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HomeMy WebLinkAbout05-2079 I Ii II II I I II II I, I II II II I .\ II II 1\ II I[ I I II THOMAS 1. PULEO, LLC By: Thomas 1. Puleo, Esquire Identitication No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY VANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC, 7159 Corklan Drive Jacksonville, Florida 32258 v. KATHERINE L. KRUEGER 257 West Baltimore Street Carlisle, P A 17013 :No. OS - O?CJ'79 C/'Ol'l ~ CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT 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 atter this complaint and notice are served, by entering a written appearance persona\\y 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 yOll by the court without further notice fOf any money claimed in the complaint or for any other claim or relief requested by the p]aintifT 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 MA Y BE ABLE TO PROVIDE VOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Cumberland County Bar Association 2 Liberty A venue Carlisle. P A 17013 (717) 249-3166 (800) 990,9108 AVISO USTEO HA SlOO DEMANDAOOfA EN CORTE Si ust d desea defenderse de ]as demandas que se prescntan mas ade]ant en las siguientes paginas, debe tamar accion dentm de los prox! os vdnte (20) dias despues de ]a notiticacion de esta Demanda y A iso radicando personalmente 0 por media de un abogado una comparecencia escrita y radicando en la Corte par escrito us defensas de, y si usted falla de tomar accion como se describe anter rmente, el caso puede proceder sin usted y un fallo par cualquier SUi de dinero reclamada en ]a demanda 0 cualquier atra reclamacion 0 r medio solicitado pOT el demandante p\.lcde scr dictado en contra ya par la Corte sin mas aviso adicionaL Usted puede perder dinero propiedad u otros derechos importantes para usted USTED DEBE LLEV AR ESTE DOCUMENTO A SU A lNMEDIA T AMENTE. 51 USTED NO TlENE UN ABa LLAMEO VAYA A LA 51GUlENTE OFlClNA ESTA PUEDE PROVEERLE INfORMACION A CERCA DE CON5EGUIR UN ABOGADO OGADO DO, FIC]NA MO SI USTED NO PUEDE PAGAR POR LOS SERVICIOS E UN ABOGADO, ES POSIBLE QUE EST^ OFICtNA LE PU DA PRO VEER INFORMACION SOBRE AGENCIAS QUE FREZCAN SERV]CIOS LEGALES SIN CARGO 0 BAJO CaSTO A PERSONAS QUE CUALlFICAN Cumberland County Bar Association 2 Liberty A venue Carlisle, P A \7013 (717) 249-3 I 66 (800) 990-9108 -II CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff, ABN AMRO MORTGAGE GROUP, INC" is a corporation organized nd existing under laws of the State of Delaware with offices at 7159 Corklan Drive, Jacksonville, Flori 2. Defendant, KATHERINE L. KRUEGER, is the mortgagor and real owner of pre ises 257 West Baltimore Street, Borough of Carlisle, Cumberland County, Pennsylvania, hereinafter escribed, whose last known address is as stated above, 3. On the 8th day of November, 2002, the above named mortgagor made, executed a d delivered a mortgage upon premises hereinafter described to ABN AMRO MORTGAGE GROUP, INC , the plaintiff herein, which mortgage is recorded in the Office of the Recorder of Deeds for Cwnberland ounty in I II II Ii II 1\ II II II \ I II Record Book 1786 page 3124. 4, The premises subject to the said mortgage is described in Exhibit "A" attached he eto and made a part hereof. 5. The mortgage secures defendant's certain Note dated the same as the mortgage in he amount of $79,025,00 payable in monthly installments with interest at the rate of 6.5% per annum, copy of the said Note is attached hereto, made a part hereof and marked Exhibit "B", 6. The said mortgage has not been assigned. 7. The mortgage is in default because the defendant has failed to make the payment the monthly installment of principal and interest in accordance with the terms of the mortgage for Janu 1,2005, and each month thereafter, up to and including the present time. 8. The following amounts are due on the mortgage: -1- .Ii II II \i Ii II II II II 1\ and hence, no notice of intention to foreclose is required by the said Act. II II \ Principal Interest at 6.5% per annum from 12/1/04 thru 3/31/05 ($13.75 per diem) Late charges accrued thru 3/31/05 ($26.61/month) Escrow deficit (taxes and insurance) ($ 1 65,64/month) Attorney's fee (5%) Title information certificate Total $77, 199.3 1,663,7 26,6 496,9 3,859,9 325.0 $83,671.5 9, The said mortgage is not a residential mortgage as defined by Pennsylvania Act N .6 of 1974, 10, The aforesaid mortgage is insured under Title II of the National Housing Act, an therefore, is not subject to the provisions of Pennsylvania Act No. 91 of 1983, WHEREFORE, plaintiff demands judgment in the swn of $83,671.58 plus interest, 1 e charges, escrow advances and costs to the date of judgment and foreclosure of the said mortgage, ,'THOMAS . PULEO Attorney for Plaintiff -2- DESCRIPTION ALL THA T CERTAIN lot of ground with the improvements thereon erected, situate in th Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described a' follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-on and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen an twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a artition wall between the premises herein described and premises No. 259 West Baltimore Street, ninet and twenty- two one-hundredths (90,22) feet, more or less, to a point on the Southern side of an u amed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16, 7) feet to a point; thence Southwardly though the center line of a partition wall between the pre ises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths 91,10) feet, more or less to a point, the place of Beginning, SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540 EXHIBIT A , ", LOAN i. 629682691 NOTE I FHACucNQ. U17051532-703 M...ltiltate NCO~BR 8, 2002 [Datel HARRISBURG, [City) PEIlIlSYLVANIA {state) 257 W BALTIMORE ST, CARLISLE, PA 17013 [Property Address] 1. PAJtTIES "Borrower" means each person signing at tile end oflhis Note, and the person's successors and assigIlS. "Lender" means ASN AMRO MORTGAGE GROUP, IHC., A DELAWARE CORPORATION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY, INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of * '" '" * '" * *SEVEN'rY NINE THOUSAND TWENTY FIVE AND NO/100..**.*......*..***..........*..*.*..**...* Dollars (U.S. $79,025.00), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX AND ONE-HALF percent ( 6.500% ) per year until 1hefull amnunlofprincipal has been paid 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed oftmst or similar security insttument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Bonower defaults under this Note. 4. MANNER OF PAYMENT (A) 11me Borrower shall make a payment of principal and interest to Lender on lhe 1ST day of each month beginning on JANUARY 1, 2003. Any principal and interest remaining on the 1ST day of DBCEMBER, 2032 will be due on that date, which is called the "Maturity Date." (8) Place Payment shall be made at U42 H. IlARLEM AVE. HORRIDG!, IL 60706 ATTN. CASHIERING or at such place as Lender may designate in writing by notice to Borrower. (C) AmOUdt Each monthly payment of principal and interest will be in tbe amount oru.s, $499.49. This amount will be part of a larger monthly payment required by the Security Instrument, that shalt be applied to principal, interest and other items in the order described in the Security Lustrnment. (0) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement lhe covenants of this Note as if tllC allonge were a part of this Note. IClteck applicabLe box! CJ Graduated Payment Allooge C=:J Growing Equity Allonge o Other {spedfy] S. BORROWER'S RIGHT TO PREPAY Borrower bas the right to pay the debt evidenced by this Nole, in whole 01' in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder oftbe month to the extent required by Lender and pennitted Py regulations of the Secretary. If Borrower makes a partial prepayn1ent, lherewill be no changes in the due date or in the amount oflhe monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdlle Paymenu If Lender has not received the full monthly payment required by the Security lnstroment, as described in Paragraph 4(C) of this Note, by the end of 15 calendar days after the payment is due. Lender may collect a bte charge in the amotUlt of FOUR percent ( 4.000' ) of the overdue amount of each payment. (B) Derault IfBonower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations oftbe SecretarY in the ease of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option wilhout waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender'srighls torcquire immediate payment in full in the case of payment 11lA MultQtate- Find Rau Note - 10195 . ExkIBIT B .){II . . .. ~ LOAN i: 629682691 deFaults. This Notedoes not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the: Secretary of Housing and Urban Development or his or her designee. (C) "aymeat of Com add E:lpeDlell lfLendef has required immediate payment in fun, as described above, Lender may require Bonower to pay costs and expenses including reaSOllable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs: shall bear interest from the date of disbursement at the same rate as the princi?Sl of this Note. 7. WAIVERS llorrower and any other person who has obligations under this Note waive the rights of presenunent and notice of dishonor. "presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to r<<J.Wle Lender to give notice 1.0 other persons that amounts due have not been paid. 8. GMNG OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at th~ property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lenderunder this Nole will be given by first class mail to Lender at the address stated in Paragraph 4(8) ~ at a different address if Borrower is given a notice: of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in lhis Note, inc1udingthe promise to pay the full amount owed. Any person who is a guarontor, surety or endorserofthis NOle isalso obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all ofthe promises made in this Note. Lender mayenforce its rights under this Note against each person i.ndividually or agait\st aU sigl\atories together. Anyone person signing this Note may be required to pay all of the amounts owed under this Note, BY SIGNING BELOW, Borrow" aceepls aod "fl'~ 10 the lenns aOdcoJnanls contained in this Note, , _i'~~O~ \ ) (SEAL) FHA MWtbbte Fbed Rat. Not. .10r'95 Page2of2 rS700NOT . Verification Ms. Paula Webb hereby states that she is Vice President of ABN- AMRO Mortgage Group, In ., the plaintiff, or servicing agent for plaintiff, this matter, that she is authorized to take this Verification, and that he statement made in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. The undersigned understands that this stateme is made to the penalties of 18 Pa,C.S.A. Sec. 4904 Relating to unsworn falsification to authorities. ~cw~ PAULA WEBB VICE PRESIDENT DATE: 4 -10 - {JeX>) N 0 ~ It '1 crt Vt ~ - ~ ...Q 8 tv \> ~ n ,...) c::;::. 0 c- <L;:~ <en 'T1 ~2:: -.... T.,., 1- ....-'.~ lil;--; r,,} ~:l:"j () "'" _0- (' ~' 1') ; ~ 'I .." C..J -< '^;, SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-02079 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS KRUEGER KATHERINE L 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 KRUEGER KATHERINE L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , KRUEGER KATHERINE L 257 WEST BALTIMORE STREET CARLISLE, PA 17013 HOUSE IS VACANT. NO FORWARDING ON FILE AT POST OFFICE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 3.70 5.00 10.00 .00 36.70 So answers:--, . /' _ ~~<<" R. Thomas Kline Sheriff of Cumberland County THOMAS PULEO 05/11/2005 Sworn and subscribed to before me this 13 '::: day of II( .2/JV5 A.D. LJ~t"- Q h1';~J._ protih notary /' qA/ THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 , By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff v. NO. 05-2079-Civil Term KATHERINE L. KRUEGER, Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter for service upon defendants. ,..., = ,-;;;.;1 e"., c..,._ s; ""'.- N o o -n ~"'n rl1r: ~ur-r~ :tj C1' i:2!~? ;::'") (.c::; ")"-r{t ,.:J -;~~ "11 :< ""CJ -l,' -. L:: <'-' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-02079 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS KRUEGER KATHERINE L 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 , to wit: KRUEGER KATHERINE L but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of LEBANON County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On June 30th , 2005 , this office was in receipt of the attached return from LEBANON Sheriff's Costs: Docketing Out of County Surcharge Dep Lebanon Co Postage 18.00 9.00 10.00 53.60 .74 91. 34 06/30/2005 THOMAS PULEO :o~~~/ Sheriff of Cumberland County Sworn and subscribed to before me 'f<,. q this <. - day of oR) <2,,"tJ{ A.D. C)'leU- () n"jP. i ~ Prothonotar In The Court of COJllmon Pleas of Cumberland County, Pennsylvania ABN AMRO Mortgage Group Ine VS. Katherine L. Krueger No. 05-2079 civil Now, June 23, 2005 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .r~~-t> Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ MORTGAGE FORECLOSURE COMPLAINT No. 05-2079 ABN AMRO MORTGAGE GROUP, INC. vs. KATHERINE L. KRUEGER STATE OF PENNSYLVANIA COUNTY OF LEBANON } } SS: THOMAS I. PULEO, LLC Thomas I. Puleo, Esquire 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 (Return to Cumberland County Sheriff) Docket Page 22299 William F. Moh!, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within MORTGAGE FORECLOSURE COMPLAINT upon KATHERINE L. KRUEGER, the within named DEFENDANT, by handing a true and attested copy thereof, personally to her on June 28, 2005 at 8:03 A.M., at 104 Stone Lane, Palmyra (South Londonderry Township), Lebanon County, Pennsylvania, and by making known to her the contents of the same. Sworn to and subscribed before me this 28th day of June, 2005 r1. 0. .t>",~ Notary Public 01 MHAL SE.~L KIM8ERL Y A, BROWER. Notary p'j~lic City If Leban,n, L!bancn County. Pa, M CIl"ll\issi.n b m O"!ll\Q!r 17, 200& SO ANSWERS, ~1:/Z(4 DEPUTY SHERIFF @ /jJ~iL'~~Q- SHE IFF @) SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced Costs paid on 06/27/05 Check No. 2416 Amount Costs Incurred: Amount Refund: Check No. 17362 Amount $100.00 $ 53.60 $ 46.40 All Sheriffs Costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriffs fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20,1911, P.L. 1072 II , THOMAS 1. PULEO, LLC II By: Thomas I. Puleo, Esquire II Identification No, 27615 660 Sentry Parkway, Suite 210 Ii Blue Bell, P A 19422 (610) 941-3600 II II II I' I ,I II 1\ II II II ]1 I I II I II II \ II II I Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INe. v, : No. 2005-02079 Civil Term KATHERINEL,KRUEGER PRAECIPE FOR JUDGMENT Enter judgment in favor of the Plaintiff and against the Defendant(s) for want of an answer and assess damages as follows: Principal Interest from 12/1104 to 8/3/05 Late charges accrued thru 8/3/05 Escrow deficit (taxes and insurance) Attorney's fee (5%) Title information certificate Total $77,] 99.33 3,382.50 133,05 1,325.12 3,859.97 325,00 $86,224,97 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certifY that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after t default occurred and at least ten days prior to the date of the filing of this praecipe. opy of the is attached, Pa,R,C.P. n7,I J TOMAS 1. P EO, ESQUIRE ttorney for Plaintiff AND NOW P (-i j "-I ,2005, Judgment is entered in favor of plaintiff and against defendants and damages ass ssed as per the above certiticatio: ~ proth~~ ' /'" THOMAS I. PULEO, LLC By: Thomas I. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 ~@G9W Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC, v. : No, 2005-02079 Civil Term KATHERINEL.KRUEGER To: Ms. Katherine 1. Krueger 104 Stone Lane Palmyra, PA 17178 Date of Notice: July 19,2005 NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237,1 IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON ALL Y OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY AND OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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, Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 , - AVISO IMPORTANTE A: Ms, Katherine 1. Krueger 104 Stone Lane Palmyra,PA 17178 FECHA DEL A VISO: USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMP ARECENCIA ESCRIT A POR SI MISMO 0 A TRA YES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENT ADO CONTRA USTED, A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE A VISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUY A SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORT ANTES, USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATEMENTE, SI USTED NO TIENE UN ABOGADO, LLAME 0 VA Y A A LA SIGUIENTE OFICINA. EST A OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ~~ >t 1; r-' C) \) CO:? ~ .. ..:.> -n \j ,~._r\ ~ ~ - ~ -J ~ -.., \ - , -J \) r-- .' ).- ~ - ~, " =E: ~ ~ ( ) [" r- .-:::- _c.. ---- .,---------- - THOMAS 1. PULEO, LLC By: Thomas 1. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PAl 9422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC, v. : No, 2005-02079 Civil Term KATHERINE 1.. KRUEGER AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS, COUNTY OF MONTGOMERY THOMAS 1. PULEO, being duly sworn according to law deposes and says 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; That Katherine 1.. Krueger is over 21 years of age, resides at 104 Stone Lane, Palmyra, Pennsylvania, and is employed by/as unknown. SWORN TO AND SUBSCRIBED BEFORE ME THIS 19th DAY OF July, 2005. ,j r:. DJuHU6~ !~ NOTARY P BLrC " :'"~' f"-=~l.XSYL'_r,' ,<,r,\RV,L SEAL ,.;~,/) 1.\ \!,'~~jE" Notary Public ~'Vrl\1.p8::' [I,,<! r\AontgomefY County My C?~::-(~',::: ;_:"~'"T::rHfes August 1,2005 ----.-' . COMMONWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP, INC., Plaintiff, COURT OF COMMON PLEAS v, NO. 2005-02079 Civil Term KA THERlNE L. KRUEGER, Defendant(s). PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $86,224,97 INTEREST FROM 8/4/05 @ $14.17 per diem $ COSTS TO BE ADDED $ 207.54 August 2, 2005 1\:J ';r 'N *'- ( \J - ~ ...Q~ --0 ~t; lJ 'i -';l. ~ c - , . g: 1l c- o. Vl () Of w ~ () c' V) \) -l::. C) -.t () ~.. .' C C- O -I":; ~ () C> I , ::;1 - ~ I::::l -0 r'l~ I \ +- ~ () \ I -.J CY ?-- i.r - ~ r ~ r- , ::: , - , .... ~ - , ~ [, - - , ,- - - - - , -... t,. - . + ~ ~ r-- . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2079 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 KATHERINE L, KRUEGER (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 (5) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $86,224.97 Interest FROM 8/4/05@$14.17PERDIEM L.L. $,50 Atty's Corum % Due Prothy $1.00 Other Costs $207,54 Atty Paid $210.Q4 Plaintiff Paid Date: AUGUST 4, 2005 CURTIS R, LONG (Seal) ProthO~ [} ~ ---Jl.y: a-,. (J ~ ..4.-' 4..~ Deputy REQUESTING PARTY: Name THOMAS I. PULEO, ESQIDRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BILL, P A 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court ID No, 27615 THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO. 200'5-02079 Civil Term v. KATHERINE L. KRUEGER, Defendant AFFlDAVIT UNDER PA. RCP RULE 3129 THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure 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 257 West Baltimore Street, Carlisle, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Katherine L. Krueger 104 Stone Lane Palmyra, P A 17178 2. Name and address of each Defendant named in the judgment: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None 4. Name and address of the last recorded holder of every mortgage of record: ABN AMRO Mortgage Group, Inc., Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 MERS P. O. Box 2026 Flint, MI 48501 5. Name and address of every other person or entity which has any record lien on the property: None 6, Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth ofPA Department of Public Welfare P. O. Box 2675 Harrisburg, P A 17105 Tenant in Possession 257 West Baltimore Street Carlisle, P A 17013 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: August 2, 2005 TOMAS 1. PU 0, ESQUIRE Attorney for Plaintiff THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff v. NO. 2005-02079 Civil Term KATHERINE L. KRUEGER. Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine L. Krueger 104 Stone Lane Palmyra, P A 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of$86,224.97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you, The Sheriff's Sale will be conducted on Wednesday, December 7, 2005, at 10:00 A.M" Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc, the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stoV 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 below 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriff's Department at (717) 240-6390. 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 bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriff's Department at (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 had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriff's 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 sheet is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 170 J3 (717) 240-6200 DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90.22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (9] .10) feet, more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-2]-0320-540 THOMAS I, PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas l. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff v. NO. 2005-02079 Civil Term KA THERlNE 1. KRUEGER, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine 1. Krueger 104 Stone Lane Palmyra, PA 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $86,224.97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you. The Sheriffs Sale will be conducted on Wednesday, Decemher 7, 2005, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriff's Department at (717) 240-6390. 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 bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriff's Department at (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 had 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of Sheriff's 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 sheet is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 2ro-6200 DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90,22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (91.10) feet, more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540 Tro'lOMAS 1. PULEO, LLC '660 Sentry Parkway. Suite 210 .. Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff : NO. 2005-02079 Civil Term v. KATHERINEL.KRUEGE~ Defendant AFFIDAVIT OF SERVICE I, Lucy Fuentes, Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordi~'try mail a Notice of Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on theJ?l!Iday of ~kr, 2005 as evidenced by the U.S. Postal Service Certificate of Mailing (Form 3817), which]s attached hereto as Exhibit "A": Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Commonwealth of P A Department of Public Welfare P. O. Box 2675 Harrisburg,PA 17105 MERS P. O. Box 2026 Flint, MI 48501 Tenant in Possession 257 West Baltimore Street Carlisle, PA 17013 >1/ / /' #- /t.- _' Cf Lucy Fuentes egal assistant to Thomas 1. Puleo tt:c SWORN TO AND SUBSCRIBED BEF~ME THIS.:2iJ...-frAY OF(j~i-(1.../ ,2005. ~t-1<~ NO ARY PUBLIC C_MONWEALTH OF PENNSVLVAHIA NOTARIAL SEAL LISA A, KANE, Notary Public Whilpain Twp" Montgomery County Mv Commission Explfes AUQust 29, 2009 11:,',111"1 I' "']" .11 I/'.',,'!,:i 1:1 ..... ,.1)1,' .' I" I II I'" ,I',I!i!I, li,'li 'I, I,l, "'" 'I, I~ "l!' , 'f" :""'t' 111~ ,j II .~: ,I. Ii 'IIi" .. ,<; :~,~;i: r- -i ,,') 0 -q !~ ,-- :-,J !f.,." ~~3 ,;):) ~ -- I,'i 1\_~ g>g- ")N:::j~E lJ... ....""tl :-" ~' ':..) ~~ g: o ~:j: IU C) ~:~, I.,) (.....I~' .:t IS',f;::! ,;~ :' !i~ ::;.~ .~_." 1::1 ".1 "i (:::1 ::j: ::~ t9 :) U'1 1".1 I'.) '!~.J (":' '::) '~"J '<'" c :0-1 ~~ ~- <;'Z i!.~ ~g ,,- ~gQ. -" g- i'r~ ~0 7J ii i: c ~ CT . 0 0 3 ." ii' i 0. !l ~ 'i ~ ~ i -~ ;; '" !l OJ !l: .. 0 a .. . 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Ql !!- "s: ~o:o 0 :T:;, LJI CD:7 l~9:~~~,~ ~5"g.s:_^ IQ ~"U i~ b> " ~ c."'Q :;;0. 0 !!. s:: 0 :D' !e. - l>> '0 ~,~ !:: i ~ i' -'-::J r:::: _ l~-li OJ; CD r-" r::::::J CT ~ 2 0- ~ ~ <5" -. !!.~ Q li~ 0 2' 0>0> c R!:; ~~ ~::;:)( "'" ~ ggs- o~ II> 05. ~ !!.Ql3 ~ 80'0 II> -,. " ~"~~ ~:O "- ~~ ~' Iii' oS"::;: ~;n lit ~g:" ~'" 0 iir::.li ~ 0-00. ~. :xJ ;="~ ~'" " <> ~fh~" ~I - :0 :om ~ ~ 30 " ~ ~:- "' ... ~ . co (,~ <--' .--::-:':J ~,l; ~:3 OJ ~ '- ~-', L,) (..0 - COMMONWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP, INC., Plaintiff, COURT OF COMMON PLEAS NO, 2005-02079 Civil Term v. KATHERINE L. KRUEGER, Defendant(s), PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $86,224,97 INTEREST FROM 8/4/05 @ $14.17 per diem $ COSTS TO BE ADDED $1,066.15 ~jcl TljelMAS 1. PULI16, ESQUIRE Attorney for Plaintiff ?() ~ r- 1( 0 ~ \ ~ - J:: -I-- ~ r "-> \) ~ w ~ -.:{ ~. --" ~ + ~ ~ P-. -- ~ \) "Q ~'l f' ..... "" 15 c...., "- -0 h \) r- :" -:tl .l-1 :- 9- C> -- c () "'1 r- w ~ () v, \) C- O - .t 0 0 -- I I c~.j ~ I ! 0 ;V r" , -- , ::: -- :. ~ ::: ~~ , .. ':: ::: ... ::: .' ... (~ , - ,'" CA.J -1-_ ,j - ::. - - - - - .\rfZ - - IN THE UNITED 3TAmS BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA In re: KATHERINE LYNN KRUEGER : Chapter 7 Debtor. : Bankruptcy No, I -05-bk-07462- MDF ABN AMRO Mortgage Group, Inc, v, KATHERINE LYNN KRUEGER ORDER AND NOW, upon consideration of the Motion of ABN AMRO Mortgage Group, Inc, for relief from stay pursuant to I I U.S.c. Section 362, and good cause having been shown, it is ORDERED that the automatic stay is terminated as to Movant which may proceed to enforce its mortgage by foreclosure and sheriffs sale of the premises 257 West Baltimore Street, Carlisle, Pennsylvania, and exercise any other rights and remedies it has under the mortgage, Bv tilt C0101. .' , This electronic order is signed and filed on the same date. Dated: December 20, 2005 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2079 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 KATHERINE L. KRUEGER (I) 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $86,224.97 Interest FROM 8/4/05 @ $14.17 PER DIEM L.L. Atty's Cornm % Due Prothy $1.00 Other Costs Atty Paid $1,066.15 Plaintiff Paid Date: JANUARY 10, 2006 (Seal) By: Deputy REQUESTING PARTY: Name THOMAS I. PULEO, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court ID No, 27615 , THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas l. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO, 2005-02079 Civil Term v. KATHERINE L. KRUEGER, Defendant AFFIDAVIT UNDER PA, RCP RULE 3129 THOMAS I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure 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 257 West Baltimore Street, Carlisle, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. I, Name and address of each Owner and/or Reputed Owner: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 2, Name and address of each Defendant named in the judgment: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None " 4, Name and address of the last recorded holder of every mortgage ofrecord: ABN AMRO Mortgage Group, Inc" Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 MERS, as nominee for Irwin Union Bank & Trust Company P. 0, Box 2026 Flint, MI 48501 5. Name and address of every other person or entity which has any record lien on the property: None 6. Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth ofPA Department of Public Welfare P. 0, Box 2675 Harrisburg, PA 17105 Tenant in Possession 257 West Baltimore Street Carlisle, PA 170B 7, Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904 relating to unsworn falsification to authorities, Date: January 4, 2006 T AS 1. PULE ,ESQUIRE ttorney for Plaintiff THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC" Plaintiff v. NO. 2005-02079 Civil Term KATHERINE L. KRUEGER, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine L. Krueger 104 Stone Lane Palmyra, P A 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $86,224.97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc, against you, The Sheriffs Sale will be conducted on Wednesday, June 7, 2006, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due, To find out how much you must pay, you may call (610) 941-3600. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, . 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 the Cumberland County Sheriffs Department at (717) 240-6390, 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 bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Department at (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 had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs 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 sheet is posted, 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ----.,-- , I DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90,22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No, 255 West Baltimore Street, ninety-one and ten one-hundredths (91.10) feet, , more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540 ----Y-. I' ,~ DESCRIPTION ALL THA T CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West BaltimoreStreet, ninety and twenty- two one-hundredths (90,22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (91,10) feet, , more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540 ("~ ~ , --1 -'1"" C) -^.~ , , C~'. , , THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff v. NO. 2005-02079 Civil Term KATHERINE L. KRUEGER, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $86,224,97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you, The Sheriffs Sale will be conducted on Wednesday, June 7, 2006, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc, the back payments, late charges, costs and reasonable attorneys' fees due, To find out how much you must pay, you may call (610) 941-3600. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, , i 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 below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RlGHTS EVEN IF THE SHERlFF'S SALE DOES TAKE PLACE, I. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriffs Department at (717) 240-6390, 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 bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Department at (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 had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs 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 sheet is posted. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 T DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251,21) feet West of the Northwest corner of West Baltimore Street and an unnamed public aJley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90,22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16,27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (91.10) feet, more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540 :'" T DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90.22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (91.10) feet, , more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcell! 04-21-0320-540 c: 'J :"'1-\ :.=J \;-1 r"::: C) C:.: ABN AMRO Mortgage Group, Inc, VS Katherine 1. Krueger In The Court Of Common Pleas of Cumberland County, Pennsylvania Writ No, 2005-2079 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Katherine 1. Krueger, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. Lebanon County Return: David A. Heath, deputy Sheriff, being duly sworn according to law, deposes and says that he served the within Real Estate Writ, Notice of Sheriffs Sale and Description upon Katherine 1. Krueger, the within named defendant, by handing a true and attested copy thereof, personally to her on September 21, 2005 at 4:40 pm, at 104 Stone Lane, Palmyra, Lebanon County, Pennsylvania, and by making known to her the contents of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 11,2005 at 2:15 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Katherine 1. Krueger located at 257 West Baltimore Street, 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: Katherine 1. Krueger, by regular mail to her last known address of 104 Stone Lane, Palmyra, P A 17178, This letter was mailed under the date of October 06, 2005 and never returned to the Sheriffs Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Thomas Puleo, Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Law Library Prothonotary Mileage Certified Mail Levy Surcharge 30.00 16.54 15.00 15.00 ,50 1.00 4,80 2.33 15.00 20.00 Out of County Lebanon County Postage Law Journal Patriot News Share of Bills 9.00 100.00 .74 305.00 287.81 20.89 $843.61 Sworn and subscribed to before me This 'r;~~ day of 2005, A.D. r,/)tJ cJ,J 5J~R') Oft /7), :)0 II J' So Answers: /~ ~L, , R. Thomas Kline, Sh;t'r By\rO~SwJJ, Real Estate Sergeant , I THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO. 200'5-02079 Civil Term v. KATHERINE 1.. KRUEGER, Defendant AFFIDAVIT UNDER P A. RCP RULE 3129 THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure 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 257 West Baltimore Street, Carlisle, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Katherine 1.. Krueger 104 Stone Lane Palmyra, PA 17178 2. Name and address of each Defendant named in the judgment: Katherine 1.. Krueger 104 Stone Lane Palmyra, PA 17178 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None I 4. Name and address of the last recorded holder of every mortgage of record: ABN AMRO Mortgage Group, Inc" Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 MERS P. O. Box 2026 Flint, MI 4850 I 5. Name and address of every other person or entity which has any record lien on the property: None 6, Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Commonwealth ofPA Department of Public Welfare P. 0, Box 2675 Harrisburg, PA 17105 Tenant in Possession 257 West Baltimore Street Carlisle, P A 17013 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorities. Date: August 2, 2005 THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff v. NO. 2005-02079 Civil Term KATHERINEL,KRUEGER, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $86,224.97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you, The Sheriffs Sale will be conducted on Wednesday, December 7,2005, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. I 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 below 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 the Cumberland County Sheriffs Department at (717) 240-6390. 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 bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Department at (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 had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs 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 sheet is posted, 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 DESCRIYfION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed pnblic alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty- two <me-hundredths (90,22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven oue..hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety-one and ten one-hundredths (91.10) feet, more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street, Tax Parcel # 04-21-0320-540 , co u) , ,YO" LL u: - [l ~ ,..- C> I c. ,!) I :~:.) (~ L'._ ~ r= = C..' ~ THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, lNC., Plaintiff v. NO. 2005-02079 Civil Term KATHERINE L. KRUEGER, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 Your house at 257 West Baltimore Street, City of Carlisle, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of$86,224.97 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you. The Sheriffs Sale will be conducted on Wednesday, December 7,2005, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1, This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice below 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 the Cumberland County Sheriffs Department at (717) 240-6390, 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 bid in the sale. To find out ifthis has happened, you may call the Cumberland County Sheriffs Department at (717) 240-6390. 4. Ifthe amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale had 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 ofthe money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs 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 sheet is posted. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2079 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 KATHERINE L. KRUEGER (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) 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due $86,224.97 Interest FROM 8/4/05 @ $14.17 PER DIEM Atty's Comm % Atty Paid $210.04 Plaintiff Paid Date: AUGUST 4, 2005 L.L. $.50 Due Prothy $1.00 Other Costs $207.54 CURTIS R. LONG (Seal) protho;iry '-.!ly: A 0.--,.., / tl. 71zc'?/7LV~ r- Deputy REQUESTING PARTY: Name THOMAS I. PULEO, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BILL, P A 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court 1D No, 27615 .~. . ! ~ c;;;u Real Estate Sale #43 On September 08, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A c:Known and numbered as 257 West Baltimore Street, Ln M QCarlisle, more fully described on Exhibit "A" ~filed with this writ and by this reference incorporated herein. ,-L) = ~ ~= ~ate: September 08, 2005 ByJ oc:LLl,,~~tG Real Estate Sergeant . . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} S5 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and Septemher 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 25th day(s) of October and the 1st and 8th day(s) of November 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly autllOrized 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 oUhe 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 . ~"~JJ~~..................... b~~~~\&IiiIber 2005 A.) Terry l. Russell, Notary Public City of Harrisburg. Dauphin County My Commission Expires June 6, 2006 ~'.0;r::; NOTA{Y PUBLlC- My commission expires June 6, 2006 REAL ESTATE SALE No. 43 Writ No. 2005-2079 Civil Term ABN AMRO Mon_ Group, Inc. Vs KatherIne L. ~ AIty: Thomas I. Puleo OESCRIP1l0N All THAT CERTAIN lot of ground with the improvemeDts thereon erected. situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and de&:ribed as follows: BEGINNING at a point on the North side of West Baltimore Street, two hundred fifty one and twenty one hundredths (251.21) feet West of the Northwest corner of West Baltimore SIreet and an unnamed public alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty five one-bundredths (16.25) feet to a point, thence Northwartlly, through the centerline of a panition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty two one-hundredths (90.22) feet, more or less, to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty seven one-hwIdredtbs (16.27) feet 10 a poinl; tllence Suuthwardly through me center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street, ninety one and ten one-~ (91.10~ CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: October 14, 21, 28, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ( ( ry tt~ (~ L'sa Mane Coyne, 1tor SWO TO AND SUBSCRIBED before me this 28 day of October, 2005 ~7f~~)i9K~!:~1~ I NOT;\RI;\L SEA: V I LOIS E. :::NYClER, Notary P'Jt;\iC 1 t Cl~dis18 Bora. C~lmberlrlriG Cou:W,l I f ( . i-",'I- r-. '/'F~:1 ~ 1 ~;-;~V \~;(tn~L\\SSIf.\n ' ",-~ i.,/.",.,.I. t ~ ,_..,.~.-",--..._.,,^." ",., .... ~~-:~<_."'..,,....;."" ..,.....,. . . REAL ESTATE SALE NO. 43 Writ No. 05~2079 Civil ABN AMRO Mortgage Group, Inc. vs. Katherine L. Krueger Aity.: Thomas I. PuJeo DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected. situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEG1NNING at a point on the North side of West Baltimore Street, two hundred fifty~one and twenty- one hundredths {251.21) feet West of the Northwest corner of West Bal- timore Street and an unnamed pub- lic alley; thence Westwardly along the North side of West Baltimore Street, sixteen and twenty-five one- hundredth (16.25) feet to a pOint; thence Northwardly, through the centerline of a partition wall between the premises herein described and premises No. 259 West Baltimore Street, ninety and twenty-two one- hundredths (90.22) feet, more or less. to a point on the Southern side of an unnamed public alley; thence Eastwardly along the same sixteen and twenty-seven one-hundredths (16.27) feet to a point; thence Southwardly though the center line of a partition wall between the premises herein described and premises No. 255 West Baltimore Street. ninety-one and ten one-hun- dredths (91,1 OJ feet. more or less to a point. the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540. THOMAS I. PULEO, LLC .660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas L Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC" Plaintiff NO. 2005-02079 Civil Term v. KATHERINEL.KRUEGE~ Defendant AFFIDAVIT OF SERVICE I, Lisa Kane, Paralegal to Thomas I. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice, of Sale pursuant to Pa.R.c.p 3129.2 upon the persons listed below on thed,f~day ofWvv) ,2006 as evidenced by the U.S. Postal Service Certificate of Mailing (Form 3817), which is attached hereto as Exhibit "A": Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth ofPA Department of Public Welfare P. O. Box 2675 Harrisburg, P A 17105 MERS, as nominee for Irwin Union Bank & Trust Company P. O. Box 2026 Flint, MI 48501 Tenant in Possession 257 West Baltimore Street Carlisle, P A 17013 d~~~ Lisa Kane, Paralegal to Thomas I. Puleo SWORN TO AND Str.~SCRIBED BEF ME THIS.t, '" DAY o V ,20. 'f.' ", .....-----------_.__._-~ for Accounta.ble Ma.il -------------------.-- - -'- .,.,. ,..'" ~ , 'b:~ '" \ ~- , I !Ie ... ~\ ~ ~g" .." ~t ~ " .:< ~ IE ... ~ ''Z, ~\ . i9.. ." \ ~ .... .,..J. ~ ..,J.. ~ (..) f\) ..J. 0 \ i~~ t ~; i \ ~ \ <a. ~ t \ ~ !l m :2 ~ \ i !t i ii~ti\~ ~ t~~\~~i : ,~!~\H\ i l~in~ I \~\\~ . h\~i\\ \\ti\\~ ~~\\l\~ \Jl~~i ~~~iU i~\~~\ ~ hii'l\i \ ~iil't\ \\~\\\ i !g,,\~\i 1 . rtl\ ~ ~,h \~ I \~ ~~_. , h:\h t ~ ~ ~ ~ ~ it' t..a. \' I-- l\ .- co O:J -J (j) U\ -~ f9[i ..~ Il'~ ,.. t;l' i~~\ :: :,. ~ 1- c: \ i4{\~ 7~(.: I \i \ ~ ~~, e-. C"'.., ~ ~l! Iii ~~ ii ft.... . '" g' ~;~ >,,0 --'" ~i\. " g \ft It ~ [:.~Ob ()_c c; ~ 0 ~ S' \!\ VI ~1 0 ;.i.l~a ~1-g~ 'Z, olSa ;:u.......~ 'i ~ ~ ~ . ~ ';:' b' ~ ~~;:~~ ~~ ~ ~ i ....\Jl~ .-0 (.,..... .- ... >'0" ...)...o~ ;, ::. "'.;: 0 rp "', o' t :: S:.. - ~ 1::1::l . :, ~.:; VI" '" u> l!1 J,~) ~ o~ " t:l\ l!!. ::h 0 6- '" " 'a \ - ~ ~ '- ~~g ~i~\ """".... >~:..., ~~~ \:3~ t\ ~.r ~t'" " (l '" - o ." ~ ~ \ %\\~ rn~ ~ i;t~- ~ t\\\ ~\\C o\:!> ~ r1~ ~ ~ ~~ ~ \ t\ li~\,' i - \ ",;I - ~~ g ,,~ C"- "..10..,1;1 ~A.' I "' '>\ \\\ \,~ ~ ".t '.: \\~~, ~ \' ,~\~ ,\ \\\0 OJ)' . . i I"" :~ :a ;;.\ -;.- ~ tt-.~ tv\,";' co v '~ -" t('. 'ol')N ..ll .J.... (:? \~, NO .t" r,) 0-. >.t:: :Jl ~, Q ~ -oi~r nIl ~ -7 "", Zl':~ '~i i,:,~, t~, 2 ';;1. ,"" "'" :;!1:. ")>7 ""'" . ~ ~ rn?; :\"O ~ QiQ. l" -('l. 6(') ~ '~7 rn ->>' Q "" ~ '-r"-::-.~. (r:f;~~::<)~ .,,( 19 ""/ t"" tt. ~'" " f!':' '\'llI/ ~~ ~~ t;_,. ,'..' ''-.!::.JY....> ..0 ., c.n - 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 ABN Amro Mtg Group Inc 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 10th day of Jan, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 2079, at the suit of ABN Amro Mtg Group Inc against Kathleen L Krueger is duly recorded in Deed Book No. 275, Page 3602. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this Ie: 1 day of ~rL~~ ' A.D. a~, () ~. '-I' , ~ "- - ~ () ,;(, tq ~ ,:~~~~ ofDceds ~ of Oeedl. Cumberllnd County, r.tsIt. PA My eo.'~.~l &pill.. File ....,at_2DIO 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 ABN Amro Mtg Group Inc 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 10th day of Jan, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 2079, at the suit of ABN Amro Mtg Group Inc against Kathleen L Krueger is duly recorded in Deed Book No. 275, Page 3602. IN TESTIMONY WHEREOF, I have hereunto set my hand /9-4 . ,A.D. rJM ~ day of R corder of Deeds Peeda. County, CaIIsII, PA ExpirM .. F"nt Monday of .IIn. 2010 .. ABN Amro Mortgage Group, Inc. VS Katherine L. Krueger The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-2079 Civil Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on March 07,2006 at 5:27 o'clock PM, she served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Katherine L. Krueger, by making known unto Renee Tambellini, adult roommate of Katherine L. Krueger, at 190 Edenderry Way, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 2:25 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Katherine L. Krueger located at 257 West Baltimore S1., 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: Katherine L. Krueger by regular mail to her last known address of 190 Edenderry Way, Enola, PA 17025. This letter was mailed under the date of April 03, 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 $40,000.00 to Attorney Thomas I. Puleo for ABN AMRa Mortgage Group, Inc., its successors and assigns. It being the highest bid and best price received for the same, ABN AMRa Mortgage Group, Inc., its successors and assigns of 7159 Corkland Drive, Jacksonville, FL 32258, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $5,500.00. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 800.00 15.00 15.00 30.00 10.00 .50 1.00 Mileage Certified Mail Levy Surcharge Out of County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 17.60 1.63 15.00 20.00. 9.00 287.00 308.00 . 19.57, 25.00 39.50 $1,643.80 / ~ ,.,/.J1!O'w ?~,,~~ R. Thomas Kline, Sheriff BY \l CQq SVvlLR Real Estate Sergeant ~ o1JD~ 30' 'D ) lJ . tJe. j'l9al J ,Zu. J f6 8rl , . 1 ," THOMAS 1. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO. 2005-02079 Civil Term v. KATHERINE L. KRUEGER, Defendant AFFIDAVIT UNDER P A. RCP RULE 3129 THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure 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 257 West Baltimore Street, Carlisle, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Katherine L. Krueger 104 Stone Lane Palmyra, PA 17178 2. Name and address of each Defendant named in the judgment: Katherine L. Krueger 104 Stone Lane Palmyra, P A 17178 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None 4. Name and address of the last recorded holder of every mortgage of record: ABN AMRa Mortgage Group, Inc., Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 MERS, as nominee for Irwin Union Bank & Trust Company P. a. Box 2026 Flint, MI 48501 5. Name and address of every other person or entity which has any record lien on the property: None 6. Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Commonwealth of P A Department of Public Welfare P. a. Box 2675 Harrisburg, P A 17105 Tenant in Possession 257 West Baltimore Street Carlisle, P A 17013 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: January 4, 2006 T AS 1. PULE , ESQUIRE ttorney for Plaintiff PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7, 14,21,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. - SWORN TO AND SUBSCRIBED before me this 21 day of April. 2006 ~r~MJ j u . "'.I ;-"".. ~.~.~ ,~,,, , '". ,'. ., ~ F ! , ',' i ~ ~i REAL ESTATE SALE NO. 21 Wrtt No. 2005-2079 Civil ABN Amro Mortgage Group, Inc. vs. Katherine L. Krueger Atty.: Thomas Puleo DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Third Ward of the Borough of Carlisle. Cumberland County, Pennsylvania, bounded and descrtbed as follows: BEGINNING at a point on the North side of West Baltimore Street. two hundred fifty-one and twenty- one hundredths (251.21) feet West of the Northwest corner of West Baltimore Street and an unnamed public alley; thence Westwardly along the North side of West Balti- more Street, sixteen and twenty-five one-hundredth (16.25) feet to a point; thence Northwardly. through the centerline of a partition wall between the premises herein de- scrtbed and premises No. 259 West Baltimore Street, ninety and twenty- two one-hundredths (90.22) feet, more or less, to a point on the South- ern side of an unnamed public al- ley; thence Eastwardly along the same sixteen and twenty-seven one- hundredths (16.27) feet to a point; thence Southwardly though the cen- ter line of a partition wall between the premises herein described and premises No., 255 West Baltimore Street, ninety-one and ten one-hun- dredths (91.10) feet, more or less to a point, the place of Beginning. SAID premises being known and numbered as 257 West Baltimore Street. Tax Parcel # 04-21-0320-540. r " THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #21 S~~;;;~~';';;d'~~~~'"''''''''':''''''''' Terry L Russell, Notary Public o of Harrisburg, Dauphin County M Commissio "Expires J e 6, 2006 a' nofNoIIUIl''' NOT Y PUBLIC My commission expires June 6, 2006 .. CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 REAL ESTATE SALE No. 21 WItt No. UTT ~,... CMT.... ABN Amro -'J .. Group, Inc. Y8 KatherIne L Krueger AtlorMy1bamlla'PuIeo DESCRIPTlOH ALL mAT CERfAIN lot of ground with the improVemenlS ~,situaIe in die Thin! Ward of the ~ of Carlisle, Cumbedand County, Pamsylvuia, bouIIded;md described as follows: BEGINNING ala point 011 die North side of West Baltimore S1Ieet, twd huDdmdfifty-oue and twenty-ooe 1Iundrdls(15111) feet West of the Northwest COl'JIl:i of West Baltimore Street and an unnamed public aDey; thence westwardly along the North side of West Ballinlme Street, sixteen and twenty~five one b.und1edth (1625) feet to a point; thence nodhwardly, 1hroush the centedine of a partition wall between the premises berein described and pmnises No. Z59 West Baltimore Street, ninety and twenty:.two one-buDdredtbs (9012) feet. IIIOle or less, to a point on the Southern side of au. qJIIIlIIIIldpublicaUey; thence Eastwardly aloog the same ~ aDd twenty- seven ~. (1627)' feet w a point; thence SOuthwaIdly tbongh the cemer line of a partition wall betWCleIllhe pnllIIiaes herein des- cribed and premises No. 155 West BaIlitoore Street, Dinety-ooe aod teI1 ~ (91.10) feet, IIlOOl or leSs ID a point, !be place of BEGINNING. SAID plIIIIiIes ~'lI--- ~ as 1ST WoIt........ s.et, TAX PAIEB.'..21.....S40 .