Loading...
HomeMy WebLinkAbout04-6401 PHELAN HALLINAN & SCHMIEG, LLP LA WRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE l400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. 8120 NATIONS WAY BUILDING lOO JACKSONVILLE, FL 32256 COURT OF COMMON PLEAS CIVIL DIVISION TERM Cu'~Lr~ Plaintiff NO. 04 - tof.l 01 v. CUMBERLAND COUNTY ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 1042 WILLOWBROOK DRIVE CHAMBERSBURG, PA 1720l Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 File #: 102369 File #: 102369 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF "DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBT AIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. l. Plaintiff is WASHINGTON MUTUAL BANK, F.A. 8120 NATIONS WAY BUILDING 100 JACKSONVILLE, FL 32256 2. The name(s) and last known address(es) ofthe Defendant(s) are: ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 1042 WILLOWBROOK DRIVE CHAMBERSBURG, PA 1720l who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11/06/2002 MARGARET R. RIGGINS made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1783, Page: 1283. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2004 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 102369 6. The following amounts are due on the mortgage: Principal Balance Interest 04/01/2004 through 12120/2004 (Per Diem $l5 .28) Attorney's Fees Cumulative Late Charges 11/12/2002 to 12/20/2004 Cost of Suit and Title Search Subtotal $92,979.93 4,033.92 850.00 136.50 $ 750.00 $ 98,750.35 Escrow Credit Deficit Subtotal 0.00 1,890.74 $ 1,890.74 TOTAL $ 100,64l.09 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not owner-occupied. 10. Mortgagor MARGARET R. RIGGINS died on 04/04/2004, leaving a Will dated 03/1 9/2004, wherein she appointed MICHAEL A. MCNEW as her Executor. Letters Testamentary were granted to him on 04/14/2004 in Cumberland County, No. 2104-358. Decedent's surviving heir at law and next-of-kin is defendant JOSHUA A. RIGGINS. 11. By waiver dated 12/07/2004, JOSHUA A. RIGGINS waived his right to be named as a defendant in the foreclosure action. Said waiver is attached as Exhibit "A". 12. Plaintiff does not hold the named Defendants, MICHAEL A. MCNEW, personally liable on this cause of action and releases them from any personalliablity. This action is being brought to foreclosure their interest in the aforesaid real estate only. File #: 102369 13. Defendants, MICHAEL A. MCNEW, have been named in accordance with Pa R.C.P. 1144 (a)(2), in order to divest the equitable interests in the premises and have no personal liability for the debt secured by the mortgage. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 100,641.09, together with interest from 12/20/2004 at the rate of$15.28 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /" PIfEL~?1:r;IEG. LLP. By,:2 Is/Frands S. Hallinan t.;RENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 102369 FEDERMAN AND PHELAN, LLP By: Francis S. Hallinan Identification No. 62695 Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff WASHINGTON MUTUAL BANK, F.A. v. ESTATE OF MARGARET R. RIGGINS, DECEASED WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, JOSHUA A. RIGGINS, Devisee of the Estate of MARGARET R. RIGGINS, hereby waive my right to be named as a defendant in a foreclosure action to be instituted by WASHINGTON MUTUAL BANK, F.A. involving a mortgage secured on premises 11 OCKER LANE, SHIPPENSBURG, P A 17257, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff s sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: 12/0 7/0i ~~~~TIS~ Of the Estate of Margaret A. Riggins * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. EXHIBIT A LEGAL DESCRIPTION ALL that following described lot of ground situate, lying and being in Southampton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and limited as follows, to wit: BEGINNING at a corner of land now or formerly of Ralph Ocker, being the Northwesterly corner of the same where said land joins corner ofland now or formerly of Errol V. Coy and Curvey M. Coy, his wife; thence along land now or formerly of Ralph Ocker in an Easterly direction, a distance of 248 feet to a point, thence along land now or formerly of Smith in a Northerly direction, a distance of215 feet to a point; thence by land now or formerly of Errol V. Coy and Curvey M. Coy, his wife, in a Westerly direction, a distance of245 feet to a point; thence continuing by land now or formerly of Errol V. Coy and Curvey M. Coy, his wife, in a Southerly direction, a distance of215 feet to a point, the place of BEGINNING. BEING NO. II OCKER LANE File #: 102369 VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifications to authorities. ~ :;;~ Fr~t~s S. Hallinan, Esquire Attorney for Plaintiff DATE: (Z I2-D J bt 1I~1; ft- .~ ~ ~ V( ~ :g () ~~:V vF= 1- .-- ( ,,' ("1 "".' . ~.; (") ._... . _ -"j i r-"J .-1 tl" ;i.'"\~ (_ "I: !".; .-.,~ ~~l_; _ ':,e, f::; r-.: ~ .-- L....J ~....~. PHELAN HALLINAN & SCHMIEG, LLP BY: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, P A 19103 (215) 563,7000 WASHINGTON MUTUAL BANK, FA Attorney For Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff v. CUMBERLAND COUNTY NO. 04-640 I-CIVIL TERM EST ATE OF MARGARET R. RIGGINS, MICHAEL A, MCNEW, EXECUTOR AND ALL HEIRS AT LAW OF THE EST ATE OF MARGARET R. RIGGINS Defendant STIPULATION FOR ENTRY OF IN REM JUDGMENT, ACCEPTANCE OF SERVICE OF COMPLAINT. AND WAIVER OF NOTICE OF SHERIFF'S SALE It 1S hereby stipulated by and between Plaintiff, WASHINGTON MUTUAL BANK, F.A., by and through its attorney, Francis S. Hallinan, Esquire, and the Defendant, MICHAEL A. MCNEW, EXECUTOR OF THE ESTATE OF MARGARET R. RIGGINS, that: I, Defendant hereby accepts service of Complaint filed in the within action on or about 12/21/04. 2. Defendant hereby waives the 10 day default notice provision provided under Pa.R.C.P.237. 3. Judgment in rem only is entered in favor of Plaintiff and against Defendant in the above-captioned matter; and damages are assessed as follows: Amount set forth in Complaint $100,641.09 together with interest from 12/20/04 at the rate of$15.28 per diem to the date of judgment, and other costs and charges collectible under the mortgage and for foreclosure and sale of the mortgaged property. It is specifically understood by the parties that the Defendant has no personal liability for the debt secured by the mortgage, and is consenting to the within Foreclosure action to divest his interest in the subject mortgaged premises. 4. Defendant hereby consents to the legal action herein without any further notice of institution ofIegal proceedings or sheriff's sale. 5. Specifically, Defendant waives the right to personal service of the notice of sale and agrees that Plaintiff may effectuate notice of sale pursuant to Pa.R.C.P. 3129 upon him by regular mail and thereafter filing an Affidavit of Service of same with the Office of the Prothonotary. } /a 5/0r- I F ncis S. Hallinan, Esquire Attorney for Plaintiff d/ 1JIc/; ~A. McNew, Executor Of the Estate of Margaret R. Riggins Date: Date: I ~ f) V - O~ , ;~ --n t--;'\ 0;) \ - "-.9 x:- ,PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103.1814 (215) 563,7000 WASHINGTON MUTUAL BANK, F.A. 8120 NATIONS WAY, BUILDING 100 JACKSONVILLE, FL 32256 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04.6401-CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 11 OCKER LANE SHlPPENSBURG, PA 17257 Defendant(s). PRAECIPE FOR IN REM JUDGMENT IN COMPLIANCE WITH SIGNED STIPULATION TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against EST ATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS, Defendant(s) in accordance with signed Stipulation for Entry ofIn Rem Judgment, Acceptance of Service of Complaint, and Waiver of Notice of Sheriffs Sale: As set forth in Complaint Interest from 12/21/04 to 3/1/05 TOTAL $100,641.09 $ 1.084.88 $101,725.97 I hereby certify that (1) the addresses ofthe Plaintiff and Defendant(s) are as shown above, and (2) that notice in accordance with Rule 237.1, is not required in this case per Stipulation. DANIEL G. SCHMIEG, EIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS lNDIC(!;D.. y; DATE: (f2'a/J r ~ ;;(., ~coS" E~ .J I:! . PRO PROTHY (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW WASHINGTON MUTUAL BANK, F.A. 8120 NATIONS WAY, BUILDING 100 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 04-6401-CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on (rJ~ .J. 20o.S. If you have any questions concerning this matter, please contact: DANIEL G. SCHMIEG. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST A nON 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** .PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS NO. 04-6401-CIVILTERM Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /'J DANIEL G. SCHMIEG, ES Attorney for Plaintiff , PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUiTE 1400 PHILADELPHIA, PA 19103.1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK, F.A. 8120 NATIONS WAY, BUiLDING 100 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO.04-6401-CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS is over 18 years of age and resides at , 11 OCKER LANE, SHIPPENSBURG, P A 17257 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. c~ ~- ~ ~ ~ ~ 9..f ~ (") -u.l. 7l~ () -3:: -.j ~ ~ ()- ~ ,J:- "".,. C:;::' c::,? "" :;ll: ')::1\0' -;;0 I N o --{1 :r. .." rnf~ _dfT1 ~f:':C) ;~;?,r-! ,.~,. l. ".";.:- -\, \,,~f,) ,',~f'n \...,.l .~--t :::r:'''' ~: .r ..s;) ~i; '...:.. . - CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 W ASHlNGTON MUTUAL BANK, F.A. Plaintiff, v. No.04-6401.CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $101,725.97 Interest from 3/1/05 to JUNE 8, 2005 (per diem -$16.72) $1,655.28 and Costs TOTAL $103,381.25 DANIEL G. S HMIEG, ESQUI One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ~ .... ~ ~ ... ~ ~ ~ ~ ~ .,J., ~ ~ .,J., ~ .... .,J., ~~ ~ -d .... 0) ~z .... .,J., ~ ~ ....~ '6 ~ .,J., '6" ~ '" ~;;.: ... <;0\.... ~~ j!, ~~ ~ ~~ ~e, ~ ~rJ1 ~~ ...~ e z ~~ ~z ~ t~ '" 'il ~~ 'i ~~ ~ o.,J., u~ p. "'$.'; ? J, ~~ Oe::, 0) ~~ .... ... ~.~ "'~ ~~ ~ i ...~ .,J.,~ 0" Ou ~ ~... "'1, ~ ~A ~ .,J.,O ~~ :a '--t ';2~ e~ u ~ 0 ~ ~:. ~ ~ ~~ ~ ~~ ~ Jl'f}. ~ ~ ~ " ~ ~u ~ >- CI' ,.~~ _':!!' ~ ::~: ., ~,~~~ - 'j;;; ~ :.a: ,!j~;~~ N .,J., : \.,) ~ '::."': I <:u 0- 0:: ::,~,ltlj "'~;): :rn - ~ .,J., ~ <j .Jl j.....~ :c ~ V:l tJ- -'" ctr.l- ~ ~ cO rl C;:!- 0 = ::n: .:: () c-> - ~ \oil - , ~cJ ~ CJ ,;) :r - \ \ \ ~ a I..-, r- \ ? \oil a , 11 ::J ,:) - try- <J () () V). \J?' <;:j (:) V1 N r/, ~ Q-' t>o VI "t ~ --:n- .----- . LEGAL DESCRIPTION ALL that following dw:ribed. lot of ground silUale, lying ar<<l being in SOIlIllam-pIOD TowllSbip, Counly of (''nmber!alld. Commonwealth ofPcnnsylvania, bounded and Iimiu:d 118 follows, 10 wit: BEGINNING al a comer of land oow or formerly of Ralph Ocker. ooing me Northwesterly corner of !he same wbcre said land joins comer of land now or formerly of Errol V. Coy and Curvey M. Coy, his wife; thence along land now or formerly of Ralph Oclrer in aJl ~crly direclion, a distance of 245 feel to a point,; lIlence a111ng 1Jmd JU}w or ft'lrmerly of Smith in a Northerly direction, a distance of 215 feet to a poimi tflence by land flOW or fOl'llletly of Br:rol V. Coy allll C\lTvey M. Coy. hill wife, in a Westl:1'l,y direction, a dislallCe uf24S feet to II point: IhellCc continuing by land now or formerly of Errol V. Coy and Curvey M. Coy. bis wife. in a Southerly direc\ioll. a <Ii.>lam':e of 215 feci to ill)oinl, lilt: place of beginning. fURTUER being described as Parcel F, in Plan 29--29. TITLE TO SAID PREMISES IS VESTED IN Margaret Riggins, a single woman hy Deed from Brian C. Hancocli: and Paula D. "allCOCk, husband and wife dated I0128f1999 and recorded \1/1/1999, in Deed. Boot 210 Page 803. TAX PARCEL # 39-37-2092-038 PREMISES BEING: 11 OCKER LANE, SHIPPENSBURG, P A 17257 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04.6401 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, F.A., Plaintiff (s) From ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OFMARGARETR. RIGGINS (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) lfproperty 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 $101,725.97 L.L. $.50 Interest FROM 3/1/05 TO 6/8/05 (PER DIEM - $16.72). $1,665.28 AND COSTS Atty's Comm % Due Prothy $LOO Atty Paid $82.00 Other Costs Plaintitf Paid Date: MARCH 2, 2005 CURTIS R. LONG (Seal) pr~tho~ ~ ,-By. . Deputy ~/2A' /' REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court lD No. 62205 " WASHINGTON MUTUAL BANK, F.A. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS CIVIL DIVISION NO.04-640I-CIVILTERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) WASHINGTON MUTUAL BANK. F.A., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at. II OCKER LANE. SHIPPENSBURG. PA 17257 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS II OCKER LANE SHIPPENSBURG, PA 17257 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None , 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained. please indicate) COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTENTION: JOHN MURPHY 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG. PA 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM \3TH FLOOR. SUITE \300 1001 LIBERTY AVENUE PITTSBURGH. PA 15222 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG. PA 17105-8486 INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 11 OCKER LANE SHlPPENSBURG, PA 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 1. 2005 DATE /7 /.. DANIEL G. SCHMIEG, ES Attorney for Plaintiff r-.::I c:? t;.."':l "-" ,. '2:~ ,'~ \ {'.) ------ J-"" :::r;. SA 9."" fnr;~\ ~_91C) "L I "_:)(~ ~t;~ :~:<~ --' -,' x:- ...p :.:::? -~ ~ WASHINGTON MUTUAL BANK, F.A. Plaintiff, CUMBERLAND COUNTY v. No.04-6401-CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS Defendant(s). March 1, 2005 TO: ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 11 OCKER LANE SHIPPENSBURG, PA 17257 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 11 OCKER LANE, SHIPPENSBURG. PA 17257, is scheduled to be sold at the Sheriffs Sale on JUNE 8. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $101.725.97 obtained by WASHINGTON MUTUAL BANK. F.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: l. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE LEGAL DESCRIPTION ALL that following: de~ribcd 101 of ground situate, lying and being in Southampton Township, County of Cumberland, COllllIlonwealth of PClUlSylvania, bounde,", and limited ag follows, 10 wil: BF.G1NN[NG al a comer of land now or formerly of Ralph Ocker, beillg thc Norrhwe.>rerly corner of the same wbere said lalld joins corner (If land now or formerly of Errol V, Coy and Cuevey M. Coy. his wife; lheoce along land now or formerly of Ralph Ocker in an Easterly dir~lion, a distance of 245 feel 10 :l )'nint; tllellCe along land now or formerly of Smillt in a Northerly directioo, a distllnce of 215 feet 10 a poilU; ll100ce by land now or fonllerl; of Errol V. Coy aOll Cuney M. CO), his wife, in a Westerly direction, a di~laOO: uf245 flX1 to a puint; thence culltinuing by land oowor fonnerly (lfErrol V. Coy and Curvey M, Coy. bis wife. ill a Soolherly directlon, a distance of 215 fCl:t to a point, the place of beginn~. FURTHER being described as Parcel F, in Plan 29,29. TITLE TO SAID PREMISES IS VESTED IN Margarct Riggins, a single, woman by Deed from Brian C, HallCoclc and Paula D. HancocK, husbllud and wife dated 1012811999 aOll recorded 1111I1999, in Deed Book 210 Page 803. TAX PARCEL # 39-37,2092-038 PREMISES BEING: 11 OCKER LANE, SHIPPENSBURG, P A 17257 r~:l' ';i:':~ 0" -::l1' y~ :;:0 \ r-> o '::0 -\ ""c...-) fnt', :91t':"J ;.:",,1.., '),l, ,~-,?:~; /-~l(:) ..:::"'f'f'. , , ':;:':~ -:~ii ~ - -- ,:- u> --- - SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-06401 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS RIGGINS MARGARET RESTATE ETAL R. Thomas Kline ,Sheriff or Deputy Sheriff, who be'ng duly sworn according to law, says, that he made a diligent searc and inquiry for the within named DEFENDANT MCNEW MICHAEL A EXECUTOR OF ESTATE OF MARGARET R RIGGINS b twas unable to locate Him in his bailiwick. He therefore returns t e COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , MCNEW MICHAEL A EXECUTOR OF ESTATE OF MARGARET R RIGGINS 11 OCKER LANE SHIPPENSBURG, PA 17257 11 OCKER LANE SHIPPENSBURG IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.80 5.00 10.00 .00 47.80 So answ,:;::~ ---:=?:~'~~,r-:- R. Thomas Kline Sheriff of Cumberland County ~/ ,-~ -------.-- PHELAN HALLINAN SCHMIEG 04/18/2005 Sworn and subscribed to before me this O(lO-o->--;;:D . 0'1:" 1YI~ Prothonotary ol0- day of /P t ~l ~,.."., SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-06401 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS RIGGINS MARGARET RESTATE ETAL R, Thomas Kline , Sheriff or Deputy Sheriff who b~ing duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MCNEW MICHAEL A EXECUTOR OF ESTATE OF MARGARET R RIGGINS but was unable to locate Him in his bailiwick. He thereforE deputized the sheriff of FRANKLIN County, pennsylvani , to serve the within COMPLAINT - MORT FORE On April 18th , 2005 , this office was in receipt of t e attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co 6.00 9.00 10.00 100.00 .00 125.00 04/18/2005 PHELAN HALLINAN So answery :> ::~~~ R. Thomas Kllne Sheriff of Cumberland -.,""' .-'- County SCHMIEG Sworn and subscribed to before me this dj day of ~. ,Jo.o,~A.D. O~.LA'~~ - prothono ry /' "\ " i (;"J"~'i, , , SHERIFF'S RETURN - REGULAR CASE NO: 2005-00002 T .it 0'-\ - (., 0\ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN WASHINGTON MUTUAL BANK VS ESTATE OF MARGARET RIGGINS ET KENNETH W. HALL , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT-MORT FORECLS was served upon MCNEW MICHAEL A th DEFENDANT , at 0015:35 Hour, on the 12th day of January ,2005 at FRANKLIN CO SHERIFF'S OFFICE 157 LINCOLN WAY EAST CHAMBERS BURG , PA 17201 by handing to MICHAEL A MCNEW a true and attested copy of COMPLAINT-MORT FORECLS together ith and at the same time directing His attention to the contents t reof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: .00 .00 .00 .00 .00 .00 KENNETH W. By / Deputy 04/12/2005 CUMBERLAND CO SHERIFF Sworn and Subscribed to /37h day of , before me /'A.D. _._--'-~ ----.- Notarial ~cal L Richard D. McCa.-ty, Not31)' Pubtic Ch3lllbersburg Boro..Flanklm CCl~ty My commission E'l:pue:, ,~. 29, _007 ------- k~b , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WASHINGTON MUTUAL BANK, FA ) ) CIVIL ACTION vs. ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE EST ATE OF MARGARET R. RIGGINS ) CIVIL DIVISION ) NO. 04-6401-CIVILTERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, DANIEL SCHMIEG, ESQUIRE attorney for WASHINGTON MUTUAL BANK. F.A. hereby verify that on March 8, 2005 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Mav 5. 2005 WASHINGTON MUTUAL BANK, F.A. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS CIVIL DIVISION NO.04-640I-CIVILTERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) WASHINGTON MUTUAL BANK, F.A., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 11 OCKER LANE, SHIPPENSBURG, PA 17257. I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 11 OCKER LANE SHIPPENSBURG, PA 17257 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record intcrest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTENTION: JOHN MURPHY 6TU FLOOR, STRA WBERRY SQUARE D EPT. 28060 I HARRISBURG. PA 17128 INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER 13m FLOOR. SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH. PA 15222 DEPARTMENT OF PUBLIC wELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM P.O. BOX 8486 wiLLOw OAK BUILDING HARRISBURG. PA 17105-8486 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 11 OCKER LANE SHIPPENSBURG, PA 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities. March L 2005 DATE DANIEL G. SCHMIEG, ES Attorney for Plaintiff "'.., ~-[ . z c_o:: ~9 o ~ ~o "," ~ 0 ~ W o .. "'.., o 0 o - 0"- ~.~ ~3 -if 'g" .0 0:; Ell 0' ga "'''' 3 0 '2.g ~~ ~~ '" . z ~ Q. i:' g S, o ~ ?g~g.&-;J p~'<i-@ ~ ~;l::8= ::;9~gg- ~FH Po gj-a- g. ~ ~ a ~ ~ g" .... _. 1Il"" 0 "",::l v.~...... :. g- J5 ~ ~ e- g 0 ~ '[ _. _.:5 a ~.~~ g.~ o ~ .... tr"" ~ ~ Q ....g c 0-11 ~ ~ ;;"n~;;lg. ~ :.. ~ ~ g ~ t;: s a ~ ~ .g~ ~ go =003 g-~ . " . :: ~.I:l'l g ~-~~~ 53 *;:-. @ _. '" :;I P.E...~n 3" t:!.3 .!l;;:!; 'i ~- g g =1: 3 ~ ilfaJl :rn'd;- o 0 ("J ..., ~:1gz. 0' tTI '" El &j g ~ ~ ~ ~~ ~ g:: _,tl S (> - E. ~ f' 9 g: - [,Il!ll ('>:3 g f"l .. e [-.3 00..:"5' ~ _.v. c.. ~~ 5' ~ ~ ~. 0 s ~ ~ g~' ~g,&~ ::: ~''<:l 2: ~ <i" <11 [. gQ' - V> ~ ::; N trltrl "'''' ...,..., ;..;.. @t;j 00 ..".." ~~ 00 ~~ -i..., ?? ~~ 00 00 ZZ "'9' I:: ",n ~~ r ?> ~ trl .~ rn @ () ~ o i" ~ ~ r :r: cn ::a '" ;.. ..., r ;.. ~ o >Tj ~ -- ~ :; -0 00 -.J ~ U> ... w N ~ ~ ..., o () () c:: '" ;.. Z :-J S:"lIO;::2",HCl () 0 Z ob!ll..,..,~~0009 ~ ~ ~ ~~ t1 ~ ~ ~ ~ ~ r><i!8>2!ili ~ ::l i ~~m::ot'"'- z~ ~ () i ~~~~~rnQ~;.. ~ '" Z:Eo;,<~'" ~;.. i ~;=::;;;j~~~~ 0 g i -mOr:-cCt'!'1t.-;1t:1tt1"T1 Z o_~ I [Do ::OMt=J""C"'~~ ~:Ero~"<~ rn 0 ()Oo:..::oo.;~rn ~ .." C)>:Eg<rnH~ '" () """m-nlOfi<:: ~ $ ~1Il!;;S::!"~-~~ @ -.....~)>g;;:lMi';!;: ~> \iJ ~o;l]::Oo-"'- r '" z.!".., '" ol'l > ~P:ti~~ i;J~~ g a r:rr<",~OM '" () 5)>0"'''' '2:> > 0 ;z:;I])>Zo "," c:: ? ~ ~ill~1ilz~l:l~~ ::;! o 1Il)>...,;;1 0\\1 z. oc:r--(fJ...... ~...., ::; ^;I]:!:4"'- ;liO 0 Z oPc"'O~iil!<! >Tj 0 ~"lIZ~~ '<lH ~ ::1 <)>=1::0'" :x: 0 til ;r: rn~- C'lO~o.;!ii t;; ()~m:?=~ll1 t-<> S;z I&-l...,t'1~ ... s; 0 )>L)>>::O" >' < s:",-l - x'" rntmV; 0 t;1 m en;l]...:!l to '" ::u m'" ~ 0 '" en 0....... ><..., ~ ~ ~ ~,~ ~ ~\ ~ ~;:; :t: jl ~ ~ o () ~ ? r ~ :5j 'd '" ~ '" to ~ ." ;;. - -.J tv V> --1 r S' " 0>2: ""'''''' ~ '" a '" ~ '" " '" " g.rIl= .. '" )> ~ c;' co z c 3 C" '" ~ o S " . > ~ ~ i ~~o~ ~~g~ ~ ~t"' G~G> -g:g.sz 0;'"'1 () ~ - . " 'tl;>:: " )>"~t"' ~S"t:::i '.o~......L.., :;~ 00>- w g.Z ~Ol",,,,, ooga-{'-o- ~~!'lCll i!g~ ~ o.@ .....CIl"Cl ;., '" - ., ft. ~ " . = - r "0'" 'tl " <=> ... <=> ~~~f'%.~ ~j~~ iT ..z ,---~- :J - PffNt:VSOW'ES ~ 02 1A $ 01.800 . ~ 0004300371 MIIR 08 2005 M/l.ILEOFROM ZIPCOOE 19103 ~~_<C'~/i> y - -<'+,;.. '", flii=-~ 1~ '~~ :~tI 1'-, ~,r;:.. ~ .., R (') C ..< c.-.:, ....~". :c.:"_"' ~: ::.) <:,J\ ~~ -:j nl -. . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Secretary of Veterans Affairs is the grantee the same having been sold to said grantee on the 8th day ofJune A.D., 202005, under and by virtue of a writ Execution issued on the 2nd day of March, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 6401, at the suit of Washington Mutual Bank F A against Michael A McNew exor/heirs is duly recorded in Sheriffs Deed Book No. 269, Page 3903. IN TESTIMONY WHEREOF, I have hereunto set my hand -Ii and eal of said office this I day of ,A.D. der of Deeds , Cumbo_ Counl)l, Carlisle PA E>jlireo the Flrot Monday of Jan.' 2C08 Washington Mutual Bank, F.A VS Estate of Margaret R. Riggins, Michael A. McNew, Executor, and all Heirs at Law Ofthe Estate of Margaret R. Riggins In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-6401 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Estate of Margaret R. Riggins, Michael A McNew, Executor, and all Heirs at Law of the Estate of Margaret R. Riggins, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania, to serve the within Real Estate Writ, Notice of Sale and Description according to law. Franklin County Return: Served the within named defendant, Estate of Margaret R. Riggins, Michael A McNew, Executor, and all Heirs at Law of the Estate of Margaret R. Riggins, on March 28, 2005 at 10: I 0 o'clock A.M., by handing to Michael A McNew at 5034 Lincoln Way West, Fayetteville, PA 17201. So Answers: Hon. Robert Wollyung, Sheriff of Franklin County, PA. Cpl. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2005 at 6:07 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Estate of Margaret R. Riggins, Michael A. McNew, Executor, and all Heirs at Law ofthe Estate of Margaret R. Riggins, located at 11 Ocker Lane, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Estate of Margaret R. Riggins, Michael A McNew, Executor and all Heirs at Law of the Estate of Margaret R. Riggins, by regular mail to his last known address of5034 Lincoln Way West, Fayetteville, PA 17201. This letter was mailed under the date of April 18, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 8, 2005 at 10:00 o'clock AM. He sold the same for the sum of$1.00 to Attorney Daniel Schmieg for Secretary of Veterans Affairs, an Officer of the United States of America. It being the highest bid and best price received for the same, Secretary of Veterans Affairs, an Officer of the United States of America of 1000 Liberty Ave., Pittsburgh, PA 15222, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $861.09. Sheriffs Costs: Docketing Poundage Posting Bills $30.00 16.89 15.00 Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postage Out of County Franklin County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 15.00 30.00 10.00 .50 1.00 14.06 6.87 15.00 20.00 .37 9.00 72.48 256.10 267.85 16.47 25.00 39.50 861.09 Sworn and subscribed to before me So Ans~;JJ~ /"' .,.. ~PI-' ~" This--.-r..:..dayof~ .'~ -r-,rr~ .~ ~, . y. Thomas Klme, Shenff 2005, A.D. \.. ~;6ilio~o~Yh~O'", ~ BY\)och5~ Real Estate eputy IJV 3D' I. t>V J~~ 0-- Ut. 50':;;)'; 62v n~/~1 WASHINGTON MUTUAL BANK, F.A. , CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS CIVIL DIVISION NO.04-640I-CIVILTERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3]29 (Affidavit No. I) WASHINGTON MUTUAL BANK, F.A., Plaintiff in the above action, by its attorney, DAN]EL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 11 OCKER LANE. SHIPPENSBURG, PA 17257. I. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS 11 OCKER LANE SHIPPENSBURG, PA 17257 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: , Name Last Known Address (if address cannot be reasonably ascertained. please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTENTION: JOHN MURPHY 6TH FLOOR. STRA WHERRY SQUARE DEPT. 280601 HARRISBURG. PA 17128 INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER 13TH FLOOR, SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH. PA 15222 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 11 OCKER LANE SHIPPENSBURG, PA 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofI8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 1, 2005 DATE DANIEL G. SCHMIEG, ES Attorney for Plaintiff . WASHINGTON MUTUAL BANK, F.A. Plaintiff, CUMBERLAND COUNTY v. No.04-6401-CIVILTERM ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS Defendant(s). March 1, 2005 TO: ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE EST ATE OF MARGARET R. RIGGINS 11 OCKER LANE SHIPPENSBURG, P A 17257 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at ,11 OCKER LANE. SHIPPENSBURG. PA 17257. is scheduled to be sold at the Sheriffs Sale on JUNE 8. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $101.725.97 obtained by WASHINGTON MUTUAL BANK. F.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5 . You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It mav not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE . LEGAL DESCRIPTION ALL that Mowing dcscri\lc(llot of gfOllnd situate. lying and beill8 in SOIllbamplOD TO\1/DSblp, County of Cumberlml. Commonwealdl of Pua.syIVllDia, IlouJIdcd B!Illlimlled a., follows. 10 wit: BF..GlNNING at a corner of land now or fonnerl)' of Ralph 0cIr0r. being the Nor!hwe$tetly corne-r af the .same where said land joins comer ofland BOW or formerly of Enol V. Cuy and c.'urvey M. CQY, his Wife; lIlence alone land now or formerly of Ralph Dew in an Easterly direction, a di$tance of 245 feet to a point; Ihence along IaD/llWw or formerly of Smid1 in II Nortberly dir~. II distanl:e of 215 feet 10 a poiLU; dletlce by land now or formerly of Eml V. Coy and C\lJYIlY M. COy. hill wife, in a Westerly dlreetloD, II disJance of 245 ReI to II point: ~c l:OIIIinuing by llllld now or fonncrly of E'.m?I V. Coy and Curvey M. Coy. bis wife. in a Soolherly direction. a distanee of 215 feet to II point, the place of begimllng. FURTlIER being described lIS Parcol F. in Plan 29-29. TITLE TO SAID PREMISES IS VESTED IN Margaret Riggins, a single woman by Deed from Brian C. HallCoc1c and Paula D. ~.k, husband and wife dated 10/2811999 and recuri.!ed 111111999, in Deed Book 210 Page !!O3. TAX PARCEL # 39-37-2092-038 PREMISES BEING: 11 OCKER LANE, SHIPPENSBURG, P A 17257 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6401 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK. F.A., Plaintiff (s) From ESTATE OF MARGARET R. RIGGINS, MICHAEL A. MCNEW, EXECUTOR, AND ALL HEIRS AT LAW OF THE ESTATE OF MARGARET R. RIGGINS (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $101,725.97 L.L. $.50 Interest FROM 3/1/05 TO 6/8/05 (PER DIEM - $16.72) - $1,665.28 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $82.00 Other Costs Plaintiff Paid Date: MARCH 2, 2005 CURTIS R. LONG (Seal) Protho~ p ~ "'-By: a.-,... 0 . :;P A'........(G.~ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG. ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 ....;:t ..... ->-- 0::1- w~ ::I: ==~ (/) c.:~ W~'t :r: ~,~. 1-- E):~'; Wee ~u_; L1-S: 1..1-...>.- 0=: (,) Real Estate Sale #28 On March 09, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA Known and numbered as 11 Ocker Lane, Shippensburg, more fully described on Exhibit "A" CT .::t rued with this writ and by this reference incorporated herein. 0... GO I ~te: March 09, 2005 :::E: By:J~/J~ Real Esta~ Deputy ~ ~ ~ ..,.., = = ....... ,....'=~ ( THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Connnonwcalth 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 Connnonwealth 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 andlor Sundayl Metro editions which appeared on the 26th day(s) of April and the 3rd and 10th day(s) of May 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge ofthc facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COpy S ALE #28 Sworn to and s CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PUBLICATION Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 267.85 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ~~ REAL Enm! MU!...... WItt.....1 I 1181 CIvlI ,.. WMIIL........1IuIllaI1l8tIII, F.A. v. .L'1"~f=:~ Aft.IlIlIrS8I..... <lithe e- <II .~= DESl:RIP'11ON , AlLlRAT!iilIooiJlg~..lJtJ'Ol'ld .......blD&-.l.....-inSoolllaqlloo'lbwDohlp. ~-of ~,Comi!Dl"- of Pamlymail,lilomded_ _.. rolIoWs," ri: . . BIlGlllllIN<lIl._ofWld-or fmrlrolyofRaljlilOdcr.bei\lIlhe__y """"oflhe __ uidlaodjom._OC WId _ '" fmrlroly ofEm>l V. Coy ... CUney M. Coy. his wile; ..... oJooc WId _ or fmrlrolyofRllpilOdcrin..liloI<JlY-,' _ofllilat..1p<i1t;,.oJooclll>d _orfmrlrolyof Smilbla.IIciIlIIrJIy-. ._ of 21.5 1at...p<iIt;..... by WId _ or fmrlroly of Em>l V. Coy aad CUney M. Coy.hiswile,ia.w..lIIIydirt<lioo.._of lASIat...poiII;..... COlIIiDPiDg by 1aIl<l_ or fmrlroly of Bmol V. Coy ml CUney M. Coy. hiswile.iIl .SolIlIlaIydirt<lioo.l_of 2ISf......poiIlt,lhep@l:eol1lllOlNNlNG. . FIJKl'llER bei\lIlIiI:ribcd Ii PmoI F, ia Kln29-2!J. 1UU!. 10 WI> . ia..- ia MaIpll!i'''' I """"-, by.Doed...... BrilnC._mlJ'aolaD._,- _ wiIe._ ~"_111l1 1'l'!9~~~~:'.. """': Ii -oo.,!.lD<, Sh\{ . 1*iTJ!t1." . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough ofCarIisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: J\priI15,22,29,2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertiselT'?ut, and that all allegations in the foregoing sta ?1.l1ents as to time, place and charact . "'blication are true. SWORN TO AND SUBSCRIBED before me this 29 day of April NOT ARI SEAl. LOIS E. SNVDEfI, Notary Public Cartisle 8010, Cumberland County My Commission Expires March 5, 2009 .t, REAL ESTATE SALE NO. 28 WIlt No. 2004-6401 CM! Washington Mutual Bank, F.A. vs. Estate of Margaret R. Riggins, Michael A. McNew, Executor and AU Heirs at Law of the Estate of Margaret R. Riggins Atty.: Darnel Schmieg LEGAL DESCRlPTION ALL that following described lot of ground situate, lying and being in Southampton Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and limited as fonows, to wit: BEGINNING at a comer of land now or formerly of Ralph Ocker. being the Northwesterly corner of the same where said land joins cor- ner of land now or formerly of Errol V. Coy and Curvey M. Coy, his wife: thence along land, now or formerly of Ralph Ocker in an Easterly di- rection, a distance of 245 feet to a point; thence along land now of for- tion. a distance of 215 feet to a point; thence by land now or formerly of Errol V. Coy and Curvey M. Coy. his wife. in a Westerly direction. a distance of 245 feet to a point; thence continuing by land now or formerly of Errol V. Coy and Cunrey M. Coy. his wife. in a Southerly di~ reellon. a distance of 215 feet to a point. the place of beginning. FURTHER being described as Parcel F. in Plan 29-29. TITLE TO SAID PREMISES IS VESTED IN Margaret Riggins. a single woman by Deed from Brian C. Hancock and Paula D. Hancock, husband and wife dated 10/28/ 1999 and recorded 11/111999. in Deed Book 2 IO Page 803. TAX PARCEL #39-37-2092-038. PREMISES BEING: 11 OCKER LANE. SHIPPENSBURG. PA 17257. x 'n Ill; .