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Home My WebLink About04-6399SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 82628, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 Milwaukee, WI 53201-1169 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: VS. Barbara M. Flot 624 4th Street New Cumberland, PA 17070 DEFENDANT COMPLAINT - CIVIL ACTION 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 82628, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 COURT OF COMMON PLEAS CUMBERLAND COUNTY Milwaukee, WI 53201-1169 PLAINTIFF VS. Barbara M. Flot 624 4th Street New Cumberland, PA 17070 DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp., the address of which is, P.O. Box 1169, Milwaukee, WI 53201-1169, brings this action of mortgage foreclosure upon the following cause of action: Parties to Mortgage: Mortgagee: Gateway Funding Diversified Mortgage Services, L.P. Mortgagor(s): Barbara M. Flot (b) Date of Mortgage: March 26, 1998 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1443 Page 35 Date: April 2, 1998 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Gateway Funding Diversified Mortgage Services, L.P. Assignee: Fleet Mortgage Corp. Date of Assignment: March 26, 1998 Recording Date: April 2, 1998 Book: 572 Page: 751 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 624 4th Street, New Cumberland, Pa 17070 and is more specifically described as attached as part of Exhibit "A": 4. The name and mailing address of each Defendant is: Barbara M. Flot, 624 4th Street, New Cumberland, PA 17070 The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2004 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of December 16, 2004: Principal of Mortgage debt due and unpaid $77,084.76 Interest currently due and owing at 7% per annum calculated from July 1, 2004 at $14.78 each day $2,497.82 Late Charge of $27.83 per month assessed on the 16th of each month from August 16, 2004 to December 16, 2004, (5 Months) $139.15 Escrow Advances made by Plaintiff $223.64 NSF Check Fee $15.00 Property Inspection $8.90 Mortgage Insurance Premium $54.34 Title Search/Report Fees $250.00 Attorneys' Fees and Costs $1,500.00 TOTAL $81,773.61 Interest accrues at a per diem rate of 14.78 each day after December 16, 2004 that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' 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 attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seg., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & KREISMAN, LLC Date: ?4-??`?? BY: Dana Zion, Esqui Attorney for Plai ' f S & K File No. 04-23323 Dec-13-2004 15:47 From-PREMIER ABSTRACT +243 3390 T-569 P•007/030 F-018 rtral- /6?J •I 14 ?. i.W 1.1 Rrclw.P ?? CO1N-1Y1746 ?,? 01' DEF.05 "a i.9l;,Nff couNr.f'A '98:9Pti X RfR 10 55 ParxtNmabcr z9-ZS-OOtl6-109 ISpp Agri tfir ltaa /ar irmrdae awN Af at zr Rat t nmad Ractn t4: DIVERSIFUD L.P. MORTGAGE ppn?• Aqa First Avanoa 2nd 71r Oenshohoahan. P& 1946 41TN: PLual8113ST Doettsaae Dapateaant 9roparod by STILO TWS MORTGAGti^Socurky lastrvmcnt) is given os HAM 26, 1996 Tho mortgagor is 3 UAR4 K FLOT (-SOfrmWar'). TWA Sowhy luatrummtt is given to ""MAT FONDYNC PSvLASSPIgD Man t= 130xv%cgv, L. P. . which h orgadiaed and muzling under the lawn of acriownreaith of P•nnsyivania , nod whoa addtcu1& Ono V4sO First Avmans. 2n4 pia Ctaaahebeekan. PA 19426 rltutder'). Dorrowa awes l.eetdtx rfu prladym) mum of Eig>rey ft raa Thottaand 63rt Hundred and no/100 DaUara (U.S. S 69, 600.00 ). 71tk debt is rAdcneed by Dorrower'a note dald Uw )tans data ae tlda Statmritylasttmaeat('Note). trbielt p ovideafor moatbly payments, wild da full daht, it va pad tardier, du: and payable to APRIL 01, 2028 116 Sccurity1ustrume-4pcweatoLeader.(s) thefopyymeatofamdobtoWdencedbytheNote,wiltlttt .wdallrusmak m "oas and modirrAdo s of the Norm (b) no payment of aR *am soma, witb interes4 advanud under puagapb 7 to protect the am ily of thin Sawrity hatrhmenq and (c) Nte pufttrmaeeeaf Borroww s om ansou and 4peememundar tbft Severity luzzumt:atand the Now For this purpose, Born madam hereby zwtgo a, grant and mom to Ltndertba fmumwing desrrihed property bmeled id CMMZR f NM Cmmty. ftwo lvania: BRING MM SAME PYLws= 7VgZcH BY DEED DATED OF EVBN DATE KUZV= "b In=090 TO BE RECORDED MOI UTZLY MM HEQBTO. "M in LAW RZOORD8 ov CUSURL D cOum. VAS GRANTED AND 4'ONVEM NY MATR OF GA= E CGOKX= VM RARDARA M FLOT TBE BORROMM(S) EERITH, XX M, AS MORE PARTICOLARLY DESCRIBED ]N Tu ATTACHED ma= "A", whieb has L6 addreao of 624 4TN STRERT, NN C11NgYRLlutu Pesmytvania 17070 fZIrCMI ffropmtyAddrop% PEWAYLVAFMAMWO FAwAV WMAfijM& UNOPM N{a'lAumuffr Pon ease 4wk;*Pnl 041" N?'? h,.t.la .tr t w t ' BOIIIIl443PIfCE 35 [`-.erect, ayi• 11111,1111 t? EXHIBIT ki A Dec-13-2004 15:47 From-PREMIER ABSTRACT +243 $390 T-569 P-008/030 F-016 CONV.12174i TOOBT95110WITN ail the Impraramaalsnow or 11anoaftwwadodoa the property, and all maramraats,apputleeutnas,aaul rmdares now or uaraatler a part of the property. All reptaaem nla and ¦dditiarat aball also bu covwcd by this Seeuoty Instrument. All of the linwina is tarmrred to in thb Suavity roalrumant ax the 'Prop": 0ORRO WEPCOVBNANTSIb41l3ortowoe'r lawfully SCIadd of the atateheteby ranvayed end ban tho right to mallma. grant and convey the Property and Chat Ilia Property is a aeneumbsrat,ampt Jar anaimbraansof tacord. llon ww warrhntx and will defend Vocrelly rho title to the Property adalost all daio ; and demandr, ambjeat to any ancnmbroaeu of record. THIS SECUR171TINSMUMi3 ooralslaw o (form evuletams for national wo and van-ItW m covenants with tirolied variations, by jurisdtedoo to constitute a unlform security Instrument covering real properly. UNiFORMCOVEMAKMODfrowtrawdl4wdaraomxw4andagreeas Wlaws: 1. Payment of Prfadpal and lsioreatt Provs3os eat and Lb chews. awrowcr slwli promptly pay whan dun the prim ipat of and bamw oo the debt IrMenand by the Moro and any pvepsymem and Into charges due under the Note. 4 Fonda for Taxes and lasuranee. Subject to applkabk law qr to a written waiver by Lender, Borrownrdwll pay to Lcndoran the day monthly payments are due under tho Note, urwil the Note is paid is fwit, a sum ('Puadsl) tar, (4)yearlY taxes and smuntantawltitb may attain priority mar dlis Scantily Inoumowas a 6ao on the Propmiy, (b) yearly kasebaldpaymcau or around romans the ItoperlA if not. (a) yearly bW^A orpeopanyinsurance premfunu:(d)yoRdY flood tawranaopraaidms, if any; (e) ytotty mortgageinsurance premiums, Ir any; and (Q any sums payable by tlorrowev to Lander, is aaeardaaftwith the provisions of ttaraaraphil, In lien of the psymeoeor moryasolWtrascapratsiums Thesciteassarmcatiod'Watow fiuous.` Lander may, at any lima, collect and Qotd FunJx le as amauntttot to fa=W the modmirm amount a leader for a fudarany related oxamculya loan may require for Barrowar's oscrow aewuat under the federal Real P.ttatoSoulementPtoeadurasAtt of 1714 as amandatifrom trout to time, %2 US.C. Section 2601 m ssq ('RESpA"), ilnkU ft"Wlaw that apptfes to the Ponds sec a teaser amount. If so, Lender may, at any time, called and hold Funds in an smuemt not to cowed the le"Cr amount. Landor may makra tethe amount of Funds due on rho basin of current data and raatlonableestimates or expenditures of rugure Fwow Items or otharwin in accordanac wilb apptleabla law. The funds shall be ilald in an inUkution whose deposits are insured by a kderal agency, instrmaentaluy, or cocky (induA g Landow, it Londeria duct an inseitutim) or in any lycdoralHoutcLoat Bann tcoderahaA apply fit IP m b to pay ebc P.scrowlIML i "WEaay not charge BarraWerfar 110141112 and al@ tug the Fumk semaally ss Wft dm escrow aMMIT4 Or voritying rho Escrow teams, ualess Lwaderpays Borrowerinterestan the bands and appliablo law permits Leradwto makes aucla a charge. However, Lamlcrmay ragairailorrowetto pay a anasiraaabarge for an im1cpandantrest estate tax repwadgsavf= usW by Linder is connection with this luau, mnlaa applicable kw pmvides otbtavise. Unless ad agraomentis made or appliaaMelaw requimslutorauto be laid, l eadershall notbc required to pay Botrowcrwry Intemstw saminpon the Fun& elorrowu and Luc dcr may aarea in wcittgy, hQW0Vtt, tkfat iutmrost shaei be paid on the Funds. 18nderehall gave to burrower, without ehurgr, an annual acCgtwtina of the Feuds, showing credits and debits to the Funds and the pwrpow for which nark debut to the Funds wax made The ponds arc plad$ad as additimoai security for all sums uxurad by this Security InviumaeL if tha Funds hold by under exduel rile amoumspemiuadto be held by applicable law. Lendusita b awouoe to Bonowar riff the cam Funds in atxwrdancewilh dan ec quir®anuof applie" law. It the amount of the Fumy hold by Lander at any that: is not adflic ad to pay tba ilwowiteo swbes lion, tandermtoy so nalry Borrawario writing, and, in such tesa Borrower 44 pay to leader the amount aeoessaxy to make up the dorWrocy, sso?rowrr shall make up the defideall in no more crate twelve mooLW payaaems, at lender's We dkaeradon Upon payment in fall of all supra sesurml by d& Security (natnsom t, L11ndorshall promptly refund w Borrower any Funds hold by tender. If, under pusgrapk24 LaaderxW saquirc at &it the Pmporwt Leader. prior to the Unuisition or sale or the Fropety, stall apply any Funds held by Lander at floe thm of acquisition or sale as a aedre against the sum secure by this Security In"maac. J. Appilostlen of Pnyanents. UnlessappliexUaliw provides atherwiic.all psypterasmAdw,dby l eoderuddoepsragrapits t sad 2 shall be applkd first, to nay propsyanentabaeses lido uoJar the Not% Sowed, to amouacapsysbtn under paragraph2; third, to interest due; but* to prinapxl dui and lost, to may late charges due antler Ills Note. ?. CbxWsl i kox, Ut rrowar shall pay all isles, aaseaafnents, charges, fd- and impositions attributabieto the Property AWII fully Instal. priat ty over this Security Instrument, and lemaboldpayments or around rants, if aey Borrowerilmll pay thoaa drGadkm in die tnaanorprovided in jes"Va II62, or If not paid in that moaner, NxTowar" pay thanes limo Amcely to the person towed psymailL Brxrowarsholl promptly fusaisla to Lamdarald aotleas or amounts to be pald under chits paragraph. It Rortower makca them psymma directlyt llorr01rer shall promptly furnish to Lender reeelpta a vidandag the payments. Borrowcraball promptly discharge any Ilea whkh has priority aver lbb Security Inetrumcadunlau Rerrlwrer; (a) aaro"in wril,ag to tho paymaoc of the abtigation seeuredby the lion In a mamterrieeeptehkw lAndarl (b) cantons in goad faith the lien byo of defends aaa a enforcement of the lien ltd kgSal pramdings which in the Leader's opinion operate to prevent Ilan onforeementat the lives or (c) socuras fmon Me holder of t ab line an agrsemeatsxtinraclorf Io Lti deraulmrdina ft0to tiara t.. this 5awrity lostrumew. It Lander dedermlaealbat my part of the Property is xub)eet to x lien which cosy attain priority a,Vr this Sonority bnarun mal, Lander may give JIMOwoera aotlea lJondfying the lien. flarrawefsla dl satisfy the ran ur take coo ar morn of the nnkoaa ltd forth above within 10 dayj of Ibe giving of 0000e. q ???C tt vn? ?.aaav?t wsrasa .3 ifDiAi1'r?la6E yp R.rwf acs luau IaaaR7pAFrm ?. ° ; ` Oec-13-2004 55:48 From-PREMIER ABSTRACT +243 $390 T-569 P-009/030 F-019 CWV-121746 I' lipaaed nr Property Iruoraav, ttarrowa? shag kvcp the imprOVameets now exisAls; or bored"r en w oa the Property tsarpd nsWa K tots by lire, hoards Waded. vidun dita hem Numdad mutters" and any atber pmadE, Wading fioodt ac Owdim for which isadar require isaaraeee.'i as InutudaocoatltiN be +^`t7tairoa:. the araauetaatrd ter the a that (andar requires. 7At iasuranra earrk* providing rho ipaonnnae skau ba ebasaa by Borroarl tab)art to Laadoc't appmnl whack shd! eat be aarnuoaabysritltbeld U Beeroaer fails to ntalala5r eererags dcsGttirsd abetq i omder toay; u t.gtdar's option. obtain cowngp to protect I udu's tWft to tbt Pfq" Ia awantaea with paragraph 7 All arwrancs pofldet and roouwatt shop be araeptabiato, and ip?thdl unlade a daedard moarWp clause, ladder shag have nrright tohotd>sadreatrnats.ltL viorwaquires, Varrowe "peomptty#mtoUaderaurcxciptsor paid peamiumsaad renewal adiam In the emu of lea, awlawarah W mna prompt ootke to the muaanedcx" rand Lander. 14ader may mates proof of Wa ff not made prompUty by Uotsower. Utdeaa erecter sad eorrowarasl>erwite aarse le vrritiag Insurapm pmoto whop be applied tp vcswrvtipnor repair of the Propcrtydamagad.9"rattaralkwarrepok4ocas micakficuftandLoedutvatarityis sokee ne UUpmdorationar repair is not ecn-Wedly feasible or Lsadat+s waft woad im Instead dm bwaw a protsmbdwm bs AppAad sothe alma secured by this Seewiry faatstmaey vr3etttar er sat than due, vviW nay engirt odd ? 8arsaaar. >t BorraNrcr abapdo? the Prapert); a dots net untx7r vrtihis 9o days a Patio from htnrfer thatthe imuranra?wrior Les offered to SWJG a calm, thce t Order may toltprt rho ioswaara proceeds Itada m.y use eke proceeds w eepa¢ ac ntttsro thu Property or to pay am& aceured M rigs Seeuritp taarumaot, whtxLec ac not Ikea due '14ne 3o day period vtd11 b<Bm when tba notion is dW& Udars t ender sad 8orrancr olhtswiw agtua is wrLiog, appueaNm of procoaa to principal shop not aecad or ::d-:V. deke mootMy paymaoti tWfcrredw (d pttragrwplnai and Z to aLaaiO the stawntof nba paymaam if 0 t4. eagraph2 the PrapOrty is .cgnieed by tAeder, Barrorrar4 riglot m any $osueana polidet nM prooeeddresultiat from tdY P+i. to prtff two RUquhdtfoa stwU pw w tmdcru tlmcdcot or ftrust smnrodby thin 5apurity buirumt,u 6. Oetatpamy. Prpsarv Ik% Malbtawance mad pruiselioa of tLa lropertyt *avrewwa taps Appiiculaot L aaebatds. Horrawerthaltaaapy, uubN* cad. utethorropergas8ormwrfipemrip.ttetidermawithis shty days after the excos ion of this Seatruy [edam mLandaW cmtimte w Wmnpy tbs neprstyn Som men priodpal suidmaater at least one year d w alas date of owupoeey, wicia Lsadaenhawke dgrene ie writing, wittah cament *A am by anmuonablywichhetd, or stdrst tateau.tiag eircumscaoeeswlst which are beyond Borrawces copal. Iloavwu abott Pat destroy, daastgeor impair der Preputy, allow the Prapaly w dererlarata,ar commit year an the PeopoW. Botroweesbait by is defatdt if any forfchure cation or prwzc&og, wkcthct dW or WrQainai, L begun that in header's good faith jadgtaatt Woad result W fo"turt or the Propmayat taiterwi.ematmiatyimpan the Ara areatodby this Swanky lsatnmuctarUnder's wmufly isimust. iilorrawetmay cure such a default and rasn ue, a provided m puWaphls, by camdog the action or procca ftia be dimAwAwith a Meg that, is Leadoes good fndh delermiPatioo, psaaiudat fo alwa of the Sorrowcr'a Isiar t in tht Pmpctty or Oka -wrist iotpoNrmpuaf the tics aearedfry this &atwiq laserumoetor LpndsYt seoorky Istprait Sorrawar dWi sine be is default it Borrower. during tLa loan appru9dioe prwxny Yavs utatpristy tabs a iafoaaataiatodmaeloaa dataaneattW I.estdet(ar faded to provide tiradervvith nay matuirdiolaerradoa)ia aosswatioawiW the loco avldaoeed by ebe Nalp, loduding, bugs" Booted tq n preaesiv'?*-ant eraiag 8artowm?t eaeapaacy of the t?rop?yas a Pr od reddaaa, tf d6 Seaoity lrotremMIk an a IanmhoW, Borrower shop mrtpy wdW all the prwiafont of the lases It Borrower aequirpa feu title to ft Property, the tpasahold and the fro title shop rot nnat$a rtdm LandeQ agrees W she daeritOr (d writing 7. Platecsion or freada'a R1gky la tae reppetq, It 13otrovrarfaslt w pactermtMe cweendga aadagrenvrnmteoot-t^rd(n this scotr$y Immrbus" , or tharc it a I at peoccaftu at may Ordficiu* affect bandana t4pu In the Property (such as a wocmvh Is baaksapty, probate, for eo^A-tlonor rar tin ar to aafattst lou or ttgsrh kw), thca l endw nay do and ppaayy tar w t va is oaacu" w protect the vahta of the Yropetty ands aWces righn is On Pngerb, leader's adore attp I ndadc pu t nay sums aeuurad by a teen wMah bas prkrlty over due Swority Invanso4 appeadag Is wont, paying restw?liN?-?r?neyt' roof sea eatuiagan she Property w raahOrapalt6 Atthongh tsadvttrq tdto aatioa undaUds paragraph 7, i andel twee sae bava w ,6 ra Any amowta disbursed by LaWa andar thin pan taph 7 ekes baeemc oddidanal debt at uvtroW uttered by thin scearity ImQVSeant Unioot Batrawsr and l eada ragrae io otbwtown ar payment, these amotmL" bear iotaex from the data of disburAMON ct the Note rata sad %bag to payabie, v A i unk upon octim tram Leoder to Borrower requasting psymeak L Meet m imaneica it Lradertogareedmottgapaiesteaupe ax a spa of rotJdag rim toga searadby thtr Security twcnunaty 21"WIVIr Abaft P1v tba premhmts ragrlrod to eiaiatiie the mastga je laaorraeee iP etfut. II, for any twaoa, the umrtgagr+iaturanae regairrd by Latodarlapaa ar aawato ba la Wov, Rarowar" pay dba pmmitmisraquirodw obtain om::=egttiralrnd to eke martgapebtwnaaospravwvaty id eftaat, at SOW svbuUf * rgatvokot to the cog w Barrewei of the mortgage iworaaw previovsy Is *be% from as a lta¦asemooigaga WNW approved iry t.eadar If aabttamiany equivakt -Wtgage 4 WWKSOOVemgp k Na avafthr. Bee WashaD pq w I codeptchmoWba sum egad so aoatwpigb of the yearly morfpgehuratoea pr6wkW being oak by Borreworwkm the inswaameavtmp Upted or erased to be iseRed,Landarwllacccpt,aaemadcatakdictepaymmtau akiss ruaaeveia ku of movasgeIttawaance- LQu reserve ?a ?+r tWd%VAYm ^{(` ? 1 rn. a r • ?? ?- aa7a oho *11443119i 37 Dec-13-2004 15:48 From-PREMIER ABSTRACT +243 3390 T-569 P.010/030 F-011 OOMY-121746 psymcw may no ten required, at tba option of I truer, if m Snsur,iocseoveraas in um amoustaad for we penis! that tssdee r:,on, bys abtsioed. say aso+ t7;w,, until tba regaitat actor madp4a imuno wltb say wrtltgpplk%*le law inar w its tldEet mry Property. tan4eraw give f or prior on. 7 s prof or ctnba for damsgcc, direct ar tamveq"rl-%in eonscoloawith any coadesrnatiasar stint taking of aey pmt of the Property, a fot tdaveyanea in lieu of oarrdaanatisa,arobordby amisuad aed .hats bs paid to 1.4ndor. InthFevtatatatotal talftofthePmparty,theprooxdeWai!beapputoOnsum occoredby"SewabyInstrument, Whathor or not then des, with any attmss paid to Horro+asa. In the CYeat of m pow taking of ate rropsrey is W" the fair market vAds of am Ptap ety lm cav&t ly blots tiro ukneg Is spd to ar pt atsr dw the amount of the mu accorod by this Scrnritytaps•tmeo+ltr??:d?lybefarathetakin& nokulloetow.rasdLutdorotiar,risaaBtssin+?riting, dwsumsaesarodby Win Scantily 3mtraaaantsbl4l bd rtaluaod by tbo mount of the procoedsmubiprod by the fOliooft fraction; (a) the torsi amount of the sums suvrad 1annod61* botors the taklas divided by (b) ttn fair madrot value of the Propmty immadiatalt bafora tht taides. Any Monte shall be paid to Soul a, In the event of a partia{ taking of the Proparty in widah the fair marketvaltte of file Property bowiiatetyberarotbe taking is it& than themasoastof the Pens seeurodiau?edistoybefore She takle& Ymless flasrotvar and Lender otbetvrise agrra in *Ada or uolux appiirahk lqw otharwLa provides, then ptWN& eball be applied to the auras wxurad by 06 Stwarky taninuptnt wbetbor a not the awn us Wes due. if the rropertyb abudonedby Borrows. or 14 sitar active by Lwdarta Barrawar that the eoodamaaraffm to make an award of settle a claim tar dazana, 8ormwar 0116 to rnapamd to Lender "o 30 dais after the data rho notice is given. 14aderk sutborbmilm collect and so* tbo ptomadr, qt its apdob, either to rWAradonor mphir of the Property or to the sums xrared by this SMrity Inatrrmwnt, wbetber oe ant tbon dun. ' Unku Leader and Banvow ogtetwisa atpca In wditr . any appricAdon of jsc mCds to principal shaft ens estood ur postpons the due date Of the wooft payments rde red to in puWapl a t and 2 w tbaegd the amomd arincb'pimonts. 17. Barranar Not Released; Forbm&A"A Dy Gender Not a Wabrvv RUNS 0a of the limo for poymest or modlliratlon of amort:to6onaf ilia swan aeerredby des Security leaaousco antadby Laaduto say succuum in interertor Borraim rslmil .ant oparateta ralansatbo ikbi?Y of the atiRioat Bavroweror tioeraarx's sucoessoreis intarol.Iaodsrsbagsot be nga6odtn commoncapma"np a`ainet any socanear in interwar Islam t0 estand time ror paymmtt or ahertriaa, aot6fy vinwilzadn" of the sums awed by this Sawrigr lostruaticet by reams of any nkmand made by the original Barraner or A mawchi saveemors in tale v% Alp' forbcarmtcaby I seder it a creidog ow right or remedy sisall not be a waiver or or pralude the ?- 3a ologyrlatt ar rwncdy. IL suourso s and Aultpo 6oesdi Joint and Sateal LtahtUM C4-41VWL The romnanvs and apameatsof this Security fustruatodshalt 61 d and benefit tits sutvrawrs and aat4W of Ltadcr and Borrower, outicat m 60 proAslmsa of paragraph 17 . Bmrownes covenants and Womosats ahatt be joint and savarat. Ann l;arrower who 048= Wit Scanty iwtrLuo"bat does mot tueemta did NOW (a) k co4 Rbg 166 Scateity IaWW=tO* to brortga`a, Gant and enmity tbgt Borrower's iattrratis She Proporty hmisr the to wof thb Seariy fasounm4 (b) h not peraaaaity abliga4ed lo pay the suss seorradby the Socur*1m4ummt;ad (4 wavoolba Ludermimay coarft erawavaay agroato caund, mouth, kwbwor make any aosamrmodatkm WU raprd to the term of this Socarky tngratnam or the Note without chat Borrower's eorr"M Its La" CYmsq• if the loss assured by this $eotrity Iattrumeaia mtbjert to a lair wbkh acts mradmhm lose ehusea, and the law h fl ly ftttttpratedso that tea inianrgtor Whw lam d agpx eptlecbed at to be oollectntl 6 aooasetion with the bon eroeisd ebe pwtaialadlbishe, thra (a) any assts loss eltagsskaY Ira redtteadby iba ataoaatt W:Co wy to radeca the charge io tits petraisedlimhi sad (bj my was nlrady tolleetonifrars Horrowerwbiah ssteatAedposrw3fedlin$s will be rdencled m iiorrowae. t.eadce may choesis ro make this rduad try reducing the prlrKipai Dual stunt this Note or by making a i0roci poyetent to Borrower, it q refract reduces priaetpd the redutsiom will be treated qP a partial prepaymarc withuat any pnspsymct dense ttedar the Noce. td. iVaged. Any soda te Sorrvavr provided Ens in this sewaity laiUatsabta6all ben glean by d4w4W it or by mailing it by lira dasa mart ne{sa appiHabk isw rsgttin? use or anottnvmttbod.'lYmrrdtkv shell be directtdto Wo PropertyAddrma or say odrisc adthrsa Hsisvaver dpigasta by strive to Laadar. Asy tmtiri to l endas shah be gives by first clans mail u, t.onder'a addrca cutedberda rat say etbs's addteas teaderdaiaaqua by trotke to Borrower. hay oodm provided far ht ihk Stauriq lastrumrarta6att 6th deemed ro bare bras giren tai3trrrpwer v Ltadw w6tw slits N provided it flab pttragtaph. IL Gevaratag Ian SnrtrrM ty: TWA Saaeily Inartoseal Shall bd got'on A by Muni law and the law of tlta jurts"an In wtriaq the Property b located In zits event that say pro den or chum err this Security 166MMu tar tits Notu aoeiltAS vtitb appUeablelawv atte6 essfiiet shah sot agaat odl6rprOVislpptc of this Slttitlly Isstntmeator t!m ktptistvhic6 pa be Oven d ku without Me mulliatiag provision. TO dais and dm provisions of this Snutthy Isdrumentand Ufa Nate are declared io Ito aamAble, tit. Barranrrns Copy: Darrovtersball ba gives tae conforletdaW of the Nato and or this Sacerily IaatrLmem. t, atnpAr seised r.n a N v wou1i 443Ixc6 ` wore= r ui • M•• so vivo Y00a1llAFrm _ iii '?.e1. k ., Dec-13-2004 15:49 From-PREMIER ABSTRACT +243 3390 M l anwrar+a R corarmmestof This Soo ptiabk low may We S?acurily Instrvvma cr 1 l coder U st®a rdrw:h I turn any dcfauk o arq udlult, laid bw aot ' the dic be; Smmr#p a{c .-A L jmmv . Sala of NOW jai iraraent)mwy be odd os am rl4an Servitor') i a mofethe"=of the t cwl.121746 FORM er s IkO AFla1 talwpt in am-or. it ae of paKOf the Proprr ycr any interestin it it besrefaW tnlaraatrl Ho tdOot is mid of uamiensdani rb Dot a aaiutal par m)w"t. seat, tray al itl oPtioy mggifc immediate p?yuimt In of ail 100 neared by this ra, atiflieo `tm:b•1? twK as escrtsul Vl i eaderif c a mn b rederd iaM as et d,a date is gdov6 imlerdall eqwree bw w*araotke of aw*n ttoa.'eba nado d4 proridn a period et net he date the notice Is dalivrred or Now wtlhta which i9etrewer Not pay -a Kama sacufed by chit arrolocr fails vwdtAait a am prior to iba+ ouldw of Wb period, L-'-may lavolte mp -4- Colt V Imminent hor cuum or demWQ an @orruvw. ahc to a dmastK. r! borrower pwato veAaia mediglnaa Borrower shall Tara the rght to have rity lnatramepl tCsr4atmaad m nay time b the eMlto of; (a) 5 4" La Nob other paned u i!y for taiwuimas[)befete oak o! tla pursumat to my power of awls coaukod id this r)onayefaJttd®otwteafareltrdthieSeaaity ri?mcat7sesseoaditio moiliotsarrower (a) yt ieo would be doe corder this Se lowpaostand dre Note r)t if;; &cca;;i abed oecone(b) attar commum s or apeema4; (c pa AU cosmo es hivsrrnd m ..w wcbg dilt Sgwky Insimmcat. i UL r -w?. •???mrtt' fbot and fd tskw tech action IN Laaderna ressonday raga4a O alturc loge of or man [eQdde 211. Haseitlotr Sitbilsum. Burrower HatardonSubt som on or in the Prapmn property tbst ie in viataefoa of any Etnvitom stor?go ca the Pra sty of uuzil yuaOGticsc resldaotie! ttfu and to mah"ovinte of the p Danowwshall pmcxply tlWa tmdur ==-7.12 COry.?weyor rtvatt a¢ulahnowldif ke as if Ito sxaNutirmhad oaatrod. However, thin rigs[ to rmmtatdmati pit 17. r. Tile [tote at a partial late red in Ilw Nuta (tagmtherwith this Security peter dadea to Borrower. A wk may n ah in a e e in the atllly (known eudueuadw11[CNaemtdthiaScdlYiSyrattmnPLTWoea maybe and sale a[ Ib11 tVeaa. I! tberdb aeha1tre ail[[ the tn4n 8orrowwwill be h parWapbl4 Above a0d pGdtDiciaw.'Y'ht:tglivewill dotathoaamanad (p vm . putymmu,beaLt be wade, rm twtim vA abd motak any other rdl datae ue pdr -it the prtaea r,, Site, like, stortpe, or reteasn of any nrorvcf tLtll not do, nor allow anyone a to do, aaythias attnraithe Law. The precedmt;pva sadtceeet*d cwt ap* to wo ?rereaoe, ate, or a rdousSubttuaccsELateragcocrady rc;gain zo be uppropriatcto normal robot: of any hwasiyation, daim, dcomand, lawrA or attar action any ittvorvint Ore and my 1Wt-mutawry antkorilytMi rarer lettraa, a< is rod by any pommn[:Kcal or rng, 110 romowlorothdsremediationofaaYHwrdovssabrtaemnt<ar?grbeEroputyumcciliary,earrawdt SM. poomptiy cairn df! neewagr raaedtal awtiow in nowd.oca wish F LAW. wa viced is this ?ZO, 'ttiaedeut Sabtla11ed' aro these aebunon dofocd no t& or haardoatorlwaorsby t=svhanmsoSalLaw and Sip subtaoodsn pasofiae, karam4 ottsee Aammabk ae tattle ra l m, wwa? putidddaaedhwbip'?,volatanaotweoy,matarialsemyai.tasmboletaloemaNkhyde,aaddad ctimve mda redr is.ASUaad 43 chic 1th7rl, n rr raomaatai Law maw kdoad 1[wa end laws or the jtuSSdrwm wham the I?Mperry is tocated ri>?t [date u slat or aoviraomnaW pfoteetfae. NON- R?s00VBNwMS.liarrotreraadl»under!iutheroaveaarrcaada?+eaaarollowi, 2L Aesafeesfres» Retradise. 14mtdtr shag v11tia u tiraravmr prior to eoodaspoa bilintiae Barrawar's breach of tmy eevemtea 1r s0ama11t hr tide Sacorly Idrmwat pat teat prior to aeW?rwtio11 aador PUMMO 17 wlw slePUwable bar Pr y otheeirYe)• fAadal eha11011(f ret7aaee eE. es11aa? 11thsr mfnSat W the aftli t M am adtao "if" u vets at 1014 (4 Srhan do ddm* twat be tired; and (,yt) thMt Woolf to am Bill ddrvff u spedw may result iR swctklaiima of she Kam aearsed qy thh S"dw bmwoeN, fou"loa11R by swid=Z! sad "k of the Prapaiy. I?nd1t ahNI [hrther lefiettt aaesower of ilia H& to refultu n alter' amunum to Kilmartin the Wteelaeure the sareshttence of 166019 !nay ochre deridae or Sonw x to wodaration and lmt+olnows, It the dClanft nr W atisd +w asedesd, 1,01141M st No 111111014 my r6kill a maIdlste PM-M le cite of as aria SWWM b this Soca tl! Inetramvst rtithaat satin dmrld and try 1Tradess, this SmIlty loollroonad by jm"ll pirameOn Bader eatrmwlt be soil" to tallest all opt:traea Iseated IN psmsfnd pie ramdloK ptavhled Id 06 PN*Fnpb 21 tttteirdlsb but set Bohm ear dursew sna end coals ago* Vdillneetwilie -- -. a Ruud brappOsbb bow. a0nvev=ed Odom Vpo p.ymmt of sit suw? me.*ad by thb ssattllv Iutmocut, this Security iKardamataud the auto *0 Nump" becomavoid. Aftrsaa?eaamteae?lae?abe>tditt srypatdaagr(yaufteurhyhaftsint to op4m two eoevrIky 7patrcobasow omit 24 RdtsrapK'tlaatai ft4,A went of biddmw at a al w fhc sSpr? ? Saaue lty fseo 2i. lalvpt Rru Ahof Jul or In ap atlfou of mwtpp let . 4ft4WAAl al t ic"I 111OLi Lag fnyaol'rcmtdaYr- lod6 % atpmmfttadby rba baefieaEwa aapana btofm wyprs osio11tor asdtetaas11sa ld11rc Iowa provfdla mvW orW for fora any is of wmortdiio11, KsebYvrsrvec tort st, fury sad auk, add 6einapeadvt+os war's tiara W =etgaleta is iohl8 slug extend to an hour prior to she nice or other axle =by to g- fa at Thed?ttL4Semdw 01e066 ient141 8artawrtaacquiroirk Boer Wowcreryaralhatat Iet racopayabrn"ludommtbmtcredmtheNato hag be the rate payable from timo to time trt?der the Not _ a tir.ar¦ eool Wffue 39 1,m,leae Nee T-569 P-011/030 F-018 Dec-13-2004 15:49 From-PREMIER ABSTRACT +243 $390 T-569 P112/030 F-019 CON-121748 n. Alders is toss Smrrl(y ftntrwneae If out or morn rides am eaewted by Barcowcrand rccorded h>aaherwith this 5cariryiaatrun:enf.2hecovannntzaadwi.? ?-a[sdrautheideraWlheipeatparatedintoandabn4waad?mdNppkmeat the carcasats and adneements 01this Sorority rnWrmroat W it dw ridm(.) were a part of" Security Instrument. IcQbec c spokablo box(es)) A499" Rote Aida Conda®ininm Rider 1.4 Family Rider Oraduated Ptyment Rider Please{ limo Davalaisam Rider BivMaly Peymeot Rider Ballow Rwar Rate boproremost Rider Sewed Hone Rider VA Rider Other(s) lsl e l BYStCNiNOBELOW, Baroweroccaptssa,iagcatslo thetertnstodWMIlltseoatstcedin"Seturlty ltuWmentavd in ear ridm(s) Comm ed by Aorrower and recardad vAh il. ?•BAttBA>Y H 71AT 410~1 a . 4kWM* rr -tenn+c• crrrtftwts or 11tytaeOCe t, U20Y STrID , do hereby ear%* that the eaffm tddrora of tbuvkhht-pamadMortpguw Ara Vast 71rac Ave*=. 2nd plr t:o,uAOhoetan, 7a 19428 Wkaass my hand obit 26th day of arfli 1998 A SY Bi nse,earstonpp- OOMMONWMA&TH OF PENNSYLVANL% Dauphin Coeurse: on tht4 On 26 dsy of NAM 1948 , bdore me, the Wlsn;PW Weer. pusavally Appeared SAMARA x n= kwmva to on (or ssWisdarHy proven) to be the person whose same is aobser%W to the vithbr bswnmaat tad aclmcs ody.i chic 71 ecetwA the, sass for dra poeposse berafs aeaaiwed, iN WM4MWHMZOg,I hereaatoactray band and 91110141 Meet MY CoPUSiutoa F.?6o: tlsM t ?? Naia,y W 4 s i _ r'M' ?yt,awa+soaseonit?-v.',mr.rott,=r I?iRfMtNNtw N /?aMM os am ,eeMpMPAprjf't: "J . ! 1041443P,st 40 Dec-13-2004 15:50 From-PREMIER ABSTRACT +243 $380 T-569 P.013/030 F-018 ALL THAT CERTAIN lot or pim of land niluto in the Borough of Now Cumberland, Conncy of Guaberland and Comluonwealth of Peauytvanla, bounded and dawribad as follows, w wit: BEGINNING at a polttt at the soudmamm corner of Rut amont Avenue and 4dt Sneer. tbetlce in an easterly direction along the aotttban line of Mb Sneer twenty-five (25) feet w a poitrq thence in a southerly dtnectimt along the line of Lot No. 20 SeWon H of the bilMnafter- Inentioned Man of LOU and through dte teeter of the partition Walt of a dauhle two story brick and framer dwelling house one hundred forty (140) feet to Roby Avenue; tfience in a westerly direcdop along the norda dy direction slang the eagtem line of Routnont Avenue ma: hundred forty (140) feet to the place of BEGINNINGi. EMNG premieres No. .624 4th $tInl, New Cuafteitaat_ PewWlvania. rr RMNG the same pr nha which 7amy Cookerly Abels and Keri Cookedy Moors. Co- Euecutris:a of the Last Will PW Testament of Oayle B- Cookarly, by a Deed dated March 24, 1998 and w be moctded herewith In rile Recradw of Deeds Office of Cumberland County, $rarred and corn'eyed rlnro Barb_nra M. Plot, the MORTGAGOR herein. BXAI131T '+A" Stateatpannrylran(a ? E6 t:ounty or C'rm:lruinnd. i! I!d ? : ?!r arlp-r. t+v the tt:u?Minl! n(!J+'.`.+(:. ACI gINI I-Ir'ryd t- hinle, In 15J.Vai. .. ?'ql:?.7 ??Itn .ab ry+ye Im+ ::1 s a, tlqce ?? sax . e - „ aai%144UAFu 4 Washington Mutual 8005614758 P.O. Box 44118 Jacksonville, FL 32231-4118 October 18, 2004 #BWNCLNNO #0980059814975894# 005445 ns BARBARA M FLOT 624 4TH ST NEW CUMBERLAND PA 17070 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT O 8005614758 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR. HOME FROM FORECLOSURE This is an official nntice that the mnrtoaae on your borne Is in default. and the lends intends to fnralose. Specific informatinn about the pature of the default is pmvided in the altarhed pqs. The HOMP.OWNER'S MORTGAGE ASSISTANCE PROGRAM (ITRMAF) miLy he able to help to save your home. This Nmira ettplains bow the p*ttal'aln wont,. To see if HEM" ran help. you must MFFT WITH A CONSUMER CRPDIT MUNSELING AG$TICY WITHIN 30 DAYS OF THR. DATE OF THIS NOTI(F Take this Notice with ynu when you meet with $hp CmunwliAg Ayl.ry. The name address and phone nu nher of C+nenm- C viit C,µ1,Vlin$ AgPa%i a rervinf your Cwnty am listed at the and of this Notir if you have aqy questltma. you way call the Penngyivania Housing Finance Agency toll frer at 1-910342-"47. (Persons with intpsirad hearing ran nil (717) 71)f.11169), This Notice txutaias Important legal lnfe matim If you have any queatiaaa, representatives at the Cotuttater Credit Cetu selhsg Agency may be able to help !:plain IL You stay also want to contact an attorney in your area. The local bar same istlen may be able to help you And it lawyer. LA NOTWICACION EN ADJUNTO ES D6 SUMA IMPORTANCIA, PUPS AFECTA SU DERBCHO A CONTINUAR VIVIENDO EN SU CASA, SI NO COMPRENDE EL OONTENIDO DE RSTA NOTIFICACJON OS'MWA UNA TRADUCCION IN WITAIIISNTE LLAMANDO FSTA AGENCIA (PENT MVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRDIA. PUEDES SIM ELEGISLE PARA UN PRESTAMO POE EL PROGRAMA LLAMADO SHOMBOWNIM'S EMERGENCY MORTGAGE ASSISTANCE PROGRAMS EL CURL PURDS SALVAR SU CASA DL LA PERDIDA DYI. DERECSO A RVDD41R SU HIPOTECA. PA ACT 91 "g . iT EXHID HOMEOWNER'S NAME(S)t Barbara M. Plot PROPERTY ADDRESSt LOAN ACCT. NUMBER: ORIGINAL LENDERt CURRENT LENDPMZRVICM 624 4th SL New Cumberland PA 17070 M%14759 Washington Mdteal Home LoaM Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCR PROGRAM YOU MAY DR ELIGIBLE FOR FINANCIAL ASS45TANCE WHICH CAN SAVE YOUR DOME FROM FORECIMURLV AND 0M •p YOU MAKE! FUXUAE MORTGAGg ?AYMRNTS- IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1933 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCEt • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBlLTTY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY nF, FORRM XAURR - Under the Act, you are entitled to a temporary stay of foreclosure an your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and strand a "fice•to-faca" meeting with one of the consumer credit counseling agencies listed at the and of this Notice. THIC MRVTING ).LUST O(YmAB WMrlN THR NRXT M DAYS. IF YOU DO NOT APPLY FOR P.METIOPfRN MORTOAnR ASSISTANCR YOU MUST BRING Y(tUR MORTnAO1i UP TO DATFt THE PART OF THIS NOrCR CATI.RTI -HOW TO CU(tjt YOUR MORTGAGE DPPAULT". "FjdklNS ROW TO DRING YOUR MORTGAGE UP TO DATF_ MNSUMFR CRVOIT MUNSRI.INC. AGRNl:113 , If you meet with one of the consumer credit counseling agencies listed at the and of this awke, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The nausea sddremm and telephone numbers o(&Ag tated consumer credit conmr1ing agevei. for the county in which the prWerty iT lo-tPA are sot forth at the and of this Noll e. It is only necessary to schedule one face-to-face meeting. Advise your lender 1mmadjAuU of your intentions. APPI.ICATRW FOR MnIITI:AGE ASUSTANCR , Your mortgage is in default for the reasons set forth later In this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do to, you must fill out, alga and file s ewnpkud Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies Bated at the end of this Notice. Only twnsumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUSTbe filed or postmarked within thirty (30) days of your face-to-f ace meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO 80 OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGRNCY AMIIN - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements at forth above. You will be notifwd directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOM* IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERRD AS AN ATTEMPT TO COLLECT THE DEBT. (if you have (Bees bankruptcy, you can atM apply for Emergency Mortgage AWagaee.) 006446lCOe76 ROW TO CM YOUR 14ORTGAGEDEFAULT (Wnf It uD to dpW. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 624 4th St. New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: O810WAN 5746.63 09101/2004 $746.63 1010112004 5746.63 Other charges (explaiulitemi:e): Uneollecitd Late Charges $66.75 Uncolloetal Fees: $15.00 Corporate advances $0.00 Less Credits SOHO TOTAL AMOUNT PAST DUEL $2311.64 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable$ HOW TO CURB THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this ootlca BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 52321.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Yaymw is mu.f M m.ne el ft, ]ty --k f.4ht.r'a eV-Ir. -ti%AA Fhe,•l., or numwy ord- -A• l SW^ A.A .?t by Waahingten Mutual Home Loans, Inc. 9601 McAllister Frwy. San Antonio, TX 7521fr4681 You can cum any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YQU DO NOT CIIRR THR DRFAULT. If you do not cure the default within THIRTY (30) DAYS of the data of this Notic6, thLlaa a[ W -. to -orel- It. , JJtM to &"A.mt. th. , --IgaV dent. This means that the entire outstanding baknca of this debt will he considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount pat due is not made within THIRTY (30) DAYS, the lender also Intends to instruct its attorneys to start legal action to rmw li lapel your asartyyrd Frew". *IF THE MORTGAGE IS FOREr1.11SND UrnN The mortgaged property will be sold by the Sheriff to pay off the tnon"c debt, if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you. you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attoreWs toes actually incurred by the lender even if they exceed 55000. Any attorney's fees will be added to the amount you a" the leader, which may also include other reasonable costs. Uyou n,fa tha d-Ault within the THIRTY (30) DAY penal. yet will pot be v a, tied to ply attorney's fen. OTHRR I.I+NDF.R Baa4RIUM. The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 RIGHT TO CORP. THE DEFAULT PRIOR TO SHRRIFFS SALR - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you m,ty still have the righj to cure fhw d.6ult and prewant the ale at any time Up to nne hnur hrfnre jha Sheriffs SA, You may do an by MAng it. Wall amount th.n Wwt due plus arty late or other cl argil Owm due. rewm•Nr attnrnPyy fe and rents nnapwrfwd with the fwarlranre ssla and arty other mats cnn-turd with the Sherifra Sale as.rlflut In writing by Ilia lends and Ity pmInrming qty other rwmylramwnts undwr thus mnrWi r Caring your default in the manner set Borth in this notice will raw* your mortgage to the same position as If you had never defaulted. F.ARMERT POMMI.R SHItal"19 SAI.R DAT3 - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 mooft from the date or this Notice. A notice of the actual date of the Sheriffs Sale will be tent to you before the sale Of course, the amount needed to cure the default will Increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THR LRNDR t Name of Leadert Washington Mutual Home (mans, Inc. Address: PD. Box 44118 Jacksonville, FL 32231.4118 Phone Number: 866.926.8937 Fax Number: 818.775.2010 Contact Person: Collection Department SMI-BS OF 11HERIFF S SAI.P.: - You should realize that a Shcriff's Sale will end your ownership of the mortgaged property and your right to occupy iL If you continue to live in the property after the Sher18's Saie, a lawsuit to remove you and your furnishings and other belongings could be started by the leader at any time. ASRIIMPTION OF MORTGAGE - You _ may or -& may not sell or transfer your home to a buyer or transferee who will assume the . mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAYE TOR RIGHTt TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED PA ACr 91 VERIFICATION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATIONS TO AUTHORITIES. Date: a -? a U? -?? 2u1??v . Name : Anita Virgil a Title: Att Asst Secretary `` Company Washington Mutual Bank, FA, (? 1? 14Q 0-1 4 a 4CZ c "t1 ''1 SHERIFF'S RETURN - REGULAR CASE NO: 2004-06399 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS FLOT BARBARA M HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE FLOT BARBARA M DEFENDANT the , at 1608:00 HOURS, on the 4th day of January , 2005 at 624 4TH STREET NEW CUMBERLAND, PA 17070 T T n r) A M T T7 T /l T was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 12.58 Affidavit .00 Surcharge 10.00 nn Z V J V Sworn and Subscribed to before me this y day of l Jt-0_5' A. D. P othonotary So Answers: '2 --, - R. Thomas Kline 01/05/2005 SHAPIRO & KREISMAN By: ?ZC ? Deputy She iff SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by COURT OF COMMON PLEAS merger to Washington Mutual Home Loans, CIVIL DIVISION Inc., successor in interest by merger to Fleet CUMBERLAND COUNTY Mortgage Corp. PLAINTIFF NO:04-6399 VS. Barbara M. Flot DEFENDANT(S) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $83,761.99 in favor of the Plaintiff and the defendant, for failure to file an answer to Plaintiffs Complaint in Mortgage within 20 days from service thereof and assess Plaintiffs damages as follows and calculates as stated in the Complaint: Principal of mortgage debt due and unpaid $77 084.76 Interest at 7% from July 1, 2004 to April 22, 2005 (296 days @ $14.78 per diem) $4 374.88 Late charges (for certain months prior to default and every month after at a rate of $27.83 per month) 250.47 Escrow Advance (As stated in Complaint) 223.64 Property Inspections $8.90 Mortgage Insurance Premium $54.34 NSF Check Fees $15.00 Title Search Report Fees 250.00 Attorneys Fees (As stated in Complaint) $1 500.00 TOTAL AMOUNT DUE $83 761.99 BY: Joseph Rejent, Es quire Attorney for Pl intiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant( 3) and damages are assessed as above in the sum of $83,761.99. , rro. gomy.,eZ 04-23323 r? c? o co N W SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 82628, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, ; Inc. successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 Milwaukee, WI 53201-1169 PLAINTIFF vs. Barbara M. Flot 624 4th Street New Cumberland, PA 17070 DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: STATE OF: y?//>GLh? `>ji(? COUNTY OF: AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eigh years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the PI and that the above-captioned Defendants' last known address is as set forth in the caption they are not in the Military or Naval Service of the United States of America or its Allies defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Washington Mutual Bank, FA successor by merger to Washington Mutual Home Inc. successor in interest by merger to Fleet Mortgage Corp. By: N TIT ,V?Sel?C/Cr ?, Sworn to and subscribed before me this daof 2004. 04-23323 ?DiY/ C c?.a7?Y5 ?C SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQUIRE ATTORNEY I.D. NO: 82628 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF VS. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 Civil Term CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Prae ipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the d to of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said otic attached hereto, March 23, 2005 to the following Defendants: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Laraine Colwell, Legal Assistant to David Fein, Esquire for Shapiro & Kreisman, LLC SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF VS. Barbara M. Flot DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:04-6399 CERTIFICATE OF SERVICE I, Joseph Rejent, Esquire, Attorney for the Plaintiff, hereby certify that I have first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Date mailed: .?G U SHAPIRO & KREISMAN, LLC BY: l4jju? IOGt?7 Jose?h ejent, squire Attorney for Plaintiff by 04-23323 SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:04-6399 Barbara M. Flot DEFENDANT(S) CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 Milwaukee, WI 53201-1169 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 SHAPIRO & KREISMAN, LLC BY: Q01 Jos ph Rejent, squire Attorney for Plaintiff 04-23323 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 PROTHONOTARY'S OFFICE Prothonotary TO: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:04-6399 Barbara M. Flot DEFENDANT(S) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. PROTHONOTARY'S OFFICE Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY JOSEPH REJENT, ESQUIRE AT (610) 278-6800. o -n Rl .0 CX) '>l ?n w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION ( ) Confessed Judgment ption: Washington Mutual Bank, FA, successor ( ) Other merger to Washington Mutual Home Loans, 04-6399 C., successor in interest by merger to Fleet File No . rtgage Corp. Amount Due $83,761.99 vs. Interest4/23/05 to 9/7/05 $2,21E .28 Barbara M. Fleas- Att 's Comm _ y Floc Costs THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sal E ccount based on a confession of judgment, but if it does, it is based on the appropriate original pr ursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amend , contract, or ceeding filed d. Issue writ of execution in the above matter to the Sheriff of Cumberland r debt, interest and costs, upon the following described property of the defendant(s) County' "See Legal Description" PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, osts, as above, directing attachment against the above-named garnishee(s) for the following pr ies of lengthy personalty list) ur co f l interest and perty (if real p o y estate, supply six copies of the description; supp ind all other property of the defendant(s) in the possession, custody or control of the said garnis ee(s). 71 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. nature: Si g Date Print Name: Joseph Re'ent Es ire Address: 2520 Renaissance Bl vd., Ste.1f King of -Prussia, 19406 for: Plaintiff Attorne y 0 - ? -G960 X ?SYff 59621 (OVE Ca by In Mo TO a p :r) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. g HIM a CO _ i „r C7 t,- N J` -? Flo \ ?' W K ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, BEGINNING at a point at the Southeastern corner of Rosemont Avenue and 4th Street; the nee in an Easterly direction along the Southern line of 4th Street twenty-five (25) feet to a point; ence in a Southerly direction along the line of Lot No. 20 Section H of the hereinaftermentioned Plan of Lots and through the center of the partition wall of a double two story brick and frame dwelling house one hundred forty (140) feet to Ruby Avenue; thence in a Westerly directi along the Northerly direction along the Eastern line of Rosemont Avenue one hundred fort (140) feet to the place of BEGINNING. BEING premises No. 624 4th Street, New Cumberland, Pennsylvania. C7 ^? 0 con 7(J CX) -yam h) l eov: --i ` N J G.J G WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6399 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor by merger to Fleet Mortgage Corp. Plaintiff (s) From Barbara M. Flat (1) You are directed to levy upon the property of the defendant (s)and to sell see legal descrip (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 fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defend: (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 garnishee and is enjoined as above stated. Amount Due $83,761.99 L.L.$.50 Interest 4/23/05 to 9/7/05 $2,216.28 Arty's Comm % Arty Paid $122.58 Due Prothy $1.00 Other Costs Plaintiff Paid Date: April 28, 2005 (Seal) CURTIS R. LONG Prothonotary By: -XI Deputy REQUESTING PARTY: Name Joseph Rejent, Esq. Address: 2520 Renaissance Blvd., Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Telephone: 610-278-6800 ext. 248 Supreme Court ID No. 59621 SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQUIRE ATTORNEY I.D. NO: 82628 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by ; merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 Civil Tenn NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Barbara M. Flot DATE OF NOTICE: March 23, 2005 You are in default because you have failed to enter a written appearance personally or by a and file in writing with the court your defenses or objections to the claims set forth against you. i vnn art within tan tlffi Aavc frnm tha data of thic nntirP a Judgment maxi ha antProd avainat vnn wi 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 to find out where you can get legal help: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. to NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su arte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la echa de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o esc char preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derecho importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no ti ne abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por tel fono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conse uir assitencia legal: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WII USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 David Fein, Esquire Shapiro & Kreisman, LLC Attorney for Plaintiff BE n ^a cn T r7 ((3. , ? t r IV OO n?? C, _ j 'C7 . .T_ _.Tt' 7 _-. ._ . C ?" S W . SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQUIRE ATTORNEY I.D. NO: 82628 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Barbara M. Flot DATE OF NOTICE: January 25, 2005 You are in default because you have failed to enter a written appearance personally or by ttorne, 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 ithout hearing and you may lose your property or other important rights. You should take this notice to lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the followin office to find out where you can get legal help: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISE: THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su arte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o es uchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derech s importantes. Debe ]levar esta notificacion a un abogado immediatamente. Si usted no ene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por tel fono a ]a oficina cuya direccion se encuentra escrita abajo Para averiguar donde se puede cons uir assitencia legal: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WI] USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 David Pein, Esquire Shapiro & Kreisman, LLC Attorney for Plaintiff BE J;: ±a. T r 1 , ?TT1l rn co (. ?' tii SHAPIRO & KREISMAN, LLC BY: DAVID FEIN, ESQUIRE ATTORNEY I.D. NO: 82628 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA successor by merger to Washington Mutual Home Loans, Inc. successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Prae for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the d: the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said attached hereto, January 25, 2005 to the following Defendants: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 1 Laraine Colwell, Legal Assistant to David Fein, Esquire for Shapiro & Kreisman, LLC of - ° ' c n F7 M3 t..; SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF vs. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 AFFIDAVIT PURSUANT TO RULE 31291 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home 1 Inc., successor in interest by merger to Fleet Mortgage Corp., Plaintiff in the above action, forth, as of the date the praecipe for the writ of execution was filed, the following informal concerning the real property located at 624 4th Street, New Cumberland, PA 17070. Name and address of Owner(s) or Reputed Owner(s) Barbara M. Flot 624 4th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Name and last known address of every judgment creditor whose judgment is a on the real property to be sold: Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Inc., successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 Milwaukee, WI 53201-1169 Name and address of the last recorded holder of every mortgage of record: Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Inc., successor in interest by merger to Fleet Mortgage Corp., P.O. Box 1169 Milwaukee, WI 53201-1169 Household Realty Corporation 5106 H Jonestown Road Colonial Commons Harrisburg, PA 17112 5. Name and address of every other person who has any record lien on the property: NONE Name and address of every other person who has any record interest in the property whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street P.O. Box 320 Carlisle, PA 17013 Name and address of every other person of whom the plaintiff has knowledge who any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 624 4th Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of personal knowledge or 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 authorities. SHAPIRO & KREISMAN, LLC BY: (I/ Qy J eph Reje t, Esquire 04-23323 ?7 a 'S7 iA? s' ( fy, l -",n Na 7 CD C, -? -'P5 _:} Sri I N 7 SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by COURT OF COMMON PLEAS merger to Washington Mutual Home Loans, CUMBERLAND COUNTY Inc., successor in interest by merger to Fleet Mortgage Corp. NO: 04-6399 PLAINTIFF vs. Barbara M. Flot DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Your house (real estate) at: 624 4th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on September l7, 2005 at: Cumberland County Sheriff One Courthouse Square Carlisle, at 10:00 AM, to enforce the court judgment of $83,76199 obtained by Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in inter by merger to Fleet Mortgage Corp. against you. NOTICE OF OWNER'S RIGHTS To prevent this Sheriffs Sale you must take immediate action rr JALL The sale will be cancelled if you pay back to Washington Mutual Bank, FA, successor merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fl Mortgage Corp. the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pa} you may call: (610) 278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may 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 of 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. 4. 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 (610) 278-6800. 5. You may be able to petition the Court to set aside the sale if the bid price was gross] y inadequate compared to the value of your property. 6. 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. 1. If the amount due from the buyer is not paid to the Sheriff, you will remain the owne of the property as if the sale never happened. 8• You have a right to remain in the property until the full amount due is paid to the Sh and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. You may be entitled to a share of the money, which was paid for your house. A sche of distribution of the money bid for your house will be filed by the Sheriff no later th October 7, 2005. This schedule will state who will be receiving the money. The moi 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 date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if yc act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DC NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 04-23323 ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, t wit: BEGINNING at a point at the southeastern corner of Rosemont Avenue and 4th Street; th nce in an Easterly direction along the Southern line of 4th Street twenty-five (25) feet to a point; hence in a Southerly direction along the line of Lot No. 20 Section H of the hereinaftermentione Plan of Lots and through the center of the partition wall of a double two story brick and frame dwelling house one hundred forty (140) feet to Ruby Avenue; thence in a Westerly directi n along the Northerly direction along the Eastern line of Rosemont Avenue one hundred fort(140) feet to the place of BEGINNING. BEING premises No. 624 4th Street, New Cumberland, Pennsylvania. c: t? o ° rj- r CO ?C i N ?jm N < SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF VS. Barbara M. Flot DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: It is hereby suggested of record that Barbara M. Flot Defendant(s) in the above captioned case has filed Bankruptcy under Chapter 7, under Docket No. 05-00135 on January 10, 2005, converted to Chapter 13 on April 7, 2005, in the Middle District of Pennsylvania and the above captioned Action in Mortgage Foreclosure is accordingly stayed during the pendency of the Bankruptcy. BY: Joe Reje t, Esquire Attorney for Plaintiff r> '? r"7 ? =t1 ? {'f1 ?? ? -??ly ` U 1 ^O ?C.?i (FJ ?? ? -. G .' ".? L:: Washington Mutual Bank FA VS Barbara M. Flot In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-6399 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph Rejent. Sheriff s Costs Docketing 30.00 Poundage 9.60 Advertising 15.00 Posting Handbills 15.00 Levy 15.00 Mileage 27.20 Certified Mail 1.60 Surcharge 20.00 Law Journal 177.00 Patriot News 159.68 Share of Bills 18.20 Prothonotary 1.50 $489.78 Sworn and subscribed to before me This 2005, A.D. . So Answers: R. Thomas Kline, Sheriff BY Ljt0? J _ Real Estate Sergeant ?k 5613i. 91, rGPYv BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by ; merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF VS. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp., Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property iocated at 624 4in Street, New Cumberland, PA 17070. Name and address of Owner(s) or Reputed Owner(s) Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Name and address of Defendant(s) in the judgment: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. P.O. Box 1169 Milwaukee, WI 53201-1169 4. Name and address of the last recorded holder of every mortgage of record: Inc., successor in interest by merger to Fleet Mortgage Corp., P.O. Box 1169 Milwaukee, WI 53201-1169 Household Realty Corporation 5106 H Jonestown Road Colonial Commons Harrisburg, PA 17112 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street P.O. Box 320 Car1l1311c, PA 11 v i 3 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: TENANT OR OCCUPANT 624 4th Street New Cumberland, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: (L/ QY J eph Rejet t, Esquire 04-23323 BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Washington Mutual Bank, FA, successor by COURT OF COMMON PLEAS merger to Washington Mutual Home Loans, CUMBERLAND COUNTY Inc., successor in interest by merger to Fleet Mortgage Corp. ; NO: 04-6399 PLAINTIFF VS. Barbara M. Flot DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 Your house (real estate) at: 624 4th Street, New Cumberland, PA 17070 25-25-0006-109 is scheduled to be sold at Sheriffs Sale on September 7, 2005 at: Cumberland County Sheriff One Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $83,761.99 obtained by Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. against you. NOTICE OF OWNER'S RIGHTS To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of how to obtain an attorney.) OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. 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 (610) 278-6800. 5. 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. 6. 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. 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. You have a 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. 9. 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 no later than Gewber 7, 2005. This schedule will state who will be receiving the 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 date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 04-23323 ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point at the Southeastern corner of Rosemont Avenue and 4th Street; thence in an Easterly direction along the Southern line of 4th Street twenty-five (25) feet to a point; thence in a Southerly direction along the line of Lot No. 20 Section H of the hereinaftermentioned Plan of Lots and through the center of the partition wall of a double two story brick and frame dwelling house one hundred forty (140) feet to Ruby Avenue; thence in a Westerly direction along the Northerly direction along the Eastern line of Rosemont Avenue one hundred forty (140) feet to the place of BEGINNING. BEING premises No. 624 4th Street, New Cumberland, Pennsylvania. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6399 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor by merger to Fleet Mortgage Corp. Plaintiff (s) From Barbara M. Flat (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,761.99 L.L.$.50 Interest 4/23/05 to 9/7/05 $2,216.28 Arty's Comm % Arty Paid $122.58 Due Prothy $1.00 Other Costs Plaintiff Paid Date: April 28, 2005 URTIS R AOG Prothonotary (Seal) By: -/4"Z i Deputy REQUESTING PARTY: Name Joseph Rejent, Esq. Address: 2520 Renaissance Blvd., Ste. 150 1, ing of Prussia, PA 19406 Attorney for: Plaintiff Telephone: 610-278-6800 ext. 248 Supreme Court ID No. 59621 Real Estate Sale #32 On May 09, 2005 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA Known and numbered as 624 4th Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein Itite: May 09, 2005 By:`, 4J% co Real Estate eputy N G a ALL p 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 19th and 26th day(s) of July 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 Miscellaneoryg Book "M", Volume 14, Page 317. 7 PUBLICATION COPY SALE #32 Sworn to and re me thl6th day of An ist 20 AMe ?+olCb oi?g\ P j A o 'C G6i,. NOTAR PUBLIC ? My commission expires June 6, 2006 'a; Qj 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 attached hereto on the above stated dates 159.68 REAL tIBIM BALE No. 32 Writ 14M 30840.989 CNHTerm Washington Mutrasl Bank, FA, Successor by nmw to Weshkwm Mut(rn1 Hard Loans, Inc„ sueessaor In Inb~ by merjw to Fleet Mor"eCorp. Vs Barbers M. Flat Atty: Joseph Rsjuu DEBCWPTM ALL -THAT CMAIN lot or piece of land siame to the Bpmgb of New CutuWand, County of Ctunbesiaed and Commonwealth of Pemsylvanis, bomtbd and demnbed as follows, towir. BEGAR4B4G at a pant at de Sounburnan oacnesoflwtmmAv ahd 41h Strew; thence m All Fimedy duecdar along the Sonihea bWOf 4th Sam twemy five (25) fed to a point, theow m a Soodrdy daection along dx line of Lot No. 20 Section N of the Lmeroaflameodaoad Pao of Lou and Ibtoto the cpmdof the partition wall of a doable two story brick ad frame dwelling house one bwdmd forty (140) fed to Ruby Avenue; ttimce in a Wewdy daecumsbag the Nuthely dhxtim MM the Fasten line of Ruminant Av ane huadmd forty (140) feet to the place OfBBGDN G. BBB4(a pmaises No, 624 4th Sued, New 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, 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. before me this oZ?,' day of REAL ESTATE BALE NO. 32 Writ No. 2004-6399 Civil Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in Interest by merger to Fleet Mortgage Corp. vs Barbara M. Flot Atty.: Joseph Rejent ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland and Commonwealth of Pennsylva- nia, bounded and described as fol- lows, to wit: BEGINNING at a point at the Southeastern corner of Rosemont Avenue and 4th Street; thence in an Easterly direction along the Southern line of 4th Street twenty- five (25) feet to a point; thence in a Southerly direction along the line of Lot No. 20 Section H of the herein- aftermentioned Plan of Lots and through the center of the partition wall of a double two story brick and frame dwelling house one hundred forty (140) feet to Ruby Avenue; thence in a Westerly direction along the Northerly direction along the Eastern line of Rosemont Avenue one hundred forty (140) feet to the place of BEGINNING. BEING premises No. 624 4th Street, New Cumberland, Pennsyl- vania. SHAPIRO & KREISMAN, LLC BY: LAUREN TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 3337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Federal National Mortgage Association P.O. Box 1169 Milwaukee, W153201-1169 PLAINTIFF VS. Barbara M. Flot DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 04-6399 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. By: pi 6 ?-;rH P 2 C7 SHAPIRO & KRE SMAN, LLC BY: LAUREN TA)3AS, ESQU ATTORNEY I.D. INO: PA Bar ,V93337 3600 HORIZON DRIVE, SUITE !150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 04-23323 Federal National Mortgage Association PLAINTIFF VS. Barbara M. Flot DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 04-6399 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on April 28, 2005 in the above entitled action vacated without prejudice to Plaintiff. KREISMAN, LLC Lauren Tabas, Esquire r CE#TIFICATE OF SERVICE I, LAUREN TABIAS, ESQUIRE, hereby certify that on 2D ' 1 served a true and correct copy of the within Praecipe to Vacate Mortgage Foreclosure Judgment upon the following parties via first class mail, postage prepaid: Barbara M. Flot 624 4th Street New Cumberland, PA 17070 KREISMAN, LLC BY L/AWREN TABAS, ESQ] Attorney for the Plaintiff a ? 6 V ? `a N Cs rn N -? _ U m tV C'fa SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # Attorney I.D. No. 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 04-6399 VS. Barbara M. Flot DEFENDANT PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. SHAPIIRRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # Attorney I.D. Nc 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 04-23323 Washington Mutual Bank, FA, successor by merger to Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. PLAINTIFF '. VS. Barbara M. Flot DEFENDANT 78447 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 04-6399 CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on o? to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Barbara A Flot 624 4th Street New Cumberland, PA 17070 SHAPIRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff 20091'0V 30 F I qd: 23