Loading...
HomeMy WebLinkAbout04-6052 FEDERMAN PHELAN, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION F/KIA PHH MORTGAGE SERVICES CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 04-~()~~CI'u~L~~ CUMBERLAND COUNTY v. JOHN E. STILL NKJA JOHN W STILL CONNIE M. REED NKJ A CONNIE M STILL 893 GRAHAMS WOODS ROAD NEWVILLE, P A 17241 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 File #: 107261 File #: 107261 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. 1. Plaintiff is CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 2. The name(s) and last known addressees) of the Defendant(s) are: JOHN E. STILL AIKJ A JOHN W STILL CONNIE M. REED AIKJ A CONNIE M STILL 893 GRAHAMS WOODS ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 05/18/1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. Book: 1543, Page: 23. 4. The premises subject to said mortgage is described as attached. s. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2004 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 107261 6. The following amounts are due on the mortgage: Principal Balance Interest 06/0112004 through 12/01/2004 (Per Diem $20.65) Attorney's Fees Cumulative Late Charges 05/18/1999 to 12/0112004 Cost of Suit and Title Search Subtotal $102,552.67 3,799.60 1,250.00 179.94 $ 550.00 $ 108,332.21 Escrow Credit Deficit Subtotal 0.00 448.75 $ 448.75 TOTAL $ 108,780.96 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 108,780.96, together with interest from 12/0112004 at the rate of$20.65 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN PHELAN, LLP _ / _ -,JIll' . ~ ..>: ~ By: /s/Francis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 107261 LEGAL DESCRIPTION ALL that certain tract of land, together with the improvements thereon, the same being situate in Upper Frankford Township, Cumberland County and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the center of a public road leading to Bloserville; thence along lands now or formerly of Charles Baughman North 68 degrees East a distance of 410.00 feet to a post; thence by the same, North 21 degrees West a distance of 405.00 feet to a post; thence along lands now or formerly of Harry Brownawell, South 74 degrees 30 minutes West a distance of 207.00 feet to a post; thence along lands now or formerly of the Upper Frankford Township School District (McClure's Gap Public School), South 16 degrees 30 minutes East a distance of200.00 feet to a post; thence along lands now or formerly of J.C. Chronister and crossing said public road above mentioned to the center thereof South 20 degrees 30 minutes East a distance of 312.00 feet to a point in the center of said public road, the Place of BEGINNING. Being No. 893 Grahams Woods Road File #: 107261 VERIFICATION MARC J. HINKLE hereby states that he is V.P. of CENDANT MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~/~ DATE: 1\ \Z6\t>t C) '" ~,; r:::> C) t5 J';"; Si2 -II A:J G - I C'J ~ ~ r "'1 it C) P'f:r1 ~ tij , -oF; .', N :::;,d 8 (-" {... ......... C/{ .. ::::;6 W :n ~ :::9 () ,J" I, _.:" ~ (~5 ~Jj ," r:? '.,:Co'C) ;,:5In ~ ~ -J .r- ::;! 0 :':? p- " w ~ ~ 4 , .... SHERIFF'S RETURN - REGULAR CASE NO: 2004-06052 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP ET AL VS STILL JOHN E ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT.. MORT FORE was served upon STILL JOHN E AKA JOHN W STILL the DEFENDANT , at 1946:00 HOURS, on the 6th day of December, 2004 at 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 by handing to JOHN STILL 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 5.92 .00 10.00 .00 33.92 ~~J~ -df{. . Thomas Klirte 12/07/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: 7~( 0~ Deputy Sheriff '- me this /(J ~ " ( )A~N)S' , (J 'thJf7{~.J L 1J1>?::' rothonotary j -'-' day of A.D. , . - SHERIFF1S RETURN - REGULAR CASE NO: 2004-06052 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP ET AL VS STILL JOHN E ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REED CONNIE M AKA CONNIE M STILL the DEFENDANT , at 1946:00 HOURS, on the 6th day of December, 2004 at 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 by handing to JOHN STILL, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~.~ R. Thomas Kline 12/07/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: ?;C~y ~;;rtf me this /6 ~ day of C}~ .;2.-IJVS/ A. D . (~~Q ~ -- Prothonotary I ~ , .. AFFIDAVIT OF SERVICE , I \ , I CUMBERLAND C01FY No. 2004-06052 CIVIL ! PIT PLAINTIFF CENDANT MORTGAGE CORPORATION FIK/A PHH MORTGAGE SERVICES CORPORATION ACCT. #0002731925 DEFENDANT(S) JOHN E. STILL AlK/A JOHN W. STILL CONNIE M. REED AlK/A CONNIE M. STILL Type of Action j - Notice of Sheriff's Sale II , 'I Sale Date: JUNE 8, 2005 'I SERVE CONNIE M. REED AlK/A CONNIE M. STILL AT 893 GRAHAMS WOODS ROAD NEWVILLE, P A 17241 o~ ~i . , Defendant. on tbe I ( ,.) day of,) (ZL L, GV<7t,'6 "'-" '." \;J DC> ~ '> f: J, ) , \2 v..; V \ \ \ ~ " \ II ~l, I' I! I II an officer of said Defendant(s)'s company. t Ih I' I f/ 1 ) "I!A ~i Des<;ription: Age:5 ~ Height Sru Weigbt~ Race wl, Sex~ Otber '5 fC5 I, ('\>1" <:: ~C"- h, C~~\f,nJient adul~ being duly swomaccording to law, depose and stale that " personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in he captioned case on the date and at the address indicated above. Served and made known to GQJ \oJ'1 \' --- ,200!!at 10 ;;ZO,o'clockfm.,at 81~) I ! SERV\fD jV\ < 'Sl-; \ I Commonwealth of PennsyLvania, in the manner described below: Defendant personally served, / i -.;:t- Adult family member with whom Defendant(s) reside(s). Name and Relationship is Au'3 '0 c;, 110 --r-=- Adult in charge ofDefendant(s)'s residence whn refused to give name or relationship, Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business, ~~w ~ 1 S~"\\ Other: Sworn to and subscribFJd beforj:et ~ .J..J!J-!J/tii!y . ' of 1QV,.200.-;) ///, f) , Notary:&<ed.,Cc ~"-~ By: (!' ~ {J' ( PLEASE ATTEMPT SERVlCE AT LEAST 3 TIMES. INDICATE DAT ATTEMPTED. NOT. IAI. SEAL LUClU.E H, CI RiV, Nolary PubIc ( LelteI1!enny 'k:, :,,~]p. Frnnid'1O Countv My ~ . Nov.10,2OO1' NOT SERVED On the day of ,200~at o'clock _,m,. Defendant NOT FOUND becaus~: Moved Unknown No Answer Vacant 1" Attempt: / / / / Time: 20d Attempt: / / I Time:-+- I: ii 1 ,I 'I " 'I 'I I I ': " " I I , , I 3rd Attempt: Time: Sworn to and subscribed before me this _ day of ,200_. Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - I.D. No. 62205 "-, (:::;J c.-~ -11 c.n , -,"., \.::.' AFFIDAVIT OF SERVICE 1 \ I CUMBERLANJ COUNTY r PIT No. 2004-06052 CIVIL ! ACCT. #0002731925 ! . i Type of Action] - Notice of Sheriff's Sale 'I , " Sale Date: JUNE 8, 2005 II PLAINTIFF CENDANT MORTGAGE CORPORATION FIK/A PHIl MORTGAGE SERVICES CORPORATION DEFENDANT(S) JOHN E. STILL AfKfA JOHN W. STILL CONNIE M. REED AfKfA CONNIE M. STILL SERVE JOHN E. STILL AfKfA JOHN W. STILL AT 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 SERVED Served and made known to ~V F, Cjtf'\ \ . Defendant, on the at /O:,)~O'clock+m"at "3 C'v'gl$>c,c,." Cuoo~S of PellIlBylvania, in the manner described below: ---i:Defendant personally served, Adult family member with whom Defendant(s) reside(s), Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place oflodging in which Defendant( s) reside( s). I Agent or person in cbarge of Defendant(s)'s office or usual place of business, ~ an officer of saId Defendant( s)'s company. I Oth~: l~ Description: Age ~ Height S Ie) '~elght /8 i) ~e kit" Sex y\1 Other 5 VG 5 t:" 'S I, C~\fC +-'C ~ h, ~\-)]: ~mpetent adult, bemg duly sworn according to law, depose and state that personally banded a true and correct copy of the Notice of Shenff's Sale ID the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. - NC :rARIAI. SEAL LUCILlE H Ct.RTY. Nct3lVPublc LetterlIenny T ',"-nSl1ip. Franklin County My '.. Exp/i'esNcN.10,2OO?' Sworn to and SUb/8i~ befo~e th1s _ a: of 1l-~'-1v1 .200_, Notary, 'f. ,~/ Ii -I . eJ-t<.-t..A-i)..c.- fV_hJ~'-O PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DAT / ES OF SERVICE A TEMPTED. On the day of I! NOT SERVED I, I ,200_, at o'clock _,m., Defendant NOT FOUND becaus~: I Moved Unknown No Answer Vacant 1" Attempt: / / / / Time: 2nd Attempt: / f I I: Time:--L-. : I' -- Ii I ':1 3rd Attempt: Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - LD. No. 62205 :--.') c::~) , (" ..:-;;) -, 1 " ,. . -:~ , I -',"1 1'-..) I f") , ,~:, ) - PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST A nON 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215\ 563-7000 CENDANT MORTGAGE CORPORATION F/KIA PHH MORTGAGE SERVICES CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 2004-06052 CIVIL JOHN E. STILL AlKJA JOHN W. STILL CONNIE M. REED AlK/A CONNIE M. STILL Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against JOHN E. STILL AlK/ A JOHN W. STILL and CONNIE M. REED AlK/A CONNIE M. STILL, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 12/1104 to 3/3/05 TOTAL $108,780,96 $1,920.45 $11 0,701.41 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~J (, trJn...Uit DANIEL G. SCHMIEG, E DIRE Attorney for Plaintiff DATE: /'1~ P, d-000 7<, DAMAGES ARE HEREBY ASSESSED AS INDICATED, PRO PROTHY PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq" Id, No, 32227 Francis S, Hallinan, Esq" Id, No, 62695 Daniel G, Schmieg, Esq" Id, No, 62205 Philadelphia, P A 19103 (? 1 ,) '1i1-7000 ATTORNEY FOR PLAINTIFF FILE Copy CENDANT MORTGAGE CORPORATION FIK/A PHH : COURT OF COMMON PLEAS MORTGAGE SERVICES CORPORATION Plaintiff : CIVIL DIVISION Vs, : CUMBERLAND COUNTY JOHN E. STILL NKJA JOHN W, STILL : NO. 04-6052 CIVIL TERM CONNIE M, REED NKJ A CONNIE M. STILL Defendants TO: JOHN E. STILL AfKJA JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 DATE OF NOTICE: DF,("F,MRF,R 28 2004 THIS FIRM IS A DEBT COLLECfOR ATTEMPTING TO COLLECf A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECf THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECf A DEB~ BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. li\lI'ORTANT 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A I' ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T, Phelan, Esq" Id, No, 32227 A TIORNEY FOR PLAINTIFF Francis S, Hallinan, Esq" Id, No, 62695 Daniel G, Schmieg, Esq., Id, No, 62205 Philadelphia, PA 19103 (? 1 'i) 'i1i1-7000 CENDANT MORTGAGE CORPORATION FIK/A PHH : COURT OF COMMON PLEAS MORTGAGESER~CESCORPORATION Plaintiff : CML DI~SION Vs, : CUMBERLAND COUNTY JOHN E, STILL AIKIA JOHN W. STILL : NO. 04-6052 CIVIL TERM CONNIE M, REED AIKI A CONNIE M, STILL Defendants TO: CONNIE M. REED AfK1A CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 DATE OF NOTICE: DFCFMRFR 28 2004 THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECf A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATIEMPT TO COLLECf THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE,lF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECf A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A IIEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELlGlI3LE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOClA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (SOO )990-9108 FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RE ohd - REGULAE CASE NO: 2004~06052 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBEELAND CENDANT MORTGAGE CORP ET AL VS STILL JOHN E ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STILL JOHN E AKA JOHN W STILL the DEFENDANT at 1946:00 HOURS, on the 6th day of December, 2004 at 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 by handing to JOHN STILL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directin3 His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18,00 5.92 .00 10,00 ,00 33,92 ~/~ . TllOmas Kline 12/07/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: -7/ 1/ .I; /I-..~l 4.--....'~ t~. Deputy Sheriff me this day of A,D, .-Prothonotary PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SmTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION FIK/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY 4001 LEADENHALL ROAD COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 2004-06052 CIVIL JOHN E. STILL AlKJA JOHN W. STILL CONNIE M. REED A!K/A CONNIE M. STILL Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended, (b) that defendant JOHN E. STILL AlKJ A JOHN W. STILL is over 18 years of age and resides at, 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241. (c) that defendant CONNIE M. REED AlKJA CONNIE M. STILL is over 18 years of age, and resides at, 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn falsification to authorities, ~~.P (, .w.."A~ DANIEL G. SCHMIEG, ES UIRE Attorney for Plaintiff . LEGAL DESCRIPTION ALL THAT CERTA[N tract of Land, together widl the improvements thereon, the samc being simate in Upper Frankford Township, Cumberland County and State of l'ellllsylvania, 11OOI1ded and described as foUows, to wit: BEGINNING at a point in the cellter of a pubLic road leading to BloservilJe; thel1Ce along lands l1QW or formerly of Charles Baughman North 68 degrees basl a dist-dIlCc of 410.00 feet to a post; thence by the same, North 21 degrees West a diJ.unce of 405,00 lect to a po!ll.; thence along lands now or formerly of Harry Rrownswell, Soulh 74 degrees 30 minules Wcsr a distimCC of 207.00 feel to a post; thence along land.~ now or formerly of the Upper Fr.m1ford Township School DiSlrict (M~-clure's Gap Public Scllool). Sou!h 16 degrees 30 minutes East a distance of 200,00 fm to a post; thence along lands oow or furmerly of lC, Chronister and crossing said public road above tneI1tioucd to the center thereof South 20 degrees 30 minutes East a distance of 312.00 feet to a point in thc centcr of said public road, the Place of Ileginning, CONTAINING 3.42 <lCres, according 11) a survey made by T, 12Iliot Milldleton, Rcgistered Surveyor, on !he 28th day of December, 1945, which survey was Irulde 10 correet an inadequate and incorrect description as contained in the deed IIf Sarah E, Burkholder to Marget M. Snyder (also known and written as Matilda Snydcr) said deed hearint; dated the 2nd day of January, 1904, and recorded in lhe Office of the Recorder of Deeds at Carlisle, PA, in Deed Ilook 'G', Volume 9, Page 45. TITLE TO SAID pREMISES [S VFSTED IN Jolm W. Still, singlcman and Connie M, Reed, single WOIIWI by Deed from Guy W, Etter, widower dated 51l8/1999, recorded 5/19f 1999. in Record Hook 199 Page !!70. PROPERTY ADDRESS: 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241 TAX PARCEL: 43-04-0385-029 (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION 4001 LEADENHALL ROAD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 2004-06052 CIVIL v. JOHN E. STILL AlK/A JOHN W. STILL CONNIE M. REED AfK/A CONNIE M. STILL Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on (Yl~r/ 20~\ If you have any questions concerning this matter, please contact: DANIEL G, SCHMIEG. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST AnON 1617 JOHNF, KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 --THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY,-- .(Q. (':::l -a c~'iQ ~ -t.\) ~~s,~ t" V) ~ ~ r t f: ~ -I--. - --L R () ~.j'i \ c:) cp (,...) ,1..~' PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION FIKIA PHH MORTGAGE SERVICES CORPORATION Plaintiff, v. No. 2004-06052 CIVIL JOHN E. STILL AJKJA JOHN W. STILL CONNIE M. REED AJKJA CONNIE M. STILL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $] 10,701.41 Interest from 3/3/05 to JUNE 8, 2005 (per diem -$18.20) $1,765.40 and Costs TOTAL $112,466,81 j~ G ~dM1~ DANIEL G, SCHMIEG, E DIRE One Penn Center at Suburban Station ]617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No, IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ,..$ O~ ~'" ~~ ~m ZZ ~~ ~ " O~ Uz ,..~ 00 U ';~ ~~ 8; e~ ...~ ~~ u ~ J"} ':-) r"'~ '~-" O? I l.r'l c,;::} ~:.~ -{)-~', - - Q~ ' . \ i::: "\Jd (l- ,(j a Z goo S~ 0& %~z u~g ~<'< CC~ ~';o ';o~ o~o ~~u ...~ ~< ~~ z- ~,.. u ri 0"- lJ) C") -..('/) ~ ,;, ... ,.;l ,.;l== ,.;l'" ~m .... m~ ~ea zZ ~z 00 ..,u << ~~ << ,.;l~ ~~ r.A~ zea ~z Oz "'0 U , ~ ~ ::: , I I .;:) J () () () VJ () 0. ~~O-:~ s ... ';;l u ~'E ~ ::l '" ,.. " o~ ... "" ;~ ~~ ~1Oll ot: ,.. " ~'g, e: u S ~ ::: ,~ $l Do< ... ..g '-'''' e o ~ .i:j ., - '... ~ ::: ':::: c3j -8 0 () 0, r/, 0- t>,-'W' N) ""J ........ ...,....,. ",,,, r--r-- ........ << ~~ ~~ ~~ zZ ~~ gg 0000 ~~ 00 00 ~~ 0000 ~~ ~~ ...,..., a-oa-o QOQO 00 <n ., ..\5 ~ "5 l: ., <n ,g [;;' g <n 'is ~ p. ~ ~ ~ rl, ~ t-- Cl- ~ G - --... --:::t ::r - l1t v (j ~ iT ----t: 'Q! 3 -.J c8 . LEGAL DESCRIPTION ALL THAT CERTAIN tract of land, together with the improvements thereon, the same being simate in Upper Franlcford Township, Cumberland County and State of !'ell/lsylvania, hounded and described as foUows. 10 wil: 8EOINNING at a point in the center of a public road leadin~ to Bloserville; thence along lands oow or formerly of Cbarl~ Baughman North 68 degrees liasl a distaIK;e of 410.00 feel 10 a post; thence by the same, North 21 degrees West a dbtoll\;e of 405,00 fecI [0 a post; thence along lands now or formerly of Harry IlrOlvnsweU, South 74 degrees 30 minutes We.st a dis!an<;e of 207 ,00 fccllO a p<lS1; thence along land.s now or formerly ofd1e Uprx:r F.dnkford Township School Disui<.t (M<.'Clurc's Gap Public School). South 16 degrees 30 minutes Ells! II distancc of 200,00 feet to a post; thence along lands now or fonnerh' of J.e. Chronister and crossing said public road above lIlelltiollcd to lhe center thereof South 20 degrws 3() millUtcS EaRl a dlstmce of 312.00 feet 10 a point in the center of said publk road. the Place of De~, CONTAINING 3.42 <lCre5. a<;x,xm.lillg to a survey made by '1', Elliot Middleton, Registered Surveyor, on !be 28th day of Ilecember, 1945, which survey was made to correct 8J1 inadequate and incorrect de.'lCription as contained in the deed of Sarah E. Burkholder to Marl,l"ef M. Snyder (also known and wrilten as Matilda Snyder) said deed bearing dated the 2nd day of Jauuary, 1904, and recorded in the Office of the Recorder of Deeds at Carlisle, PA, in Deed Ilook "0", Volume 9. Page 45, TITLE TO SAID l'REMI~ES \S VFSfED IN JoIm W. Still, singlcrnan aod Connie tot, Reed. single WOIIWl by Deed from Guy W. Eller, widower dated 511811999, recorded 511911999. in Record Book 199 Page 870. PROPERTY ADDRESS: 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241 TAX PARCEL: 43-04-0385-029 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6052 Civil CIVIL ACTION ~ LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION FIKIA PHH MORTGAGE SERVICES CORPORATION, Plaintiff (s) From JOHN E. STILL AlKlA JOHN W. STILL, CONNIE M. REED AlKlA CONNIE M. STILL (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 ofthe 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 himlher that he/she has been added as a garnishee and is enjoined as above slated, AmountDue $1l0.701.41 L.L. $.50 Interest FROM 3/3/05 TO 6/8/05 (PER DIEM - $18.20) - $1,765.40 AND COSTS Atty's Corom % Due Prothy $1.00 Alty Paid $131.92 Other Costs Plaintiff Paid Date: MARCH 8, 2005 CURTIS R. LONG (Seal) ProthonotarY ~y: ~a....." J} ~!J)/Z<'I ",,;- Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORA TlON CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION JOHN E. STILL AlK/A JOHN W. STILL CONNIE M. REED AlK/A CONNIE M. STILL NO. 2004-06052 CIVIL Defendant(s). CERTIFICATION DANIEL G, SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities. A~pr;,.~ DANIEL G. SCHMIEG, SQUIRE Attorney for Plaintiff ")':;-' co - -"", 1,:"," :;-:.1 c-::' c,.) (.f\ Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center _ Military Status Report .. Pursuant to the Servicemen's Civil Relief Act of2003 MAR-03-200507:42:16 -<Last Name First Middle Begin Date I Active Duty Status I Service/Agency STILL JOHN E, Currently not on Active Military Duty, based on the Social Security Number and last name provided, Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant( s), per the Information provided, as to all branches of the Military. ~W~CJ-~ Robert J, Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd" Suite 400 Arlington, V A 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research will be done. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non- match. https://www.dmdc.osd.mil/udpdri/ owa/sscra, prc _Select 3/3/2005 Request for Military Status Page I 0 f 1 Department of Defense Manpower Data Center A Military Status Report . Pursuant to the Servicemen's Civil Relief Act 01'2003 MAR-03-200507:43:15 <:Last Name First Middle Begin Date I Active Duty Status I Service/Agency REED CONNIE M. Currently not on Active Military Duty, based on the Social Security Number and last name provided, Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military, ~w~O-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research will be done. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non- match. https:/ /www.dmdc.osd.milludpdri/owa/sscra.prc _Select 3/3/2005 CENDANT MORTGAGE CORPORATION F/KJA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN E. STILL A/K/A JOHN W. STILL CONNIE M. REED AlKJA CONNIE M. STILL NO. 2004-06052 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATiON F/KJA PHH MORTGAGE SERVICES CORPORATiON, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241. I, Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JOHN E. STiLL AlKJA JOHN W. STiLL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED AlKJA CONNIE M. STiLL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 2, Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None . 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa, C.S. Sec, 4904 relating to unsworn falsification to authorities, March 3, 2005 DATE 1L-.v.iJ (; . 2.-l",~~ DANIEL G, SCHMIEG, E QUIRE Attorney for Plaintiff ....'r ::;/;,: :::0 (, {,:f.) -,.( c,) (..fi CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 2004-06052 CIVIL v. JOHN E. STILL NK/A JOHN W. STILL CONNIE M. REED NK/A CONNIE M. STILL Defendant(s). March 3, 2005 TO: JOHN E. STILL AiK/A JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED AiK/A CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at. 893 GRAHAMS WOODS ROAD. NEWVILLE, PA 17241, is scheduled to be sold at the Sheriff's Sale on JUNE 8. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $110.701.41 obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa,R,C.P., Rule 3129,3, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5, You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7 , You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale, CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lraa of land. together with the improvements thereon, the same being simale in Upper Franl;ford 'I'owllJlhip. Cumberland County and Stale of Pennsylvania. hounded ami described as follows, ro wit: BIo:GINNING at a point in tile center of a public road leading to Rloscrville; thern;e along lands now or forlDl:r1y of Charles Baughman North 68 degrccs East a disl'dIlCe of 410.00 feet ro a post: tbence by the same, North 21 degrees West a dh'tlllll.'e of 405,00 feet to a post; tbence along lands now or formerly of Harry Brownswell, South 74 degrees 30 minules West a distalll:e of 207,00 fect to a post; thence alollg laud.s now or formerly of tile Upper Pr.mkford Township School Distric;t (M~'Clure's Gap Public School). SQuth 16 degm:s 30 minllleS East a distance of 200,00 feet to a post; tI1encc along lands now or formerly of j,C, Chronister and crossing said public road above mentiollCd to the center thereof Soutl120 degn.'Cs 30 millUtcs EaIlt a distance of 312.00 feet to a point ill tI1c centcr of said public road. the Place of Beginning, CONTAINfNG 3,42 acr~. ao:.ordillg to a survey nude hy T. 12Ilio\ Middleton. Registered Surveyor, on the 28th day of Oecember, 1945, which survey was made to correct an inadequate and incorrect description as contained ill the deed of Sarah E. Burkholder to Marget M. Snyder (also known ami writren lIS Matilda Snyder) said deed hearing dated the 2nd day of January, 1904. and reconJed in the Office of tbe Recorder of Deeds at Carlisle, PA, in Deed Book "G", Volume 9. Page 45. TITLB TO SAil) pREMlSFS IS VESTED IN john W. Still. singlcman and Connie M, Reed, s.ingle woman by Deed from Guy W. Etter, widower dated 511811999. recorded 5119/1999, in Record Book 199 Page 870. PROPERTY ADDRESS: 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241 TAX PARCEL: 43-04-0385-029 " c' -" -, ~~ -.( :;,j \ cP , (..1 U" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENDANT MORTGAGE CORPORATION F/KJA PHH MORTGAGE SERVICES CORPORATION ) CIVIL ACTION ) vs, ) CIVIL DIVISION ) NO, 2004-06052 CIVIL JOHN E. STILL AIKIA JOHN W, STILL CONNIE M, REED AIKIA CONNIE M, STILL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, DANIEL SCHMIEG, ESQUIRE attorney for CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION hereby verify that on March 8. 2005 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto, DATE: Mav 5, 2005 IEL G, SCHMIEG UIRE Attorney for PI ' tiff .. CENDANT MORTGAGE CORPORATION FIKIA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN E. STILL AIKIA JOHN W. STILL CONNIE M. REED AIKIA CONNIE M. STILL NO. 2004-06052 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 893 GRAHAMS WOODS ROAD. NEWVILLE. P A 17241 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JOHN E. STILL A/K/A JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED A/K/A CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, P A 17241 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa, C.S, Sec, 4904 relating to unsworn falsification to authorities. March 3, 2005 DATE ~/j (, , ~rim~~ DANIEL G, SCHMIEG, E QUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION FIKlA PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 2004-06052 CIVIL v. JOHN E. STILL AIKIA JOHN W. STILL CONNIE M. REED AIKIA CONNIE M. STILL Defendant(s). March 3, 2005 TO: JOHN E. STILL AlKlA JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED AlKfA CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY ** Your house (real estate) at. 893 GRAHAMS WOODS ROAD. NEWVILLE. PA 17241. is scheduled to be sold at the Sheriffs Sale on JUNE 8. 2005 at 10:00 a,m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $110.701.41 obtained by CENDANT MORTGAGE CORPORATION F/KlA PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R,C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings, t~) c-::-, ,:.:. UI <: ) -n I :; :-r-" -". " Cd 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 Sheriffs Deed in which Phh Mtg Serv Corp is the grantee the same having been sold to said grantee on the 8th day of June A,D" 2005, under and by virtue of a writ Execution issued on the 8th day of March, A.D" 2005, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 6052, at the suit ofCendant Mtg Corp against John E Still aka John W & Connie M Reed aka Connie M Still is duly recorded in Sheriffs Deed Book No, 269, Page 3899. IN TESTIMONY WHEREOF, I have hereunto set my hand /~ and eal of said office this day of Cendant Mortgage Corporation flk/a PHH Mortgage Services Corporation VS John E. Still a1k/a John W. Still and Connie M. Reed a1k/a Connie M. Still In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2004-6052 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2005 at 8: 12 0' clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: John E, Still a1k/a John W. Still and Connie M. Reed a1k/a Connie M, Still, by making known unto John E. Still, personally and husband of Connie M. Still, at 893 Grahams Woods Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same, David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2005 at 4:03 o'clock P,M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John E. Still a/k/a John W. Still and Connie M. Reed a/k/a Connie M. Still located at 893 Grahams Woods Road, Newville, 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: John E. Still a/k/a John W. Still and Connie M. Reed a1k/a Connie M. Still, by regular mail to their last known address of 893 Grahams Woods Rd., Newville, P A 17241, These letters were mailed under the date of April 18, 2005 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 June 8, 2005 at 10:00 o'clock A.M, He sold the same for the sum of$1.00 to Attorney Daniel Schmieg for PHH Mortgage Services Corporation f/k/a Cendant. It being the highest bid and best price received for the same, PHH Mortgage Services Corporation f/k/a Cendant of 4001 Leadenhall Road, Mount Laurel, NJ 08054, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of$935.78. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library $30,00 18.35 15.00 15.00 30.00 10,00 .50 Prothonotary Mileage Certified Mail Levy Surcharge Postage Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 1.00 13.32 9.12 15.00 30.00 .74 339.80 326.98 16.47 25.00 39.50 935.78 Sworn and subscribed to before me So Answers: This It' dayofql, r~-~t:.~~ Q I _ R. Thomas Kline, Sheriff 2005, AD. ----1' ~ Q. /t~ ~ J' C'_u r thonotary , BY c ~ ~ Real Estate eputy -~~ lYQ~ 30'(j'D I,':.-D b()~:"1... ~k._., / ~. /(,J,/3~ CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN E. STILL AlK/A JOHN W. STILL CONNIE M. REED AlK/A CONNIE M. STILL NO. 2004-06052 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 893 GRAHAMS WOODS ROAD. NEWVILLE. PA 17241. I, Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JOHN E. STILL AlK/A JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED AlK/A CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 2, Name and address of Defendant(s) in the judgment: Same as above 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: . Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 OS I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties ofl8 Pa, C.S, Sec, 4904 relating to unsworn falsification to authorities. March 3, 2005 DATE ~i.J (,. 2ri..UJ~ DANIEL G, SCHMIEG, E QUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION FIK/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 2004-06052 CIVIL v. JOHN E. STILL AfKIA JOHN W. STILL CONNIE M. REED A/KJA CONNIE M. STILL Defendant( s). March 3, 2005 TO: JOHN E. STILL AlKJA JOHN W. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 CONNIE M. REED AlKJA CONNIE M. STILL 893 GRAHAMS WOODS ROAD NEWVILLE, PA 17241 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THA T PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, ** Your house (real estate) at, 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241, is scheduled to be sold at the Sheriffs Sale on JUNE 8, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $11 0,701.41 obtained by CENDANT MORTGAGE CORPORATION FIKJA PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C,P" Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. Ifthe Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORT ANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the olaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lIact of land, together with the improvements thereon, the same being situate in Upper Franlct'ord Township, Cumberland County and State of Pennsylvania, hounded and described as follows, to wit: BEGINNING at a point in tI1e celller of a public road leading to Bloscrville; thence along lands !IOW or formerly "f Charles Baughman Nord1 68 degrees East a distance of 4.10.00 feet ro a pott; thence by the same, North 21 degrees West II distance of 405,(1() fect to a post; thence along lands now or formerly of Harry Brownswell, Soutll 74 degrees 30 minutes West II dislani:e of 207,00 feet to a post; llletlcc along land.~ now or formerl)' of the Upper Plankton! Townsllip School Diwicl (M~'CIure's Gap Public School), South 16 d~ 30minules East a distance of 200.00 ti:ct 10 II post; thence along lands now or formerly of J,C. Chronister and crossing said public wad above mentioood to the center thereof Soulb 20 degrees 30 mitlllWi Easl a distance of 312.00 fm to a poinl in the centcr of said public roa4l, the Place of Deginning, CONTAINING 3.42 acres, at:l:>Ording to a SIIrvcy made by T. UlIiot MiddletQn, Registered Surveyor, on !be 28lb day of December, 1945, which survc:y W'as made to correct an inadequate and incorrect description as conrained in the deed of Sarah E. Burkholder to Marget M. Snyder (a1SQ known and wrillellll8 Matilda Snyder) said eked bearing dared the 2nd day of Jalluary, 1904. and recorded in !be OffICe of the ~order of Deeds 31 Carlisle, PA, in Deed Book '0', Volume 9, Page 45. TITLE TO SAID PRfiMlS~ IS VF4'ITED iN John W. Still, singleman and COIl.lIie M. Reed. single WUIIlllIl by Deed from Guy W. Etter, widower dated 5/18/1999, recordtd 511911999. in Record Book 199 Page !r70. PROPERTY ADDRESS: 893 GRAHAMS WOODS ROAD, NEWVILLE, PA 17241 TAX PARCEL: 43-04-0385-029 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION F/K1A NO 04-6052 Civil CIVIL ACTION - LAW PHH MORTGAGE SERVICES CORPORATION, Plaintiff(s) From JOHN E. STILL AlKlA JOHN W. STILL, CONNIE M. REED AlKlA CONNIE M. STILL (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 gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $110.701.41 L.L. $.50 Interest FROM 3/3/05 TO 6/8/05 (PER DIEM - $18.20) - $1,765.40 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $131.92 Other Costs PlaintitTPaid Date: MARCH 8, 2005 CURTIS R. LONG (Seal) prothon~ ~ rJ",..,-, P 7lz0l 4/L r--- Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG ESQillRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No, 62205 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 whicb is securely attached hereto is exactly as printed and published in their regular daily andlor Sunday/ Metro editions which appeared on the 26th day(s) of April and the 3rd and 10th day(s) of May 2005, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, COpy S ALE #35 Sworn to and subsc PUBLICATION CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publication attacbed hereto on the above stated dates 326,98 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By......,......,..........,........,......,..,......,....,........,.., PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: 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. SWORN TO AND SUBSCRIBED before me this 29 day of April NOTARiAl SEAL LOIS e. SNYDER, Notary Public CerlisIe Bolo, Cumberland County My Commis8Ion ElqlIres Man:h 5, 2009