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HomeMy WebLinkAbout04-5415Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 mtg@pkh.com HOMEAMERICAN CREDIT, INC. DB/A UPLAND MORTGAGE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. STEVEN A. FINKEY AND JOANNE K. FINKEY ACTION OF MORTGAGE FORECLOSURE ?Y el-01 Defendants THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 HOMEAMERICAN CREDIT, INC. DB/A UPLAND MORTGAGE, Plaintiff VS. STEVEN A. FINKEY AND JOANNE K. FINKEY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof , is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff vs. STEVEN A. FINKEY AND JOANNE K. FINKEY, Defendants ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, is a Corporation, with an address of THE WANAMAKER BUILDING, 100 PENN SQUARE, EAST PHILADELPHIA, PENNSYLVANIA 19107. 2. Defendant, STEVEN A. FINKEY, is an adult individual, whose last known address is 69 PEACHY ANN DRIVE, NEWVILLE, PENNSYLVANIA 17241. Defendant, JOANNE K. FINKEY, is an adult individual, whose last known address is 69 PEACHY ANN DRIVE, NEWVILLE, PENNSYLVANIA 17241. 3. On or about, November 19, 2002, the said Defendants, executed and delivered a Mortgage Note in the sum of $58,400.00 payable to HOMEAMERICAN CREDIT INC. D/B/A UPLAND MORTGAGE, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants, made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1789, Page 1875 conveying to original Mortgagee the subject premises. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266 and is more particularly described in Exhibit "B" attached hereto. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0 y-.5y/,5 CIVIL ACTION - LAW 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 05, 2004 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $57,180.17 Interest at $18.15 per day $3,248.84 From 06/05/2004 To 11/05/2004 ( based on contract rate of 11.5900%) Accumulated Late Charges $313.20 Advances $1,314.99 Prepayment Fee (5%) $2,859.01 Attorney's Fee at 5% of Principal Balance $2,859.01 TOTAL $67,775.22 **Together with interest at the per diem rate noted above after November 05, 2004 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to Foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 11.590% ($18.15 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PU ELL, KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) NOTE Borrower(s): JOANNE K. FINKEY and STEVEN A. FINKEY LOAN ID# 1301041550 November 19, 2002 WALNUT BOTTOM Pennsylvania [Date] [City] [State] 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 [Property Address] 1. BORROWER'S PROMISE TO PAY In return fora loan that I have received, I promise to pay U.S. $ 58,400.00 (this amount is called "principal"), plus interest, to the order of the Lender. The Lender is HomeAmerican Credit Inc DBA Upland Mtg I will make all payments under this Note in the form of cash, check or money order. I 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 the "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 11.590%. The interest rate required by this Section 2 is the rate I will pay both before and after any defa At described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 5th day of each month beginning on January 05, 2003 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date. If, on 12/05/2022 , I still owe amounts under this Note, I will pay those amount:, in full, on that date. I will make my monthly payments at One Presidential Boulevard, Suite 411, Bala Cynwyd, PA 19004 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ $ 626.42 4. BORROWER'S RIGHT TO PREPAY I 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 I make a prepayment, I will tell the Note Holder in writing that I am doing so. A prepayment of all of the unpaid principal is known as a "full prepayment." A prepayment of only part of the unpaid principal is known as a "partial prepayment." 1301041550 PENNSYLVANIA FIXED RATE NOTE-Single Family -With Prepayment Penalty Pagel a4 P105NPA (ooos) VMP MORTGAGE FORMS -iWO)521+r291 Innlels: ?- 1, I xhlb { LOANID# 1301041550 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, there will be no delays in the due dates or changes in the amount of my monthly payments unless the Note Holder agrees in writing to those delays or changes. I may make a full prepayment at any time. If I choose to make a partial prepayment, the Note Holder may require me to make the prepayment on the same day that one o - my monthly payments is due. The Note Holder may also require that the amount of my partial prepayment be equal to the amount of principal that would have been part of my next one or more monthly payments. If I make a full prepayment or a partial prepayment during the first 36 months o- the term of the Note, I agree to pay a prepayment charge as follows: in the 1 month through the 36 month of the term of the Note, the prepayment charge will be 5.000.%of the amount prepaid ; in the N/A month through the N/A month of the term of the Note, the prepayment charge will t e N/A of the N/A ; in the N/A month through the N/A month of the term of the Note, the prepayment charge will be N/A of the N/A ; in the N/A month through the N/A month of the term of the Note. the prepayment charge will be N/A of the N/A ; in the N/A month through the N/A month of the term of the Note, the prepayment charge will be N/A of the N/A At any time after the 36th month of the term of the Note, I may make a full prepayment or a partial prepayment without charge. 5. 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 collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any miss already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of Fifteen calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 10.000 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I 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 nol pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note 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 costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must 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 Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or 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 I am given a notice of that different address. 1301041550 P105NPA (ooo5) Page 2 of 4 54T IniliNS: _}Y-y._ LOAN ID# 1301041550 8. OBLIGATIONS OF PERSONS UNDER 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, surety 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. 9. WAIVERS I 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. "Notice of dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paic. 10. APPLICABLE LAW This Note shall be governed by the laws of the State of Pennsylvania. If a law, which applies to this loan and sets maximum loan charges is finally interpreted so that the interest and other charges collected or to be collected in connection with this loan exceed the permitted limits, then: (A) any such interest or other charge shall be reduced by the amount necessary to reduce the interest or other charge to the permitted limit; and (B) any sums already collected from me which exceed permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment, but in no event will a prepayment charge be assessed if the Note Holder chooses to reduce my principal balance by applying such excess amounts. 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without --ender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay .hese 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. 12. OTHER CHARGES A. NSF Charge If I make a payment under this Note by check, negotiable instrument or other means and the payment is returned to the Note Holder unpaid, I agree to pay the Note Holder a charge for not sufficient funds (NSF charge) in the maximum amount permitted by applicable law. B. Administrative Charges Except as limited by applicable law, I agree to pay the Note Holder any administrative charge that the Note Holder may impose in connection with (1) my failure to comply with the terms and conditions of this Note and (2) the release or satisfaction of any mortgage, financing statement or other security instrument appearing on the public record which relates to my obligations under this Note. 1301041550 C, C P105NPA raoost Pape 3 of 4 11W.. LOANID# 1301041550 WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. 4 A CqA? STE N A. FINKEY (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower JO K. FINKEY (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower [Sign Original Only] 1301041550 P105NPA (ooo5) Page 4 of 4 J29pm From-PREMIER ABSTRACT +243 3390 T-916 P031/035 F-004 ? .. ., ... ....,... .,....:. c.,-??.FASUrrrcIY`US9s Ma f4NWP.fi? Its; l.NIL'MV.?!(?''.'.wY, ..?'. ',""°Y•.'{S' ."s?F.?F+Po{kJ 71?f_J'?JJ . ALL ?HOSE CERTAIN lots of ground with the improvements i • -. thereon erected, situate in South Newton Township, Cumberland q County, Pea:sylvania, bounded and described as follows: Tract eln+._l BEGINNINC at an iron pin in the center of the public road leading fron, Jacksonville to Stoughstown at line of lands now or - formerly of Barry Beidel; thence by the center of said road South 36 degrees last BO feet to a point at line of lends now or formerly of Raymond S. and Dorothy s. Black; thence by said lands south 65 degrees SO minutes west 100 feet to a point; thence by Same North 36 degrees West 80 foot to a point on line of lands now or formerly of Barry Beidel: thence by said lands now or formerly of Beidel North 6S degrees 50 minutes list 100 feet to the center line of said public road, the Place of BEGINNING. Tract N . s -- • BEGINNINg at a point at the southeast corner of Tract No, 1 k ??'? =?f9.?.. `' , in the center of Legislative Route 21003; thence by the center of r . '0:•i " Legislative Route 21089 South 90 degrees 9 minutes 20 seconds East 22 feet to a Point at lands now Or formerly of Lewis A. .. Goodhart, at ux; thence by the lands now or formerly of Lewis A. j Gocdhert, at ux, South 63 degrees 34 minutes 20 seconds West 100 -- - - East to a point at lands new or formerly of Edward L. Glass, at ux: taeace by the lands now or formerly of Edward L. Glass, et ux, North 3n degrees 9 minutes 20 seconds West 36 foot to a point ' 'E "?:' at lald9 Of Tract No. 1; thanes by the lands of Tract No. 1 in a 3+• • ? h ?' Northijast direction loo twat, more or less, to a point in the tm+•' a • cents: of Legislative Route 21089, the point and place of :. BEGINNING. . "EEBE meaauramente are in accordance with a survey made by 'r .._.? Thomau A, Neff, a registered surveyor, on April 27, 1970. s a I Certify this to be recorded _ In Cumberland County PA Recorder of Deeds r IK 1'7 8.9 FIG 18 91 ?xhL?; ff VERIFICATION Carolee Berasi hereby states that she is Assistant Vice President of HomeAmerican Credit, Inc. d/b/a Upland Mortgage the plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements made therein are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unworn falsification to authorities. ?l esident DATE: 10) ZZ)oq Q w HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) STEVEN A. FINKEY AND JOANNE K. FINKEY for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance $57,180.17 interest $3,248.84 Per diem of $18.15 From 06/05/2004 To 11 /05/2004 Accumulated Late Charges $313.20 Advances $1,314.99 Prepayment Fee @ 5% $2,859.01 5% Attorney's Commission $2,859.01 TOTAL $67,775.22 **Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff s Sale. PURCELL, KRUG & H R By` Le . Haller PA I.D. # 15700 1 9 North Front Street Harrisburg, PA 17102 (717) 234-4178 HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, PLAINTIFF VS. STEVEN A. FINKEY .JOANNE K. FINKEY. I )EFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before nee this Y_ day of Off/ 20 D )01 Public I MARYL;, `:^-f.' ;'•hr,1, otar, Puk it ,gip auphin County M?':y t on:,rn_oion Exoires Aug. 8 200f? ON P. HALLER, ESQUIRE HOMEAMERICAN CREDIT, INC. DIBIA UPLAND MORTGAGE, PLAINTIFF Vs. STEVEN A. FINKEY JOANNE K. FINKEY. DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certi Cy that on November 29, 2004 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice, li By Leon P. ler PA I.D. # 15700 Atto ey for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff VS. STEVEN A. FINKEY AND JOANNE K. FINKEY Defendants DATE OF THIS NOTICE: NOVEMBER 29, 2004 TO: STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-05415 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & H By LEON P LER, Attorney for Plaintiff I.D. # 1 700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 Lq RI ,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2004-05415 HOMEAMERICAN CREDIT, INC. D/B/A UPLAND Total Judgment Amount $67,775.22 MORTGAGE, Interest $3,811.50 PLAINTIFF Per diem of $18.15 to sale date 6/8/2005 VS. Escrow Deficit $2,000.00 STEVEN A. FINKED` JOANNE K. FINKEY_ TOTAL WRIT $73,586.72 DEFENDANT(S) *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, June 08, 2005 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: December 9. 2004 Attorney for Plaintiff 1719 North Front Street eon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the j udgment. interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ALL T8 . CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Fennsylvaaia, bounded and described as follows: Tract No. x BEGINNING at an iron pin in the center of the public goad leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Seidel; thence by the center of said road South 35 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Seidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract. No. 2 BEGINNING at a point at the southeast corner of Tract No. 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at Iifids now or formerly of Edward L. Class, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds West 36 feet to a pout at lands'of Tract No. 1; thence by the lands of Tract No. 1 in a northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. THESE measurements are in accordance with a survey made by Thomas A. Neff, a registered surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book I40, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 cq '`y. w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5415 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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 $67,775.22 L.L. $.50 Interest PER DIEM OF $18.15 TO SALE DATE 6/8/05 Atty's Comm % Due Prothy $1.00 Atty Paid $152.36 Other Costs ESCROW DEFICIT - $2,000.00 Plaintiff Paid Date: DECEMBER 22, 2004 CURTIS R. LONG Prothono/ (Seal) Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-2344178 Supreme Court ID No. 15700 HOMEAMERICAN CREDIT, INC, D/BlA UPLAND MORTGAGE. PLAINTIFF VS. STEVEN A. FINKEl' JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 1 Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Boscov's Department Store Inc. c/o Arthur- M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 11 16 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 UNKNOWN Name and address of every other person who has any record lien on the property: 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 (In the prcce(ing information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authori Leon aller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 9, 2004 -} ..?} .. ;..? ? .[_ ?? r•? -`( - ? r : ? ` ' ' t ? : - i , i'?? ,.1 r - ? t?: S`,? '? ? ., , _ "' ? J ,,; C.?,, I HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 08, 2005 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-05415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K. FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or govennnental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CA USE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 lrvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule nnist be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL TROM CERTAIN lots of ground with the improvements tberean erected, situate in South Newton Township, Cumberland County,'Pennsylvania, bounded and described as follows: Tract No. I BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Beidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees Rest 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Beidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No. Z in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at IEjids now or formerly of Edward L. Class, et ux; thence by the lands now or formerly of Edward L. Glass, et uk, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at lands of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. THESE measurements are in accordance with a survey made by Thomas A. Neff, a registered surveyor, on April 27, 1970, HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Fifflcey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 ti '" r•J ? ( S ' - + ? ? =? ?- ,:.-? ?i .s." __j f ? ?"l ? 1 i _. i, I: t r•.. ._ , 4 . .. SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-05415 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOMEAMERICAN CREDIT INC ET AL VS FINKEY STEVEN A ET AL R. Thomas Kline Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT 36 MAPLE AVENUE OCCUPANT WALNUT BOTTOM, PA 17266 DEFENDANTS LIVE AT THE WALNUT BOTTOM ADDRESS. PER MINDY, SERVICE WAS NOT ATTEMPTED AT NEWVILLE ADDRESS. Sheriff's Costs: So answers -? Docketing 6.00 -_! y Service .00 Affidavit .00 - 1R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 16.00 PURCELL KRUG HALLER 11/05/2004 Sworn and subscribed to before me this day of J-W A. D. Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004-05415 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMEAMERICAN CREDIT INC ET AL VS FINKEY STEVEN A ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FINKEY STEVEN A the DEFENDANT at 1546:00 HOURS, on the 4th day of November , 2004 at 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 STEVEN FINKEY by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.36 .00 10.00 R. Thomas Kline .00 38.36 11/05/2004 PURCELL KRUG HALLER Sworn and Subscribed to before me this day of 1 A.D. 1Pro notary By. tj d 10puty Sheriff CASE NO: 2004-05415 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMEAMERICAN CREDIT INC ET AL VS FINKEY STEVEN A ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FINKEY JOANNE the DEFENDANT , at 1546:00 HOURS, on the 4th day of November-, 2004 at 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE FINKEY by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 R. Thomas Kline .00 16.00 11/05/2004 PURCELL KRUG HALLER Sworn and Subscribed to before me this day of OA I .,2uvS? A.D. t vl. . P othonotary By: ,f D uty Sheriff Homeamerican Credit, Inc. VS Steven A. Finkey and Joanne K. Finkey In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-5415 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Leon Haller. Sheriff's Costs Docketing 30.00 Surcharge 40.00 Poundage 5.76 Levy 30.00 Advertising 30.00 Mileage 9.62 Share of Bills 16.47 Law Journal 130.55 Law Library .50 Prothonotary 1.00 $ 293.90 Sworn and subscribed to before me This ?' day of 2005, A.D. ?QrX, Prothonotary So Answers: ??mn?e,SC rhkif BY , '? - dtJ Re Estate Sergeant 5V s G c )&' ' /? Y A V } HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 .JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 2. Name and address of Defendant(s) in the Judgment, if different from that listed, in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland Comity Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which maybe affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 (in the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unworn falsification to author PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 9, 2004 I HOMEAMERICAN CREDIT, INC. DfBlA UPLAND MORTGAGE, PLAINTIFF V S. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 STEVEN A. FINKL-Y IOANNE K. FINKEY, OEFENDANT(S) IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 08, 2005 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Connnonwealth and County to: No. 2004-05415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. f INKEY and JOANNE K. FINKEY • A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Shcriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be tiled by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Libcrty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED 13EFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. if a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 JLLL TMM CERTAIN lots of ground with the improvements thereon erected, situate in south Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract_ 1o, 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstovn at line of lands now or formerly of Harry Seidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Slack; thence by said lands south 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Beidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No. 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at I`aads now or formerly of Edward L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at lands of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction loo feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. THESE measurements are in accordance with a survey made by Thomas A. Neff, a registered surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-5415 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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 $67,775.22 L.L. $.50 Interest PER DIEM OF $18.15 TO SALE DATE 6/8/05 Atty's Comm % Due Prothy $1.00 Atty Paid $152.36 Other Costs ESCROW DEFICIT - $2,000.00 Plaintiff Paid Date: DECEMBER 22, 2004 CURTIS R. LONG Prothonot? (Seal) j ?By: //AO o c` Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 , Supreme Court ID No. 15700 Real Estate Sale #16 On February 15, 2005 the Sheriff levied upon the defendant's interest in the real property situated in South Newton Township, Cumberland County, PA Known and numbered as 36 Maple Ave., Walnut Bottom, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 15, 2005 ByeQ,?.? Real Est e Deputy LE :E d bZ 330 4001 Vd'AiNflui ONTI,638WU d3183HS 3Hi A 331330 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, April 15, 22, 29, 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 character of publication are true, isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 29 day of April _ NOTARIAL SEAL V LOIS E. SNYDER, Notary Pubic Carlisle Bom, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE ME NO. 16 Writ No. 2004-5415 Civil Homeamerican Credit, Inc., d/b/a Upland Mortgage VS. Steven A. Finkey and Joanne K. Finkey Atty.: Leon Haller ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract No. 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Beidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Beidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGIN- NING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No. I in the center of legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at lands now or formerly of Edward L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 sec- onds West 36 feet to a point at lands of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. THESE measurements are in accordance with a survey made by Thomas A. Neff, a registered sur- veyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701. BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and con- veyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROP- ERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDG- MENT NO. 2004-05415. ASSESSMENT NO. 41-31-2230- 001. 0y __15? y/S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2004-05415 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 20024, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, PLAINTIFF vs. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) Total Judgment Amount $67,775.22 Interest $13,249.50 Per diem of $18.15 to sale date 6/13/2007 Escrow Deficit $2,104.23 TOTAL WRIT $83,128.95 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, June 13, 2007 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Kindly Issue a Writ of Execution in the above captioned c e. Date: March 13, 2007 Attorney for Plaintiff 1719 North Front Street L Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract No. 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Beidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees Rest 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Beidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract No- 2 BEGINNING at a point at the southeast corner of Tract No. 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodbart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at I`aads now or formerly of Edward L. C318ss, et ux; thence by the lands.now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at lands'of Tract No. 1,• thence by the lands of Tract No. 1 in a northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. These measurements are in accordance with a survey made by Thomas A. Neff, a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 0 u r O o? ?o w "4.O t? P 1 ?1 ? 1 ?T N t -F' 0 rYy i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5415 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 20024 MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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 $67,775.22 L.L. Interest PER DIEM OF $18.15 TO SALE DATE 6/13/07 -- $13,249.50 Atty's Comm % Due Prothy $1.00 Atty Paid $379.26 Other Costs ESCROW DEFICIT - $2,104.23 Plaintiff Paid Date: MARCH 14, 2007 (Seal) Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff Vs. STEVEN A. FINKEY JOANNE K. FINKEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.2004-05415 CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE VOLUNTARY SUBSTITUTION OF PLAINTIFF PURSUANT TO RULE 2352 (a) 1. JPMorgan Chase Bank, N.A., as Trustee for the registered holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass-Through Certificates, Series 2002-4, will be the last assignee of record and wishes to substitute itself for Plaintiff. 2. Material facts in which the right of succession and substitution is based are as follows: (a) Homeamerican Credit, Inc. d/b/a Upland Mortgage assigned all of its right, title and interest to JPMorgan Chase Bank, N.A., as Trustee for the registered holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass- Through Certificates, Series 2002-4, and same will be sent for recording. 3. JPMorgan Chase Bank, N.A., as Trustee for the registered holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass-Through Certificates, Series 2002-4 does voluntarily substitute itself as Plaintiff herein. Leon P. H , Esquire Purcell, Krug and Haller 1719 North Front Street Harrisburg, PA 17102 ID#15700 Attorney for Plaintiff Date: March 13, 2007 -? ? -Ti { l JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE RELIEF FROM STAY IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA In re: Joanne K. Finkey, Debtor. JPMorgan Chase Bank, N.A., et al., Movant, V. Joanne K. Finkey, Debtor, and Charles J. Dehart, III, Trustee, Additional Respondent. CHAPTER 13 BANKRUPTCY CASE NUMBER 1-05-bk-02058 MDF ORDER AND NOW, after notice to all required parties and certification of default under the terms of this Court's Order of January 20, 2006, and based upon Debtor's Response to Default and Movant's Response thereto, and upon a hearing having been held on August 29, 2006, it is hereby ORDERED AND DECREED that the automatic stay of all proceedings, as provided under 11 U.S.C. §362 of the Bankruptcy Code is lifted to permit JPMorgan Chase Bank, N.A., et al., and its successors in interest, if any, to proceed with the foreclosure process through, among other remedies, but not limited to, Sheriffs Sale regarding the premises located at 36 Maple Avenue, Walnut Bottom, PA 17266; and it is FURTHER ORDERED that Rule 4001(a) (3) is not applicable and JPMorgan Chase Bank, N.A., et al. or its successors may immediately implement and enforce this order granting relief from the automatic stay; and it is FURTHER ORDERED that JPMorgan Chase Bank, N.A., et al. or its successors shall be awarded attorney fees and costs in defense of this matter totaling $ 500.00. By the Com-t, Dated: August 31, 2006 74i 14 B P j1j+dge This document is electronically signed and faded on the same date. C"> "'' r.-• c? -- ? ?y ? _ .„? - _ -*- ?? f? --! ? ?? ? ?; ._. ? ? r _.?. ,?,,: axe -' r? ,;ern r C ) ? ? A y »` ?y r 1 AS TRUSTEE JPMORGAN CHASE BANK, N.A., FOR THE REGISTERED RTRU HOLDERS 2 OF ABFS MORTGAGE MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, RE who being duly sworn according to law deposes and states that the LEON P. HALLER, ESQUI a ed in any way ants above named are not in the Military or Naval Service nor are they eng g Defend ( ) them within the Soldiers and Sailors Relief Act of 1940, as amended. which would bang Sworn to and subscribed before me this Zday of ? 20 D? COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public LowSr POW My Comm ssipn Explres Dauphin 8, 2010 ?a T7 t ?. .?Yf jj Co JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. WPA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 13, 2007 ni 47 Q0 'f t ? W ?J JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 13, 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-05415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K. FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPFRTY_ IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition'with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract_No . 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry 'Seidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy s. Black; thence by said lands south 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Seidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No.of in the center of Legislative Route 21089, Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at I`aads now or formerly of Edward L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at laads'of Tract No. 1; thence by the lands of Tract No, 1 in a northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. These measurements are in accordance with a survey made by Thomas A. Neff, a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. F , KEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 - TI .1 C..:j '•G r HOMEAMERICAN CREDIT, INC. D/B/A UPLAND MORTGAGE, Plaintiff Vs. STEVEN A. FINKEY AND JOANNE K. FINKEY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No.2004-05415 CIVIL ACTION - LAW - : IN MORTGAGE FORECLOSURE VOLUNTARY SUBSTITUTION OF JPMORGAN CHASE BAN N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002x4, MORTGAGE PASS-THROUGH CERTIFICATES. SERIES 2002x4 PURSUANT TO RULE 2352 (a) 1. JPMorgan Chase Bank, N.A., as Trustee for the Registered Holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass-Through Certificates, Series 2002-4, will be the last assignee of record and wishes to substitute itself for Plaintiff. 2. Material facts in which the right of succession and substitution is based are as follows: (a) HomeAmerican Credit, Inc., DBA Upland Mortgage assigned all of its right, title and interest to JPMorgan Chase Bank, N.A., as Trustee for the Registered Holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass-Through Certificates, Series 2002-4. Said Assignment has been sent for recording. 3. HomeAmerican Credit, Inc., DBA Upland Mortgage assigned all of its right, title and interest to JPMorgan Chase Bank, N.A., as Trustee for the Registered Holders of r 3 ABFS Mortgage Loan Trust 2002-4, Mortgage Pass-Through Certificates, Series 2002-4 does voluntarily substitute itself as Plaintiff herein. BY: Leon P. Haller, Esquire Purcell, Krug and Haller 1719 North Front Street Harrisburg, PA 17102 ID#15700 Attorney for Plaintiff Date: March 20, 2007 rte- 0 ril rr. C rn w JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINYEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 cog,, O IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my ersonal knowledge, information and belief. I understand that false statements herein are made ct to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. r PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 13, 2007 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 13, 2007 TRAE: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-05415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K. FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition'with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract NO. -L BEGINNING at an iron pin in the center of the public road leadinq from Jacksonville to stoughstown at line of lands now or formerly of Harry Beidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy 'S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Seidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. 't'ract No. 2 BEGINNING at a point at the southeast corner of Tract No. Y in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a Point at IEnEds now or formerly of Edgard L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds Kest 36 feet to a point at lands'of Tract No. 1; thence by the lands of Tract No. 1 in a S ortheast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. These measurements are in accordance with a survey made by Thomas A. Neff, a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 JP Morgan Chase Bank, N.A. VS Steven A. & Joanne K. Finkey In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-5415 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Leon P. Haller. Sheriff's Costs: Docketing $30.00 Poundage 1.79 Levy 15.00 Mileage 13.44 Prothonotary 1.00 Surcharge 40.00 $ 101.23/ 01 4,?,o Ste" s R. Thomas Kline, Sheriff B Real Estat Sergeant Do tp?o C04 # ?4 188 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5415 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4 MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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 $67,775.22 L.L. Interest PER DIEM OF $18.15 TO SALE DATE 6/13/07 -- $13,249.50 Atty's Comm % Due Prothy $1.00 Atty Paid $379.26 Plaintiff Paid Other Costs ESCROW DEFICIT - $2,104.23 Date: MARCH 14, 2007 (Seal) REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 -.,r-1.7 s Real Estate Sale # 108 On March 19, 2007 the Sheriff levied upon the defendant's interest in the real property situated in South Newton Township, Cumberland County, PA Known and numbered as 36 Maple Ave., 40 Walnut Bottom, more fully described on Exhibit "A" ?ni filed with this writ and by this reference incorporated herein. Date: March 19, 2007 By: J&Gtk Real Estate Sergeant S 7 ., Vl ...A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2004-05415 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) Total Judgment Amount $67,775.22 Interest $15,952.20 Per diem of $18.15 to sale date 12/05/2007 Escrow Deficit $2,373.72 TOTAL WRIT $86,101.14 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, December 05, 2007 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Kindly Issue a Writ of Execution in the above ca - d case. Date: August 20, 2007 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Ian P. Haller PA I.D. #15700 WRIT OF EXECUTION- MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Date: C ;L-, 9007 BY PROTHONOTARY/CLERK CIVIL DIVISION DEPUTY 1 Ift ALL THOSE CERTAIN lots of ground with the improvements thereon erected., situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Seidel; thence by the center of said road South 36 degrees last so feet to a point at line of lands now or formerly of Raymond S. and Dorothy'S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Seidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No. 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at IiEds now or formerly of Edward L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et ux, North 30 degrees 9 minutes 20 seconds Nest 36 feet to a point at lands'of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of HEVINNING. These measurements are in accordance with a survey made by Thomas A. Nei a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 .r v, a r*) q C O 7\ lop J Q c N ,?L I % sue,. i...:... ..+ i..? 7 IL JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HAULER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this C&day of? 206: aryl an Ferretti Not Public ESQUIRE COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County M ca"Wrslon L ; Aug. 6 2010 c -r: ? ? ? ???; G ? ? ?rn ? N ? : ,? > r ? ? JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 20024, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: 1. Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 I' (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P er PA T.D. #15700 P , Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: August 20, 2007 rya . N c?."_' C7 O n -C JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, DECEMBER 05, 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE,DESCRIPTION ATTACHED) .... THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 200405415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K. FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date -is,desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition 'to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGI3MING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown at line of lands now or formerly of Harry Seidel; thence by the center of said road South 36 degrees last 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy'S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said loads now or formerly of Beidel North 65 degrees 50 minutes last 100 feet to the center line of said public road, the Place of BEGINNING. Tract No. 2 BEGINNING at a point at the southeast corner of Tract No. 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Levis A. Goodhart, et ua; thence by the lands now or formerly of Lewis A. Goodhart, et uz, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at 11ads now or formerly of Edward L. Glass, et ux; thence by the lands now or formerly of Edward L. Glass, et uX, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at lands'of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction 100 feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. These measurements are in accordance with a survey made by Thomas A. Nei a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 Cl) ......;? U i r rrn Fi y cp WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N004-5415 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 20024, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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$67,775.22 L.L. Interest PER DIEM OF $18.15 TO SALE DATE 12/05/2007 - $15,952.20 Atty's Conun % Atty Paid $588.99 Plaintiff Paid Date: August 22, 2007 (Seal) Due Prothy $2.00 Other CostsESCROW DEFICIT - $ 2,373.72 R. Long, Prothonotary Deputy REQUESTING PARTY: Name LEON P HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-2344178 Supreme Court ID No. 15700 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 VS. STEVEN A. FINKEy JOANNE K. FINKEy, IN MORTGAGE FORECLOSURE DEFENDANT(S) MTURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Penns August 31, 2007 , a true and correct co py of the Notice of Sale of Real Estate pursuant t to PA .P. 3129.1 to the Defendants herein and all lienholders of record b regular ylvana t (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is t c d first class mail Rand .C also to the Defendants by Certified Mail, which mailing receipts are attached. hereto as evidence), as follows: Service addresses are STEVEN A. FINKEy 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEy 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266-9701 Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 NOTICE IS HEREBY GIVEN to the Defendants in the within action an those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate by the sale and that you have an opportunity to protect your interest, Sheriffs Sale. ' 1 be if any, by bei no ed of . bailer PA I.D.15700 ;y for Plaintiff MG3M%4997525214 TO: STEVEN A. FINKEy 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 SENDER: NOS 12/05/07 REFERENCE: OCWEN/FINKEY RETURN Postage RECEIPT ??ed Fee SERVICE Return Receip Restricted Der Total Poste US Postal Se Receipt f r Certified ii No Insuranq Covwap Do Not U« POSTMARK OR D G 31 2007 711 39p], 9849 9752 SW I 7X): JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 SENDER: NOS 12/05/07 REFERENCE: OCWEN/FINKEY RETURN Postage RECEIPT Fee SERVICE Certified Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal %r Am Receipt for Certified Mail No Ine unme C01iwwW Provided 00 Not Use for Irdoney«,r Ma U 2. Arode Number • • 11 aa4e Addressed to: STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 - - ianuery 2005 Domestic Return Receipt 2. Article Number ` - -. 7360 3?], 9649 4752 52x7 WALNUT BOTTON,PA 17266 981 t, ,ley ? NOS 12/0107 DOn>•afic Retum LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN 10 Mx0e&' xn?v d-')Ka? 1719 NORTH FRONT STREETS HARRISBURG, PENNSYLVANIA 1 7 1 02-23 92 TELEPHONE (717) 234-4178 FAX (717) 234-1206 STEVEN A. FINKEy 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266-9701 Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 BOscov'S Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 BOSCOV'S Department Store Inc, c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, pA 17101 HERSHEY JOSEPH NISSLEY 0910-1982) JOHN W.PURCELL VALERIE A. GUNNOF COUNSEL Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 By runt G & HALLER Att s for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 JPMORGAN CHASE BANK, N.A., AS TRUSTEE LDE FOR THE REGISI D HOT 200 RS OF ABFS MORTGAGE LO MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY' PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE STEVEN A. FINKEY I JOANNE K. FINKEY, DEFENDANT(S) NOTICE OF SHERIFF'S SALE OF RED' ESTATE PURSUANT TO ___,tT rnnriwniTRE 31. TAKE NOTICE: That the Sheriff s Sale of Real Property (real estate) will be held: DATE: Wednesday, DECEMBER 059 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 SOLD is delineated in detail in a legal description on of he buildings THE PROPERTY TO BE ertto ether with a brief of a statement of the measured boundaries boundaries erected of on the the prop land. Y, (SEE DESCRIPTION ATTACHED) and any other major improvements THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Pursuant to which your property is being sold is docketed in the THE JUDGMENT under or p within Commonwealth and County to: AMOUNT $67,775.22 No. 2004-05415 JUDGMENT THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or . ed and to be entitled to receive part of the proceeds of the ale receiv pal ties that are corporate entities or agencies bung to banks that hold mortgages an ff of this County thirty (30) days after the sale and distribution of disbursed by the Sheriff (for example, will be filed by the Shen owed taxes) with this schedule will, in fact, be made unless someone objects by the proceeds of sale in accordance days of the date it is filed. filing exceptions to it within ten (10) of Distribution maybe obtained from the Sheriff of the Court of information about the Schedule specified herein. Common Pleas of the within County at the Courthouse address T= . -v nF THE SALE O= BUR PROPERTY. THE JUDGMENT taken away. A lawyer can advise you may have legal rights to prevent your property from being YOU MUST ACT you more specifically of these rights. If you wish to exercise your rights, PROMPTLY. TAKE THIS PAPER TO YOUR LAWYER T WHERE YOOU O N ET YOU SHOULD TELEPHONE THE OFFICE SET FORTH BELOW TO FIND FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row 17013 Carlisle, Pennsylvania 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE County to open the petition with the Court of Common Pleas of the within that has entered judgment 1. You may file a erson or company are aware of a legal defect in the judgment if you have a meritorious defense against the p you ou. You may also file a petition with the same Court if y against y obligation or the procedure used against you. of the within Sale you may file a petition with the Court of Comoro causes This petition 2. After the Sheriffs Sa y grossly inadequate price or for other proper County to set aside the sale for a ST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. MU receding paragraphs petitions raising the legal issues or rights mentioned in the p 3. A petition or p The petition must be served on f the within County. must be presented to the Court of Common Pleas o and a proposed order or the attornbe afor the creditor or on ttached to the petit onhe creditor before presentation to the court rule must ourt date is desired, such date must be obtained of the petition to the If a specific return Courthouse, before a presentation office - Civil Division, of the within County Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 of ground with the improvements thereon erected, situate in south Newton ALL THOSE CERTAIN lots o Cumberland County, Pennsylvania, bounded and described as follow Township, Xa,.t uo - 1- ubl is road T in in the oughStovn center of thcf lands aoW or BEGINNING at an iron P at line leading thence by the center of said road South fxom Jacksonvil l e to St of Barry Seidel; tint at line of lands nO14or lands formerly 80 feet amto a d Dorothy S• Black; thence by said and S. Dint; thence by 36 degrees East o West 100 feet a formerly of Raym 50 minutes 65 deg a vint on line of lands tees es degrees Aest 80 feet to P lands now or same North 36 degr Seidel; thence by said 00 feet to now or formerly of Barry degrees 50 minutes East 1 formerly of Seidel North 65 ublic road, the place of BFr'1M1NG. the center line of said P Tract No. 2 of Tract No- 1 e southeast come= center of BgGIpIiING at a point at th • thence by the s 9 minutes 20 seconds in the center of Legislative Rout e 2108 of Lewis A• Legislative Route 21089 South 30 degrees of Lewis A• East 22 feet to a poine bt lands now or torme2 lands now or formerly West 100 Goodhart, et ux; thenc y the Goodhart, et ux, south 63 derr forme lytof Edward L. t3lass,?t of Edwazd L. Dint feet to a point at Iands now Glass, et thence by the lands now or formerly ux, Dtorth 30 degrees 9 minutes 20 sthe Irls land9sof3Tracttllo? 1 ii thence by n a at lands'of Tract No. 1, to a point in the Northeast direction 100 feet, more or leoint and place of center of Legislative Route 21089. the p REOINNING. These measurements are in accordance with a survey made by Thomas A. Neff, a Registered Surveyor, on April 27, 1970. WALNUT THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, HAVING 17266-9701 BOTTOM, PENNSYLVANIA REMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed BEING THE SAME Pd and conveyed unto Steven A. Finkey and Joanne K. Finkey. Book 140, Page 910, gI' OF STEVEN A. FINKEY AND JOANNE K. FINKEY ON TO BE SOLD AS THE PROPERTY JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 r C. DBA UPLAND MORTGAGE v. STEVEN A. FINKEY JOANNE K. FINKEY HOMEAMERiCAN CREDIT, IN% Cumberland County Sale 1215107 U. 5. POSTAL SERVICE CERTIFICATE OF MAILING In com Nance with postal Service Form 387 Received from Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 U. S. POSTAL- SERVICE CERTIFICATE OF MAILING In com Nance with Postal Service Form 387 Received from: Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (I Service Form 3877 an com Nance with Postal Received from: Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 O ",FNFY 00WE5 0 2 R $ 01.050 200 00 E4353871 AIJG31 D FROM ZIPGODE 1710 nG USri i INC. DBA UPLAND MORTGAGE V. STEVEN A. FINKEY JOANNE K. FINKEY HOMEAMERICAN S?D2?5/07 ale Cumberland County U. S. POSTAL SERVICE F MAILING CERTIFICATE' In com Nance with Postal Service Form 387 Received from: Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM pENNSYLVANIA 17266-9701 U. S. POSTAL SERVICE CERTIFICATE OF MAILING In com Hance with Postal Service Form 387 Received from: Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: BOSCOV's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 U. S. POSTAL SERVICE CERTIFICATE OF MAILING In com Nance with Postal Service Form 3877 Received from: Postage: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postmark: One piece of ordinary mail addressed to: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 P PN PUNEY HONES $ 01.05 1A 004353871 AUG31 20( MAILED FROM ZIP CODE 171 ( U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In com liance with Postal Service Form 3877 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comp liance with Postal Service Form 3877 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In com liance with Postal Service Form 3877 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 Postage: Postmark: O6 YI 7 UPITNEY BOWES Pig's $ 01.050 3871 AUG31 2007 FROM ZIP CODE 1 71 02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In com liance with Postal Service Form 3877 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: John Billman P. O. Box 56 Newville, PA 17241 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In com liance with Postal Service Form 3877 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: John Billman C/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 Postage: Postmark: Q G PQ 7j7 0', L02 00 r M t1?PS ?? PITNEY BOWES $ 02.10° 353871 AUG31 2007 :D FROM ZIP CODE 1710 2 - -n 4 _T _ a co CYI .,.aC? r-I W K (04 -5115 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Holders of ABFS Mtg Loan Trust 2002-4 is the grantee the same having been sold to said grantee on the 5th day of Dec A.D., 2007, under and by virtue of a writ Execution issued on the 22nd day of Aug, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 5415, at the suit of ABFS Mtg_Loan Trust 2002-4 Tr against Steven A Finkey & Joanne K is duly recorded as Instrument Number 200801486. IN TESTIMONY WHEREOF, I have hereunto set my hand a7I,11 eal of said office this ICy day of ?aAAj A.D. A it `l i /I Z) of Deeds Records Deeds, Cumberland County, Carlisle, PA My Con#ssion Expkes Me First Monday of Jan. 2010 JP Morgan Chase Bank, NA, as Trustee for the In the Court of Common Pleas of Registered Holders of ABFS Mortgage Loan Cumberland County, Pennsylvania Trust 2002-4 Mortgage Pass Through Certificates Writ No. 2004-5415 Civil Term Series 2002-4 VS Steven A. Finkey and Joanne K. Finkey Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2007 at 1939 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Steven A. Finkey and Joanne K. Finkey, by making known unto Steven A. Finkey, personally and husband of Joanne K. Finkey, at 36 Maple Ave., Walnut Bottom, Cumberland County, Pennsylvania its contents and at the same time handing to him 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 08, 2007 at 1243 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 Steven A. Finkey and Joanne K. Finkey located at 36 Maple Ave., Walnut Bottom, 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 defendants, to wit: Steven A. Finkey and Joanne K. Finkey by regular mail to their last known address of 36 Maple Ave., Walnut Bottom, PA 17266. These letters were mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 5, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon P. Haller, on behalf of JPMorgan Chase Bank, N.A., as Trustee for the Registered Holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass Through Certificates, Series 2002-4. It being the highest bid and best price received for the same, JPMorgan Chase Bank, N.A., as Trustee for the Registered Holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass Through Certificates, Series 2002-4 of 1675 Palm Beach Lakes Blvd., Suite 402, West Palm Beach, FL 33401 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,238.87. Sheriff s Costs: Docketing $30.00 Poundage 24.29 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Prothonotary 2.00 Mileage 26.88 Levy 15.00 Surcharge 40.00 Law Journal 503.00 Patriot News 430.28 Share of Bills 14.92 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 1,238.87 ? ??/ 3'?G Y., So Answers: R. Thomas Kline, Sheriff B'?--J?'Cu vvbkL Real Estate rgeant d?" W? ,;7, V-0 (:1"- 41 899 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701: 1. Name and address of the Owner(s) or Reputed Owner(s): STEVEN A. FINKEY 36 MAPLE AVENUE WALNUT BOTTOM, PA 17266 JOANNE K. FINKEY 36 MAPLE AVENUE WALNUT BOTTON, PA 17266 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Cumberland County Adult Probation 1 Courthouse Square Carlisle, PA 17013 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606 0674 - Boscov's Department Store Inc. c/o Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 1116 John Billman P. O. Box 56 Newville, PA 17241 John Billman c/o Melissa K. Dively, Esquire 455 Phoenix Drive Suite A Chambersburg, PA 17201-4534 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Pennsylvania Housing Finance Agency 211 North Front Street Harrisburg, PA 17101 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 Robert L. O'Brien, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made to the penalties of 18 PA C. S. Section 4904 relating to unsworn falsification to authorities. Leon P er PA I.D. #15700 P , Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: August 20, 2007 JPMORGAN CHASE BANK, N.A., AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2002-4, PLAINTIFF VS. STEVEN A. FINKEY JOANNE K. FINKEY, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2004-05415 IN MORTGAGE FORECLOSURE DEFENDANT(S) C-D NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO -" PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 rv r TAKE NOTICE:, + = j That the Sheriffs Sale of Real Property (real estate) will be held: c c DATE: Wednesday, DECEMBER 05, 2007 t I TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 36 MAPLE AVENUE WALNUT BOTTOM, PENNSYLVANIA 17266-9701 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2004-05415 JUDGMENT AMOUNT $67,775.22 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: STEVEN A. FINKEY and JOANNE K. FINKEY A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, .before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THOSE CERTAIN lots of ground with the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract No. 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to stoughstown at line of lands nou or formerly of Barry Beidel; thence by the center of said road South 36 degrees East 80 feet to a point at line of lands now or formerly of Raymond S. and Dorothy S. Black; thence by said lands South 65 degrees 50 minutes West 100 feet to a point; thence by same North 36 degrees West 80 feet to a point on line of lands now or formerly of Harry Beidel; thence by said lands now or formerly of Beidel North 65 degrees 50 minutes East 100 feet to the center line of said public road, the Place of BEGINNING. tract No. 2 BEGINNING at a point at the southeast corner of Tract No_ 1 in the center of Legislative Route 21089; thence by the center of Legislative Route 21089 South 30 degrees 9 minutes 20 seconds East 22 feet to a point at lands now or formerly of Lewis A. Goodhart, et ux; thence by the lands now or formerly of Lewis A. Goodhart, et ux, South 63 degrees 34 minutes 20 seconds West 100 feet to a point at I`aiids now or formerly of Edward L. Glass, et LIZ; thence by the lands now or formerly of Edward L. Glass, et uX, North 30 degrees 9 minutes 20 seconds West 36 feet to a point at lands *of Tract No. 1; thence by the lands of Tract No. 1 in a Northeast direction loo feet, more or less, to a point in the center of Legislative Route 21089, the point and place of BEGINNING. These measurements are in accordance with a survey made by Thomas A. Neff; a Registered Surveyor, on April 27, 1970. HAVING THEREON ERECTED A DWELLING KNOWN AS 36 MAPLE AVENUE, WALNUT BOTTOM, PENNSYLVANIA 17266-9701 BEING THE SAME PREMISES WHICH Ruth A. Craig by deed dated 8/3/90 and recorded in Deed Book 140, Page 910, granted and conveyed unto Steven A. Finkey and Joanne K. Finkey. TO BE SOLD AS THE PROPERTY OF STEVEN A. FINKEY AND JOANNE K. FR\KEY ON JUDGMENT NO. 2004-05415 ASSESSMENT NO. 41-31-2230-001 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N004-5415 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A. AS TRUSTEE FOR THE REGISTERED HOLDERS OF ABFS MORTGAGE LOAN TRUST 2002-4, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 20024, Plaintiff (s) From STEVEN A. FINKEY AND JOANNE K. FINKEY (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$67,775.22 L.L. Interest PER DIEM OF $18.15 TO SALE DATE 12/05/2007 - $15,952.20 Atty's Comm % Atty Paid $588.99 Plaintiff Paid Due Prothy $2.00 Other CostsESCROW DEFICIT - $ 2,373.72 Date: August 22, 2007 (Seal) REQUESTING PARTY: Name LEON P HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF liepury Telephone: 717-234-4178 Supreme Court ID No. 15700 Real Estate Sale # 57 On September 5, 2007 the Sheriff levied upon the defendant's interest in the real property situated in South Newton Township, Cumberland County, PA Known and numbered as 36 Maple Avenue, Walnut Bottom, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2007 By: Real Estate Sergeant v` JJ? PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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 26, November 2 and November 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 57 Writ No. 2004-5415 Civil JP Morgan, Chase Bank, N.A. as Trustee for the Registered Holders of ABFS Mortgage Loan Trust 2002-4, Mortgage Pass- Through Certificates, Series 2002-4 vs. St - . Finkey and J e K. Finkey A Leon Haller CRIPTION ALL THE CERTAIN lots of ground ?v the improvements thereon erected, situate in South Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: Tract No. 1 BEGINNING at an iron pin in the center of the public road leading from Jacksonville to Stoughstown _gJhne of lands now or -formerly -of, L sa Marie Coyne, Edl or SWORN TO AND SUBSCRIBED before me this day of November, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 The Patriot-News Co. +?... 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE ?e Patr1*ot%X1ews 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. ? [#MI finllllMllls s? Ihi? ?7... This ad ran on the date(s) shown below: 1Aa» d 7tae 10/24107 loan 10131107 rwagh 8 s 2000.4 11107107 Ys 9=A.FVd*y OW . . I ........... .. .. . ........ s p ION n& t& o d of M ' Sworn to an su cribed before this 30 day of November, 2007 A.D. T n p 11 CIMAN lots L growd, sitow in Sowh - 2 coomy, NW= P; Cad `PnosyhNia. booaded asd_descnoed IS Not4ry Public Tod No.1 B»GINNI Q at 0 inns On in 111E neater of 1110 M road > from tad OO& to owaat3?coflaedansaatfomnedyuf COMMONWEALTH OF PENNSYLVANIA ? abuy BeiK *me by the oeotrr of Wd load li Notsdai Seal - on ' Sooih 36 dWm Eat 20 feet to A paid at James L Clark. Notary Public (4) d Isms mar a tgnot of Mquand & and City Of Hartistxn9 Dauphin CountJ 7 DaotY7 S. Blade:llieatx by seal lards Soed? 65 o My CommlWw Ewres June 2, 20 C1, ut; degas so minow west im fed in a p ?eowfw to Member, Pennsylvania Association of Notaries a, pow a tiYe r[ sar'snta'tet of t rte ne by H=y Bd i ?isi? +f idii pai?c ? it ?