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Home My WebLink About05-0280 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE JACKSONVILLE, FL 32258-4455 ATTORNEY FORPLAINTWF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Or ->>'0 c"<>d'r~ CUMBERLAND COUNTY v. LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISLE, P A 17013 Defendant 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 Slteet Carlisle, PA 17013 (800)990-9108 File #; 109949 File #: 109949 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S,C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFfER 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 ABN AMRO MORTGAGE GROUP, INe. 7159 CORKLAN DRIVE JACKSONVILLE, FL 32258-4455 2, The name(s) and last known addressees) of the Defendant(s) are: LEE A. WOODALL 21 WEST MULBERRY HlLLROAD CARLISLE,PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On OS/24/2002 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office ofthe Recorder of CUMBERLAND County, in Mortgage Book No. 1760, Page: 486. 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 09/0112004 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 #: 109949 6, The following amounts are due on the mortgage: Principal Balance Interest 08/01/2004 through 01/12/2005 (Per Diem $42.13) Attorney's Fees Cumulative Late Charges OS/2412002 to 01/1212005 Cost of Suit and Title Search Subtotal $219,680.86 6,951,45 1,225.00 299,40 $ 550.00 $ 228,706.71 Escrow Credit Deficit Subtotal 0.00 299,84 $ 299,84 TOTAL $ 229,006.55 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 Sheriff's Sale. Ifthe Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974. Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or haslhave been denied assistance by the Pennsylvania Housing Finance Agency. 9, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 229,006.55, together with interest from 01112/2005 at the rate of$42.13 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, ~ PHELAN HALLINAN & SCHM'~~ ~fh ~~ By: Is/Francis S, Hallinan LAWRENCE T, PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 109949 ALL THAT CERTAIN tract of land situate in Middlesex 'l:ownship, Cwube:dand County, Pennsylvania, being Lot No", 5', as shown on the plan entitled Meadowbrook Farms Final SUbdivision Plan Phase 11 dated February 12, 1999, last revised June 3, 1999, and recorded August 17, 1999, in Cumberland County plan Book 79, Page 85, more particularly bounded and described as follows, BBG:I1IlN1NG at an iron pin, lying in a westerly right-of-way line of country Side Drive (50-foot right-af-way)', and being a northerly corner of Lot No, 77; thence along said Lot, South 62 degrees 01 minutes 02 seconds West, 189.06 feet to an iron pin, being a westerly corner of said Lot and lying in an easterly line "f Lot No. 60; thence along said Lot. North 27 degrees 58 seconds West, 120.00 feet to an iron pin. being a northerly corner of said Lot and lying in a southerly right-Of-way line of Mulbe~ Hill Road (SO-foot right-ot-way); thence along said right-ot-way, North 62 degrees 01 minutes 02 seconds Bast, 187.73 feet to a point, lying along said right-of-way; tbence continuing along said right-ot-way, along a curve to the right, having a cbord bearing of South 69 degrees 38 Illinutea 16 seconds East. a chord distance of 37.36 teet, a radius of 25,,00 feet, and an arc distance of 42.19 feet to II. point, lying in a westerly line of Country Side Drive (SO-foot right-of-way); thence along said right-of-way. South 21 degrees 17 minutes 34 seconds East, 19.94 feet to II. point; thence continuing alons said right-of-way. along a curve to the right, baving a chord bearing of South 11 degrees 39 minutes 25 sedonds East, a chord distanCe of 75.32 feet, a radius of 225.00 feet, and an arc distance of 75.68 feet to an iron pin, being the place of BEGINNING. CONTAINING 0,564 acre. BEING THE SAME PREKISKS which Wdrt.l1.ington Development, L ,1'. , by deed dated November 13, 2001 and recorded November 29, 2001 in the Office of the Recorder of Deeds in and fo,," cumberland County, Peunsylvania. in Deed Book 249. Page 1828, granted end conveyed unto Mark Sheely Builder, Inc. PREMISES BEING: 21 WEST MULBERRY HILL ROAD . VF,RIF1(,ATTON Loan Administration Katrina Dupuy hereby states that he/she is Officer ot ABN AMRO MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his /her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. CoSo Sec. 4904 relating to unsworn falsification to authorities. DATE: \ Ilul 0<: ~ -(Q. ~ 1- lf1 .....' 0 r ~~, CI\ C,','> -n cr' .-\ '- "'(' 8 :;'," i"1JJ W .' r- ",;"::... _"rtl - ....0 -.,..,\e) lr\ w "39\ -0 ...a -0 ,-n ...t:::: ~~; -"') -~~ Vl p- ..c) C/) ."..,.n W ~? C,>, - ,,";:,-, ( ~ _,.1 Q , " -<, c.... .~ - PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T, PHELAN, ESQ., ID, NO. 32227 FRANCIS S. HALLINAN, ESQ., ID, NO, 62695 DANIEL G. SCHMIEG, ESQ.. ID, NO, 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND County LEE A. WOODALL No. 05-280 CIVIL TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP By: ~~~ FRANCIS S. HALLINAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff Date: February 10. 2005 Imrm, Svc Dept File# 109949 -n SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-00280 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS WOODALL LEE A R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WOODALL LEE A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , WOODALL LEE A 21 WEST MULBERRY HILL ROAD CARLISLE, PA 17013 PER PO, LEE IS AT GIVEN ADDRESS. PER PARENTS, LEE IS LIVING IN PHILA AREA, NO ADDRESS GIVEN. PARENTS RESIDE AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: .., 18.00 3.70 5.00 10,00 .00 36.70 ,..-, _....,~-;.. -~-"" ~,;?--;;-." .-, ...---- ~7 ~: R, Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 01/25/2005 Sworn and subscribed to before me this J,L4 day of L.p~.. h '} :U'Os A.D, (Itt~ Q. fl.1AJIIAJ ti,."".1f P 0 honotary I I . PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ" rD. NO, 32227 FRANCIS S, HALLINAN, ESQ., ID, NO. 62695 DANIEL G, SCHMIEG, ESQ., ID, NO, 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. ATTORNEY FO vs. CNIL DIVISION Plaintiff CUMBERLAND Co ty LEE A. WOODALL Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE F RECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with eference to the above captioned matter. PHELAN HALLINAN & C~IE~ }LP By: . 5, ~ FRA CIS S. HALLINA ,ESQUIRE LAWRENCE T. PHELA ,ESQUIRE DANIEL G. SCHMIEG, SQUIRE Attorneys for Plaintiff Date: March 31. 2005 /jrnr. Svc Dept File# 109949 r--" " \,..~'" ,,' - - SHERIFF'S RETURN - OUT OF COUNTY CAS~ NO, 2005-00280 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND . ABN AMRO MORTGAGE GROUP INC VS WOODALL LEE A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent sea ch and and inquiry for the within named DEFENDANT , to wit: WOODALL LEE A but was unable to locate Him in his bailiwick. He therefo e - .- - - deputized the sheriff of CHESTER -- County, Pennsylvania, to -,- serve the within COMPLAINT - MORT FORE - On March 3rd , 2005 , this office was in receipt of t e -<loo ..... ..... - attached return from CHESTER Sheriff's Costs: Docketing Out of County Surcharge Dep Chester Co 18.00 9.00 10.00 24.55 .00 61.55 03/03/2005 PHELAN HALLINAN So answers,;, ...'~ ~"-") -..~ County SCHMIEG Sworn and subscribed to before me this '7 day of ~ ') otc?-'; A.D. Lj~~/>"""-<> . .?b4 I P{~thon~t-;;:; "7'.J - -,- - ..... - ..... I =1 -..1 ::':::1 ..... - , SHER:1 F'S (OS1S ~. l~ L~ te ,- I 7 - " ,) In .The 'Court of Common Pleas of Cumberland Coun1f,_!,-e_ri_ ~'lni~~g ABN AMOO Mortgage Group Ine, Rec:cipi Ph. .<71(, (, if VS. " :2 /1" -oS Lee A. Woodall .. (,), (, 'IF lost day to 3 rlice s(-: (J.5 (' u,; 8' () 05-280 civi No. /6. I':' Now, February 15, 2005 , I, SHERIFF OF CUMBERLAND COUNT , P A, do hereby deputize the Sheriff of Chester County to execute this Writ, this .3 C) deputation being made at the request and risk of the Plaintiff. ~ ~(?p:? ,,:V,#' M r ;'~':1":i'5~"<~ '/lr4"T'(;''::i~~ OJ Sheriff of Cumberland County, P -J ..'.' {~ r".I~-'< C"in -r~ _-'~' :;J........--. ("') -! ou;-.. ,.=...., .:~~ ,.,. :x - ., Affidavit of Service C>> --(,.. ~<- .. c -OC:\' };;o Now, ,20_, at o'clock M. se led the within upon at by handing to a copy of the original and made known to the contents there f. So answers, Sheriff of Coun , PA Sworn and :}ubscribed beforp me this .1:'" day of11\D-J\J:v...., 20 ()5 COSTS SERVICE MILEAGE AFFIDAVIT $ \. b NOT ARlAL SEAL Rebecca S, Yepremian. Notary Public West Chester Boro" Chester County My commission expires August 6, 2008 $ _ i . _ '." oJ '......"-...,.:. i "" '"" " . -1 -'c',5' "',~ ._--,~=~- -- :-. .. /?0 r(,;lj II ,._._..._ ...~_~~ ..- -_._~_.._.. .,j ,,\~ ot (!C Umbel' ~~~ ,', {~It<> ~1;} "~ $~!2" \€\j7'V,Jfi!. . ',vt , !l'<7-r-t'lJ, ~\ " {.of,,"/;, ,k . ;,1", g lr "-";-_~~ ,~ 1.(., "i ~.J,A~~~YS 2W '_ ~I! ''':'~~\:%~'_~:'''' I:; , .:;~? /,6 Ie. R~' .i;~" N1. ! .1'..1 .. R. THOMAS KLI NE Sheriff EDWARD L, SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RE: TO: Hon , Carolyn Welsh Chester County Sheriff ABN AMRO Mortgage Group I c VS Lee A, Woodall 05-280 civil Dear Sheriff: Enclosed please fmd Notice and Canplaint in Mortgage Foreclosure, rein (0. Lee A. Woodall to be served upon 1512 Windemere Place WAcr rhAarArr PA ,qiRO in your County. Kindly make service thereof and send us your return of service, 7'1 2-!4fj,e IC"{olAlY> f71"L 15 0rt er'f,~ hlf;. .:c Y\R.<2. d ""., .f) t+ 1't. Very truly yours, ~~~.z:--~ ' R, Thomas Kline, Sheriff Cumberland County, Pem1sylvania N0fZ0 ,Enclosures: .;? 71& {, <( J II.. .. (' ') (' C'it-';? t'J RO NY R. ANDERSON Chief Deputy ODY S. SMITH R al Estate Deputy ;;)/Je t~_ ~ -.' ~ FF=U) G] ~i~, -.J ~?;;.:-r;-; c. ., .':;":, ;bo ::..:: N I'\) '--1 _~, ;<~' :;"7h: p. ---.---- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-00280 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS WOODALL LEE A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent sea ch and and inquiry for the within named DEFENDANT , to wit: WOODALL LEE A but was unable to locate Him in his bailiwick. He therefo e deputized the sheriff of CHESTER County, pennsylvan a, to serve the within COMPLAINT - MORT FORE On April 19th , 2005 , this office was in receipt of he attached return from CHESTER Sheriff's Costs: Docketing Out of County Surcharge Dep Chester Co 18.00 9.00 10.00 22.05 .00 59.05 04/19/2005 PHELAN HALLINAN So answer~,-'- --;;:~,.<- -~-->:"- '~~$': R. 'Thomas Kline Sheriff of Cumbe ~-; / and County SCHMIEG Sworn and subscribed to before me this ~---- day of 0,- '.1' / doo" ---;: D . J-<-.J: ~ ~hO~:,~4~J~T - Phelan Hallinan & Schmieg, L.L.P, By: Daniel G. Schmieg, Esquire No. 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff ABN AMRO Mortgage Group, Inc. COURT OF COMMON PLEAS CIVIL DIVISION vs. Cumberland COUNTY Lee A. Woodall NO. 05-280-Civil Term MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, L.L.P., moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant, Lee A. Woodall and , by first class mail and certified mail to the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises, 21 West Mulberry Hill Road, Carlisle, P A 17013, and in support thereof avers the following: I. Attempts to serve Defendant, Lee A. Woodall, with the Complaint have been ',unsuccessful. The Sheriff of Cumberland County attempted to serve the Defendant at the mortgaged ipremises, 21 West Mulberry Hill Road, Carlisle, P A 17013. As indicated by the Sheriff's Return of iService attached hereto as Exhibit "A". 2. Secondly, the Sheriff of Cumberland County attempted to serve the Defendant, !Lee A. Woodall, by deputizing the Sheriff of Chester County on Lee A. Woodall at 1512 ~indemere Place, Apt. 102, West Chester, PA 19380. As indicated by the Sheriff's Return of Service attached hereto as Exhibit "B", the Defendant, Lee A. Woodall, does not live at this address. . . 3. Pursuant to Pa.R.C.P, 430, Plaintiff has made a good faith effort to locate the Defendant An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "C". 4. Plaintiff has reviewed its internal records and has not been contacted by the Defendant as of May 5,2005 to bring loan current 5. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pa.R.c.P. 430 directing service of the Complaint by first class mail and certified mail. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. B~~ ____ Daniel G, Schmieg, Esquire Attorney for Plaintiff Date: May 5, 2005' Phelan Hallinan & Schmieg, LLP. By: Daniel G. Schmieg, Esquire No, 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia,PA 19103-1814 (215) 563-7000 Attorney for Plaintiff vs, COURT OF COMMON PLEAS CNIL DNISION Cumberland COUNTY NO, 05-280-Civil Term ABN AMRO Mortgage Group, Inc. Lee A. Woodall MEMORANDUM OF LAW Pa. R.c.p, 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation, which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made, Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new fOlviarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adootion of Walker, 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the ;,Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of ':\ocal telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriff's Retums of Service, attached hereto and marked as Exhibit "A" and Exhibit 'B", the Sheriff has been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the ~ttached Affidavit of Reasonable Investigation, marked Exhibit "C", WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pa.R.c.P. 430 directing service of the Complaint by first class mail and certified mail. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. >f By: ~~ - Daniel G. Schmieg, Esquire Attorney for Plaintiff ~ i Date: May 5, 2005 ,------- .-\ 1\ \[k.\Y , ~~ . . SHERIFF'S RETURN - dOT OF COUNTY ,. i CASE NO: 2005-00280 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS WOPDALL LEE A R. Thomas Kline duly sworn according to law, says, that he made a diligent search and , Sheriff or Deputy Sheriff who being and inquiry for the within named DEFENDANT W09DALL LEE A but was unable to locate Him , to wit: in his bailiwick. He therefore deriutized the sheriff of CHESTER se~ve the within COMPLAINT - MORT FORE County, Pennsylvania, to 3rd , 2005 , this office was in receipt of the On March attlached return from CHESTER She~iff's Costs: Doc!<eting Out! of County sur~harge Dep!Chester Co 18.00 9.00 10.00 24.55 .00 61. 55 03/03/2005 PHELAN HALLINAN Sworn and subscribed to before me thi~ day of A.D. " Prothonotary s~.nswer;::::::,:..~~:~ __,,:~ ' _<- ?:_:-::::: F~'C';>- Fe. omas Kl e Sheriff of Cumberland County SCHMIEG y{,\l.-WI G loq q t.l4 -'" - '....... '''''". ' ,..,...,. - - - -"" -..1iiio --'" -- ..,... ~,-- - - - - - -- - - - - ~ - ....... - - -, -' ..... - ~...- - - ---- - - - -------- () \ .1 ~ ~L', V" SHERIFF'S RETURN - OUT OF COUNTY , 'CASS NO: 2005-00280 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS WOODALL LEE A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT W09DALL LEE A , to wit: but was unable to locate Him in his bailiwick. He therefore de~utized the sheriff of CHESTER senve the within COMPLAINT - MORT FORE County, Pennsylvania, to On April 19th , 2005 , this office was in receipt of the att~ched return from CHESTER Sheriff's Costs: Docj<eting Outlof County surtharge Dep\Chester Co 18.00 9.00 10.00 22.05 .00 59.05 04/19/2005 PHELAN HALLINAN So answe~ ,/':;;7 .,"'~ ;7 ~</ <~~:~:.--- / ~.:::: /~ / ~.... .--'" R. Thomas Kline Sheriff of Cumbe County SCHMIEG Sworn and subscribed to before me this day of A.D. Prothonotary In The Court of CQIllmOn Pleas of Cumberland County, Pennsylvania ,;,'Ii,:,'. " ABN AMro M()l;'tgp'~~ ~t!p.iInc , 21: :Lo\': - .....', p" ('pFYS'~i{ cou~~ ~ II I p'.. Lee A, WoOdall 2GG5 /1.PR -8 Ail \0: 00 No. 05-280 civil Now April 4, 2005 , , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Chester County to execute this Writ, this deputation being rnade at the request and risk of the Plaintiff. ~4'" .-'~, //~'-" ~ ~~4__.P.$""",..R Sheriff of Cumberland County, PA Affidavit of Service NoW, , 20_, at o'clock M. served the wit~in upcjn at by lianding to , a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Swo+ and subscribed before met:liis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ .4. I (!; t>- c!. u.. OJ-. Si"a .;J iC. ....'s COC'T' SHER!n- . .;;>, ". 03t8 q-.r-CJS- . /S-eJ. rl Paid ~ . t ". 2- '7 4''1.2%.,., ReCC1P 110. L:~;;t~~'{ to seIVice c - J.( - (] S" R. THOMAS K~I:NE;. U:'. ' She~ ~ ~,~\f;= F [~?\, ;-;'.\.r,}: Pi,. .....~l,_C I ~ cd ,-,Utl,e. EDWARD {c,'sCHORPP Solicitor D D :\H \0: 00 l~n~ ~\P" - () ~'1.1? of. ([[UlltfJet: ~l~ .'. 1<1'4<> ""~ 1{'1 "t" ~".'~. --~ ~~" ~. ._.' l~ ~,_ . ~7t\" - "' t ~,,' '~\,,' if ;;V'-'., ."J'e~'" (r, ~ l!o "~l~~, 1/, "' ."~ - "'-..... ,~,_~ ~. ,y.~', . 0' .,?-,'.{:, ":'" !;;r-'l;1"~ RONNY R. ANDERSON Chief Deputy OFFICE OF THE SHERIFF JODY S. SMITH Real Estate Deputy One Courthouse Square Carlisle, Pennsylvania 17013 ,~.:tI~ 7.~ fS' TO: Hon, Carolyn Welsh Chester County Sheriff RE: ABN AMOO Mortgage Group Inc VS Lee A. Woodall 05-280 civil i l.\ ) 1\ !Dear Sheriff: Enclosed please find Notice & Canplaint in Mortgage Foreclosure. reinstated to be served upon (?) Lee A, Woodall 1512 Windemere Place apt 102 West Chester. PA 19380 ip. your County. Kindly make service thereof and send us your return of service. l1A.)e., ID ~b I'I."-f ue .Il Woott.t/ Je; "'<)j ;;:.lJie tJ,fx,J€.. a...dck'if_ ^'~ ~ o..dcf..t.5j -3 '\')- ine- 'EJcIosures: Very truly yours, r~~~-#' R. Thomas Kline, Sheriff Cumberland County, Pemlsylvania . . ......-- .I.'~ ~ ~ ys k, b I .... FORECLOSURE REVIEW SERVICES, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 109949 Attorney Firm: Phelan, Hallinan & Schmieg, LLP Subject: Lee A. Woodall Current Address: 21 West Mulberry Hill Road, Carlisle, PA 17013 Property Address: 21 West Mulberry Hill Road, Carlisle, PA 17013 Mailing Address: 21 West Mulberry Hill Road, Carlisle, PA 17013 I, Brendan Booth, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Lee A. W oodall- 602-98-6509 B. EMPLOYMENT SEARCH Lee A. Woodall- A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Lee A. Woodall reside(s) at: 21 West Mulberry Hill Road, Carlisle, PA 17013. 11. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office contacted directory assistance, which indicated that Lee A. Woodall reside(s) at: 21 West Mulberry Hill Road, Carlisle, PA 17013. On 3/24/05 our office made a telephone call to the subject's phone number, (717) 249-7034, and received the following information: answering machine. l1I. INQUIRY OF NEIGHBORS On 3/24/05 our office attempted to contact Steve Larson, at 22 West Mulberry Hill Road, Carlisle, PA 17013: spoke with an unidentified male who confirmed that the subject reside(s) at 21 West Mulberry Hill Road, Carlisle, PA 17013. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 3/25/05 we reviewed the National Address database and found the following information: Lee A. Woodall- 21 West Mulberry Hill Road, Carlisle, PA 17013. - B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: 1512 Windemere Place, West Chester, P A 19380 and 21 West Mulberry Hill Road, Apt 102, Carlisle, PA 17013. V. DRIVERS LICENSE INFORMATION A MOTOR VEHICLE & DMV OFFICE Per the P A Department of Motor Vehicles, we were unable to obtain address information on Lee A Woodall. VI. OTHER INQUIRIES A. DEATH RECORDS As of 3/25/05 Vital Records and all public databases have no death record on file for Lee A Woodall. B. COUNTY VOTER REGISTRATION The county voter registration was unable to confirm a registration for Lee A. Woodall residing at: last registered address. VII. ADDITIONAL INFORMATION OF SUBJECT A DATE OF BIRTH Lee A. Woodall- not available * All accessible public databases have been checked and cross-referenced for the above named individual(s). * Please be advised all database information indicates the subject resides at the current address. 1 certify that the foregoing statements made by me are true. 1 am aware that if any of the foregoing states made by me are willfully false, I am subject to punishment. 1 herby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. See. 4904 relating to unsworn falsification to authorities, ,/Z---f2r^-f ,~~~ AFFIANT - Brendan Booth Foreclosure Review Services, Ine. COMMONWEALr~~~:~ PEt'..:.NSYLVANIA NOTt\::~!/\{>. SEAL RYAN P G~.L\j:\~, Notary Public City of Phiiace:phia, Phila. County My Comr"""on Expires December 21,2008 Sworn to and subscribed before me this 25th day of March 2005, The above information is obtained from available public records and we are only liable for the cost of the affidavit. VERIFICATION Daniel G, Schmieg, Esquire, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to make this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements made are subject to the penalties of 18 Pa. C.S, Sec. 4904 relating to unsworn falsification to authorities. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P. B~L-~' Daniel G. Sc ieg, Esquire Attorney for Plaintiff Date: May 5, 2005 ,_.:l' ;) " ,1 .", ~<. --.. c;-A ,-\ -\\:~-;0 \ \.D ,') t.~ - Phelan Hallinan & Schmieg, L.L.P. By: Daniel G. Schmieg, Esquire No. 62205 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff ABN AMRO Mortgage Group, Inc. COURT OF COMMON PLEAS CIVIL DIVISION Vs, Cumberland COUNTY Lee A. Woodall NO. 05-280-Civil Term CERTIFICATION OF SERVICE I, Daniel G, Schmieg, Esquire, hereby certify that a copy of the foregoing Motion for Service Pursuant to Special Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. Lee A. Woodall 21 West Mulberry Hill Road Carlisle, P A 17013 1512 Windemere Place, Apt. 102 West Chester, PA 19380 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Respectfully submitted, Phelan Hallinan & Schmieg, L.L.P, BY:~ Daniel G. Schmieg, Esquire Attorney for Plaintiff Date: May 5, 2005 c-, ~;:~ w; l--" ~~Ji , U) ;~l f'..) eJ PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T, PHELAN, ESQ" !D, NO. 32227 FRANCIS S, HALLINAN, ESQ., !D. NO, 62695 DANIEL G, SCHMIEG, ESQ" !D, NO, 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ABN AMRa MORTGAGE GROUP, INC. Plaintiff vs. LEE A WOODALL Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County No. 05-280 CIVIL TER PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: May 5, 2005 Ijme, Svc Dept. File# 109949 PHELAN HALLINAN & SCHMIEG, LLP By: ~~. 5 J-t~ FRANCIS S. HALLINAN, ESQUIRE LAWRENCE T, PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff .------ C~, {,:-:-:l ,":~) ".I' r " ~-\:1 oS) - . , .'-~' "D IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ABN AMRO Mortgage Group, Inc. RECEIVED MAY 11 ZOOS( vs. CIVIL DIVISION NO. 05-280-Civil Term Lee A. Woodall AND NOW, this ORDER I 2--- day of 11ii;{'\ , , 2005, upon consideration of Plain tift's Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED, It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on the above captioned Defendant, Lee A. Woodall, by: 1, First class mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises located at 21 West Mulberry Hill Road, Carlisle, PA 17013; and 2. Certified mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises located at 21WestMulbt?rryHillRoad,C~rlisle,P:\17QI3, e'l Ie L'" }'vVO:{ 3 ?C\r)\\~}11~10\, (VI\., G ,,~h -pl.'. ,Ul''oU'''I:; U'. - ,u . - ,), \ \ '. \ \..t( ~t- {"- ~1o("cf Q,i"L..~ Ie. A- ""'<.{.9/"',/,"'- ~I ,~).1 IJ 11,\' BY THE tou . , , -J \ \ c ,\', L ,v \.(I\\'J ':::,\.\\)..J ----------'-~"'/ PHELAN HALLINAN & SCHMIEG LLP By: Lawrence T, Phelan, Esq., Id. No, 32227 Francis S. Hallinan, Esq., Id. No, 62695 Daniel G, Schmieg, Esq., Id. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 ABN AMRO Mortgage Group, Inc. Plaintiff ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS vs. : CNIL DIVISION Lee A Woodall Defendant( s) : Cumberland COUNTY : NO, 05-280-Civil Term AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certi1)r that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons Lee A. Woodall at 1512 Windemere Place, Apt.102, West Chester, PA 19380 and 21 West Mulberry Hill Road, Carlisle, PA 17013 on Mav 20, 2005, in accordance with the Order of Court dated May 12, 2005. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: May 20. 2005 1~~ 5 ~11 '_ FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff C~) , . .''/ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JULIA WAGNER, EXECUTRIX OF THE ESTATE OF FRANK WAGNER, DECEASED CIVIL DIVISION Plaintiff, No: 05-556 CIVIL TERM Ys. SHEPHERDSTOWN FAMILY PRACTICE, P .C., HERITAGE MEDICAL GROUP, LLP, HERITAGE MEDICAL GROUP, LLP D/B/A SHEPHERDSTOWN FAMILY PRACTICE (A DIVISION: OF HERITAGE MEDICAL GROUP, LLP), HERITAGE MEDICAL GROUP, LLP D/B/A HERITAGE DIAGNOSTIC CENTER (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), GARY M. SCHWARTZ, M.D., and GEOFFREY JAMES, M.D" Defendants JURY TRIAL DEMANDED CERTIFICATE OF MERIT AS TO GEOFFREY JAMES, M.D. I, Edmund Berger, counsel of record for Julia Wagner, Executrix of the Estate of Frank Wagner, hereby certi1)r that an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by Geoffrey James, M.D. in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm. !J-- ?-O- 0 S- Date Edmund Berger Counsel for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the foregoing document, Certificate of Merit as to Geoffrey James, M.D., on the following person, in the manner indicated: VIA FIRST CLASS MAIL Michael D. Pipa, Esq. Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Date: May 23, 2005 c_, C') c S" .') - PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST A nON 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE JACKSONVILLE, FL 32258-4455 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. LEE A. WOODALL NO. 05-280 CIVIL TERM Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against LEE A. WOODALL, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/13/05 to 7/7/05 TOTAL $229,006.55 $7,4i4,88 $236,421.43 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached, C' . ", . ) Q;\- , ESQUIRE (J (, DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: ~ )" J diY, ;)J)os; ( IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RECEIVED MAY 11 zool ABN AMRO MOJ1gagc Group, Inc, vs. CIVIL DNISION NO, OS-280-Civil Term Lec A W oodatl ORDER AND NOW, this /2 day of , 2005, Upon considcl ation of Plainti iTs Motion for Service Pursuant to Spec ORDERED and DECREED that said Motion is GRANTED. Complaint and all future pleadings on the above captioned Defendant, Lee A. Woodall, by: It is furthcr ORDERED and DECREED that Plaintiff may obtain service of the I. First class mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. ] 02, West Chester, PA 19380 and the mortgaged premises located at 21 West Mulberry Hill Road, Carlisle, PA 17013; and 2, Certificd mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises located at 21 West Mulberry Hill Road, Carlisle, p A 17013. 3 fhb\i:1\~ Ot\Ce. "nthe. ClJ.mberIQ"'~ Lo.w Jou,r-no..l 4'Llbl\shln one.e it' Q Gent:.r-a..\ Circ.L..\a,hon ne.\.\)5 po..peR. - BY THE COURT: , \j '~ , , , , (Rule of Civil Procedure No. 236) _ Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC, 7159 CORKLAN DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Y. Plaintiff, CIVIL DIVISION LEE A. WOODALL NO. 05-280 CIVIL TERM Defendant(s). Notice is given that a Judgment in the above-captioned malter has been entered agains1 you on ---.JuL_, llf 209$, , ~ A()~o ,P7Jc~ DEPUTY If you have any questions concerning this matter, please contact: ~-,hw~t~Cr Altorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST N 1617 JOHNF, KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T, Phelan, Esq" Id, No, 32227 Francis S. Hallinan, Esq" Id, No, 62695 Daniel G, Schmieg, Esq., Id, No. 62205 Philadelphia, PA 19103 (71 ,) ,1\1-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INe. Plaintiff : COURT OF COMMON PLEAS Vs, : CIVIL DIVISION LEE A. WOODALL , CUMBERLAND COUNTY Defendants : NO, 05-2BO-CIVIL TERM TO: LEE A. WOODALL 2\ WEST MULBERRY HILL ROAD CARLISLE, PA 17013 p'. i "" , ( .5....... r'" "'f """'. I DATE OF NOnCE: JUNF 24 200, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.lF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY LA WYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PAl 70 13 (800)990-9108 (J~* FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T, Phelan, Esq., Id, No, 32227 Francis S. Hallinan, Esq., Id, No, 62695 Daniel G, Schmieg, Esq" Id, No, 62205 Philadelphia, PA 19103 pI)) )1i1-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, 1Ne. Plaintiff : COURT OF COMMON PLEAS Vs, : CIVIL DIVISION LEE A. WOODALL : CUMBERLAND COUNTY Defendants : NO, 05-280-CIVIL TERM TO: LEE A. WOODALL 1512 WIND MERE PLACE, APT. 102 WEST CHESTER, PA 19380 DATE OF NOnCE: ./lfNF 24 200, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.lF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER, IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE MAYBE 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 LA WYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, P A ] 7013 (800)990-9108 ~'}} FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, L.L.P. .- By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. v. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS LEE A. WOODALL CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM CERTIFICATION DANIEL G, SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matler, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) 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. r---- ~ . IEL G. SCHMI 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 PHILADELPIDA, PA 19103-1814 [215) 563-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. 7159 CORKLAN DRIVE v. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION LEE A. WOODALL NO. 05-280 CIVIL TERM Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G, SCHMIEG, ESQUIRE, hereby verifies that he is altomey 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) thai defendant LEE A. WOODALL is over 18 years of age and resides at, 21 WEST MULBERRY HILL ROAD, CARLISE, P A 17013 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. \.::) CA(t- ~ B --- -t \" f ~ 6"" j W ~ IU ~ ~ - r ~ -0 , D () ~ b t ---..c... ~ ~ ~~ ~ C- _..._-" ,-- rl1p:= r-::=' ~Jrll _ :,:.)Y ":.:- ~:',,~q, :r"P :~:2, f,~~ :J: "I (::-.':? '~:.l ~~; ~.,' <J' :....;. -". 0\ ~~~ Dl!:SCRlPTION ALL THAT CERTAIN Lract ofland sirualC in Middle.<c~ Township. Cumberland County, PelUl>ylvania, being Lot No, 59. as shOWn on lhe Plan entitled Meadowhrook. Farms Final Subdivision Plan Phase II dated I'ehrnary 12, 1999, last rcvise<f JUlie 3, 1999, and recorded August 17, 1999. in Cumberland Coumy Plan Rook. 79. Page 85, more particularly bounded and described as follows; BEGINNING at an iroll pin, lying in a WCSlerly right-of-way line of C,oonlry Side Drive (50-foot right- of-way), and hclOg a Nnl'lherly (;Omer of LOI No. 77; thellce along said Lot, Soutlt 62 degrees 01 minutes 02 seconds West, lS!H16 feet to an iron pin. being a W~lerly corner of said Lot and lying in an Easterly line of Lot No. 60; theno:: along said 101, North 27 degrees 58 seconds West, 120.00 feet 10 an iron pin, ""ing a Northerly Wmer of said Lot and lying in a Soutberly righl-of-way line of Mulberry Hill Road (50,foot right-of-way); thence along said right,of-w"y, North 62 degrees 01 minutes 02 ~nds East, 187,73 feet to a point, lying along said right-<lf-way; thence continuing along said right-of. way , alollg a CUtve 10 the righI, having a chord bearing of South 69 degrees 38 minutes 16 seconds East, a chor~ distancc of 37.36 f~l. a radius of 25,00 feet, and an arc distallce of 42.19 feel to a point, lying in a Westerly Jine of Country Side Drive (50-foot right-of-way); thence along said riglll-uf-way, South 21 degrees 17 minutes 34 seconds Easl. 19,94 fCCt to a point; thence colltinuing along said righl-of-way. along a curve to the right. having a chord bearing of Sooth II degrcc~ 39 minutes 25 'oconds East, a chord disullIce or 75,32 feel, a radius of 225.00 fcct. and lUI arc diSlantt of 75.68 feet to all "on pin, hcillg the place of Deginlling, CONTAINING 0,564 acre. Tax Parcel #21.15,1253,13-1- TITLE 1'0 SAID PREMISDS IS VI:-':STED IN Lee A. WoOOall, nliIlTioo man hy Deed frolll Mark Sheely Builder, Inc., a Pennsylvania Corporation dated 5/24/2002 and reconJed 5129/2002 in Deed Book 251 Page 4436. Premises: 21 West Mulberry Hill Road, Carlisle, PA 17013 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 ABN AMRO MORTGAGE GROUP, INC. Plaintiff, v. No. 05-280 CIVIL TERM LEE A. WOODALL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $236,421.43 Interest from 7/7/05 to DECEMBER 7, 2005 (per diem -$38.86) $5,945.58 and Costs TOTAL $242,367,0 I -- ~ "'-... \ ~Y , ESQUIRE One Penn Center at uburban Station 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103-1814 Attorney for Plaintiff 00 Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. '" ,..; Q r-- ,..; < ~ ~. en ... ~ u Q / < ~;:$ 0 Z ~ o~ U 0 en> Z ... E-< <"" ... ;:J ~~ ~ u ~ "Ci ""en ;:J ~'F 0) ~Z 0 "" ~ Zz 0) ~ :;J ~ = ~ '" o~ (..? '" = 0) ~ 0 ~~ O<l "" .D ~ . ~ ~ '" ;:J >> (..? 0 E-< .. '" o~ ~ .; 0 Sl& ~ s uz ;- ~ E-< '" ~ '" ... ~;:J E-< I>ll en 0) 00 ~ < ~~ ~ ~ E-<U 0 ~ 01:: ~ 0.. ~~ ~ ~ ~ 0 ,..; ~ ;:J~ 0 "" ~~ '" ,.q 8~ ~ ~'-' Vi ~ 1 ... ~ U '" ~~ ~ ~ == "1:l Z "1:l E-<~ ~ < Z;:J ~ ...u FI ---J-. >-. r.,.o ,;] a: (n i3 8 3 c ;- Lu _.0: C)...,: rc ~~_,_~ .-.>:~ ~ (-')1::.'-: ....:.:c ~ . , J ~ W T C', ...::r ; ~ aCL . ~ ~,l.J_ t . f1j -llU _J ~ ~ ~ D::r: ::::> 1-- --, ..... I ~ t'v) ;B tJ_ "'" :.:;-:;; J ~ ...J ,=, , --.l 0 coo (5 . , . '\J ~ "" > ,() , -...j. <;;::) ~ --- (j ,f', B~ ~ 'J (,::J ~ ~ -.J <:"\ it j lI:l ~ ~ "" ., V) 11 q '- <s- @) "J ~ ~ '0 ~~ n '::::J. ~ ~ It, U WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL V ANIAl COUNTY OF CUMBERLAND) NO 05-280 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP INC., Plaintiff (s) From LEE A. WOODALL (\) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) (2) You are also directed to attach the property of the defendant( s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $236,421.43 L.L.$.50 Interest FROM 7/7/05 TO December 7, 2005 (per diem-$38.86) $5,945.58 and costs Atty's Comrn % Due Prothy $1.00 Atty Paid $239.30 Other Costs Plaintiff Paid Date: JULY 14, 2005 CURTIS R. LONG (Seal) Prothonotary By: ~t;4</.l ,t:'. ~ 91 Deputy REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Snburban Station 1716 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No, 62205 In T~~~o~ SOPV FROM RECOItD and the seat of :;~OCf, I there unto set my hand our at Carlisle Pa Th' /L/ ' . IS.. ...7..........:.. day of/J~,A....,.. ~ ~~.......... ................... ;K' -~" c1.-:7' _...........,.............~~,...~ ProthOllotary ABN AMRO MORTGAGE GROUP, INC. v. Plaintiff, CUMBERLAND COUNTY LEE A. WOODALL COURT OF COMMON PLEAS CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) ABN AMRO MORTGAGE GROUP. INC., Plaintiff in the above aC1ion, by its attomey, 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 .21 WEST MULBERRY HILL ROAD, CARLISE. PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name LEE A. WOODALL Last Known Address (if address cannot be reasonably ascertained, please indicate) 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 2, Name and address ofDefendant(s) in the jUdgment: PRINTED IMAGE 137 N. HANOVER STREET CARLISE, PA 17013 CITlBANK OF SOUTH DAKOTA, NA 701 EAST 60TH STREET SIOux FALLS, SD 57104 SYSCO FOOD SERVICE ERIC J. SWIDLER 3905 COREY ROAD P.O. BOX 3641 HARRISBURG, PA 17105 ERIC A, GARONZIK 845 HAMILTON STREET CARLISE, PA 17013 ROBERT B. COLLINS / COLLINS CONTRACTING COMPANY 110 VINE STREET CAMP HILL, PA 1701l 1101 LINDHAM COURT, BUILDING 502 MECHANICSBURG, PA 17055 3, Name and last known address of every jUdgmen1 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 oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ORRSTOWN BANK 2250 SPRING ROAD CARLISE, PA 17013 KIM C. RARAIGH AND CATHLEEN D. RARIGH 7 GORDON DRIVE CARLISE, PA 17013 COMMERCE BANK 100 SENATE AVENUE CAMP HILL, PA 17011 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) TAMARA WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interes1 in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PAl 7013 Commonwealth of Pennsylvania Department of WeIfare PO Box 2675 Harrisburg, P A 171 05 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, Julv 7,2005 DATE "'-.,,^ - , o c c' ::'. , "'> = = "" '- c:: r- o -n :r.!" rnr= ~m6' -'.- .> ,I - ._~- -r-I ~:~~ f;~ (_oj ---t ~~ ...- :r.~ o en 0'> ABN AMRO MORTGAGE GROUP, INC. Plaintiff, CUMBERLAND COUNTY v. No. 05-280 CIVIL TERM LEE A. WOODALL Defendant(s). July 7,2005 TO: LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. *. Your house (real estate) at , 21 WEST MULBERRY HILL ROAD, CARLISE, P A 17013, is scheduled to be sold at the Sheriffs Sale on DECEMBER 7, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $236,421.43 obtained by ABN AMRO MORTGAGE GROUP, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a pe1ition asking the Court to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out 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 ifthe 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 dis1ribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff, It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 ALL THA l' CERTAIN ll<lctofJalld situate in Mlddlescx Township, Cumberland County, PennsYlvania, being Lot No. 59, atl show~ 011 the PIM entitled Meadowhrook FamlS Final Subdivision Plan Phase II dared February 12. 1999, l1st revist'd June 3, 1999. and recorded August 17, 1999, in CUmberland COUtU), Plan a.>Ok 79. Page 85. more palticularly bounded and described as fOllows: Dl;:SCl!wrrON BEGiNNING at an iro~ pin, lYing in a Wcsterly right-ofcway line of Country Side Drive (50-fwI right- of,way), ,Ul(/ bejng a Northerly corner of Lot No. 77; t/ICllCe along said Lot, South 62 degrces 01 minutes 02 seconds West, 189,06 fect to an iron pill, being a Westerly corDer of said Lot and lying in an fusterly line of Lot No. 60; thence along said /at, North 27 degrees 58 seconds West. 120,00 feet to an iron pin, being a NOrtherly COmer of said Un and lying in a SOutherly right-ot~way line of Mulberry ffjJj Ro:ul (.50-fool right-ot.way); thence along said right,of-I....y, North 62 degrees 01 minulCs 02 seconds Ea.>l. 187,73 feet to a POint. lying along said right"'f-way; thcIlCe continuing along said right-of-way, along a curve 10 tile right, having a chord be~ing of South 69 degR'e8 38 mill!lt'" 16 seconds East. a chord distance of 37.36 feet. a radius of 2,5,00 feet, and all arc distance of 42.19 feel to a point, lying in a Westerly lille of COUntry Si<lc Otive (50-foot riglll-Of,way); the.nce along said riW""'"" ""'. " "'''''' " .- H -.., ,"" 19." "" . ""'," "'= 00","'., along .aid right.or-way, along a curve to the right. 1!3ving a chord hearing (If SOUIII II (legrec~ .19 minute, 25 Rcconds East. a chold diStance of 75.32 feet, a radius of 22.1.00 fecl, and an arc distal1Ce of 75.68 feet to an imn pin. hei,,!: the place of Beginning, CONl'AlNfNG 0,564 acre. Tax Parcel #21,15-1253,134 TITlE TO SAID PREMISES IS Vf;STEn IN Lee A, WOOdall, n14ffied man hy Deed from Mark Sheely Builder, Inc,. a PennSYlvania COrporation dated 5/24/2002 and recorded 5/29/2002 in Deed Book 25 I Page 4436, Premises: 21 West Mulberry Hill Road, Carlisle, PA 17013 <;:" ...., = = c-'" '- c::: , ;.- .j:'" o -n -l ::t:.... rl1p::::: -om ")0 c~~~) -r~_ -;1 (",? ("'j >;;rn ~.:! <r) '-<: 7"'" -'. __f" c;:; (n CJ) Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, P A 17013 ' 1\," '.. ,~r: ", \.Jr . ,- (' ~ .~~ I' \ ...,. -,--'- ,.- ,."> ",'"\C,,": r ", (.\J Ll'; J ,J -~- t.., ~") , ,,\. <", ". ' . _'...1 h~ i \ ,. , .',l o~ -.)pO C\JN\~jl: . r-C,,:)I LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, P A 17013 WOOD02~ ~70~33050 ~a05 ~3 07/~f RETU'IN TO SENDER WOODALL/LEE A MOVED LEFT NO ADORESS UNABLE TO FORWARD RETURN TO SENDER i 1 & i j+ ~~ fa= ir~@fl:::::::'3:::' l/..U/l..IIU.....Jll..II.../I...II..1..1i.J..J1iilli,llil..llllll , PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL SCHMIEG, ESQUlRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION COUNTY vs. No.: 05-280 CNIL TERM LEE A. WOODALL AFFIDAVIT I hereby certi1)r that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to LEE A. WOODALL on 7/28/05 at 21 WEST MULBERRY HILL ROAD, CARLISE, PA 17013, in accordance with the Order of Court dated 5/12/05 I further certi1)r that the mortgaged premises was published in the Cumberland Law Journal on 8/05/05 and The Sentinel 7/27/05 in accordance with the Court's Order. The undersigned understands that this statement is made subject to the penalties of 18 P A . C.S. s 4904 relating to unsworn falsification to authorities. ~Q~ ~CY1~~ ANIEL . SC . G, ESQUlRE r Date: August 18, 2005 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) fulv 27, 2005 COPY OF NOTICE OF PUBLICATION NIltMllllt'M~,'" 0Il)~;'~ ' c" .'c . ';'.~:"',"."" "," Lee,.. wOodall '-i, ',;'i':.'-' ";~m:&~~PIl...iJ,... > i.'i,' A~~J~~~;'~ '""" '..~, t%':J:" . , " .' ',':/' ,;." , , .......~pI,R-uj .~- I c-, . ..-.- ....' '.' r I , 8ljI-....'_8ljI"""'lnaol.1I '10 ~.. ". .' . '_:,.M f'el-~o_."8ljI_.""I8_'_ I ,iIil!lIb<Oll108 - JO -. 8I\p88JO , "', -1lIIrJ"1q',,,__~ ~-,~- '..-., ,-... WOO'l/IJ!fJf]qwno~ \lJOQ'~ {)€~l"lJll'l:I08J!P~.. ssm~ t~~t6Q' .. 'oo~o-agg '~~9G'-B"C: Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of pu lication are true. Sworn to and subscribed before me this 27th day of July, 2005. C'-fUUlroNh;f fA )~ Notary P lic My commission expires: q I' (r) t COMMONWEALTH OF PENNSYLVANIA Notarial Seal CI1nstina L WriIfe, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sepl1, 2008 Member, PC!r!:lsy!vani2. Association Of Notaries PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Curnberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and desigr.at~d 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 a'l~/./>/ ,~ ,/}/'Ji'A-) 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. 'k S TO AND SUBSCRIBED before me this ,"J day of a~, r2t1tJ5' NOTARIAL SEAL LOIS E. SNYDER. Notary Public \. Carlisle Boro. Cun\beIl8nd Counl'J My commission ExpiIes March 5, 2009 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECWSURE In the Court of Common Pleas of Cumberland County. Pennsylvania No. 05-280 Civil Term ABN AMRO MORTGAGE GROUP. INC. vs. LEE A. WOODALL NOTICE TO: LEE A. WOODALL NOTICE OF SHERIFF'S SALE OF REAL PROPERlY ALL THAT following described lot of ground situate, lying and beIng in MIDDLESEX TOWNSHIP, County of CUMBERLAND. Commonwealth of Pennsylvania. bounded and limited as follows, to wit: ALL THAT CERTAIN tract of land sJtuate in Middlesex Township. Cum- berland County. Pennsylvania. be- ing Lot No. 59. as shown on the Plan entitled Meadowbrook Fanns Final SubdMslon Plan Phase II dated Feb- ruary 12, 1999, last revised June 3, 1999. and recorded August 17, 1999, in Cumberland County Plan Book 79, Page 85. more particularly bounded and described as follows: BEGINNING at an Iron pin. lying in a Westerly right-of-way line of Country Side Drive (50,foot right- of-way), and being a Northerly COT- ner of Lot No. 77; thence along said Lot. South 62 degrees 01 minutes 02 seconds West, 189.06 feet to an tron p1n. being a Westerly comer of said Lot and lying in an Easterly line of Lot No. 60; thence along said lot. North 27 degrees 58 seconds West. 120.00 feet to an Iron pin, being a Northerly comer of said Lot and ly- 2 tng tn a Southerly right-aI-way line of Mulberry Hill Road (50-foot right' of-way); thence along said right-of- way, North 62 degrees 01 minutes 02 seconds East, 187.73 feet to a point. lying along said right,of-way; thence continuing along said rtght~ of-way. along a curve to the right. having a chord bearing of South 69 degrees 38 minutes 16 seconds East. a chord distance of 37.36 feet. a radius of 25.00 feet. and an arc distance of 42.19 feet to a point. lying in a Westerly Hne of Country Side Drive (50-foot right-oC-way); thence along said right-of-way. South 21 degrees 17 minutes 34 seconds East. 19.94 feet to a point; thence continuing along said right- of-way. along a curve to the right, having a chord bearing of South II degrees 39 minutes 25 seconds East, a chord distance of 75.32 feet. a radius oC 225.00 feet. and an arc distance of 75.68 feet to an iron pin. being the place of Beginning. CONTAINING 0.564 acre. Tax Parcel #21,15-1253-134. TITLE TO SAID PREMISES IS VESTED IN Lee A. Woodall. married man by Deed from Mark Sheely Build, er. Inc.. a Pennsylvania Corporation dated 5/24/2002 and recorded 5/ 29/2002 in Deed Book 251 Page 4436, is scheduled to be sold at the Sher- iffs Sale on December 7, 2005 at 10:00 a.m" at the CUMBERLAND County Courthouse. South Hanover Street. Carlisle. PA to enforce the Court Judgment of 7/15/05. ob- tained by ABN AMRO MORTGAGE GROUP. INC.. (the mortgagee). against you. Prop. sit. in the City of TOWN- SHIP OF MIDDLESEX. County of CUMBERLAND, and State of Penn, sylvania. CUMBERLAND LAW JOURNAL Being Premises: 21 WEST MUL- BERRY HILL ROAD. CARL[SLE. PA [7013. Improvements consist of residen- tlal property. Sold as the property of LEE A. WOODALL. TERMS OF SALE: THE HIGHEST AND BEST BID' DER SHALL BE THE BUYER The purchaser at the sale must take ten (lO%) percent down pay- ment of the bid price or of the Sheriffs cost, whichever Is higher, at the time of the sale in the form of cash. money order or bank check. The balance must be paid within ten (10) days of the sale or the pur- chaser w111 lose the down money. DANIEL SCHMIEG. ESQUIRE Attorney for Plaintiff One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 [215) 563,7000 Aug, 5 3 C) c ~--=-: -"J'''''' <.")';"'" ~~ G::::> iJ' ~ c::: G) -- - ~ p. ->- - - '-' '~i ,,4, q. _-I-n ;J;;,- ,"r: -.'".'.'20 ->:1 L ()C) ~~)(\__:~ (J :::~-\ ~ '.Z - - - rugntr"ax 8/10/2005 10:58 PAGE 001/001 Fax Server Fedennan and Phelan is now Law Offices PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, P A 19103-1814 Sandra.Cooper@fedphe.com SANDRA COOPER Judgment Deparbnen~ Ext 1258 Representing Lenders in Pennsylvania and New Jersey August 10, 2005 Office of the Sheriff Cumberland County Courthouse I Courthouse Square Carlisle. PA 17013 ATTENTION: JODY Re: ABN AMRO MORTGAGE GROUP, mc. v, LEE A WOODALL No, 05-280 CIVlL TERM Premises: 21 WEST MULBERRY HILL ROAD, Dear Jody: Please STAY the Sheriff's Sale of the above rererenced property, which is scheduled fur 12/0705 The Derendant{s) filed a Chapter 13 Bankruptcy on 8/02105 #05-05050, Please return the original writ of execution to the Prothonotary as soon as possible, Very truly yours, Sandra M, Cooper cc: ABN AMRa MORTGAGE GROUP Attention: FileNo, 0624076549 Original Writ returned to the Prothonotary's Office on 8/31/05. Copy of writ and $1500.00 returned to Attorney Schmieg on 8/31/05. / ...., PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 ABN AMRO MORTGAGE GROUP,INC. Plaintiff, v. No. 05-280 CIVIL TERM LEE A. WOODALL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $236,421.43 Interest from 7/7/05 to MARCH 8, 2006 (per diem -$38.86) $9,481.84 and Costs TOTAL $245,903.27 ATTORNEY FEES AND COSTS $5,676,21 ;jJCVv~jJl-1 ~~ DANIEL G. SCHMIEG, ES 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. <<t ~.... O~ ~~ Ijf" ~~ ~z ~~. ~~ VZ ~-g Ov ~~ -g~ ;.~ p~ ~~ -,.-. ~) V"; ,'OJ \'-' ,--- ,-- t', C) H'? v ~ ~ -g ~ ~ <It .;, r,; ~ ~ i ~ ~ ~ ,~ ~ g o ~ .J. \ilil Ij ~ ~ ~ \ilil~ ~~ Q ~-.; o '" .. ~~ ~~ ~~ 0" ~~ ,,",-, ~ V ~ ~ ~b ~ -: ': ~ CJ::. pJ '::. :. _ :: ~~:: '" :: -=- (JC'J I I \ \ ^ \' f'\()()() '-J () I.f) (J) '-' (} '() (;) 0. ~ ~ ~ ~d-t.hrl U)....9-~\J) ....... -"'1~lJ) tfr t"l 'S t"" ... <<t ~ ~ ~ V . ~ ~ ~ $ ~ ~ ~ ~ :6 ..;l ~ ~ ~ <-' Ii) iJl ;r \ilil p.. ~ 1t> ';'i ~ .~ ~ <<t .:g :;:l \>-0 .:: \ o ""! ~ 't,. 'b,. i f -I / ~~ -() \J (') lJl ...., . ~",. ~ ..,) t: -- r{) ~ ~ -::z: '\1 c) DI!.SC~IPTION 1\ LL THAT CERTA IN Ir<lct of land ,ituale IU Middlcsox Township, Cumbcrlarld County, rOM.yl vallia, being Lot No. 59. "" shown on the Plan entilled Meadnwhrook Faml'l Final Sulxlivisiou Plan Phase II dated l'ebnwry 12. 1999, last revised Junc 3, 1999. and recorrkd Augus< 17, 1999, in Cumberland Coullty Plall Rook. 79. Page 85, more paltfcularly houllded and described as follows: BEGlNNING at an iron pin, lying iua Westerly rigltt..(\f-way line of Cwntry Side Drive (50,foot right, of.way). and being a NMlhe:riy rorne, of Lot No, 77; tflCllCe along said Lot, South 62 degrees 01 minutes 02 seconds West, 1&9.06 feet to an iron pin, being a Westerly C(}fner of said Lot and lying in an Easterl)' line of Lot No. 60; thellt;C along said lot, North 27 degrees 58 seconds West, 120,00 feet 10 311 iron pin, being a Northerly comer of said Lot and lying ill a Southerly right-of-way line of Molbcrry Hill Road (SO-fool right-of.way); !hence alollg said right,of,way, North 62 degrees 01 miuutes 02 =nds Ea.t. 1&7.73 feet to a point, lying along said right-Qf-way; thCllCe conrinuing along said righe-of-way, along a curve 10 too right, having a chord bearing of South 69 deg""'" 38 minllle:; 16 seconds East, a chord distance of 37.36 feet, a radius of 25,00 feec, and an arc distll1lce of 42. 19 feet to a point, lying in a Westerly tine of Country Side Drive (51HooI rigbt'of-way); U,ence along said righl-of,way, South 21 degrees 17 minutes 34 seconds East. 19.94 feet 10 a poinl; thence ronlinuing along said right-of,way. all"'! a curve to the right. having a chord bearing of SOUth 11 degrcc~ 39 minute, 25 ",conds East, a chord diStance of 75.32 feel, a radius of 225.00 fcct, and all arc distance of 75.611 feet to an iron pin. hcing the place of Degillrling, CONTAINING 0 564 acre. Tax Parcel #2\-15,1253-134 TITLE TO SAID Pe,EMISES IS VE.')Tf.O IN Lee A. Woodall, married man hy Decd from Mark Sheely Builder, Illc.. a Pennsyl.ania CQrporalion dated 5124/2002 and recorded 5/29/2002 in Deed Book 251 Page 4436, Premises: 21 West Mulberry Hill Road, Carlisle, P A 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-280 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (5) From LEE A. WOODALL (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION, (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $236,421.43 L.L. $.50 Interest FROM 7/7/05 TO 3/8/06 (PER DIEM - $38.86) -- $9,481.84 AND COSTS Atty's Corum % $5,676.21 Due Prothy $1.00 Arty Paid $254,30 Plaintiff Paid Date: DECEMBER 6, 2005 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STAnON 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No, 62205 'C'~.._' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA ., .\ RECEIVED MAY 1 :, 'IOO't ABN AMRO Mortgage Group, Inc, vs. CIVIL DNISION NO. 05-280-Civil Term Lee A. Woodall ORDER AND NOW, this /2 day of / ,2005, upon consideration of Plaintiffs Motion for Service Pursuant to Spec I Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on the above captioned Defendant, Lee A Woodall, by: 1. First class mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises located at 21 West Mulberry Hill Road, Carlisle, PA 17013; and 2. Certified mail to Lee A. Woodall at the last known address, 1512 Windemere Place, Apt. 102, West Chester, PA 19380 and the mortgaged premises located at 21 West Mulberry Hill Road, Carlisle, PA 17013. 3"t~\i~"~ onCe. ',n the ~l.LrnberIQl\d.. La.w Jou.,no..l 4. P~\ishin once i(\ Q Gene.ra-\ c.ir~l.\.\o.hon ne.\.\)" p"'peR. . BY THE COURT: " UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Lee A. Woodall d/b/a Woodall Enterprises Inc. F/kla Lee Woodall's Stadium 54 CHAPTER 13 CASE NO.: 1-05-bk-05050 Debtor(s) ORDER DISMISSING CASE At Harrisburg, in said district, upon consideration of the Trustee's Motion to Dismiss Case for failure to file required documents and it having been determined after notice and hearing that the case should be dismissed, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U,S, Bankruptcy Court, By tllt Com1, ~~fJ~ Dated: October 24, 2005 ThiS electronic order is signed and filed on the same date. . . ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LEE A. WOODALL CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3] 29 (Affidavit No.1) ABN AMRO MORTGAGE GROUP, INC., 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 conceming the real property located at ,21 WEST MULBERRY HILL ROAD, CARLISE, P A 17013 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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) PRINTED IMAGE 137 N. HANOVER STREET CARLlSE, P A 17013 CITlBANK OF SOUTH DAKOTA, NA 701 EAST 60TH STREET SIOUX FALLS, SD 57104 SYSCO FOOD SERVICE 3905 COREY ROAD P.O. BOX 3641 HARRISBURG, PA 17105 ERIC J. SWlDLER 845 HAMILTON STREET CARLlSE, PA 17013 ERIC A, GARONZIK 11 0 VINE STREET CAMP HILL, PA 17011 ROBERT B. COLLINS / COLLINS CONTRACTING COMPANY 1101 LINDHAM COURT, BUILDING 502 MECHANICSBURG, PA 17055 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) ORRSTOWN BANK 2250 SPRING ROAD CARLISE, PA 17013 KIM C. RARAIGH AND CATHLEEN D. RARIGH 7 GORDON DRIVE CARLISE, PA 17013 COMMERCE BANK 100 SENATE AVENUE CAMP HILL, PAl 7011 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) TAMARA WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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) TenanUOccnpant 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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 1hat false statements herein are made subject to the penal1ies ofl8 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities, December 5, 2005 DATE J1~JJ-i~'J DANIEL G. SCHMIEG, ES"QUIRE Attorney for Plaintiff ) CJl .,1 -'.i (. (,) c::; PHELAN HALLINAN AND SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ABN AMRO MORTGAGE GROUP, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION LEE A. WOODALL NO. 05-280 CIVIL TERM 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: o an FHA mortgage () non-owner occupied () vacant (X) 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, ff~JJJ~ DANIEL G. SCHMIEG, ESQifurn Attorney for Plaintiff ,;_'-1 , ,'."", V '" i ABN AMRO MORTGAGE GROUP, INC. Plaintiff, CUMBERLAND COUNTY v. No. 05-280 CIVIL TERM LEE A. WOODALL Defendant(s). December 5, 2005 TO: LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 **THlS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THlS 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. 21 WEST MULBERRY HILL ROAD, CARLISE. PA 17013. is scheduled to be sold at the Sheriffs Sale on MARCH 8,2006 at 10:00 a,m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce 1he court judgment of $236,421.43 obtained by ABN AMRO MORTGAGE GROUP, INC. (the mortgagee) against you, In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.RC.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 1he 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 atIorney to assert your rights. The sooner you contact one, thc 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 no1 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 pricc was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have thc 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 of1he 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 distribu1ion 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 ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale, CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 " DESCRIPTION ALL THAT CERTAIN tract ol'land situam in Middlesc, Township. Cumberland Coonl)', Pennsyh'ania, being Lot No, 59. as shown Oil Ihc Plan entitled Meadowhrook Famls Final Suhdivision Plan Phase II dated rehrllilIY 12. 1999. last revised JUIlC 3, 1999. and recordcd AuguS[ 17, 1999. in Cumberland County Plan Rook 79. Page 85. more pmtK:ularly bounded and described as follows: BEGINNING at an iron pin. lying in" Westerly right-i\f-way linc of C.ounlry Side Drive (50'[001 right, of-way), and bclllg a NMtherly corner of Lot No. 77; thcnce along said Lot. South 62 degrccs 01 minntes 02 seconds West, 189.06 feet to aD iron pin, being a Westerly corner of said Lot and lying in an Easterly line of Lot No. 60; thence along said lot, Norm 27 degrees 58 seconds West. 120.00 feet to an iron pin, bdng a Northerly COrner of said Lot and lying in a Soutberly right.."f-""ay line of Mulberry Hill Road (50,foot right-of-way); thence along said right-of'w"y. North 62 dcgrees 01 minutes 02 secondS East. 187,73 feet 10 a point, lying along said right-uf-way; thence continuing along said right-of-way. along a curve to the right, having a chord bearing of South 69 degrees 1& minutes 16 seconds East. a chord distance of 37.36 feet. a radiUS uf 25,00 feet. and an arc distance of 42.19 feel to a point, lying in a Westerly line of Counlry Side Drive (50-fOOl righl'of-way); Ule.ncc along said right-uf-way, Soulh 21 degrees 17 minntes 34 seconds EaSt. 19,94 feet to 'I point; Ulenee continuing along said rigbt-of,way, along a curve (0 lhe tight. having a chord bearing of Soulh 11 degrcc~ 39 minutes 25 scconds East, a chord diSlanc.e of 75.32 feel, a radius of 225.00 fccI. and an arc distance or 75.68 reet to aJl iron pin. heillg the place of Degillflillg, CONl'AINING 0564 acre. Tax Parcel #21-15,1253-134 TITLE TO SAID P~EMISES IS VESTED IN Lee A. Woodall, matTied man hy Deed from Mark Sheely Builder, IIIC, a Pennsylvania Curporation dated 5/24/2002 and recurded 5/29/2002 in Deed Book 251 Page 4436. Premises: 21 West Mulberry Hill Road, Carlisle, P A 17013 ~ .) '"j ",1 '..- ,-'I . " c> <, PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL SCHMIEG, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103,1814 (215) 563-7000 ABN AMRO MORTGAGE GROUP, INC. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs, No.: 05-280 CIVIL TERM LEE A. WOODALL AFFIDAVIT I hereby certify that a true and correct copy ofthe Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to LEE A. WOODALL on 12115/05 at 21 WEST MULBERRY HILL ROAD, CARLISE, P A 17013, and 1512 WUNDEMERE PLACE, APT. 102, WEST CHESTE,R, PA 19380 in accordance with the Order of Court dated 5/12105. I further certify that the d2lte and location ofthe Sheriffs Sale was published in the Cumberland Law Journal on 12/16/05 and in The Sentinel on 12/21/05 in accordance with the Court's Order. The undersigned understands that this statement is made sut>ject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities, fJO/.;),.JJJ~ DANIEL G. SCHMIEG, ESQ(JIRE Date: January 4,2006 .. PROOF OF PUBLICATION State of Pennsylvania, County ofCumberlancl Tammv Shoemaker, Classified AdverlisingManager , of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) December 16, 2005 COPY OF NOTICE OF PUBLICATION NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-280 CIVIL TERM ASN AMRO Mortgage Group, Inc. Vs, LEE A. WOODALL NOTICE TO: LEE A. WOODALL, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" ALL THAT following described lot of ground situate, lying and being in TOWNSHIP OF MIDDLESEX TOWNSHIP, County of CUMBERLAND, Commonwealth of Pennsylvania, bounded and limited as follows, to wit: DESCRIPTION ALL THAT CERTAIN tract of land situate In Mldd....x TownShip, Cumberland County, Pennsylvania, being Lot No. 59, a. ahown on the Plan entitled Meadowbrook Fann. Final Subdivision Plan Ph... II dated February 12, 1199, la8t revised June 3, 1999, end recorded AugU8t 17, 1999, In Cumberllnd County Plan Book 79, Page 85, more partlcullrly bounded and described .. follows: BEGINNING at In Iron pin, lying In I We.terly rlght..of-wlY line of Country Side Drive (50-foot right-of-way), and being a Northerly comer of Lot No. 77; thence Ilong said Lot, South 62 degrees 01 minutes 02li1Conds Wast, 189.08 teet to an Iron pin, being I Westerly corner of said Lot Ind lying In In e..terly line of Lot No. 60; thence along aald lot, North 27 degrees 58 .econds West, 120.00 feet to an Iron pin, being a Northerly corner of said Lot and lying In . SOutherly right-of-way line of Mulberry HIli Road (50-foot rllJht..of~wey); thance alonq Jl ~;~~p~~~"B;el;mo;"~lfi ptiti ~~no'H nOl-eg u~ wnwms l:l2fU.O U~~A\1"" s~urnll ~uioq UOS~~S lllJOll~J Iqll!~ Jplpl!Ids W~lpllU!A~q plrn ~U"'I~W U! Al!lP~J llu!u!"JI J!~1p 01 w~lpllU!WIll~J p~JOA~JI ~q P!';S' plrn O!tlOIUY U~S U! SJ~A~ld SIU!"S ql!M. I~W M.~qsdfl .uos-e~s lX:JU SU-e;.lllO Nt..~N Irnqmqns U! sJ~).nmbp~~q llu!tI!"JI p~ll~urnpun s, W~~I ~lpl~ '1JOM. 01 uod~J AJO'I!lISOW I1,A~IpI~1p Uo!sS~Jdw! ~Ip ql!M. w~ql IPI M.~qsdfl ~U~D JOI~~J!P ~A!lno~X~ UO!l~POSSY SJ~A~ld ldN 1p!M. llu!l~~w )U~~~J ~ A~S SJ~A~Id SIUf"S - (dY) SNV'iIT!lO M.'iIN UJRlaJ sUlla/JO MaN SJOAIlJ tlJl:lN AilS sJaAllld SIU!"S '('1:O0l) SUOWW!S lI"pn")! plllnll plrn (toOl) nl"w 1-"IOd AOJL Al~J1ls '(tOOl) J~llJ~qs!JIll~O}/ u~H '1~"qJ~).I1mb 'pJ"M.~ :JP{OOJ ~tp JO SJ~UU1A\ lua~al lSOW aalql ~ql spaao~~s J~IH~_ Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are t':~ Sworn to and subscribed before me this 21st day of December, 2005, C~ ,( [;.1:6 Act/ My commission expires: q/I lor COMMONWEAL TH OF PENNSYLVANIA Notarial Seal Chnstina L Wolfe, Notary Pubftc Carlisle 80m, Cumberland County My Comm,;sion Expires Sept 1 , 2008 Member. PennsylvanlJ:l I\SGOClatlon Of Notaries PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local COUlts 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 December 16, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and 1hat he is not interested in the subject matter of the aforesaid notice or advertisemen1, and that all allegations in the foregoing statements as to time, place and character of publication are true, TO AND SUBSCRIBED before me this day of December, 2005 ~~A~).1:. ~rM~ Notary CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 05-280 Civil Term ABN AMRO MORTGAGE GROUP, INC. vs, LEE A WOODALL NOTICE TO: LEE A WOODALL. NOTICE OF SHERlFF'S SALE OF REAL PROPERIT ALL THAT following described lot of ground situate, lying and being in TOWNSHIP OF MIDDLESEX TOWN, SHlP, Counly of CUMBERlAND, Com, monwea1th of Pennsylvania, bounded and limited as follows. to wit: DESCRlPTION ALL THAT CERTAIN tract of land situate in Middlesex Township. Cum- berland County. Pennsylvania, being Lot No. 59, as shown on the Plan entitled Meadowbrook Fanus F:II1al Subdivision Plan Phase n dated Feb- ruary 12, 1999, last revised June 3. 1999, and recorded August 17. 1999. in Cumberland County Plan Book 79, Page 85. more particularly bounded and described as follows: BEGINNING at an iron pin. lying in a Westerly right-oC-way line of Country Side Drive (50-foot right- of-way), and being a Northerly cor- ner of Lot No. 77; thence along said Lot, South 62 degrees 01 minutes 02 seconds West. 189.06 feet to an iron pin. being a Westerly corner of said Lot and lying in an Easterly line of Lot No. 60; thence along said lot. North 27 degrees 58 seconds West. 120.00 feet to an iron pin, being a Northerly comer of said Lot and ly- ing in a Southerly light-of-way line of Mulberry Hill Road (50,foot right, of-way); thence along said right-of- way, North 62 degrees 01 minutes 02 seconds East, 187.73 feet to a point, lying along sald right-of-way; thence continuing along said right- of-way. along a CUIve to the right, having a chord belling of South 69 degrees 38 minutes 16 seconds East, a chord distance of 37.36 feet. a radius of 25.00 feet, and an arc dis- tance of 42.19 feet to a poInt, lying in a Westerly line of Country Side Drive (50-foot right..of~way); thence along said right-of-way, South 21 degrees 17 minutes 84 seconds East, 19.94 feet to a point: thence contin- uing along said right-of-way, along a curve to the right, having a chord bearing of South II degrees 39 min- utes 25 seconds East, a chord dis- tance of 75.32 feet, a radius of 225- .00 feet, and an arc distance of 75.68 feet to an iron pin, being the place of Beginning. CONTAlNING 0564 acre. Tax Parcel #21-15-1253-134. TITLE TO SAID PREMISES IS VESTED IN Lee A. Woodall, mar- ried man by Deed from Mark Sheely Builder, Inc.. a Pennsylvania Cor- poration dated 5/24/2002 and re- corded 5/29/2002 in Deed Book 25 I Page 4436, Premises: 21 West Mulberry Hill Road. Carlisle, PA 17013. is scheduled to be sold at the Sher- iffs Sale on MARCH 8,2006 at 10:00 A.M., at the CUMBERlAND County Courthouse, SOUTH HANOVER STREET. CARLISLE,. PA to enforce the Court Judgment of 7/7/05, ob, tained by ABN AMRO MORTGAGE GROUP. INC., (the mortgagee). against you. 2 CUMBERLAND LAW JOURNAL Prop. sit. in the City of TOWNSHIP OF MIDDLESEX, County of CUM, BERlAND, and State of Pennsylva- nia. Being Premises: 21 WEST MUL- BERRY HILL ROAD, CARLISLE, PA 17013. Improvements consist of residen- tial property. Sold as the property of LEE A. WOODALL. TERMS OF SALE: THE HIGHEST AND BEST BID, DER SfW-L BE TIlE BUYER The purchaser at the sale must take ten (10%) percent down pay- ment of the bid price or of the Sheriffs cost, whichever is higher, at the time of the sale in the form of cash. money order or bank check. The balance must be paid within ten (10) days of the sale or the pur- chaser will lose the down money. DANIEL SCHMIEG. ESgUlRE Attorney for Plaintiff One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563,7000 Dec. 16 3 ('"" o 'n :~ _l.,,'-r1 -\1 ,....;~ 'T~ (-- I (n f -, " i-:.:} rr1 :~~ (,; , .. SALE DATE: MARCH 8, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC. No.: 05-280 CIVIL TERM vs. LEE A. WOODALL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 21 WEST MULBERRY HILL ROAD. CARLlSE, P A 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy ofthe notice is attached as an Exhibit. A copy of the Certifica1e of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice, March 7, 2006 4 ABN AMRO MORTGAGE GROUP, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LEE A. WOODALL CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) ABN AMRO MORTGAGE GROUP. INC., 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 ,21 WEST MULBERRY HILL ROAD, CARLISE. PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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) PRINTED IMAGE 137 N. HANOVER STREET CARLlSE, PA 17013 CIT1BANK OF SOUTH DAKOTA, NA 701 EAST 60TH STREET SIOUX FALLS, SD 57104 3905 COREY ROAD P.O. BOX 3641 HARRISBURG, P A 17105 845 HAMILTON STREET CARLlSE, P A 17013 SYSCO FOOD SERVICE ERIC J. SWIDLER ERIC A. GARONZIK llO VINE STREET CAMP HILL, PA l70ll ROBERT B. COLLINS / COLLINS CONTRACTING COMPANY 1101 LlNDHAM COURT, BUILDING 502 MECHANICSBURG, P A 17055 , 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) ORRSTOWN BANK 2250 SPRING ROAD CARLISE,PA 17013 KIM C. RARA1GH AND CATHLEEN D. RAR1GH 7 GORDON DRIVE CARLISE, PA 17013 COMMERCE BANK 100 SENATE AVENUE CAMP HILL, PA 17011 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) FIRST TENNESSEE BANK NATIONAL ASSOCIATION 300 COURT A VENUE MEMPHIA, IN 38103 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) TAMARA WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrishurg, 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. 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'^#'JI.~ ~ " .~ ;. :s ~ . t,. . ,.. "~ " " ~~ 3~ ,..<" . . .~,~ ,..0 -O'g n '? ~ "ifE {3.;t " ~ () ~ ::2 ,,~ Vl ,," n M '" '" on '.D r- oo '" 0 - ('ol '" '" "" :z..l - - - - - - '3~ 0_ \-<,.. ABN AMRO MORTGAGE GROUP, INC. vs. LEE A. WOODALL TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): LEE A. WOODALL PROPERTY: 21 WEST MULBERRY HILL ROAD CARLISE, P A 17013 Improvements: Residential dwelling Judgment Amount: $236,421.43 CUMBERLAND COUNTY NO. 05-280 CIVIL TERM The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on MARCH 8, 2006, at the Cumberland County Courthouse, South Hanover Street, Carlisle, P A at 10:00 a.m.. Our records indicate that you may hold a mortgage, judgment, or other interest on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests, If you have any questions regarding the type oflien or the effect of the Sheriff s Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice, The Sheriff will file a schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. .. SALE DATE: JUNE 7.2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC. No.: 05-280 CIVIL TERM vs. LEE A. WOODALL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 21 WEST MULBERRY HILL ROAD. CARLISE. P A 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. June 5, 2006 .. ABN AMRO MORTGAGE GROUP, INC. Plaintiff, CUMBERLAND COUNTY v. COURT OF COMMON PLEAS LEE A. WOODALL CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) ABN AMRO MORTGAGE GROUP, INC., 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 ,21 WEST MULBERRY HILL ROAD. CARLISE, P A 17013 . L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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) 137 N. HANOVER STREET CARLISE, PA 17013 PRINTED IMAGE CITmANK OF SOUTH DAKOTA, NA 701 EAST 60111 STREET SIOUX FALLS, SD 57104 3905 COREY ROAD P.O. BOX 3641 ~SBURG, PA 17105 845 HAMILTON STREET CARLISE, PA 17013 SYSCO FOOD SERVICE ERIC J. SWlDLER ERIC A. GARONZIK 110 VINE STREET CAMP fiLL, PA 17011 ROBERT B. COLLINS I COLLINS CONTRACTING COMPANY 1101 LINDHAM COURT, BUILDING 502 MECHANICSBlJRG, P A 17055 .. 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) ORRSTOWN BANK 2250 SPRING ROAD CARLISE, P A 17013 KIM C. RARAIGH AND CATHLEEN D. RARIGH 7 GORDON DRIVE CARLISE, PA 17013 100 SENATE AVENUE CAMP HILL, P A 17011 COMMERCE BANK 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) FIRST TENNESSEE BANK NATIONAL ASSOCIATION 300 COURT AVENUE MEMPHIA, IN 38103 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) TAMARA WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, P A 17013 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 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities, March 7. 2006 DATE DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff -. ABN AMRO MORTGAGE GROUP, INC. vs. LEE A. WOODALL TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): LEE A. WOODALL PROPERTY: 21 WEST MULBERRY HILL ROAD CARLISE, P A 17013 Improvements: Residential dwelling Judgment Amount: $236,421.43 CUMBERLAND COUNTY NO. 05-280 CIVIL TERM The above-captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on MARCH 8, 2006, at the Cumberland County Courthouse, South Hanover Street, Carlisle, PA at 10:00 a.m.. Our records indicate that you may hold a mortgage, judgment, or other interest on the property, which may be extinguished by the sale, You may wish to attend the sale to protect your interests. If you have any questions regarding the type of lien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. 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Ei-li'~ff .sgeg, g'f!! a ~ ge, If g'~ i ~I'I . ~ ~ . 3r;;' rf~S: g'i m' ~ J ~ 8 ! li f ;;.-o.l !. ~ ~ " ~(/''\'8POe,.~ .fQ.t~~ 021A $ 00.950, . 0004309825 JAN 09 2006 i MAILED FROM ZPCODE 19103 I'...:> f:'::) {,:::::l <:;..--, L_ c:: ~ I 0'1 -..... ..' -...-.' r:~) N o --n --I T.,., rn;= ;n Cl I s.t': .'f'j () in 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 Orrstown Bank is the grantee the same having been sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 6th day ofDec, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 280, at the suit of ABN Amro Mtg Group Inc against Lee A Woodall is duly recorded in Deed Book No. 275, Page 3598. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this l~ day of ~-A '. ~ 'iiY\h"1.-~ ,'(). W.,~-tt~ ,CZ--Fi.S,;\ Recorder of Deeds R~ of Detda. Cumbel1lnd County. CaIIIII. PA My CClI..W.. e,..1II Fill MaldarGf_2D1O A D '.:1 "'''', i ", , . . ~ ~ Il- , , ABN Amro Mortgage Group, Inc, VS Lee A, Woodall The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2005-280 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice of Sale and Description, in the above entitled action, pursuant to order of court, in the following manner: The Sheriff mailed a copy of the within action to the within named defendant, to wit: Lee A. Woodall, by certified mail, return receipt requested, restricted delivery, deliver to addressee only, at his last known address of 1512 Windemere Place, Apt. 102, West Chester, PA 19380, This letter was mailed on the date of December 19, 2005. The unopened letter was returned to the Cumberland County Sheriffs Office on January 12,2006 with reason marked "Unclaimed. " Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2006 at 8: 17 0' 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 Lee A, Woodall, located at 21 West Mulberry Hill Road, Carlisle, Pennsylvania, according to law, R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Lee A. Woodall, by regular mail to his last known address of 1512 Windemere Place, Apt. 102, West Chester, PA 19380, This letter was mailed under the date of January 13,2006 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 07, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $257,000.00 to Attorney David Baric for Orrstown Bank It being the highest bid and best price received for the same, Orrstown Bank of 22 South Hanover Street, Carlisle, PA 17013, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $262,340.00. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 5,140.00 15.00 15.00 30.00 10.00 ,50 1.00 Mileage Certified Mail Levy Surcharge Postage Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 4.40 12.56 15.00 20,00 .78 437,00 348.80 21.05 25.00 39.50 $6,165.59 / ~ S?~K~~~~ R. Thomas Kline, Sheriff BY "Jc (~ Real Estate ergeant 1JJJ/lJ(, ~v 'll> ,Uv J J ,:>'0 . Ck.. 5'Y &,1 D ~ J fIJffY ABN AMRO MORTGAGE GROUP, INC. ., ~ CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LEE A. WOODALL CIVIL DIVISION Defendant(s). NO. 05-280 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) ABN AMRO MORTGAGE GROUP, INC., 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 .21 WEST MULBERRY HILL ROAD, CARLISE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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) PRINTED IMAGE 137 N. HANOVER STREET CARLISE, P A 17013 CITIBANK OF SOUTH DAKOTA, NA 701 EAST 60TH STREET SIOUX FALLS, SD 57104 SYSCO FOOD SERVICE 3905 COREY ROAD P,O, BOX 3641 HARRISBURG, PA 17105 ERIC J, SWIDLER 845 HAMIL TON STREET CARLISE, P A 17013 ERIC A. GARONZIK 110 VINE STREET CAMP HILL, PA 17011 ROBERT B. COLLINS I COLUNS CONTRACTING COMPANY 1101 UNDHAM COURT, BUILDING 502 MECHANICS BURG, PA 17055 r ~ 4. Name and address oflast recorded holder of every mortgage of record: Name .. Last Known Address (if address cannot be reasonably ascertained, please indicate) ORRSTOWN BANK 2250 SPRING ROAD CARLISE, P A 17013 KIM C. RARAIGH AND CATHLEEN D. RARIGH 7 GORDON DRIVE CARLISE, P A 17013 COMMERCE BANK 100 SENATE AVENUE CAMP HILL, P A 17011 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) TAMARA WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 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 21 WEST MULBERRY HILL ROAD CARLISE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification: to rtuthorities. . . December 5. 2005 DATE ~~JjJ~ DANIEL G. SCHMIEG, E QUIRE Attorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. Plaintiff, CUMBERLAND COUNTY v. No. 05-280 CIVIL TERM LEE A. WOODALL Defendant(s). December 5, 2005 TO: LEE A. WOODALL 21 WEST MULBERRY HILL ROAD CARLISE, PA 17013 * * THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON 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 21 WEST MULBERRY HILL ROAD CARLISE A 17013 is scheduled to be sold at the Sheriffs Sale on MARCH 8~ 2006 at ] 0:00 a.m. in the Cumbe . land County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of ~~36~421.43 obtained by ABN AMRO MORTGAGE GROUP~ INC. (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.PI., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, l~te 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 stri~e or open the judgment, if the judgment was improperly entered. You may also ask the dourt 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 Y9ur rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 f' D~SCRIf'TION ^ LL TH ^ T CERTA rN LrdCt of land situam Ir} Middlesex TO\VIlShip, Cumberland County, Pent1.>Y1 vania, being Lot No. 59, as shown on the Plan entitled Meadowbrook famls Final Subdivision Plan Phas~ n dated Pebruary 12. 1999, last revised June 3, 1999, and r~cordcd Augwa 17, 1999, in Cumberland County Plan Book 79, Page 85. more palticularly bounded and described as fbllows: BEGINNrNG at an iron pin. lying in a Westerly right-of-",'ay line of ('.wntey Side Drive (50-foot right- of-way), and being ~ Nt')ttherl)' comer of Lot No. 77; thence along said Lot, South 62 degrees 01 minutes 02 seconds West. 189.06 feet co an iron pio. being a Westerly comer of said Lot and lying in an Easterly fine of Lot No, 60; thence along saki lot, North 27 degrees ~8 ~conds West, 120.00 feet to an iron pin, being a Northerly COmeT of said Lot and lying in a Southerly right-of-way line of Mulberry Hill Road (50-fOO( right-of.way); lheoce along said right-of-wlty, North 62 dcgree.s 01 minutes 02 secondS E~st, J 87.73 feet to a point, tying along said right..{)f-way ~ thence c~.mtinuillg along said right-of-way, along a CUrve to the right. having a chord bearing of South 69 degrees 38 minutes ]6 seconds East. a chord dmtance of 37.36 feet, a radius of 25.00 feet, and an arc distance of 42.19 feel to a point, lying in a \Vesterly line of Country Side Drive (50-fOOL right-of-way)~ thence along said righl-Qf-way, South 21 degrees 17 minutes 34 secmlls East, 19.94 fcello It point; thence continuing along said right-of-way. along a l.~rvc to the right. having :i chord bearing of SOOth 11 deg.rcc~ 39 minutes 25 licconds Eut, a chord distance of 75.32 feet, n radius of 225.00 fect. and an arc distance of 75,68 feet to an imn pin, hcing tbe place of Deginning, CONTArNING 0.564 acre. Tax Parcel 1121-15- t 253-1 J4 TITLE TO SAID PRElvfISES rs Vl--,:sTED IN Lee A. \\'oodall, malTied ma.n hy Deed From Mark Shedy Builder, Inc.. aPcnusylvania Corporation dated 5/24/2002 and recorded 5/29/2002 in Deed Book 251 Page 4436, Premises: 21 West Mulberry Hill Road, Carlisle, P A 17013 WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-280 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s) From LEE A. WOODALL (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 $236,421.43 L.L. $.50 Interest FROM 7/7/05 TO 3/8/06 (PER DIEM - $38.86) -- $9,481.84 AND COSTS Arty's Comm % $5,676.21 Due Prothy $1.00 Atty Paid $254.30 Other Costs Plaintiff Paid Date: DECEMBER 6, 2005 (Seal) By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, P A 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 lUB~~l~S ~lBlSg IB~"M , !~~1(' h1l)v( :AH , , ~ooz 'tl1~qUl~~~a :~lBa .Upl~l{ P~lB10d.IO~U! ~~U~l~J~l SIl{l Aq pUB l!lM S!4l 4l!M P~IY "v" lIqIl{x9 uo p~q!l~S~P AllllJ ~lOUl '~IS!PBJ (~) r:v:a c;;;] c:::::::::::I G=e1 V"V1l 'PBOllIHH A.u~qlnw lS~ 1ft 1 Z SB p~l~qUlnu pUB UMOU)I Vd 'AlUnO:) PUBpdqUln:) 'd!l{SUMOl XdS~IPPIW U! p~lBnl!S All~dold IB~l ~4l U! lS~l~lU! S,lUBPU~J~P dl{l uodn Pd!Adl JJ!l~l[S dl[l ~OOZ 't 1 ldqUld~~a uO tt # ~IBS dlBlS9 IBd"M LZ :t d L- 330 Gll tJd 'A1NfW:J UN '1) 'ld38Wn~ .:HIH3HS 3Hl .:10 3~1.:f.:fO SCHEDULE OF DISTRIBUTION SALE NO. 33 Date Filed: July 07, 2006 Writ No. 2005-280 Civil Term ABN Amro Mortgage Group, Inc. VS Lee A. Woodall 21 W. Mulberry Hill Road Carlisle, P A 17013 Sale Date: Buyer: Bid Price: June 07, 2006 Attorney Baric for Orrstown Bank $257,000,00 Real Debt: Interest: Attorney Costs: Misc. Costs: $236,421,43 9,481.84 254.30 5,676.21 Total: $251,833.78 DISTRIBUTION: Receipts: Cash on account (12/12/2005): Cash on account (06/07/2006): Cash on account (06/21/2006): $ 1,500.00 25,700,00 236,640.00 Total Receipts: $263,840.00 Disbursements: Sheriffs Costs Legal Search Penny Davis, Tax Collector Attorney Daniel Schmieg ABN Amro Mortgage Group, Inc. Orrstown Bank Total Disbursements: Balance for distribution: So Answers: r~-,,-t:~/---- R. Thomas Kline Sheriff $6,165,59 200.00 2,985.74 1,500.00 251,833,78 1,154.89 ($263,840.00) 0.00 TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECf TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 33 Held Wednesday, June 7, 2006 Date: June 7, 2006 TAXES: Receipts for all taxes for the years 2003 to 2005 inclusive. Taxes for the current year 2006. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2006, and recorded , 2006, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Mark Sheely Builder, Inc., by deed dated May 24, 2002 and recorded May 29, 2002 in the Office of the Recorder of Deeds for Cumberland County in Deed Book 251, Page 4436 granted and conveyed to Lee A. Woodall, married man. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbeds of Countryside Drive and West Mulberry Hill Road. 6. Mortgage in the amount of $225,000, given by Lee A. Woodall to ABN Amro Mortgage Group, Inc. dated May 24, 2002 and recorded May 29, 2002 in Mortgage Book 1760, Page 486. Complaint in Mortgage Foreclosure filed by ABN Amro Mortgage Group, Inc. as Plaintiff against Lee A. Woodall as Defendant in the Office of the Prothonotary of Cumberland County to file number 2005-280. Default judgment in the amount of $236,421.43 entered. 7. Mortgage in the amount of $52,000.00 given by Lee A. Woodall to Orrstown Bank dated April 7, 2003 and recorded April 14, 2003 in Mortgage Book 1805, Page 3723. 8. Mortgage in the amount of $80,000.00 given by Lee A. Woodall to Kim C. Raraigh and Cathleen T. Raraigh, dated July 7, 2003 and recorded July 8, 2003 in Mortgage Book 1821, Page 3110. 9. Mortgage in the amount of $165,000.00 given by Lee A. Woodall to Commerce Bank/Harrisburg, N.A. dated February 3, 2004 and recorded February 10,2004, in Mortgage Book 1853, Page 3032. 10. Judgment in the amount of $83,286,84 entered by Kim C. Raraigh and Cathleen D. Raraigh, as Plaintiff against Lee A. Woodall, as Defendant, on September 21,2004 in the Office of the Prothonotary of Cumberland County, to File No. 2004-3247. 11. Mechanic's Lien filed by Robert B. Collins and Collins Contracting Group as Plaintiff against Lee A, Woodall, Lee Woodall's Escape Fitness, and Lee Woodall Enterprises as Defendants on April 22, 2004 in the Office of the Prothonotary to File No. 2004-1745 in the amount of $18,690.70. See also judgment entered in the same matter at File No. 2004-1744. 12. Judgment in the amount of $51,451.74 entered by Orrstown Bank as Plaintiff against Lee A. Woodall as Defendant on November 16,2004 to File No, 2004-4598. 13. Judgment in the amount of $125,000.00 entered by Paramount Development, Inc., as Plaintiff against Lee A. Woodall as Defendant in the Office of the Prothonotary on May 13, 2005, to File No. 2005-537. 14. Judgment in the amount of $55,080.63 entered by Orrstown Bank as Plaintiff against Lee A. Woodall as Defendant in the Office of the Prothonotary on March 4,2005 to File No. 2005-1156. 15. Judgment in the amount of $60,000.00 entered by Kim C, Raraigh and Cathleen D, Raraigh, as Plaintiff against Lee A. Woodall, as Defendant, in the Office of the Prothonotary on April 25, 2005 to File No. 2005-2143. 16. Judgment in the amount of $6,995.43 entered by Printed Image, as Plaintiff against Lee A. Woodall, L. Woodall Enterprises, and Lee Woodall's Escape Fitness as Defendants in the Office of the Prothonotary on July 9, 2004 to File No. 2004-3299. 17. Judgment in the amount of $22,528.20 entered by Citibank (South Dakota), N.A., as Plaintiff against Lee A. Woodall, as Defendant in the Office of the Prothonotary on August 4, 2004 to File No. 2004-3839. 18. Judgment in the amount of $4,181.63 entered by Kim Raraigh and Cathy Raraigh, as Plaintiff against Lee A. Woodall, as Defendant in the Office of the Prothonotary to File No. 2004-4748. 19. Judgment in the amount of $1,959.06 entered by Sysco Food Service of Central Pennsylvania as Plaintiff against Lee Woodall, as Defendant in the Office of the Prothonotary to File No. 2004-6524. 20. Judgment in the amount of $18,436.95 entered by Hammel Associate Architects, LLC. as Plaintiff against Lee Woodall and Escape Fitness as Defendants in the Office of the Prothonotary on March 9, 2005 to File No. 2005-1223. 21. Judgment in the amount of $170,263.33 entered by Horst Construction Company as Plaintiff against Lee Woodall as Defendant in the Office of the Prothonotary on January 12, 2006, to File No. 2006-5016. 22. Building conditions, easements, and restrictions as shown on or set forth with the Plan for Meadowbrook Farms recorded in Plan Book 79, Page 85. 23. Subject to the Declaration for Meadowbrook Farms recorded in Miscellaneous Record Book 567, Page 1090, as amended by First Amendment recorded in Miscellaneous Record Book 622, Page 475, and subsequent Amendments recorded in Miscellaneous Record Book 622, Page 478, and Miscellaneous Record Book 642, Page 967. 24. Rights granted to PP & L and Sprint United as set forth in Miscellaneous Record Book 631, Page 495, and in Miscellaneous Record Book 560, Page 1037. 25. Subject to Declaration of Conservation Easement as set forth in Miscellaneous Record Book 623, Page 147. 26. Rights granted to Socony Vacuum Oil Co. by instruments recorded in Miscellaneous Record Book 83, Page 401, and in Miscellaneous Record Book 83, Page 402. 27. Rights granted to Laurel Pipeline Company by instrument recorded in Miscellaneous Record Book 129, Page 6. 28, Subject to Affidavit establishing a wetland conservation easement as set forth in Miscellaneous Record Book 468, Page 435. 29, Rights granted to United Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 660, Page 53, 30. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 31. Real estate taxes accruing on and after July 1, 2006 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. \~j.- Robert G. Frey, Agent Note: This Title Report shall not be valid 0 bi mg until countersigned by an authorized signatory. '. -.. 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2006. That neither he nor said Corripany is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #33 (I CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 REAL ESTATE SALE No. 33 WItt.... 11 .._ ClllTenn ABN Amro~lrgl Group, Inc. v. Lee A. Woodall Ally: DanIel SchmIeg DESCRIP110N AlL THAT CERfAIN tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, being Lot No. 59, as shown on the Plan ~. M~ Farms Fmal Subdivision! Plan Pbase II ~ February 12. 1999, Last revised June 3':"1999, and recorded August 11~ 1999, in Cwnberland County Plan Boot. 79, Page 85, n1IWe particularly bounded and ....,............ :,...~lk...........) ,co ... '..... ~,- ""., ..>......... ..- of Lot No. 77; thence along said Lot, M'~ 01 minUles 02 seconds West, 189.06 feet to an iron pin, being a Westerly comer of said Lot and lying in an Easterly line of Lot No. 60; thence along .... lot, North 27 degrees 58 seconds.... l_ feet to an iron pin, being a NodIIIIl, ... of said Lot and lying in a Soulhedy. .., line of Mulberry Hill Road (50 foot""- of-way); thence along said right-of-way, North 62 degrees 01 minUles 02 seconds East. 187.73 feet to a point, lying along said right-of-way; thence continuing along said right-of-way. along aCUIVe to the right, having a chord bearing of South 69 degrees 38 minUles 16 seconds East, a chord distance of 37.36 feet, a radius of 25.00 feet, and an arc distance of 42.19 feet to a point, lying in a Westerly line ofCOUIIIlySide Drive (50 fQOt right- of-way); 1beaee a10ug . rigbt-of-wa)\ South 21 degrees 17111inuleS 34secoods East, 19.94 feet to a poiitt; thence 00Dtinuing along said right-of-way, along a cum to the ti&k. baYing a chord bearing of South 11 degrees ~ iDinUtes25 secends East, a chord distance of 7532 feet, a radius of 225.00 feet, and an arc distante of 75.68 feet to an iron pin, heiDg the place ofSEGIfooNG. CONI'AINING 0.564 acre. TAXPAltCllL 121-15-1253-134 '1TfLE 10 SAID PJBtJSF.8 is vested in Lee A:WoocIaIl, lIIIIftied.lDan by Dood Born Mark SbeeIy BuiIcIer, IDe., a PemmyIVIDia corpomtion dated ~ and ftltmIed SfJ9f1J!J1}. in Deed ...251 PIlle 4436. ~ 21 West MuIINny Hill Roed, CIIIWt, PA 11813 PROz, ,.' OF PUBLICATION OF !\'OTICE p< '. UIVIBERLAND LA \V JOU RNAL (Under Act :D, 587, approved May 16, 1 (j29), P. L.1784 STATE OF PENNSYL V Al\; c : COUNTY OFCUMBERLA\.. : ss. I jisa Marie Coyne, E'll.! d ire, Editor () r the Cumberl~1I1d Law Journal, of the County and State aforesaid, being duly S\\, JournaL a legal periodical pub;: was established January 2, periodical for the publication issued weekly in the said Cu , exactly the same as was prilll Journal on the following dates VIZ: -==~ .I anuary 20, 2 /\ftiant further cleposl'. Law Journal, a legal periodic:, matter of tile aforesaid noti ,:. ~lccording (0 law, deposes ~lnd says that the Cumberland Law . ;l.:d in the Bcmugh of Carlisle in the County and State aforesaid, 2. and desi :rnated by till' iocal courts as the official legal Ii legalnotl(":s, and has, >l! .,'L' January 2, 1952, been regularly . ~lnd that tile printed nOl ie,' or publication attached hereto is ;1 the reguLl: editions an(j i ,sues of the said Cumberland Law ,.::'bruary 3, 2(J1)6 "It he is auLI' ,rized to ver: '\ :his statement by the Cumberland general cij(,'.ilation. and Ll:' he is 110t interested in the subject )1' advertisl'ment, and tl1:1t all allegations in the foregoing statements as to time, place al . .aracter of publication are true. S\., )";UBSCRIBED before me this ,i ,,:JxlIarv , 2006 ~~~J',L,__", ~lcb"'/ ;\o:ary REAL ESTATE SALE NO, 33 Writ No. 2005-280 Civil ABN AMRO Mortgage Group, Inc. vs. Lee A. Woodall Atty.: Daniel Schmieg DESCRIITION ALL THAT CERTAIN tract of land situate in Middlesex Township, Cumberland County. Pennsylvania. being Lot No. 59. as shown on the Plan entitled Meadowbrook Farms Final Subdivision Plan Phase II dated February 12, 1999, last re- vised June 3, 1999, and recorded August 17, 1999, in Cumberland County Plan Book 79, Page 85. more particularly bounded and described as follows: BEGINNING at an iron pin, lying in a Westerly right-of-way line of Country Side Drive (50-foot right- of-way), and being a Northerly cor- ner of Lot No. 77; thence along said Lot, South 62 degrees 01 minutes 02 seconds West. 189.06 feet to an iron pin. being a Westerly corner of said Lot and lying in an Easterly line of Lot No. 60; thence along said lot, North 27 degrees 58 seconds West. 120.00 feet to an iron pin, being a Northerly comer of said Lot and ly- ing in a Southerly right-of-way line of Mulberry Rill Road (50-foot rig;ht- of-way); thence along said right-of- way, North 62 degrees 01 minutes 02 seconds East. 187.73 feet to a point, lying along said right-of-way; thence continuing along said right- of-way. along a curve to the right, having a chord bearing of South 69 degrees 38 minutes 16 seconds East, a chord distance of 37.36 feet, a radius of 25.00 feet, and an arc distance of 42.19 feet to a point. lying in a Westerly line of Country Side Drive (50-foot right-of-way); thence along said right-of-way, South 21 degrees 17 minutes 34 seconds East, 19.94 feet to a point; thence continuing along said right- of-way, along a curve to the right, having a chord bearing of SOUill 11 degrees 39 minutes 25 seconds East. a chord distance at 75.32 feet, a radius of 225.00 feet. and an arc distance of 75.68 feet to an iron pin, being the place of Beginning. CONTAINING 0.564 acre. Tax Parcel #21-15-1253-134. TITLE TO SAID PREMISES IS VESTED IN Lee A. Woodall, mar- ried man by Deed from Mark Sheely Builder, Inc.. a Pennsylvania Cor- poration dated 5/24/2002 and re- corded 5/29/2002 in Deed Book 251 Page 4436. Premises: 21 West Mulberry Hill Road, Carlisle. PA 17013.