?e.s ? ??s ice Atrov Tbli Une Por H? rdln Data MORTGAGE 3 -? 7 THIS MORTGAGE ("Security Instrument") is given on SEPTEMBER 15, 1995 The mortgagor is PATRICIA WOLL ("Borrower"). This Security Instrument is given to York Federal Savings and Loan Association which is organized and existing under the laws of THE UNITED STATES OF AMERICA and whose address is 101 South George Street, PO Box 15068, York, PA 17405-7068 ("Leader"). Borrower owes Lender the principal sum of EIGHTY THOUSAND SIX HUNDRED FIFTY AND NO/100*****************'?************""********* Dollars (U.S. $ 80, 650.00 ). This debt is evidenced by Borrower's note dated we same date as this Security instrument ("Note'), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on OCTOBER 1, 2025 . This Security Instrument secures to Lender. (a) the repayment of the debt evidenced by die Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Burrower does hereby mortgage, grant and convey to Lender the following described property located in CUMBERLAND County, Pennsylvania: ALL THAT CERTAIN piece or parcel of land situate in Upper Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a Plan by Rogers and Frederick dated July 4, 1981, with revisions through and including September 8, 1982, as follows, to wit: ALL THAT LAND in Stage III, Section B, Townhouse Plots No.6, being more paticularly described on said plan and recorded in plan book 42, page 69, and being designated on said Plan on Lot No. 6-C, and also known as 750 Allenview Drive, Mechanicsburg, Pennsyvania 17055. 4 which has the address of 750 ALLENVIEW DRIVE Istreetl Pennsylvania 17055 ("Property Address7; [zip Codal PE NNSXLVANIA oaSe roooo iy -- Fannle Mae/rreddle Mae UNIFOX JNS'MUMENT e66xiP82 PACE 372 MECHANICSBURG Icityl Form 3099 9/90 (pate 1 of 6 poles) flan Lebo Nnnn Fama, lae ¦ Teemu Cae 14ee4304393 ONCI 51e.7at•1131 ACCT# 100063690 4 TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be coveted by this Security • Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." BORROWER COVENANTS dial Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the tide to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when dire die principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Now 2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to Lender on the day monthly payments are due under die Note, until the Now is paid in full, a sum ("Funds") for. (a) yearly taxes and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or ground fonts on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (c) yearly mortgage insurance premiums, if any, and (1) any sums payable by Borrower to Lender, in accordance with die provisions of paragraph 8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items." Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount u lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estate Scrtlemenl Procedures Act of 1974 as amended rom time to time, 12 U.S.C. § 2601 et seq. rItESPA'), unless another law that applies to die Funds sets a lessor amount. If so, Leader may, at any time, collect and hold Funds in an amount not to exceed die lesser amount. Lender may estimate the amount of Funds due on die basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. However. Lender may require Borrower to pay a one-time charge for an independent real csutc tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be paid, Lender shall not be required to 4y Borrower any interest or eaminh3 on the Funds. Borrower and leader may agree in writing, however, that interest shall be paid on the Funds. Leader shall give to Borrower, without charge, an annual accounting of die Funds, showing credit; and debits to the Funds and the purpose for which each debit to tie Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument. If the Funds hold by Lender exceed the amounts permitted to be hold by applicable law, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender ut any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the dcflcicncy. Borrower shall make up the deficiency it% no more than twelve monthly payments, at Lender's sole discretion. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds hold by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against tie sums secured by this Security Instrument. 3. Application ol'Payinenta. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any, late charges due under the Note. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, flats and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if ahy. Borrower shalt pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly to due person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If Borrower makes these payments directly, Borrower Shull promptly furnish to Lender receipts evidencing die payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to die payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating die lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying die lien. Borrower <h„ri v,,6krv ph&. Noto or inke nor. or more of the actions set forth above within 10 days of the giving of notice. S. Hazard or Property Insurance. Borrower shall keep the improvements now existing or hereafter ercetod on Ute Property insured against loss by fire, havirds included widiin dic term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maim ainod in the amounts and 0 ITEM 195062 192111 00o100099000940 BOOKI9,89W PACE 373 17arm 3039 9/90 (page Z o/6 peg") at"I Lek" vuew. FWm Inc. ¦ To Order Cat 1400.00-SM 0 FAX 016.701.1131 ACCT# 100063690 V f L V V 1 1 J• V T L L\ L {'{ L V {? P•,? V L 1\/,V • L Y • L, L T v V V J V ?? ? . r for the periods that Lender requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in die Property in accordance with paragraph 7. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender ; shall have the right to hold the policies and renewals. If Lander requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of ate Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the amount of the payments. If under paragraph 21 Ore Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. 6. Occupancy, Preservation, Maintenance and Protection or the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's prnxipal residence within sixty days after ate execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at Icact one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lender's good faits judgment could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or , Lender security interest Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in tine Property or other material impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property ms a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the tease. If Borrower acquires fee title to the Property, ten leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Lender's Rights fu the Property. If Borrower falls to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of Vie Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lieu which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may hake action under this paragraph 7. Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from die date of disbursement at the Nola rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 8. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason, die mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost whstamially equivalent to die cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage ---- - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - insurer approved by Lender. If substantially equivalent mortgage insurance covcMgc is not available, Borrower shall pay to Lender each month a sum equal to one-tweirth of the yearly mortgage insurance premium being paid by Borrower when the .insurance coverage lapsed or ceased to be in effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in the amount and for me period that Lender requires) provided by an insurer approval by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. , 9. Inspection. Lender or its agent tray make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause ror the inspection. 10. Condemnation, The proceeds of any award or claim for damages, d-uect or consequential, in connection with iTEA1 19SOL7 (9211) eoeld 00000009,14 Form 3039 9190 (pore 3 of 6 paler) anot L%h* 1"MM f"NO, IM i To Ordtr CU: VOI-SW0303 O FAX lit-711.1171 BOOK 1282 PAGE 374 ACCT# 100063690 NY-lb-dl 15:3b k'MZManlc A135ll(Hl 1 1 L- e l f L`f O=w C 4...1 1 J any condemnation or other taking of any pan of the Property, or for conveyance in lieu of condemnation, are hereby • assigned and shall be paid to Lender. In the event of a total taking of the Property, tae proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than The amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower and Lender odtcrwisc agree in writing, the sums secured by this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is less than the amount of tae sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applio to the sums secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to die sums secured by this Security Instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the date date of the monthly payments referred to in paragraphs 1 and 2 or change rho amount of such payments. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. P.xtension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in Interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortizagon of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. I2. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shalt be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent • I3. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or otter loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note. 14. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. 111e notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by rust class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. Governing Law; Severability_ This Security Instrument shat be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end die provisions of this Security Instrument and the Note arc declared to be severable. 16. Borrower's Copy. Borrower shalt be given one conformed copy of the Note and of this Security Instrument 17, Transfer of the Property or a Beneficial Interest in Borrower. If all or any pan of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide 1 period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by - r . v .. --- C 1 Y I 1 J applicable law may specify for reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower. (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action as lender may reasonably require to assure that the lien of this Security Instrument, Lender's rights in tine Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon rcinstatume nt by Borrower, this Security Instrument and die obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 17. 19. Sate of Note; Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as die "Loan Service") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Servicer unrelated to a salt of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. 'Me notice will also contain any other information required by applicable law. 20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, not allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property, Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other rcmodiation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in dais paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located U129 relate w health, safety or environmental protection. NON-UMFORM COVENANT'S. Borrower and Leader further covenant and agree as follows: 21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower or, among other things, (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (e) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower or the right to reinstate after acceleration and true right to assert in the foreclosure proceeding the non-existence, of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by U1is Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding it a sheriff's tale or other sale pursuant to this Security Instrument. 25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire tide to the Property, this Security Instrument shall be a purchase money mortgage. 0 ITEM 795OLM (gall) DaGld ODOOOD0944 Agent or Leakier BOOK1282 PAGE 377 V Norm 3039 9190 (yaSc 6 o/6 pater) Wag Was gwka gaga. Im ¦ TO Orar Call' I-CO.530•RM D FAA 611.711.1171 ACCT# 200063690 ALL THAT LAND in Stage III, Section B, Townhouse Plots No. 6, being _ more particuarly described on said Plan and recorded in Plan Book 42, Page 69, ?eing designated on said Plan of Lot No. 6-C, and also known as Allenview Drive, Mechanicsburg, Pennsylvania 17055. UNDER AND SUBJECT to all restrictions, easements, covenants, conditions and agreements of record. TOGETHER with all and singular the buildings and improvements, ways, streets, alleys, passages, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the hereby granted premises belonging, or in any wise appertaining, and the revisions and remainders, rents, issues and profits thereof; and all the estate, right, title interest, property, clam and demand whatsoever of them, the said Grantors, as well at law as in equity, of, in and to the same. UNDER AND SUBJECT nevertheless to all easements, restrictions, encumbrances and other matters of record that a physical inspection or survey of the hereby granted premises would reveal. BEING the same premises which Chris F. Cuomo and Deborah S. Miller, by Deed dated March 9, 1992 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 0-35, Page 433, granted and conveyed unto Chris F. Cuomo and Deborah S. Cuomo, his wife, Grantors herein. PREMISES BEING ON: 750 ALLLNVIEB DRIVE 04/04/01 WED 15:56 FAT 2155637588 FEDERMAN & PHELAN 4 002 V C U r hereby states that he/she is s6, s??rli- Qc refar-y ofl eomlvail mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her imowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: N \ W c? C C n gi- O.+ T° ?Cl 3> c.? t..? T? C a. W U? q G, rn -G SHERIFF'S RETURN - REGULAR CASE NO: 2002-00361 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS WOLL PATRICIA A GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE WOLL PATRICIA A DEFENDANT the at 2045:00 HOURS, on the 15th day of February , 2002 at 622 N. BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 PATRICIA WOLL was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Additional Comments HOUSE AT 750 ALLENVIEW IS VACANT. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this U4k day of 0 o 0. A.D. P o honot So Answers: R. Thomas Kline 02/19/2002 FEDERMAN & PHELAN By: // / J i3L a7& Deputy She f ' FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY 8120 NATIONS WAY, BUILDING 100 JACKSONVILLE, FL 32256 Plaintiff, V. PATRICIA A. WOLL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-361 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against PATRICIA A. WOLL, 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 1/2/02 to 3/19/02 TOTAL $85,037.37 $1,295.91 $86,333.28 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: M.-aaa ;2,s aw?;L? INDICAT -J-J - ? PRO PROTHY FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY Plaintiff vs. PATRICIA A. WOLL Defendant(s) TO: PATRICIA A. WOLL 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: MARCH 8. 2002 FILE czar THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-361 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY Plaintiff vs. PATRICIA A. WOLL Defendant(s) TO: PATRICIA A. WOLL 750 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: MARCH 8, 2002 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-361 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Fede man, Esquire Attorney for Plaintiff N ? ? _ ? ? ? ? ?? ? ?_ c,, : ? _ _ r r , '? {7?? c, .? .? C? -{ -'_, -. c?i (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY 8120 NATIONS WAY, BUILDING 100 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 02-361 V. PATRICIA A. WOLL Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on R&?,2X 200 dL. DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 *"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."* PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY Plaintiff, No. 02-361 V. PATRICIA A. WOLL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 3/20/02 to 9/4/02 (per diem -$14.19) TOTAL $86,333.28 $2,398.11 and Costs $88,731.39 FRANK FEDERMAN, ESQUIRE 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. L? O C7 z 0 W ? >,.? 0-4 L^ U a? z mm Za zoo a L oW a? c wy w s O E d OF o -4 Uz y pO 00 U ? x as C?7FO d ? o G? Fa'a?w a, a? D a o., 0 0 ?tn ? o a E cli i \ . ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows in accordance with a Plan by Rogers and Frederick dated July 4, 1981, with revisions through and including September 8, 1982, as follows, to wit: ALL THAT LAND in Stage III, Section B, Townhouse Plots No. 6, being more particularly described on said Plan and recorded in Plan Book 42, Page 69, and being designated on said Plan of Lot No. 6-C, and also known as 750 Allenview Drive, Mechanicsburg, Pennsylvania 17055. TAX MAP #28-2423, PARCEL #307 Premises: 750 ALLENVIEW DRIVE, TOWNSHIP OF UPPER ALLEN CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN 'Patricia A. Woll, a single individual, by Deed from Chris F. Cuomo and Deborah S. Cuomo dated 9/11/1985 and recorded 9/18/1985 in Record Book 128, Page 326. I r# -zo 1 j C- C ?47 1 1 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY 8120 NATIONS WAY, BUILDING 100 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 02-361 v. PATRICIA A. WOLL Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant PATRICIA A. WOLL is over 18 years of age and resides at, 622 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. / x h A 1 2" FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff r c? ,-, C: cv -c,,cr' y ... L J ' ,.:, . . _ i ? .-? ?' ?.? { _ _i / ' r` ` Y ' r_ ?. C., ?? •• ? \ l 1! ? r ..? l FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE CUMBERLAND COUNTY MORTGAGE COMPANY COURT OF COMMON PLEAS V. Plaintiff, CIVIL DIVISION NO. 02-361 PATRICIA A. WOLL Defendant(s). CERTIFICATION FRANK FEDERMAN, 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: Q 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. / Li? - FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff s? ? ?? 41 ? ??' lf.. ( ? ?+ ? - . / ?._I ? t , 1 • L r ?. - ;, _ _._ -? ._; cn MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY Plaintiff, V. PATRICIA A. WOLL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-361 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,750 ALLENVIEW DRIVE, MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name PATRICIA A. WOLL Last Known Address (if address cannot be reasonably ascertained, please indicate) 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(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 AMERICAN EXPRESS COMPANY Last Known Address (if address cannot be reasonably ascertained, please indicate) WORLD FINANCIAL CENTER NEW YORK, NY 10285 r 4. Name and address of last recorded holder of every mortgage of record: Name CHASE MANHATTAN BANK, AS INDENTURED TRUSTEE Last Known Address (if address cannot be reasonably ascertained, please indicate) C/O RESIDENTIAL FUNDING CORP. 1301 OFFICE CENTER DRIVE,SUITE 200 FT. WASHINGTON, PA 19034 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 750 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 18, 2002 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff C V tf1 mfr ' a=? r; , -ti MORTGAGE ELECTRONIC REGISTRATION CUMBERLAND COUNTY SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY No. 02-361 Plaintiff, V. PATRICIA A. WOLL Defendant(s). March 18, 2002 TO: PATRICIA A. WOLL 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 "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 ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY. * * Your house (real estate) at, 750 ALLENVIEW DRIVE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $86,333.28 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY (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 Sheriffs 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. 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. 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. 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 or parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows in accordance with a Plan by Rogers and Frederick dated July 4, 1981, with revisions through and including September 8, 1982, as follows, to wit: ALL THAT LAND in Stage III, Section B, Townhouse Plots No. 6, being more particularly described on said Plan and recorded in Plan Book 42, Page 69, and being designated on said Plan of Lot No. 6-C, and also known as 750 Allenview Drive, Mechanicsburg, Pennsylvania 17055. TAX MAP #28-2423, PARCEL #307. Premises: 750 ALLENVIEW DRIVE, TOWNSHIP OF UPPER ALLEN CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Patricia A. Woll, a single individual, by Deed from Chris F. Cuomo and Deborah S. Cuomo dated 9/1111985 and recorded 9/ 18/ 1985 in Record Book 128, Page 326. C.m ? .. L F /- :? in AFFIDAVIT OF SERVICE PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY DEFENDANT(S) PATRICIA A. WOLL SERVE PATRICIA A. WOLL AT 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND COUNTY KMD No. 02-361 ACCT. #317177 Type of Action - Notice of Sheriffs Sale Sale Date: 9/4/02 -SERVED Served and made known to tL 1 C l LI 1, Defendant, on the day of r, I 1200-4 at S ), o'clock9.m., at N NA. I' t P. ,jA&.,I%e. 11 1 ?-, 4V (r/ , Conunonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age Height,5 Weight ? Race CO Sex Other fl?-i° rV'\ I, A. U', C e(jf (SU,4'TY ` , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of 200 W"6 Nota By: PLEASE`ATT T SERVICE A LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. Notarial Seal I Lisa MG r Notary Public NOT SERVED Carlisle Boro, Cumberland County n,? commission F r Sept. 9, 2002 , 200_, at o'clock `.m., Defendant NOT FOUND because: Moved Unknown No Answer 1st Attempt: Time: Vacant 2nd Attempt: Time: 3rd Attempt: / J Time: Sworn to and subscribed before me this day of , 200-. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 1 1 7 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY ) CIVIL ACTION vs. PATRICIA A. WOLL CIVIL DIVISION NO. 02-361 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY hereby verify that on 4/22/02 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. Notice of Sale was sent to the Defendant(s) on 4/22/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: July 18. 2002 F NK FEDER AN, ESQUIRE Attorney for Plaintiff 0 0 v a 0 R L a ? ° o R ?a c u R = c o? a R o? a W x d w a w s. t L H ? L y .D ao v C _ t E m v y t u 7 n 'y 09£8909 O = ? -E - s' tl313W ed s = + ,O = KJ lay Ud's "?7+?-- .s A 9 A N o u G cc ° C 'O L = G O G N ? A = ?vEo n ° . 'C1 c a_ a o .4 v` A ° u G ' O $ I -20 .3E v c c o u 0 06 d w ? _ o ? y •? = fi N y ? u v = o nc v' N L L A. L F ?/?, Nu cc E > R = .T O O Z E - N c LU o E 2.agc E c c?? A = C L N A _ E •O E _ 'X 'y °- ? ? n u y ?.E=E?c L E= u j O E c F cn: W W ? c ? F u F 5 ` O o W E F z a a~ v ee .? X m a a -? < ' Za aprn j No: o E 'n F U c < F Oz Z Z 0^ o W a a k Q ?z U mz a W.. o yE. °W •„ jin 0 ?Uy CZ .?E.? o ?<e n . F.]Fj . F. :d00 M '->e 3P Frs F d 3a? xz z Fad° =I=U 96 ?m z? w a ?ooa, aF a v a` a=O Z`z aow z zv a U?u C? [ 3WZ ; o0 ?jCE. UOp ?rnWV?i FWZ E-F.A 2 ;D °E- ° z ?? m e'. ??°3 a QZ Wo=? ? I + z" z a?? Q3Z UUM ? F U - s uc= ?r °-cr s E ? <z' v w y O ? E d E N M [ t vl ? O 00 ", o N M v n z' N J F a 7160 3901 9844 7040 3220 TO: PATRICIA A. WOLL 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 SENDER: KMD REFERENCE: SALES/317177 PS Form 388 ,tune 2000 RETURN Postage RECEIPT SERVICE Certified Fee Return Receipt Fee Restricted Delivery _ Total Postage & Fees h ^' US Postal Service Receipt for Noa' Certified Mail No Insurance Coverage Provided Do Not Use for Int "Vim ernational Mall + W'._. n Cl ?-? ` _, N in ` < :n , rte- ?- l] COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Home Loan Mtg Corp is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., - )2002, under and by virtue of a writ Execution issued on the 25th day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 361, at the suit of Mortgage Eletronic Reg Systems Inc Nominee for Alliance Mtg Co against Patricia A Woll is duly recorded in Sheriff's Deed Book No. 253, Page 3249. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office thi2G h day of Sept, A.D. 2002. Recorder of Deeds Mortgage Electronic Registration Systems In The Court of Common Pleas of Inc., as Nominee for Alliance Mortgage Cumberland County, Pennsylvania Company Writ No. 2002-361 Civil Term VS Patricia A. Woll Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2002 at 9:06 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Patricia A. Woll, by making known unto Patricia A. Woll personally, at 622 North Baltimore Ave., Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2002 at 9:46 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Patricia A. Woll located at 750 Allenview Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Patricia A. Woll, by regular mail to her last known address of 622 north Baltimore Ave., Mt. Holly Springs, PA 17065. This letter was mailed under the date of July 09, 2002 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, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage Corporation. It being the highest bid and the best price received for the same Federal Home Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna, VA 22183-5000, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $642.08, it being costs. Sheriff's Costs Docketing $30.00 Poundage 12.59 Posting Handbills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.73 Certified Mail 3.46 Levy 15.00 Surcharge 20.00 Law Journal 223.55 Patriot News 174.55 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriff's Deed 29.50 $ 642.08 paid by attorney 9/17/02 Sworn and subscribed to before me This Jn tr- day of R. Thomas Kline, Sheriff 2002, A.D. p ,i1 Diu Jij VLl lki ro onotary Real Estat eputy e? ? 3 ,, 11ORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION PATRICIA A. WOLL NO. 02-361 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,750 ALLENVIEW DRIVE, MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name PATRICIA A. WOLL Last Known Address (if address cannot be reasonably ascertained, please indicate) 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(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 AMERICAN EXPRESS COMPANY Last Known Address (if address cannot be reasonably ascertained, please indicate) WORLD FINANCIAL CENTER NEW YORK, NY 10285 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) CHASE MANHATTAN BANK, AS INDENTURED TRUSTEE C/O RESIDENTIAL FUNDING CORP. 1301 OFFICE CENTER DRIVE,SUITE 200 FT. WASHINGTON, PA 19034 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 750 ALLENVIEW DRIVE MECHANICSBURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. March 18, 2002 aX4?41-( DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION CUMBERLAND COUNTY SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY No. 02-361 Plaintiff, V. PATRICIA A. WOLL Defendant(s). March 18, 2002 TO: PATRICIA A. WOLL 622 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 "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 BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOTAND 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, 750 ALLENVIEW DRIVE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $86,333.28 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY (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 Sheriffs 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. 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. 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 or parcel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows in accordance with a Plan by Rogers and Frederick dated July 4, 1981, with revisions through and including September 8, 1982, as follows, to wit: ALL THAT LAND in Stage III, Section B, Townhouse Plots No. 6, being more particularly described on said Plan and recorded in Plan Book 42, Page 69, and being designated on said Plan of Lot No. 6-C, and also known as 750 Allenview Drive, Mechanicsburg, Pennsylvania 17055. TAX MAP 1/28-2423, PARCEL 11307 Premises: 750 ALLENVIEW DRIVE, TOWNSHIP OF UPPER ALLEN CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Patricia A. Woll, a single individual, by Deed from Chris F. Cuomo and Deborah S. Cuomo dated 9/11/1985 and recorded 9/18/1985 in Record Book 128, Page 326. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-361 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR ALLIANCE MORTGAGE COMPANY, Plaintiff (s) From PATRICIA A. WOLL, 622 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065 (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 garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $86,333.28 L.L. $.50 Interest FROM 3/20/02 TO 9/4/02 (PER DIEM - $14.19) $2,398.11 AND COSTS Arty's Comm % Due Prothy $1.00 Arty Paid $108.28 Other Costs Plaintiff Paid Date: MARCH 25, 2002 CURTIS R. LONG Prothonotary, Civil Division ?BY //.On t Ail ? REQUESTING PARTY: , 4?/ Name FRANK FEDERMAN, 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. 12248 Real Estate Sale #19 On May 10, 2002 the sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA Known and numbered as 750 Allenview Drive, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 10, 2002 By: (NOX-tdj c? Q • ?q? ? ¢? =L L-T - LZ as w 1? Pat- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 19 R ger M. Morgenthal, Editor Writ No. 2002-361 Civil Mortgage Electronic Registration Systems, Inc. as Nominee for Alliance Mortgage Company Vs. Patricia A. Woll Atty.: Frank Federman ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Township of Upper Allen in the County of Cum- berland and Commonwealth of Pennsylvania, more particularly de- scribed as follows in accordance with a Plan by Rogers and Frederick dated July 4, 1981, with revisions through and including September 8, 1982, as follows, to wit: SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 NOTARIALSEAL Mr Cori Evku MIM 5, 2DW ALL THAT LAND in Stage III, Section B, Townhouse Plots No. 6, being more particularly described on said Plan and recorded in Plan Book 42, Page 69, and being desig- nated on said Plan of Lot No. 6-C, and also known as 750 Allenview Drive, Mechanicsburg, Pennsylva- nia 17055. TAX MAP #28-2423, PARCEL #307. Premises: 750 ALLENVIEW DRIVE, TOWNSHIP OF UPPER AL- LEN, CUMBERLAND COUNTY, PENNSYLVANIA. TITLE TO SAID PREMISES IS VESTED IN Patricia A. Woll, a single individual, by Deed from Chris F. Cuomo and Deborah S. Cuomo dat- ed 9/11/1985 and recorded 9/18/ 1985 in Record Book 128, Page 326. 1 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION .,%.::`.. COPY E?bo_rnt"IA%"cribed befor m s 14th day pfAugpiM'2002 A.D. SALE #19 Terry L. Russell, Notary Public ty Of Harrisburg, Dauphin County L REAL ESTATE SALE No. 19 Commission Expires June 6, 2006 ?f Writ No. 2002-361 NOTARY PUBLIC Civil Term Member, Pennsylvania Association Of Notaries Mortgage Electronic My commission expires June 6, 2006 Registration Systems, Inc. as Nominee for Alliance Mortgage Co. CUMBERLAND COUNTY SHERIFFS OFFICE Patricia A. Woll CUMBERLAND COUNTY COURTHOUSE Atty: Frank Federman DESCRIPTION CARLISLE, PA. 17013 ALL THAT CERTAIN tract or parcel of land and premises. situate, lying and being in the Township of Upper Allen in the County of Cumberland and Statement of Advertising Costs Commonwealth of Pennsylvania, more particularly described as follows in accordance To THE PATRIOT-NEWS CO., Dr. with a Plan by Rogers and Frederick dated July For publishing the notice or publication attached 4,1981, with revisions through and including September 8, 1982, as follows, to wit: hereto on the above stated dates $ 172.80 ALL THAT LAND in Stage Ill. Section B. Probating same Notary Fee(s) $ 1.75 Townhouse Plots No.6, being more particularly Total described on said Plan and recorded in Plan Book $ 174.55 42, Page 69, and being designated on said Plan of Lot No. 6-C. and also known as 750 Allenview Drive. Mechanicsburg. Pennsvlvania 17055. Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. TAX MAP #28-2423. PARCEL #307. PREMISES: 750 Allenview Drive, Township of Upper Allen, Cumberland County. Pennsylvama TITLE TO SAID premises is vested in Patn6a.N 05 single Cuomo and Deborah S I Cuomo dated 9/11/19 and recorded 9118/1985 in Record Book 128. Page 326.