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HomeMy WebLinkAbout04-5043LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN ID# 55669 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERIVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING, TEXAS 75038 PLAINTIFF VS. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 DEFENDANT Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. mac(- 5CqL3 ?t v ?L / E/2-in NOTICE COMPLAINT IN MORTGAGE FORECLOSURE 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 defense 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 NOTICE 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 Bar Association 52 S. Bedford Street Carlisle, PA 17013 717-249-3166 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. LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN ID# 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 Attorney for Plaintiff LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERIVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING, TEXAS 75038 PLAINTIFF VS. CAROLYN M.SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 04 - sby3 l_.LC?? COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE 1. LaSalle Bank, N.A., f/k/a LaSalle National Bank, as Trustee under the Pooling and Serivcing Agreement dated 10/01/2000, Series 2000-3, (hereinafter referred to as "Plaintiff") is an Institution, conducting business under the Laws of the Commonwealth of Pennsylvania with a principal place of business at the address indicated in the caption hereof. 2. Carolyn M. Sheaffer, (hereinafter referred to as "Defendant") is an adult individual residing at the address indicated in the caption hereof. 3. Plaintiff brings this action to foreclose on the mortgage between Defendant and itself as Mortgagee by Assignment. The Mortgage, dated August 29, 2000, was recorded on August 29, 2000 in the Office of the Recorder of Deeds in Cumberland County in Mortgage Book 1635, page 785. Plaintiff is the Mortgagee by Assignment by virtue of an Assignment of Mortgage recorded on August 5, 2002 in the Office of Recorder of Deeds in Cumberland County in Book 689, Page 734. A copy of the Mortgage is attached and made a part hereof as Exhibit `A'. 4. 5. 6. 7 The Mortgage secures the indebtedness of a Note executed by Defendant on August 29, 2000 in the original principal amount of $64,800.00 payable to Plaintiff in monthly installments with an interest rate of 10.875%. A copy of the Note is attached and made a part hereof as Exhibit `B'. The land subject to the mortgage is 3471 Spring Road,Carlisle, PA 17013. A copy of the Legal Description is attached as part of the Mortgage as Exhibit `A' and incorporated herein. The Defendant is the record owner of the mortgaged property located at, 3471 Spring Road, Carlisle, PA 17013. The Mortgage is now in default due to the failure of Defendant to make payments as they become due and owing. As a result of the default, the following amounts are due: Principal Balance $75,581.64 Interest to 9/5/2004 3,191.64 Accumulated Late Charges 168.00 Escrow Advance 1,087.06 Recoverable Balance 380.75 Cost of Suit and Title Search 550.00 Attorney's Fees 1,000.00 TOTAL $81,959.09 8 9. plus interest from 9/6/2004 at $20.45 per day, costs of suit and attorney fees. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff s sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Pennsylvania law requires that a plaintiff in mortgage foreclosure provide a defaulting mortgagor with a Notice of Homeowners' Emergency Mortgage Assistance ("Act 91 Notice") 35 P.S. Section 1680.403c, 10. The Notice of Homeowners' Emergency Mortgage Assistance was required and Plaintiff sent the uniform notice as promulgated by the Pennsylvania Housing Finance Agency to the Defendant by regular and certified mail on June 2, 2004. A copy of the Notice is attached and made a part hereof as Exhibit `C'. WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiff's favor and against the Defendant, in the sum of $81,959.09 together with the interest from 9/6/2004 at $20.45 per day, costs of suit and attorney fees. Law offices of Gregory Javardian BY: cry t d' #Attomey rney ID 55669 for aintiff 4 , Sep-15-2004 0911am From-PREMIER ABSTRACT +243 3390 T-808 P.002 7^ry NNW UC== MAIL 701 ARLYer1CN ?,,?==AC Nq{YOk06 cakwpA7zoN ' . rte. p ORPBN M MUM, svlas 299 =Q??? a?i Tm7B11LR1? 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E.u¦m ales r3 mw 1mpa+atmt wm ? aemma vmw ales 6a ?IgeWry) ?' o?°ucoazr,r xNarrnmp>:epr r.. m wnvANA•"Oo hmp• mocamomewo am RRnmun ?ww Rnpap wmmww v.?en suaKtE35amm .790 , Sea-15-2004 D8:13am From-PREMIER ABSTRACT +243 3380 T-808 P.008/018 F-881 by xamwa mmow, &=-a am" hod e{" a m W= mr wrawa eoadoed In ale 9etwiV rowueeae.a m aT ddafq aacmed b Boemvaam melwa NMIL j?2bA In( SAO= Goff .w Mao 8mmw jw COMMO 7WUL78 of ONSM TAWA. C.R-L.41-W wan w ma dde.6b7fWa( AvAdQ'i"- .n"17 beM as, ? M olEsee - maam0er s?mr'd.ao?.eam ?nmea?a+eda?wStOa kmwr ud s?pgdtaa uw .r.l•G• .aeNWlheJeusdrdlrpalpawintleeaaghed. w Wnwa W XUW. I bffm a<aY U4 ad *mold re. Mr emo daa QwlFw I . y r'° a •• e . ??! f C ?i umalomw enamrevuw.uwrMlwNb•v++eudmuee aa?nmMmeemmaaer h..amreno +®+rww er,., M11635na •791 ? i Sep-16-2004 00:14am From-PREMIER ABSTRACT +243 3300 T-008 P.008/016 F-881 AU thin canto lot or ground with the improvement dmemn erected sinaa In b iddleeeo Tow w*. County of Curnbalad, and State of PemnyWalm, bounded and douviecd as follows, m wlt.• B6Rm7vBYVa apo m (a stelae) in Jim of load nowor fo mater efPear Sehuehmpn and Annie E. gahV IM1006 hie wife, which point Al plan a comer of other Lads now or famady of Peta Slabodbanus ad Annie & SrLoduam, lda Xft tbaaw *UMWdly WWA told Loris of Pelts gohuoba rom and Annie 8 Sahuahman, his wife, a dL4nct of 10 feet he a point (A staler); Mexico anahwu* sloog.eaiQbpde, a distaace of 19 list to apoloto ant); Sam 0111 AWS the said lands a nt"dly, a distance of 172 K Ra to a polar hr Had of layfa Vow or famaly of H. IL Goodall; them wWhwardly along bads ofda said H. & Oaabali, a db mow of 73 hot 3 hwhas to a point (a stake be line of left nag's Masterly of b(ahla Long and leads now or formerly of John Memo* thaw. westwoolly #u Leads of dsaild-14" Lang ad be* of the mid Jahn Ebmde, a d(stanoa of 1'14 feet a a point (a aLhe)1. lfae of lands of dw said Marsball Z Harkey and trace V. Hurley, his wife; thence rorthwsrdly along said lads, a distance of53 hot 4luehss to a point (a oLke), the Place of'HEGI)MG. AM 'am mR S feet Para SahuGwa and Annie &.Sebtcomm, his wife, =W01, ,1945 pad reCOtdtd m the Office Rift And Grant; V. Huft, hie w1h, by dad of the Recorder ofDsede for Cnodwdsodod County in Deed BaA r. Vobmw 17. Pegs 122 .flat that aanin la of round Siouan In Middtem Towaship, Cumberland County, Paneeylva)s, bounded and d6arTw as follows: BSWZW G at apoiw (a wake) in gas of other hands ofMatabaii E Hurley and Or= V. Hurley, We wife; educe Votthwadty along aid other laahy a didanae of2o fast a WAN to a per Human °atwadly 11101W hells now or formerly of Peter Soonebma, vildowey a diatmce of 60 fe0; thane mWomardly by the mama 30 feet to odw leads now orf0®adyofbbowl $ Healey and Orson V. Harley, his wife; thane weriwan* by Mid Ian& 54 fee In a pduS theme by the W41N ualkwudly 19 feet m a point the= by the memo, 10 feet to npoint the place of HHGINNING. 17 etlali,635ma .= Sea-15-2004 09:14am From-PREMIER ABSTRACT +243 3390 T-808 P.010/016 F-891 llltPi'C 1LIS ADDOaDUta 70 YOdt701A0YlJ?DOde SlU87th dr fAVISBDB. 2000 wells hmma lrma'rdModyhmm8ms_pa+fyivermy ddl hW:gtmot 799C ddqos ADO pdhholimnd arMadopna dw 700m 9wderdOled (ma b app lnwsp4Nw (l^ NORTOW 'Nem9m 71RLIA0'! TcADI3'AL NOR77A4R CORPORATION No •Imd?) aldreerdr rdarwmt me pop"i b W rWebp Oemuaod ed he19rd se 3471 SPRM ROAD, CARLSSLB, pMWSnVPI 16 17017 0`asaaYew h sddhlw b dw anse as sad gnewtws a:de In dw &pyiy bwrorm, lsee?vr mil Leda AleMetr'e p rd?saa: 1. U do teaaly lud mant h A domed usapte PNKAAgnm UAhta fowr , am dw Seem, omdded.^Fepawd orFrbdpd rdhomme bum" b badubpopy7rw dome p praalded b eq p+g4'? RNaeraaed heeweeWaaaLLlbe Nam. 2, T. port4h d di, $w4* Fpwmm dhl0ed, 'AppiapM'ar mq w, y 1!a7rwY^ JP."W M a .r Pyrow.^ h edam b W w9hgd M ?Nbnma otpdrmmu u y to New. la?wwd to New. p. UeYrproalbhod by epplbeblaw', tlpppetwphaady40xiw NWWA*eaddw,'AOWW&Ibt 11. vidp?ewoaRerr FammRw T?:hsadM mm; J, aupp'"Rewal a p" dwJORWNW? I:oe 'A *wUy,I." edy Valdes bow"pq'new in haarmff aorta wand rwdabtuopud order 950 NOR and 96h pasdy bwumaal. 0 M on rpplludaa of Ind%, iw or *nn Y tardiw Wopdw Oowwed to do amw m do dW a b oId9M 4'M Pdpwq Y lenad, alas w Yore pdklr IorAq du 6opoleP rd mq:ormpw w dm Ngpa; w CD Sawpaa but. ZWO my pyprp nq*W by a prier soydpe, deed of bad, 4wd to eewge deN w Opw em.YOy bep®wt eommbdap w dhgft mr popww w am p bap sly ad& ptwlre w Wrmod h np soda m OIK ded of nab dud o'n am"w adar perky 4wbamea hd a dRau.{ dsr pupmg7 at M Ally epnw rial =6 or hbrmnhu dwe to Luhd by aswaer N epaeNaa VA Banaaw^o spplknla far the ban wNpwd by do Mae is She w ddwdmt in toy wmW *pP4 Sandacr e0wa tla: Aupany tube mW meomwdoawkh dq algalwdrdy.' a. For a teat wowed by rent val papwgs . i 7be a0daybWwdpw4s WM w owed of doperalto ordo ywmiy bm[mumemman, 9Rdrre w elleamdy'ledaup9me haled:' • MOW rime pa my RaMmim mdOi%Wftd WO In wuwmla with 911, madppe.' mama,uw aproewww•rmwpa M1Malew M ? /? C? cul NQ .7+93 Sap-16-2004 09:14am From-PREMIER ABSTRACT +243 3390 T-909 P.0111016 F-991 4 {apsp Ys4fta idwwlp 6tdmdal4w lWswel •NO!'TC!<YQ 10g1lply,9?, ! IR7W{g1'AHO TEAT. ,PRC!l9RTT 191N 3fAf1YG98i 1amTIpM AD100F A N6 q}WIp.1'AM W MY 1]lalT TO ?>T M'711118 am R IIl1R7'4Afi6PVGLUN7laglBl'' i777t R{¢pal-t7p CI.AnQ 1tAS8D 9TONT n hWATOAW." e. Hths bank ladza t b a mw "1J1wbr Pick /pint lam =saw. &M dm adYebp OPSW VaNa W ww1m 3aaampN by aPpIWPk find W now Aw. IW OuOy+mm DOW ad atWsq=' 0m Pmsblsa am PeapVW 1.3.7. 1a and 23 sm ds%W 61 aft*W. S: to ptrignO of dm #nno* bsbmamu OdW. 41dtr or IY hspmtr ar ¦ BwdkM Iatmam WBanw . Is xWOWWbg ioftdo ooddWab a rlnrldem bw rks 60 rIMaaNW W PaVPWInOn smarC?sWttd a I" d"If Won IW ." r 3 It ban b ax pump in an no of W DUAL 0. F rraa laiinWOMW tdpepmy, Ifdn3smdp? Ypnm 30t7, hsbd mdl8 %"A IIah6:.0Yydw .R "m !W aRs dtOaaki: WWW W W1 P RWgra t but mt rlmlWw W, Vassal" 4atkn4a'' hrMk W nun Oven" by smikok Yw.• . A &"dos. me'pin;drspb and w, -Aft"MW FW%- b ddsW to b W&W. 7. Per afOM 11=81 by Ginn 1W MOWQ, dm asa4w 1o" bslMll anu dr tq'd Oervpdm ss I0sof 161 OWA* WWam m: 'fhb mmplp Is ihm Won on pYtmy raodbba. -adsnty c"dm- is debw in atnlso !303.14 of the Rmbed Coda and paaldm paawpY =m it Rmm?m pigs aw.pl smeMWralau and 6umswsalurhv hmrdl anddmd 0u r f?4ww,dlmObWOMPUM hwwma awdv", d. Oar a 1splaobaN dy Saar Ood4mrad pmpany: R ms Samdry Ym=wpat Y Potm 301E de rrsA smnm r dr Pmpap6 amWtl,'WsiBea,• IN dd" R 01 pk0dy bmmsW Y Poe 3111 dm PIW* WYJ 4 •Wdrwr f VJ& r A"ppWd,• Y dddr. 9. The puv&,Vb of On Seadp howmat wdd=d. 4aw TIM dl r TW amply h sh"MOOLnaap' W' WwddY %ffW 4p'L1ry Spra%la ," Is bmwded by 69*4 dm OM /puma Wd uyldup It wild CA f01faw1aS Im~ •TW 39mty bmm WWitW a1WWd by ft" Yw 04, 86s touO OR WoMm with ar ma" Mkdn aft Word Yw n mplada proebp Isde, dm Imp r drpwbddsw In whW dw P1apa y is h."v wORd3ATd ADDID"M TO OMW 1mwltAmd alwASltmr aaea.ty tmtabmmrr auorcpwMp.annvrpm m.wOO.aw aw1K1 pod im"a m 1 e N 1 Sep-16-2004 09:16am From-PREMIER ABSTRACT +243 3399 T-606 P.012/016 F-991 30. Kme Semdq nlmmMaLaaMmgM wJmmrpmiryeMryhuafmw,mmapwpgA6aldM .rr bmammm dd aaMm 9PAMA l 7i mr> M-gf W 7'AMT. aamwr ".` n wilcoMMM 0 d a m = as miou g .ay, mk laww.aq rq wd mwlwftd d1M twLmmtl l• m WAR umdftq hmmmmmw as c'wf.v.+ lw I m WAI a vfbi a)wl f W. advlfmr, ac m A. ..hr y pmlWd Lm. , wlvr l.lfaw awnwmrl r a tf Aw w which pav" eamp M M ,br NP % wa MM Nnrt. mM fs. Yd m .1 M "d ImM Amt , awmi ON wma.ity a> aOtrrLgm? Pf•P+q• mmweylmdbrmamlgahgwtmm aam r. tlllMm Mmbmhdfbfil v,wbthw vdlmemymflwdmmlq, emu of.yt.r dm WAIr.+am 4a0.. no Andmw dmd i.drhtMmm.m mM.md henry' . H. A@ I JO.ddmdmmmlmmadq?ohvmmtmfaWre •aw.w Iway f1dw.NMlr male, am-chol., f.tmmmpr Nlr eaaaigLwnmw.• m. lmsmr wuw ? If dw bm lhavw hr b1d kb,*W Lava wlw Off aph.ww for lsmeaar m w.b pgmmnm m I®dm br wm eaaw awm faNtmad a b w Nor tamlq bmammm mwlmd. dkol* 0 lAs, wrrm iff p m rbmw - ! lmmwrmbawswmawkmm.afmm mw pmw°" w0d mi. v-Am plr lp tm ?afAaft m? no maw N UrwmMwwrohmatly pp cokjw. Lmdwlmmlw lhedlhtm IpdMlMaawM mob ;dM, brTfffis mil eoq'lfll OwMeow N and 41w.w hw and " Ohba 1..m and wimb m. Om. w mw buymmadm eaw a laeawa by I MAN, Lady plfavM lWb mi0 twem*wO Lmdw did W lmOM comb wmmw aoMwmme..dlMeruvwmM, N rc tlr p I mgmam mmm.rmmdmpgwArm7.Mef r peavwmd Aamft a4 Ow pefwldme eemgpvpY N Of amdw bm 7 t eadddm, vPwdelAWnmb Pfam••m (r 7Smf and AsnlfaM' 1f0 bis m mu ll(.wandalk". aRdd. l7. Ap.W*4MdrdtodwSM,fiykw umwmPmadwm ROAC6PLACmVORMANCtt. UNmfammwhspm.m'6YMyyplwNalaw, ife.rmwwdw s^'^ "P .. faImdef wM whmam of mw.mm wvmv W MW WN df Ww.md mm h mgww Iblmadte pooh. This mewfa Mir. bog mfecd EKI geibp.won www. Tiff wmw "[mdv P.dmf. coq a per asp mdaiw mw mmm WM.1wa dwm mm be mdd 4pwa ademwer In awmMm With m. Prampq, mamwe My UN aatl efq mmlmmparb w by Leader, bm a* &W PmWmd lmda wim away dMt DW hr OW" do wq" mafagm lflwdm Prrheemm mawwwmlmrM?1°?' Dm.wmw0bmgmmmi'br.meem Nam N come r kaarmm. bml.dlea t mm do to a• eb "'beds mm mw m k mf ,m% %M me and *COW of afpr mrPm to k I w hew bgwm h*COW N dm mlmemme ? ammmpa, M Loco bb ardor or w plmmb l do m m. mmf N p1wad mmmmJ. aamamdAMndaN 1 be WA i"fdmm , bd,,atmo imawm, 71w p1m Mdw lagamw.Tmdmmmmp•b. amewam oth.mrm mitm .r coq MlNo mdhwm do* b.adn Ladw*ai be pmebeml bmlmm wdw a to" PWW ft am am wwww lmfe~j imdivw..ihummmd.mmq.• . m11mmU14ufrmra.llY IfOTWfaT ANmlfa.dAl dM1mIChaO'ma•mmrlwY XNMMMf M1fm V ?y0y36+3Jfd? r i i Sep-15-2004 09:15am From-PREMIER ABSTRACT +243 3390 T-909 P.013/019 F-991 14. Apopwdt rttdddw Wiwwb?hWlNWwe4WW •Ymd4mdw*FUWNkdaef de emgwyeetlewrmaewywewMMddwlMmmwmdbmmwNd ra Wwmrmwq.6mnpM apwtdda w'""a ydeewwnld.padfia aD a mpw Is =.kV wM5 Ladw wdrr m "I"4 w a u1M Me uWq ud ?..,` amOWMfilWl Vpr"Mb(s R{sdoeiwroplwud Rynn:. IS. If m ApMO&W RM AMw r mmnM is mmdwwWw w*qm droetN Mmnmew. W mlw r - mmwddb: toddogw ON" Ed" 7rn& mf*64VA" W&X"p "&wwlr llwwmw." and MmyMYww4wtllyd,'er•wmellmM mmeeMmfitM b)wlM Craw dm thm 9.8775 $ 0 %..ira Clmmpm," W rm.rdrweae •NS Mremewn Wlwvrr Mw 9.• Ifi. If W Saadq ie"wmt r rJpdermwrpq? YtaFpwtraaHYr?Ywir wp r voided m dmmpbm mlMdedpwateummw. Aqr w.*PWVMi MImf AYAdiwdmmMmM "Ww we1LS dm"ewwi by W Do mm um fW6mwb Lwlmm caaarm mYwwTATlmmtwlWm lM IelANO wtmf4uw MtwrM?mofaVmrcmmwwr 9mmmC memw-mlOmTfe"m w.wtew. m...• 1MM1535m .7% Sap-15-2004 08:15am From-PREMIER ABSTRACT +243 3380 T-908 P.014/018 F-891 AttMbPWANI.$ HATS XWOM O.mdRt iMaW dAAid (Aaaa *O b 7ka WAR Rant JrOwO -Mok C+00 TMAMWAVAMMOM b and h b,*Ood kuwA dW Mim od amod 00 i9th m10? WA=Wl *4Pk% Amd of T"m? 6amd4 Dmd'Mm'SamO'mwdme odd wa Ar oaimiOyWwbwAad 007admaa9m ?AOM*ZORUN061-MM9M AU=QM CAPZVIL M R20 = OW%Odom adaama us ad waded dwrWall'"a"6 ON hoot o-"rdlanmd a 3471 SPRYNO WAD, CAPZZWA, PUM MWJ= 17017 'viyawWwY TSMNOIiCi01•ICA4Y6lIe0Y1?OPRAGLOIPNF]d01?C4A[FOlISY'1?C5?R'II( i' RATS Ado) TM MOMMY PAVAMV. T86 ROBS a.M= SIR AltOt 2 286 Aanow6R'S Dn&ug' mas PAN OMAN= AT ANT OW TM AND T88 KAM M RATB'l'is SOW WW>a M1mP PAY. ADD IOML COVWM M 4 dada m W Im M as a MMM Wads m W sacamr kwmW.6mmevad Ladw VAGO mmw aN awm r had-- A. DrDRPBI' RATSAMMMVZrVAY6MrQUNOW 71m Mft"ffA *ra MWRWmamMae 10.075 c Tw Namprdadam AKrrgaW W Wow we ma dM paddy wd.daM, m MMU . . t Df!'amp RATS AlO)MONfW.Y PAYMV7P CBANGfB co tmd IoY wwyy WyabmpaW 19t dvd 88Pa8NBR1. 2003 addm dradgamy 6th mml6a?mapx.SrAdmaamw6kkm6'bo m"WAo 5awmadw' 'Ckmw Ow.• olmmda • . B" a "ttW Omccmp Do,IVtoo" mm alato WMadaa Odm. 7fe'mra' M dm amy. a Wmalmk AINmd o for i m Mk Vd.-4Ww4W WdW.iW 4aad W W Lamm made ?,••?. ('LAAr'},. a µMddlr7ma wa0/maia idw"L 7* AAmmer Wdw Odard mPaNaradW(In+ N m IOW n WWk VA Nam RWda Wt tlmam a m Wdu 00 h mmad Apod mAft 710 MW MAMmWW" w"doof hA*V6 AND 551100----- - paaR6 ( 6.650 %) m ae pmwmapmwp maa, adw dim us), Md* &P a W ratwu sa Om amaa hi ami w hi a44a K4m bow, prNyiO alma p Da, dia dadodaa amaon wrp m my wpm a" em vi ). W a d 0 Om6e Dam. . I'aa Ddieadaamlw W mx asmmddyplp'mW tlut wad InmdOo na a mW Mmaparta w W dma In =dmrram mPrdadmaw a DAawd0mm1WIa W dMoNdly o ow D m ra acgwlpgmrm.7la AAAlrardmtllldaipaAOl6aWwwamwt Am ml wanda7tAS?wr?MSU?rtiD?aam:dMnDevaaa r..swcw w?>+a?wm?mw7swAw Alma'rJmmNaymyr aNq`• mrrMu W6r aariaaA wd++ 1 l? . a MM'f,?$tdOL .? I Y, ' . Sea-16-1004 09:16am From-PREMIER ABSTRACT +143 3390 T-906 P.015/016 F-691 04 tidyas Ift"ot RW Chow q 00pd , tr 9.1175 %.7bpwW%w.xWlUwox poor 7dayaksChop Due iyawo am CMR...-• yip,{ rwIW. M7 `tue+las rle tkuP'MO' is. 7$ .MYInY?sbe?/i'rY edb . 8.875 M. 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Eenooew eMepb and Was m the ems nel ereamb owdmdle pool I WA R of deh A4mwwPJ WaW, nwa Zino anc Antes aeeren COMMONWEALTH OF FENM"VANIA r. 1,816 COUNTY OF CUUMLA" t On thiy the SM day at AwFON 9000, bake me, On uWxgaad mow, pam many HWmred CaroW Id. @mYHsry leeawa to me toe rtl7faaccttaop ly p avail to be the pasm whw hems In M kwasibtd to the within Iaetreaeaat, uM sa wMedged that *be sasostaa the ame fop the pmpwa thseln omtateed. Sep-16-2004 09:15am From-PREMIER ABSTRACT IN WTrvzW azzatMaE. I hereto net my head ahd •afida eeaL NUMMALIft waaytts MAm-aAram9lRA4Me Mama MM GerUPJm In7WVALbataaarJaamtW•Mre pedb _ ... _.. _ IeWYLLMYhR..Me Mfre rwealldlM :ORIGINAL ADJUSTABLE RATE NOTE (LIBOR 6 Month Index (As Published in The Wall Sheet Journuq -Rate Caps) THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTF.RESTRATF AND MY MONTIILY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTERESTRATE CAN CHANCE AT ANY ONE TIME, AND THE MAXIMUM RATE I MUST PAY. AUGUST 29, 2000 BENSALEM, PENNSYLVANIA 3471 SPRING ROAD, CARLISLE, PENNSYLVANIA 17013 IPmpetry Addms9l 1. BORROWER'S PROMISE TO PAY In return fora loan that 1 have received, [promise to pay U.S. E 64,800.00 (this amount is called 'principal'), plus interest, to the order of the Lender. The Lender is ARLINGTON CAPITAL MORTGAGE CORPORATION 1 understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called ft 'Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 10 . 875 %, The interest rate I will pay may change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Sermon 4 of this Note is the rate I will pay both before and after any default described in Section 7(B) or this Note. 3. PAYMENTS (A) Time and Place of Payments 1 will pay principal and interest by making payments every month. 1 will make my monthly payments on the tat day of each month beginning on OCTOBER 1, 2000 1 will make these payments every month until 1 have paid all of the principal and interest and any other charges described below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, on SEPTEMBER 1, 2030 , 1 still owe amounts under this Note, I will pay those amounts in full on that date. which is called the "Maturity Dale." I will nuke my monthly payments at 2 GREENWOOD SQUARE, SUITE 200, BENSALEM, PENNSYLVANIA 19020 or at a different place if required by the Note Holder. (B) Amount of My Initial Monthly Payments Each of my initial monthly payments will be in the amount of U.S. $ 611. 00 This amount may change. (C) Monthly Payment Changes Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 of this Note. 4. INTEREST RATE AND MONTHLY PAYMENT CHANGES (A) Change Dales The interest rate 1 will pay may change on the let day of SEPTEMBER 1, 2003 , and on that day every 6th month thereafter. Each date on which my interest rate could change is called a "Change Date." (B) The Index - Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the average of inter- bank offered rates for 6 month U.S. dollar-denominated deposits in the London ('Libor'), as published in The Wall Street Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in which the Change Date occurs Is called the 'Current Index." If the Index is no longer available, the Note Holder will choose a new index that is based upon comparable information. The Note Holder will give me notice of this choice. (C) Calculation of Changes Before each Change Date, the Note Holder will calculate my new interest rate by adding S IX AND 65/100 - - - - - percentage point(s) ( 6 . 650 %) to the Current Index. The Note Holder will then round the result of this addition to the nearest one-eighth of one percentage paint (0.125%). Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date. no Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid principal that I am expected to owe at the Change Date in full on the Maturity Date at my new interest rate in substantially equal payinems. The result of this calculation will be the new amount of my monthly payment. (D) Limits on Interest Rate Changes The interest rate 1 am required to pay at the first Change Date will not be greater than 13 , 875 % or less than 9 . 875 %. Thereafter, my interest rate will never be increased or decreased on any single Change Date by more than ONE----- percentage point(s) ( 1.000 %) from the rate of interest 1 have been paying for the preceding 6 months. My interest ram will never be greater than 16 . 875 %. My interest rate will never be less than 9 . 875 %. (E) Effective Date of Changes My new interest rate will become effective on each Change Date. I will pay the amount of my new monthly payment beginning on the first monthly payment date after (lie Change Date until the amount of my monthly payment changes again. MULTISTATE ADJUSTABLE RATE NOTE.LIEOE 6 MONTH INDEX (AS PUBLISHED IN THE WALL STREET JOURNAL) - Shvle Famify-Fannie Mae 11n11o2m Imtramenl Foml 7520 6M IIMUbE.MJ. On1 tll<6.11929 A9eINJ (F ) Notice of Changes v ` The Note Holder will deliver or mail to me, a notice of any changes, in my interest rate and the amount of my monthly payment before the effective date of any change. The notice will include Information required by law to be given me and also the telephone number of a person who will answer any question f may have regarding the notice. 5. BORROWER'S RIGHT TO PREPAY 1 have the right to make payments of principal at any time before they are due. A payment of principal only is known as a "prepayment." When 1 make a prepayment, 1 will tell the Note Holder in writing that I am doing so. 1 may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, ilium will be no changes in the due dates of my monthly payments unless the Now Holder agrees in writing to those changes. My partial prepayment may reduce the amount of my moraddy payments after the first Change Date following my partial prepayment. However, any reduction due to my pullet prepayment may be offset by an interest rate increase. PREPAYMENT RIDER ATTACHED HERETO AND MADE A PART HEREOF 6. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collated in connection with this loan exceed the permitted limits, then: (1) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (eft) any sums already collected from me that exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal 1 owe under this Note or by making a direct payment to me. If n refund minces principal, the reduction will be treated as a partial prepayment. 7. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charges for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 10 calendar days after the data it is due, 1 will pay a late charge to the Note Holder. The amount of the charge will be 5.00 % of my overdue payment of principal and interest. 1 will pay this late charge promptly but only once on each late payment. (8) Default If 1 do not pay the full amount of each monthly payment on the date it is due, 1 will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that If I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the rut] amount of principal that has not been paid and all the interest that i owe on that amount. That date most be at least 30 days after the dale on which the notice is delivered or mailed to me. (D) No Waiver By Note Holder Even if, at a time when 1 am in default, the Note Holder does not require we to pay immediately in full as described above, the Note Holder will still have the right to do so if 1 am in default at a later time, (E) Payment of Nate Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its coals and expenses in enforcing this Note to am extent not prohibited by applicable law, Those expenses include, for example, reasonable attorneys' fees. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that most be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the properly Address above or at a different address if I give the Note Holder a notice of my different address. Unless the Note Holder requires a different method, any notice that must be given to the Note Holder under this Note will be given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if 1 am given a notice of that different address. 9. OBLIGATIONS OF PERSONS TINDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surely or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 10. WAIVERS 1 and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. 'Presentment' means the right to require the Note Holder to demand payment of amounts due. "Noice of dishonor' means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. It. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given no the Note Holder under this Note, a Mortgage, Dad of Trust or Security Deed (the "Security Instrument"), dated the sane date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises that i make in this Note. That Security Ins,trument describes how and under what conditions 1 may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described fls follows: MULTISTATE ADJUSTABLE RATE NOMLISOR 6 MONTH INDEX (AS PUBLISIRD IN VIE WALL SHREET IOURNAI) - Sinsk Family-Famde M. Uatform lostrYmed Form 3520 6190 aN1253),C4mM 12148.11920 PW23 , Transfer of the Property or a Beneficial Interest In Borrower. If all or any part of the Property Or any s 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 Under'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. Lender also shall not exercise this option iL (a) Borrower causes to be submitted to lender information required by Lender to evaluate the intended transferee as if a new loan were being made to the transferee; and (b) Lender reasonably determines that Lender's security will not be impaired by the loan assumption and that the risk of a breach of any covenant or agreement in this Security instrument is acceptable to Lender. To this extent permitted by applicable law, Lender may charge a reasonable fee as a condition to Lender's consent to the loan assumption. [under may Alm require the transferee to sign an assumption agreement dial is Acceptable to tender and that obligates the transferee to keep all the promises and agreements made in the Note and in ibis Security Instrwnent unless Lender releases Borrower in writing. If Lender exerciaes the option to require immediate payment in full, Lender shall give Borrower notice of acceleration. The notice shall provide a period of nm Ins than 3D days from the date the notice is delivered or mailed within which Borrower most pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. i (S"n Lcmn C OLYN SHI;A Bommrer Bormwrr (Seel) (Seen Borrower Borrower (Seel) (See) aormwer Borrower (Sian Original Onlyl nxfto?flttfolNOrYfPpI?r001NM? 9r 5'.6'tt4t n- Vf? 9. Rieman nano ASSISTANT n MULTISrATB AD MABLE RATE NOMLIBOR 6 MONTH INDEX (AS PUBLISHED IN THE WALL STREET JOURNAL) - Sinsie Pemity.Fanrde Mae Urdrorm IutrmneN Form 3525 6)94 IINIifA.R'.f.INi e2746.11929 r,p rary EMC Mortgage 7104 5400 2100 0969 8862 Corporation June 02, 2004 `0002685067' Carolyn M. Sheaffer 3471 Spring Rd Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving vour county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing can call 717-780-1869). This Notice contains important legal information If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta so derecho a continuar viviendo en so casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediammente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para on prestamo per el programa llamado "Homeowners' Emergency Mortgage Assistance Program" a] coal puede salvar so casa de Is perdida del derecho a redimir so hipoteca. HOMEOWNER'S Carolyn M. Sheaffer PROPERTY 3471 Spring Rd Carlisle, PA 17013 LOAN ACCOUNT 7546336 CURRENT EMC Mortgage Corporation You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for emergency mortgage assistance: If your default has been caused by circumstances beyond your control, you have a reasonable prospect of being able to pay your mortgage payments and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Page two 7546336 A TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which vour property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 3471 Spring Rd Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 04/01/2004: $2,338.20 (b) Late charge(s) : $67.20 (c) Other charge(s): NSF & Advances $253.30 (d) Less: Credit Balance $.00 (e) Total amount required as of 06/01/2004: $2,658.70 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $2,658.70, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to EMC Mortgage Corporation at PO BOX 660530, DALLAS, TX 75266-0530. Page three 7546336 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, EMC Mortgage Corporation also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If You cure the default within the THIRTY (30) DAY period, You will not be required to pav attomevs' fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such sheriffs sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of EMC; Mortgage Corporation Lender: Address: Mac Arthur Ridge II, 909 Hidden Ridge Drive, Suite 200, Irving, Texas 75038 Telephone 1-888-609-2379 Number: EFFECT OF SHERIFF'S SALE - You should realize that a sheriffs sale would end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and your furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT • To sell the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third parry acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted under the mortgage documents. • To assert any other defense you believe you may have to such action by the lender. • To seek protection under the federal bankruptcy law. Page four 7546336 EMC Mortgage Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, EMC Mortgage Corporation Mac Arthur Ridge II, 909 Hidden Ridge Drive, Suite 200, Irving, Texas 75038 MAILING ADDRESS: P.O. Box 141358, Irving, Texas 75014-1358 VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. lJ -'4 G 6 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A COURT OF COMMON PLEAS LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND CUMBERLAND COUNTY SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 No.: 04-5043 CIVIL TERM 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING, TX 75038 VS. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against CAROLYN M. SHEAFFER, Defendant, 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 $81,959.09 Interest 1,513.30 9/6/04 to 11 / 19/04 TOTAL $83,472.39 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. RDIAN, ESQUIRE GRE Y jn?tiff Attd ey for Damages are hereby assessed as indicated. DATE: '&u. , ?Cjl 6 G06y PRO PROTHY LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10101/2000, SERIES 2000-3 PLAINTIFF VS. CAROLYN M. SHEAFFER DEFENDANT TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 DATE OF NOTICE: November 4, 2004 In The Court of Common Pleas Cumberland County No. 04-5043 NOTICE, RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims se 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 Bar Association Lawyer Reference Service 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 9 r. f Gre o `ry Jay? rdieaj, qt-ire ` 13 dus`trial l vrd 1S loor, Suite 101 Southampton, PA 18966 (215) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tomado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en corte o escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o !lame por telpfono a la oficina, cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" C N q', _ "1::; ... .. -Tl LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD I ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER VERIFICATION OF NON-MILITARY SERVICE GREGORY JAVARDIAN, 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) Defendant, CAROLYN M. SHEAFFER, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers' Civil Relief Act of Congress of 1940, as amended. (b) Defendant, CAROLYN M. SHEAFFER, is over 18 years of age, and resides at 3471 SPRING ROAD, CARLISLE, PA 17013. (c) Plaintiff, LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, is an institution conducing business under the Laws of the Commonwealth of Pennsylvania with an address of 909 HIDDEN RIDGE DRIVE, SUITE 200, IRVING, TX 75038. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. ` GR]*G Y ARDIAN, ESQUIRE C) r'' C) j co , w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5043 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 Plaintiff (s) From CAROLYN M. SHEAFFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,472.39 L.L. $.50 Interest FROM 11/19/04 TO DATE OF SALE @ $13.72 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $113.70 Plaintiff Paid Date: NOVEMBER 30, 2004 (Seal) Other Costs CURTIS R. LONG Prothonota s?/! Dom. o REQUESTING PARTY: Name GREGORY JAVARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 Deputy C COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/ 000, SERIES 2000-3 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING, TX 75038 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due Interest from 11/19/04 to Date of Sale @ $13.72 per diem $83,472.39 Subtotal (Costs to be added) 9455 AVARDIAN, ESQUIRE r Plaintiff 69 1310 Industrial Boulevard 1 st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 I? I 1 cri / v • ?V /1 ? W ?/`? ?- a v p -C? -, TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 % feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NO. 21-12-2958-015A. LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 vs. CAROLYN M. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3471 SPRING ROAD, CARLISLE, PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 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) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities. Z/ G O /JJAVARDIAN, ESQUIRE orne or Plaintiff November 19, 2004 C7 r.? ?: .x- rtti r "+?• c?a rr? 77- q4 GJ LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM vs. CAROLYN M. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD, CARLISLE, PA 17013, is scheduled to be sold at Sheriffs Sale on MARCH 2, 2005 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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) 942-9690. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 %2 feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NO. 21-12-2958-015A. c? IC) r"? ?? `t7 m Lw% LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A COURT OF COMMON PLEAS LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND CUMBERLAND COUNTY SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 No.: 04-5043 CIVIL TERM vs. CAROLYN M.SHEAFFER AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and-regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 CAROLYN M.SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Dated: GREGO AV IAN, ESQUIRE Attorn or Plain iff a 0 mmt`"?? Z nAn Q.d? m 3 v O n go U fir.. r v M.a y"ry C3, og N irr A m Z ny? o m w g A b% g A m0 $ ffi e 9 7 7 ?. any f; pue I ir >H S7 a lr ? I t ?'?a a.njx m E c ?' I. c?B?nol ? g 3 c lai C L? _ YN u G . Y J'' C` E m 0 y C M $ E v m ''m °' C a?xN " ?+ S4 (1) N H o S ci oo? p 6 - e E II , g B a ?j : ti . C 0 Q S7 -i m ?$,8 I ! w. Sa N ? ? u"UxuScl G U S4 o: b w a J ]o- _ DD- a-Q L O " ;sz ?C ? O O? Q N L 2 m t a N Lh u 34 ?O W N mwrn 41 0) U -1 ,I' Q) Q 0 N > O F?V N -'I M ?'°LSTCyya R' 'O (Q O U m O 44 O ? RC O q w 4-1 (U vi a Pa ?2 ?PE? . 44' y N '? GCi Z q ?I -q?? N C9 02 y3? rt? O? q Ee aPA v m ro ?? ? r Q `i v O qM U FM UmU Pa Id n w K 0 c 0 m W N u a u a d d wr a O d c .n v ?4 o? N J 2 LL n n m w a ? 0 m ? a November 19, 2004 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CAROLYN M. SHEAFFER PLAINTIFF/SELLER: LASALLE BANK, N.A., F'/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 DEFENDANT(S): PROPERTY: CUMBERLAND C.C.P. NO. CAROLYN M.SHEAFFER. 3471 SPRING ROAD CARLISLE, PA 17013 04-5043 CIVIL TERM The above captioned property is scheduled to be sold at Sheriff s Sale on MARCH 2, 2005 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You may hold a judgment on the property, which maybe extinguished by the sale. You may wish to attend the Sheriffs Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. V rely, Gregory Jav dian, Esquire Law Offices of Gregory Javardian 1310 Industrial Boulevard I st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 '1 (-J i % s l \.. (J? .J ? ,.? ?? ? _ ,_ x?- ' ,„ <a _.- ;1;. ?? ?:: ' ? , i- { .? ? , ?.. SHERIFF'S RETURN - REGULAR CASE NO: 2004-05043 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NA VS SHEAFFER CAROLYN M SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEAFFER CAROLYN M the DEFENDANT , at 2020:00 HOURS, on the 14th day of October , 2004 at 3471 SPRING ROAD CARLISLE, PA 17013 by handing to CAROLYN SHEAFFER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.70 Affidavit .00 Surcharge 10.00 .00 31.70 Sworn and Subscribed to before me this y day of A u u? 02 t?. A. D. rothonotary So Answers: R. Thomas Kline 10/15/2004 GREGORY JAVARDIAN By J. Deputy Sheriff LaSalle Bank, N.A. et al The Court of Common Pleas of VS Cumberland County, Pennsylvania Carolyn M. Sheaffer Writ No. 2004-5043 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 07, 2004 at 7:10 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Carolyn M. Sheaffer, by making known unto Carolyn Sheaffer, personally, at 3471 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 same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2005 at 9:49 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 Carolyn M. Sheaffer, located at 3471 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 defendant, to wit: Carolyn M. Sheaffer, by regular mail to her last known address of 3471 Spring Road, Carlisle, PA 17013. This letter was mailed under the date of December 29, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Gregory Javardian. Sheriffs Costs: Docketing 30.00 Poundage 20.29 Posting Bills 30.00 Advertising 30.00 Law Library .50 Prothonotary 1.00 Mileage 7.40 Certified Mail 4.42 Levy 30.00 Surcharge 30.00 Law Journal Patriot News Share of Bills 404.90 415.66 30.72 $1,034.90 Sworn and subscribed to before me So Answers- This !5-`f day of ?jN • ?? _ R. Thomas Kline, Sheriff 2005, A.D. ro onotary BY Real Estat eputy J,5t Ck y'00'7 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER • THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 VS. CAROLYN M.SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3471 SPRING ROAD CARLISLE PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M.SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 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) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. G GO JAVARDIAN, ESQUIRE orne or Plaintiff November 19, 2004 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD IST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M.SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD. CARLISLE, PA 17013, is scheduled to be sold at Sheriffs Sale on MARCH 2, 2005 at 10:00 A.M., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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: 2i 15) 942-9690. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a comer of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 %z feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NO. 21-12-2958-015A. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5043 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 Plaintiff (s) From CAROLYN M. SHEAFFER (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 $83,472.39 L.L. $.50 Interest FROM 11/19/04 TO DATE OF SALE @ $13.72 PER DIEM Any's Comm % Due Prothy $1.00 AttyPaid $113.70 Other Costs Plaintiff Paid Date: NOVEMBER 30, 2004 CURTIS R. LONG Prothonotary o? ? (Seal) /1yl? By r/l/Ji Depu ty REQUESTING PARTY: Name GREGORY JAVARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 Real Estate Sale #24 On December 01, 2004 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 3471 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 01, 2004 By'D Real Esta Deputy oil =£ d 0£ AN 4001 3GWfl d33183HS 03 Pi 10 30 JA00 N 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 swom according to law, deposes and says: That he is the Accounts Receivable Manager 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 18th and 25th day(s) of January and the 1st day(s) of February 2005. 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. / C/ PUBLICATION .............. I..............? G .................................................. COPY Sworn to and subscribed before 23rd day of Feb; A.D. SALE #24 U-NNOTAR ry 1. Russell , f Harrisburg, Dauphin Coprygsy p LIC mmis on Pxplr &UPPAi expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE / ONE COURTHOUSE SQUARE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 415.66 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. By ................................................................... emr o m,,r`o' o Comm bud wat Ina Ye?? ,gyp;a4o 14 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 14, 21, 28, 2005 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 charact- of publication are true. Editor WOMTO AND SUBSCRIBED before me this 28 day of January. 2005 ,1 REAL ESTATE SALE NO. 24 Writ No. 2004-5043 Civil LaSalle Bank, N.A., f/k/a LaSalle National Bank, as Trustee Under the Pooling and Servicing Agreement Dated 10/01/2000, Series 2000-3 VS. Carolyn M. Sheaffer Atty.: Gregory Javardian TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Com- monwealth of Pennsylvania, bound- ed and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a comer of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife: thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake): thence southwardly along said lands, a dis- tance of 19 feet to a point (a stake); thence still along the said land east- wardly, a distance of 172 1/2 feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in the line of lands now or formerly of Melvin Long and lands now or for- merly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a dis- tance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground sit- uate in Middlesex Township, Cum- berland County. Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Pe- ter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, north- wardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attomey-in-Fact, Carol A. Chromster, by Deed dated and recorded August 29, 2000 in the office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NO. 21-12-2956-015A. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK, N.A., F/K/A COURT OF COMMON PLEAS LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND CUMBERLAND COUNTY SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 No.: 04-5043 CIVIL TERM 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING, TX 75038 VS. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $83,472.39 Interest from 11/19/04 to Date of Sale @ $13.72 per diem $ Subtotal $ (Costs to be added) ?- GREGORX/AVARDIAN, ESQUIRE Attorney Pl tiff I.D. #55M9 1310 Industrial Boulevard 1 st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 t? (J w Vt l `Y M t C -t h ins .,.. try ? 4 . d CCCG? ,? n ? r fi?? y TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 %Z feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5043 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 Plaintiff (s) From CAROLYN M. SHEAFFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,472.39 L.L. Interest FROM 11/19/04 TO DATE OF SALE @ $13.72 PER DIEM Atty's Comm % Atty Paid $1161.10 Plaintiff Paid Date: AUGUST 23, 2006 Due Prothy $1.00 Other Costs )?AIS . ONG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name GREGORY JAVARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Carolyn Marie Sheaffer Debtor(s) Lasalle Bank National Association, "Assignee", FKA LaSalle National Bank, in its capacity as indenture trustee under that certain Sale and Servicing Agreement dated 10/1/2000 among AFC Trust Series 2000-3, as Issuer, c/o EMC Mortgage Corp. V. Carolyn Marie Sheaffer and Charles J. DeHart, III Trustee Respondents ORDER BK. NO. 1:05-bk-03793 MDF CHAPTER 13 AND NOW, upon the filing of a Certification of Default by the Moving Party in accordance with the Stipulation of the parties approved on February 22, 2006 it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. Section 362, is modified to allow Lasalle Bank National Association, "Assignee", FKA LaSalle National Bank, in its capacity as indenture trustee under that certain Sale and Servicing Agreement dated 10/1/2000 among AFC Trust Series 2000-3, as Issuer, c/o EMC Mortgage Corp., and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriff's Sale regarding the premises 3471 Spring Road Carlisle,PA 17013 and a possessory action if necessary. The stay provided by Bankruptcy Rule 4001(a) (3) has been waived. By the Cowt, 7 Dated: July 6, 2006 B p dradgc This document is electronically signed and filed on the same date. L6SALTE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 VS. CAROLYN M. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3471 SPRING ROAD, CARLISLE. PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every othef 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) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities. 7 GREGORY VA IAN, ESQUIRE Attorney f lai ff August 18, 2006 C? ? n s C5 7 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM vs. CAROLYN M. SHEAFFER CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied () Vacant O Commercial () As a result of Complaint in Assumpsit (X) Act 91 complied with ?- GREGORYffiJEDIAN, ESQUIRE Attorney f lai N ?? G .,,. `? --? ?.., fT r ?? t.:i? ? _ri i t'3 -N . ? r."") CS lf: ?' ? ?Yi {": = _r _ -' : s - (7 _ W: --r? , ? _ { { f T V ? .,.P ? LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 VS. CAROLYN M. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD, CARLISLE, PA 17013, is scheduled to be sold at Sheriff s Sale on DECEMBER 6, 2006 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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: 2211,5_) 942-9690. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 '/2 feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A. I -TI v n o L 6 n r LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. BOX 2675 Harrisburg, PA 17105-2675 Dated: ( GREGORY JA AN, ESQUIRE Attorney for P inti _L 7 "M,9849.7757 21.77 TO: Tenants/Occupants „. TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD 3471 SPRING ROAD CARLISLE, PA 17013 CARLISLE, PA 17013 4 SENDER: TEP REFERENCE:sheaffer, c. PS Form 380 0 January 2005 RETURN P08" 9 RECEIPT Certified Fee SERVICE Return Receipt Fee Reshided Delivery Total Postage & Fees i POS **R'e, le US Postal Serv Receipt for , o Certified Mail 5 No Insurance Coverage Provided y Do Not Use for International Mall `?rII 1 C SENDER:, TEP REFERENIbE: sheaffer, c. PS Form 3800, January 2005 - I RETURN Postage I RECEIPT Certified Fee SERVICE Retum Receipt Fee - J Restricted Delivery j Total Postage & Fees US Postal Santa Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mall 1 I/Q DATE \ti_? SQL ttt 060 8A1 2roga; Ojj ? 6U ? Ipu 1 ioaft ttt 3 ?yy?,ny? U01 WJIJ.1 cKXOAII 1 ?? o / . t ? N ?rrr m C 1 ? W G c > m N r >? a a g6 S 1 c W 0 ) w W o• ? n-? 0 y m CZ.?i o ?4A LL ? .. W O1 .4 y 0 C? fli m 44 W c m q •¢ - U j - ?-+ a z ? n RS 4J' r? U ? RS (S1 i N U ? t0 c F, 0 a ?? rt3 44. m +ri U q O N ,n EmE? a? E+ I I i r O m m? U1 - M M 12+ , W c--I m ? D ? ? , C? +? r 1 44O O W Cy2 r I cH RS r I C) C1 c coo C ?J a U U C4 .'C4. (U -d O W U N O U1 4? l o N \ ?j W W }{' U ?j (D CL I 0 -1 44 C).-?U Ur1 Q 0 1 E-+ c+1U MU aGil. C1, x ao • w o W C, 0 0 E 10 E ~ ? z > Z ,- 1 2 11 Q'JW W V V Q Q H Q ?Q?tn U :DL-- a m :- : 0 ° D LL0Z0 E co L Z a ? U L?Ci7 Q r N M ( O f ? 0 0 H a T - .- c 0 a R m Lo Y ?C CL T r m G. E O U N `o m m 0 0 N Z c0 N LL ti Go M O LL a August 18, 2006 TO: OWNER(S): NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ALL PARTIES IN INTEREST AND CLAIMANTS CAROLYN M. SHEAFFER PLAINTIFF/SELLER: LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 DEFENDANT(S): PROPERTY: CUMBERLAND C.C.P. NO. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 04-5043 CIVIL TERM The above captioned property is scheduled to be sold at Sheriffs Sale on DECEMBER 6, 2006 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriff's Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Sincerely, A , Gregory avar Esquire Law Offices of Gregory Javardian 1310 Industrial Boulevard 1 st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 - r- LaSalle Bank, N.A., f/k/a LaSalle National Bank In the Court of Common Pleas of As Trustee Under the Pooling and Servicing Cumberland County, Pennsylvania Agreement Dated 10/01/2000, Series 2000-3 Writ No. 2004-5043 Civil Term VS Carolyn M. Sheaffer William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2006 at 2033 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Carolyn M. Sheaffer, by making known unto Carolyn M. Sheaffer personally at 3471 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 same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2006 at 0915 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Carolyn M. Sheaffer located at 3471 Spring Road, Carlisle, Cumberland County, 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 defendant, to wit: Carolyn M. Sheaffer, by regular mail to her last known address of 3471 Spring Road, Carlisle, PA 17013. This letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Daniel Schmieg. Sheriff s Costs: Docketing 30.00 Poundage 22.37 Posting bills 15.00 Advertising 15.00 Law Library Prothonotary 1.00 Mileage 8.80 Certified Mail 3.52 Levy 30.00 Surcharge 30.00 Law Journal 521.00 Patriot News 398.18 Share of Bills 15.94 Postpone Sale 20.00 $1,140.81 ? s1?`??b7 ?S O?A 3 ?' ;e? R. Thomas Kline, Sheriff BY Real Estate Sergeant `? ? ?77SB' LASACLE BANK, N.A., F/K/A LASALLE ` NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 VS. CAROLYN M. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3471 SPRING ROAD, CARLISLE, PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 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) Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance PA Department of Public Welfare Bureau of Child Support Enforcement 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 7. Name and address of every other person of whom the plaintiff has knowledge who has arty interest in the property which may be affected by the Sale; Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities. GREGORY V IAN, ESQUIRE Attorney f la ff August 18, 2006 t LAW OFFICES OF GREGORY JAVARDIAN By, GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-%90 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD, CARLISLE, PA 17013, is scheduled to be sold at Sheriffs Sale on DECEMBER 6, 2006 at 10:00 A.M., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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: 2? 15? 942-9690. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 '/Z feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A. • WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-5043 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 Plaintiff (s) From CAROLYN M. SHEAFFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,472.39 L.L. Interest FROM 11/19/04 TO DATE OF SALE @ $13.72 PER DIEM Atty's Comm % Atty Paid $1161.10 Plaintiff Paid Date: AUGUST 23, 2006 (Seal) REQUESTING PARTY: Name GREGORY JAVARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: Deputy Supreme Court ID No. 55669 "W-' Real Estate Sale # 49 On September 8, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 3471 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 8, 2006 By -.r Real Estat Sergeant C 80 :Z d S z my 9001 Vd, "k 3 tt'L 1, i ; tfS C,a .. ?Ja 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 Joseph A. Dennison, being duly swom according to law, deposes and says: That he is the Assistant 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 in the 25th day(s) of October and the 1st and 8th day(s) of November 2006. 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 ............1 .......................................... COPY Sworn to an su scri ed before me this SALE #49 MM Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County My Commis ' Expir ne 6, 2010 emher PAnn vlvpnie ^ gtinn of Notaries NOTAIfY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 U13A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 20, October 27 and November 3, 2006 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. 74 ,-- isa arie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 3 day of November, 2006 NOTARIAL SEAL v LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 REAL. ERTATE SALE NO. 48 Writ No. 2004-5043 Civil LaSalle Bank, N.A. f/k/a LaSalle National Bank, as Trustee Under the Pooling and Servicing Agreement Dated 10/01/2000, Series 2000-3 VS. Carolyn M. Sheaffer Atty.: Gregory Javardian TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Com- monwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a dis- tance of 19 feet to a point (a stake); thence still along the said land east- wardly, a distance of 172 1/2 feet to a point in line of lands now or formerly of H.R. Gutshall, thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence north- wardly along said lands, a distance of 53 feet 4 inches to a point .(a stake), the place of beginning. TRACT NO2: round ALL that certain lot of g situate in Middlesex Township, Pennsylvania, Cumberland County, Y bounded and described as( follows: BEGINNING at a point in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardiy along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or fern alY Of Pc- ter Schuchman• of 60 feet; thence southwardly by the same, 3o feet to other lands no Hurley or formerly of Marshall his wife; and Grace v • ?Y Hurley, lands 54 thence westwar by feet to a point; thence by the same, e thence by thelsamee, 1o feet to a northwardly thence by point, the place of beginning- BEING known as 3471 Spring Road, Carlisle, PA 17013 REMISES BEING THE SAM acting which Grace V. Hum F ct, Carol through her Attorney- A. Chronister, by Deed dated and recorded August 29, 2000 in the office of the Recorder of Deeds Deed and for Cumberan38 county ted and Book 228, Page M, Sheaffer. conveyed unto Carolyn PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A. .-1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK, N.A., F/KIA LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 800 STATE HIGHWAY 121 BYPASS LEWISVILLE, TX 75067-4180 VS. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in.the above matter. Amount Due Interest from 11/19/04 to Date of Sale @ $13.72 per diem Subtotal (Costs to be added) $83,472.39 $ `4 GRE Ir JAVARDIAN, ESQUIRE Atto y Plaintiff I.D. #55664 1310 Industrial 4pulevard 1 st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 70 m Y .. TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 '/2 feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013 BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: CAROLYN MARIE SHEAFFER Debtor(s) LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/1/2000, SERIES 2000-3 Movant V. CAROLYN MARIE SHEAFFER CHARLES J. DEHART, III, (Trustee) Respondents Chapter 13 Proceeding 1:06-bk-02809 RNO ORDER Upon consideration of LaSalle Bank, N.A., f/k/a LaSalle National Bank, as Trustee under the Pooling and Servicing Agreement Dated 10/1/2000, Series 2000-3's Certification of Default it is hereby ORDERED AND DECREED that the Automatic Stay be modified to permit, LaSalle Bank, N.A., f/k/a LaSalle National Bank, as Trustee under the Pooling and Servicing Agreement Dated 10/1/2000, Series 2000-3 and/or its successors and assigns to proceed with foreclosure on the property located at 3471 Spring Road, Carlisle, PA 17013 and obtain all other Relief available under the Non-Bankruptcy law. Upon the order being granted and entered, LaSalle Bank, N.A., f/k/a LaSalle National Bank, as Trustee under the Pooling and Servicing Agreement Dated 10/1/2000, Series 2000-3 shall have the continuing authority to contact the Debtor(s) directly to determine intent regarding the property and/or to verify vacancy of the home. It is further ORDERED AND DECREED, that relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. Case 1:06-bk-02809-RNO Doc 60 Filed 01/09/09 Entered 01/09/09 10:29:42 Desc Main Document Page 1 of 2 It is FURTHER ORDERED AND DECREED, the bankruptcy Rule 4001(a)(3) is not applicable and Movant is allowed to immediately proceed with foreclosure and all other relief available under the Non Bankruptcy law. (P't U. (?W'r Robert N. Opel, 11, Bankruptcy Judge This document is electronically signed and filed on the same date. M Dated: January 9, 2009 Case 1:06-bk-02809-RNO Doc 60 Filari ni moino c!-4.--- 1^^ • - - - LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 VS. CAROLYN M. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 347.1-SP G INROAD, CARLISLE, PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. .., 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 Cumberland County Domestic Relations Cumberland County Tax Claim Bureau PA Department of Public Welfare Bureau of Child Support Enforcement Last Known Address (if address cannot be reasonably ascertained, please indicate) 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. GRE JAVARDIAN, ESQUIRE Atto y or Plaintiff February 20, 2009 N ?? -, i ,._ -:-? -? f _ _?, r? ,?, .. .?-- -.. r.? _ - ? t`?? f; 4: .-?' C`4J LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied O Vacant O Commercial O As a result of Complaint in Assumpsit (X) Act 91 complied with G O Y JAVARDIAN, ESQUIRE A ey for Plaintiff '??' ? ` "' -? -_; -r Y; ? ?? n .m: C:?-D r , r . ?? .r- -_ _?, - ;s . ° r?,? - ? ? , -- -?' := . _ i? ,r LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD I ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD CARLISLE PA 17013, is scheduled to be sold at Sheriffs Sale on JUNE 10, 2009 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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) 942-%90. 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 EVENT 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,, 94. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5043 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., f/k/a LASALLE NATIONAL BANK, as Trustee under the POOLING AND SERVICING AGREEMENT DATED 12/01/2000, SERIES 2000-3, Plaintiff (s) From CAROLYN M. SHEAFFER (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 $83,472.39 L.L. Interest from 11/19/04 to Date of Sale @ $13.72 per diem Atty's Comm % Due Prothy $2.00 Atty Paid $2,231.41 Other Costs to be added Plaintiff Paid Date: 2/24/09 (7jh* C is R. Long, Eonotary (Seal) By: Deputy REQUESTING PARTY: Name: GREGORY JAVARDIAN, ESQUIRE Address: LAW OFFICES OF GREGORY JAVARDIAN 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 ('215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM Vs. CAROLYN M. SHEAFFER AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A") Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Dated: GREGO AV IAN, ESQUIRE Attorne for Pl tiff a W 3 IFL 31 ?o C) +U a ? T f m ? o 0 w 0 C3 n ti 0 w 0 w , w u- m m ? m m ?u U, t7l w ? C3 n 0 ti 0 w 0 r J _ W ? .?y an 7d d O c° Q o rn I ©N 00 .O W 0W O N N LL ? J CD, Y S Q Q311N,n O 02 1 1 M N D U C ? m C N L U C Y mamvo `mom °' °m LL x y t .n co m C H O o v a ? L d ° 4 Z m _ m p v U a m E 'ti ?mmm ? U_ CO {mir E 0 0 .? E U E w m o tp' a? N m O m x c a U U p w_ V ?DO?? m L U ^^ 10 r `a Ol L `n _ m z i I ry• { ti7 ? «i r-1 N a- M M ? M 41 O : U) P4, t` d o ? °? i ' 1 4 cl) 1.4 3 ? o Ln Lf) O M LL W ^d t` O 4, + 0 ? w '? ? O o o + a 0 rn a o k . ul, , c'r1 U W 7 J C6 Iti ?OC) m L d C O M m G 0 M W N V 4 V IL m m c m 1 C O CD O Y c CL a N 01 U_ m ? N a -- o ma m E m m a o? No N cc 7 m m LL d ° c c0 n N CO) Z? ° m LL -6 U) F- :D LL February 20, 2009 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CAROLYN M. SHEAFFER PLAINTIFF/SELLER: LASALLE BANK, N.A?D AR THE POO INGIAONND BANK, AS TRUSTEE SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 DEFENDANT(S): PROPERTY: CUMBERLAND C.C.P. NO. CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 04-5043 CIVIL TERM The above captioned property is scheduled to be sold at Sheriffs Sale on JUNE 10. 2009 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriffs Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Sincerely, Gregory Jav 'an, Esquire Law Offices of Gregory Javardian 1310 Industrial Boulevard 1 st Floor, Suite 161 Southampton, PA 18966 (215) 942-9690 2DO4 MAY i 1 P1? 3? 58 i C S CV"\ l,l In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-5043 Civil Term LaSalle Bank, N.A., f/k/a LaSalle National Bank, As Trustee Under the Pooling and Servicing Agreement Dated 10/1/2000, Series 2003-3 VS Carolyn M. Sheaffer Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 4, 2009 at 2015 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit Carolyn M. Sheaffer, by making known unto Carolyn M. Sheaffer, personally, at, 3471 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 same Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009 at 0746 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Carolyn M. Sheaffer, located at, 3471 Spring Road, Carlisle, Cumberland County 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 defendant, to wit: Carolyn M. Sheaffer, by regular mail to her last known address of, 3471 Spring Road, Carlisle, PA 17013. This letter was mailed under the date of April 2, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 24.72 Posting Bills 30.00 Advertising 30.00 Prothonotary 2.00 Milage 9.00 Levy 30.00 Surcharge 30.00 Law Journal 515.00 Patriot News 411.91 Share of Bills 15.43 Post Pone Sale 40.00 1,166.21 So Answers, R. Thomas Kline, Sheriff By 10 1 161AA 6 1/ Lul-? Real s ate Coordinator F1LED-+.:FFA-/E (IF THE PR 1-171 11-17APY 2009 OCT 12 Ali 11: 11 r' I A r. d.ev a 6V- 7J, Y3'7 Z3/7P0 ,A LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM VS. CAROLYN M. SHEAFFER AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3471 SPRING ROAD, CARLISLE, PA 17013: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. . , 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 Cumberland County Domestic Relations Cumberland County Tax Claim Bureau PA Department of Public Welfare Bureau of Child Support Enforcement Last Known Address (if address cannot be reasonably ascertained, please indicate) 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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) Tenants/Occupants 3471 SPRING ROAD CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities. GRE JAVARDIAN, ESQUIRE Atto y tor Plaintiff V February 20, 2009 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 04-5043 CIVIL TERM vs. CAROLYN M. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CAROLYN M. SHEAFFER 3471 SPRING ROAD CARLISLE, PA 17013 Your house (real estate) at 3471 SPRING ROAD, CARLISLE, PA 17013, is scheduled to be sold at Sheriffs Sale on JUNE 10, 2009 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,472.39, obtained by LASALLE BANK, N.A., F/K/A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED 10/01/2000, SERIES 2000-3, against you. 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: 2? 15) 942-9690. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 '/z feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), the place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point; thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013 BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attomey-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-5043 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., f/k/a LASALLE NATIONAL BANK, as Trustee under the POOLING AND SERVICING AGREEMENT DATED 12/01/2000, SERIES 2000-3, Plaintiff (s) From CAROLYN M. SHEAFFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,472.39 L.L. Interest from 11/19/04 to Date of Sale @ $13.72 per diem Atty's Comm % Due Prothy $2.00 Atty Paid $2,231.41 Other Costs to be added Plaintiff Paid Date: 2/24/09 C is R. Long, onotary (Seal) By: Deputy REQUESTING PARTY: Name: GREGORY JAVARDIAN, ESQUIRE Address: LAW OFFICES OF GREGORY JAVARDIAN 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 r Real Estate Sale # 53 On February 27, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 3471 Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 27, 2009 By:.. . r , o Its, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: May 1, May 8, and May 15, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ?isa Marie Coyn, Editor ?Zz I?le SWORN TO AND SUBSCRIBED before me this day of May, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL EBTATE SALE NO. 83 Writ No. 2004-5043 Civil Lasalle Bank, N.A. f/k/a Lasalle National Bank, As Trustee Under the Pooling and Servicing Agreement Dated 10/1/2000, Series 2003-3 VS. Carolyn M. Sheaffer Atty.: Gregory Javardian TRACT NO. 1: ALL that oertain lot or ground w 0b the improvements situate in Middlesex Towmabip, Couidy ofCumberiand and Connoon- 0 otpe as1 am descrilood as , to wit BEGINNING at a point (a stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and An- nie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuch- man, his wife, a distance of 10 feet to a point (a stake); thence south- wardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardly, a distance of 172 1/2 feet to a point in line of lands now or formerly of H.R. Gutshall; thence southwardly along lands of the said H.R. Gut- shall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Eber- sole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a dis- tance of 53 feet 4 inches to a point (a ,et?ke the pss??- orb??=n.ns.--_. TRACT NO.2: ALL that certain lot o(Smund situ- ate in Middlesex Township, Cumber- land County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwardly along lands now or formerly of Peter Schuchman, widower, a distance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence an!?l'sriardly by ?vl 1nnAa SA fwwt to a point; du%xv by the eases, north- woe ft 19 >aest to a paint; dwom by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMIS- ES which Grace V. Hurley, acting through her Attorney-in-Fact, Carol A. Chronister, by Deed dated and recorded August 29, 2000 in the Of- fice of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 138, granted and conveyed unto Carolyn M. Sheaffer. PARCEL NOS. 21-12-2958-015 and 21-12-2958-015A. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE ZhePatriot-News Now you know CARLISLE PA 17013 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant 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 date(s) indicated below. 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 This ad ran on the date(s) shown below: 04/24/09 05/01/09 05/08/09 ........... Sworn to nd rib,ed before me thi da /f of Wy, 2009 A.D. Notary`Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Kisner, Notary public city OF Harrisburg; Dauphin Cou* MY Corrwr>iaaion res Nov. 26, 2011 Member, Pennsylvania Assoclatlon of Notaries OM 54111040 Bats No. 53 1.8000 Dank, N.A., FltklA Lasalle National ®ank, As TrLvhe Under the PooHny and Sarviclnq A9reement,Dated Ion&000, Satins 20034 vs Carolyn M. Sheatter Attorney Gregory Javardlan ' LEGAL DESCRIPTION TRACT N0.1: ALL that certain lot or ground with the improvements thereon erected situate in Middlesex Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit BEGINNING at a point (-'stake) in line of land now or formerly of Peter Schuchman and Annie E. Schuchman, his wife, which point is also a corner of other lands now or formerly of Peter Schuchman and Annie E. Schuchman, his wife; thence eastwardly along said lands of Peter Schuchman and Annie E. Schuchman, his wife, a distance of 10 feet to a point (a stake); thence southwardly along said lands, a distance of 19 feet to a point (a stake); thence still along the said land eastwardiy, a distance of 172 1/2 feet to a point in line of lands now or formerly of H.R Gutshall; thence southwardly along lands of the said H.R. Gutshall, a distance of 33 feet 3 inches to a point (a stake) in line of lands now or formerly of Melvin Long and lands now or formerly of John Ebersole; thence westwardly along lands of the said Melvin Long and lands of the said John Ebersole, a distance of 174 feet to a point (a stake) in line of lands of the said Marshall E. Hurley and Grace V. Hurley, his wife; thence northwardly along said lands, a distance of 53 feet 4 inches to a point (a stake), thr place of beginning. TRACT NO. 2: ALL that certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point (a stake) in line of other lands of Marshall' E. Hurley and Grace V. Healey, his wife; thence northwardly along said other lands, a distance of 20 feet 8 inches to a point; thence eastwart0y along lands now or f")nnerly of Peter Scbuchman, widower, a dihance of 60 feet; thence southwardly by the same, 30 feet to other lands now or formerly of Marshall E. Hurley and Grace V. Hurley, his wife; thence westwardly by said lands 54 feet to a point; thence by the same, northwardly 19 feet to a point thence by the same, 10 feet to a point, the place of beginning. BEING known as 3471 Spring Road, Carlisle, PA 17013. BEING THE SAME PREMISES which Grace V. Hurley, acting through her Attorney-in-fact, Carol A. Chromster, by Decd dated and recorded August 29, 2000 in 12office of the Recorder of Deeds in and for Cumberland County in Deed Book 228, Page 938, granted and conveyed unto Carolyn M. Sheaffer. PARCEL'NO& 21-12.2958-015 and 21-12- 2958.015A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5043 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK, N.A., f/k/a LASALLE NATIONAL BANK, as Trustee under the POOLING AND SERVICING AGREEMENT DATED 12/01/2000, SERIES 2000-3, Plaintiff (s) From CAROLYN M. SHEAFFER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,472.39 L.L. Interest from 11/19/04 to Date of Sale @ $13.72 per diem Atty's Comm % Due Prothy $2.00 Arty Paid $2,231.41 Other Costs to be added Plaintiff Paid Date: 2/24/09 Curtis R. Long, rothonotary (Seal) By: REQUESTING PARTY: Name: GREGORY JAVARDIAN, ESQUIRE Address: LAW OFFICES OF GREGORY JAVARDIAN 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Deputy Supreme Court ID No. 55669 % ~ s KML I.AW GROUP, P.C. Suite 5000 -- BNY Mellon Independence Center 701 Market Street Philadelphia. PA 1 91 06-1 532 215-6~'?-132 Attorney for Plaintiff LASAI~LE BANK, N.A.. F/K.A LASALLE NATIONAL BANK, AS TRUSTEE UNDER THE POOLING AND SERti7CING AGREEMENT DATED 10/ 112000. SERIES 2000-3 909 HIDDEN RIDGE DRIVE, SUITE 200 IRVING. Ti;XAS 75038 Plaintiff vs. CAROLYN M. SHEAFFER Mortgagor(s) and Record owner(s) 3471 Spring Road Carlisle. PA 1701 Defendant(s) ENTRY OF APPEARANCE No. 04-5043 Civil Term TO TI-[E PROTHONOTARY: Kindly enter nay appearance on behalf of the Plaintiff in the above-captioned matter. By. .~ LAW OUP, P.C. -- - _- Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. I.D 61858 DavicC Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ~II P. Jenkins Pa. ID 306588 Alyk L_ Oflazian, P.A. ID 3l 2912 Attorneys for Plaintiff ;, `/J+Ir .~. .. ~ ;.~ = ,~ I raj t., ~,quq~l~J,, IN THE C01URT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - k_A W ACTION OF MORTGAGE 1.=ORECLOSliRF, KML Law Group, P.C. Suite 5000 ~- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-62%-13 22 Attorney for Plaintiff 1.ASALLE BANK, N.A., F/Ik.A LASALLE NATIONAL BANK, AS TRUSTEE 1JNDER TBE POOLING .AND SERVICING AGREEMENT DATED ] 0l 1 /2000, SI?RIES 2000-3 909 H IDI>EN RIDGE DRIVE, SUITE 200 1RV1NG. TEXAS 75038 vs. CAROLY"N M. SHEAFFER Mortgagor(s) and Record Owner(s) 3471 Spring Road Carlisle. PA 17013 TN THE. COtTKT' OF COMMON PLEAS OF Cumberland COUNTY Term No. 04-5043 Civil Term CERTIFICATION OF SERVICE 1 do hereby certify that a true and correct copy of the foregoing Entry of Appearance was served upon the following via first class mail on the date listed below: CAROLYN M. SHEAFFER 3471 Spring Road Carlisle. PA 1701 ~~ ~ ~ KML LAW GRO , P.C. Salvatore Filippello Telephone: (21'>) 627-1322 Date: l C' _ (C~' ~s~