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HomeMy WebLinkAbout05-2888 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLIlBECK, ./R, ATTOR"EY I.D, #16132 SUITE 5000 - MELLO" l'iIlEPE!\IlENCE CENTER 701 MARKET STREET PIHLAIlELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T I3Ai\iK F/KlA ALLFlRST BANK 1100 Wehrle Dril'C 21ld Floor WiJlimnS\ille. NY 14221 IN THE COURT OF COMMON PLEAS OF CUlllberl'lIJcl COUNTY Pjail1/if! CIVIL ACTION - L\ \V vs. NORMAN W. DANIELS Mortgagor and Real Owner 412 4th Strcet New Cumberland, PAl 7070 Defendant ACTION OF MORTGAGE FORECLOSURE Term OS' -anf;J c!./u;( No. ~ CIVIL ACTION: MOFlTGAGE IfmrJ I=Ojl\ECLOSURf 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 atier the Complaint and notice are servcd, by entering a written appearance personally or by attorney and tiling ill writing with the court your defenses or objections to the claims set fm1h against you. You are warned that if you tail to do so the case may proceed without you and a judgment may be entered against you by the Comt without turther notice 1t)!. any money claim in the Complaint of for any other claim or reliefrequested by the Plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE, 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 YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PA 17013 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DlAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN EST A DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTlFICARIO, DECIDIR A FA VOR DEL, DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ES.TA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE PAPEL A SU ABOGADO ENSEGUIDA, SI USTED NO TIENE UN ABOGADO, V A Y A 0 LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVIClOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES I:\C 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOC]A nON 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Rcsourccs available for Homcowners in Foreclosure ACT NOW! Even though your Icnder (and our client) has filcd an Action of Mortgage Foreclosure against you, you still may be ablc to SA VE YOUR HOME FROM FORECLOSURE. I). Call an attorney. For referrals to a qualified attomey call eithcr of the following numbers: 717-243- 9400 or . 2), Call Pennsylvania Housing Finance Agency at 800-342-2397 for a counseling agency in your neighborhood. 3). Visit HUD'S website ~y\V_\y.hllCi.lo\(J'y/.Qm.ces/ill;gLsfh~c.;on/econ.cfin for Help for Homeowners Facing the Loss of Their Homes. 4). Call your lender 716-630-4924 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to requcst the amount to bring the account current, or payoff the mortgage or rcquest a Loan Workout 1 Home Rctention Package. Call Carol at 2]5-825-6329 or Nancy at 215-825-6358 or fax 215-825-6429 or 215-825-6458. . The figure and/or package you requested will be mailed to the address that you request or fllxed if you leave a mcssage with that information. The attorney in charge ofollr firm's Homeowner Retention Depmiment is Edward Sparkman who can be reached at 2] 5-825-6318 or Fax: 215-825- 6418, Please reference our Attorney File Number ofMTB-0081. Para informacion en espanol puede communicarse con Loretta aI215-825-6344, This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T BANK FIKIA ALLFIRST BANK, 1100 Wehrle Drive, 2nd Floor Williamsville, NY 14221. 2, The name and address of the Defendant is NORMAN W. DANIELS, 412 4th Street, New Cumberland, PA 17070, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On January 22, 200 I mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to M&T BANK F/K/A ALLFIRST BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1670, Page 391. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure IOl9(g) which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record, 4, The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A". 5, The mortgage is in default because monthly payment of principal and interest upon said mortgage due November 18, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 10/18/2004 through 05/3112005 at 9,0400% Per Diem interest rate at $15.63 Reasonable Attorney's Fee If the Mortgage is reinstated prior to a Sheriffs Sale the Attorney's Fees may be less than this amount based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff reserves its right to collect Attorney's fees of up to 5% of the remaining principal balance ($3,155,96) in the event the Property is sold to a third party purchaser at Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Late Charges from 11118/2004 to 05/3112005 Monthly late charge amount at $74.09 Costs of suit and Title Search $63,119,19 $3,280.33 $1,250.00 $469.73 $900.00 $69,019.25 7. Plaintiff is not seeking a judgment of personal liability (or in personam judgment) against the Defendant in this Action but reserves it's right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8, Notice ofIntention to Foreclose and a Notice of Homeowners' Ernergency Mortgage Assistance has been sent to Defendant by Certified and regular mail, as required by Act 160 of 1998 of the . Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $69,019.25, together with interest at the rate of$15.63, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: FERTY & McKEEV. R B : JOSEPH A. GOLD ECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Barbara Maute as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief, I understand that false statements therein are made subject to the penalties of 18 Pa, C,S, 4904 relating to unsworn falsification to authorities. ~ -/ - OS: Date: 1&12mr\l\~ir\/AuW / Barbara Maute Assistant Vice President p,~lii6it Yl F'RO~l ,u~""'"" rEb il{'jii~~ entitii,'''" " M' MADE THE \- of our Lord","" thou.a1ld nln, hundred Jon F. LaFaver Executcrr under Ihe Last Will and Testam,mt of iliRoY Sl'.EIGARr, deCeMed /<It, of East 1'enru!boro T<:1.rl$hip, Cl..<rberlillld County, Pennsylvan:1.a, day f ~~~ eighty (1 80) in th, lie.,. by and betw~€" ,..- .' AND GRANTOR OOm\NW.ll\NTEtS of the Borough of New Ctnt>erland, Onberland COOnty, PennsylvaxUa, GRANTEE , , WHEREAS; th, B4id Leroy Swei!l"rt ...... veBud in his lif.Um. with title to m-em,iseB h oiTUJfter dllBcrib,d, aitfUlle in the Borough of New Qmberland, , C""n/Ji of o..nberland , C"",monweouA. of Pentl8ylvanu.; and WHEREAS, the said u.roy 9.oeigart died teswt, On Mtrch 4, 1980 I . and his Last Will and Testament WCUl duly ptob~ted in tho RegiBler 01 Wills Olfice in the County of <Unberland ; and WlIEREAS, tho .aid real ..141s MrriTU1.ft.,. de.mb.ri WlU 'Wt epecifiMlly devhled, a"d tho .aid Jon F. LaFaver I " , I' 'l"4li/kd lU ,,,,.,,,,t or of tit, LatJt Will and Te.ta 'lenl; NOW THEREFORE, This Indenture Witnosoeth thai he .aid , Jon F. , EXeCUIOr llB aforeoaid, for a1ld ill oll1l8ideration of tM SUm of 'I\;mCY-one usand and 00/100--_______________ ---------------------------------($21,000.00)___________-.---------------Dol~r., lawful m<m"ll of tll, United States to him in 1/4 pow. bli 110, said No>;man W. lXm1.els M an bef.r. the B1U1'4li"g and d6live1'lJ heroof, t^" receipt wh6Tsof is hereby ackMwledged, has 0 ted, b.roalned, Bold, all...ed, releMed and conjl....ed. a"d bll IIl..e present.. bV virtue of 0.. po",er nd authorily In him V.sted bll the Probate, E.tates a1ld Fi<lu.ciari.. Cod. of th. CmnmM "ealth 01 Pe-n7Ul1Jlvania, doea u"""t. bargain, s<.1I, alim, releu.se a.ut contl"", unto the said 0= W. Itlntels, his heirs and aSsig1l1l, All 'IHAT lot or piece of land situated in the Eorough of New D.nIDer1and, Cotney of . rland, and State of P=ylvania, being Lot V. Block "J", in t.he General Plan 0 George W. Buttorff's Addition to New CUnberland, as reCOl;'ded:ln the Recorder's Office of CUnberland, County in Book "N", Voll.llle S, Page 500. said lot being <led and described as follows, BEmNNING ate. point on the South side of 1'1 Street. one hundl:-ed and ~ty..five (125) feet West fmm the Soutl_st coxner of burt:h Street and Reno Avenue, thence in a Westwardly c1iroct1.on along said },Outth S eet, t:t..'enty (20) feet to line of pro~ of Umd oS. lilprolllm'.n!: Carpany; thenc :In a Souehwardly direction along said l:lne of =perty of Land & ImpmVenent Y. one hw<lred and forty (140) feet to Ruby Awnue; thence :In an Eastwardly rectlon along said Ruby Avenue, twenty (20) feet to l:!:ne of property of l.este~Cook; thence in a Northwardly direct10n alOng said limo of property of Lest Cook, one hundred and forty (140) feet to Fourth Street:, the place of BEGINNIN::;J 0 !lAVING nlEREoF EREC'J:ED a three story frmre m",flUng house known as Nol. 412 ~OUtth Street, and a fram>. garage in the rear. . """ ' ~ I ~ \\ o,.;:t " ! /"''' P,~lii6it (B ACT 91 NOTICE DATE OF NOTICE: April 22, 2005 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose, Specific information about the nature of the default is proyided in the attached pages, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to saye your home, This Notice explains how the program works, To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE, Take this Notice with YOU when yOU meet with the Counseling Agency, The name, address and phone number of Consumer Credit Counseling Agencies serving your Count are listed at the end of this Notice, If ou have an uestions ou ma call the Penns lvania Housin Finance A enc toll free at 1-800-342-2397, Persons with im aired hearing can call (717) 780-1869,) This Notice contains important legal information, If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area, The local bar association may be able to help you find a lawyer. La notificacion en ad junto es de suma importancia, pues afecta su derecho a continuar viyiendo en su casa, Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba, Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. . Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 1 Date: April 22, 2005 Homeowners Name: NORMAN W. DANIELS Property Address: 412 4th Street, New Cumberland, PA 17070 Loan Account No,: 92218390001 Original Lender: ALLFIRST BANK Current Lender/Servicer: M&T BANK HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice, During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice, THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -If you rneet with one ofthe consumer credit counseling agencies listed at the end ofthis notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting, The names. addresses and telephone numbers of desi ated consumer credit counselin a encies for the count in which the ro ert is located are set 2 - forth at the end ofthis Notice. It is only necessary to schedule one face-to-face rneeting. Advise your lender irnrnediately of your intentions, APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one ofthe designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited, They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application, NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emer2ency Mort2a2e Assistance.) HOW TO CURE YOUR MORTGAGE DEF AUL T (Brin!!: it UP to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 412 4th Street, New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 11118/2004 thru 4/22/2005 (6 mos. at $740,94/month) $4,445.64 (b) Late charges from 11118/2004 thru 4/22/2005 $395.64 (c) Other charges; Escrow, Inspec" NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $4,841.28 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 4.841.28 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD, Pavments must be made either by cashier's check. certified check or money order made payable and sent to: ' M&T BANK 1100 Wehrle Driye 2nd Floor Williamsville, NY 14221 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!:hts to accelerate the mortl!:al!:e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments, If full payment ofthe total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!:al!:ed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay offthe mortgage debt. Ifthe lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50,00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender eyen if they exceed $50,00, Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs, If vou cure the default within the THIRTY (30) DAY period. vou will not be required to pav attornev's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE _ If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yOU still have the ri ht to cure the default and revent the sale at an time u to one hour before the Sheriffs Sale, You ma do so b a' n the total amount then ast due Ius an late or other char es then due reasonable attorne 's fees and costs connected with the foreclosure sale and an other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements 4 under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date ofthis Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale, Of course, the amount needed to cure the default will increase the longer you wait. You inay find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M&T BANK Address: 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Phone Number: 716-630-4924 Fax Number: 716-630-4914 Contact Person: Alicia Oliver EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT, * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL T HAD OCCURRED, IF YOU CURE THE DEF AUL T, (HOWEVER, YOU DO NOT 5 HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, Contact Person: Alicia Oliver Phone Number: 716-630-4924 6 PENNSYLVANIA HOUSING F1NANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYL VANIA INC. 2000 Ling1estown Road Harrisburg, P A 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 "J it - t'- J::: ~ --r:::. ~ (.:l 'Is i- ~ ~ ~ ~~ ~~ --z.. 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N ...- ~ :J:f m:!l ~ITI aY ..,6 :C~ O-'J ~"7(J on' ~ -< 8 SHERIFF'S RETURN - REGULAR CASE NO: 2005-02888 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T BANK ET AL VS DANIELS NORMAN W MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DANIELS NORMAN W the DEFENDANT at 1727:00 HOURS, on the 9th day of June , 2005 at 412 4TH STREET NEW CUMBERLAND, PA 17070 by handing to CAROL LONGNECKER, GIRLFRIEND, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 12,58 ,37 10.00 .00 40,95 ,r"~~ R, Thomas Kline "" me this .lo- day of 06/13/2005 GOLDB::~ :;,;;;: 2-c~ C~; Deputy Sheri Sworn and Subscribed to before ~. J&o:/ A,D. L~~ Q /h-,~DJ ~ I othonotary , , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T BANK FIKIA ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Plaintiff vs. NORMAN W. DANIELS (Mortgagor(s) and Record owner(s)) 412 4th Street New Cumberland, PA 17070 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 05-2888-CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor ofM&T BANK F/KIA ALLFIRST BANK, and against NORMAN W, DANIELS for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of$6 933.30, 1 hereby certify that the above names are correct and that the precise residence address of the judgment creditor is M&T BANK F/KIA ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williarnsville, NY 14221 and that the name(s) and last known addressees) of the Defendant(s) is/are NORMAN W. DANIELS, 412 4th Street New Cumberland, P A 17070; GO ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $63,119.19 Interest from 10/18/2004 through 07/1912005 $4,046.20 Reasonable Attorney's Fee $1,250.00 Late Charges $617.91 Costs of Suit and Title Search $900.00 Escrow Balance Deficit $0.00 $69,933.30 DB CK Mc l\FFERTY & Mc VER B Jose h A. Goldbeck, Jr. A omey for Plaintiff AND NOW, this day of , 2005 damages are assessed as ahove. Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, NORMAN W. DANIELS, is about unknown years of age, that Defendant's last known residence is 412 4th Street, New Cumberland, PA 17070, and is engaged in the unknown business located at unknown address. 2, That Defendant is 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 Action of Congress of 1940 and its Amendm nts. Date: =1 \ l~ I o( In the Court of Common Pleas of Cumberland Cumberland County M&T BANK FIKJA ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Plaintiff vs. NORMAN W. DANIELS (Mortgagor(s) and Record Owner(s)) 412 4th Street New Cumberland, P A 17070 No. 05-2888-CIVIL Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT, Enter the Judgment in favor of Plaintiff and against NORMAN W. DANIELS by default for want of an Answer. Assess damages as follows: Debt $69,933.30 Interest - 10/18/2004 to 07/19/2005 Total (Assessment of Damages attached) I CERTIFY THAT 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 the default occu d and at least ten days rior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 I. AND NOW ,.-} J. N,J , BANK FIKIA ALLFIRST BANK and against NORMA assessed in the sum of$69,933,30 as per the above certi - , Judgment is entered in favor of M&T IELS by default for want of an Answer and damages 0.~ Prothonotary f ~~ Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW M&T BANK FIKJA ALLFIRST BANK 11 00 Webrle Drive 2nd Floor Williamsville, NY 14221 Plaintiff No. 05-2888-CIVIL vs. NORMAN W. DANIELS (Mortgagors and Record Owner(s)) 412 4th Street New Cumberland, P A 17070 Defendant( s) TIDS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Joseph A, Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 MTB-0081 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PUJU>OSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 30, 2005 TO: NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 M&T BANK FIKJA ALLFIRST BANK 1100 Wehrle Drive 2nd Floor WiIliamsville,.NY 14221 In the Court of Conunon Pleas of Cumberland County Plaintiff CIVIL ACTION - LAW Vs. NORMAN W. DANIELS (Mortgagor(s) and Record Owner(s)) 412 4th Street New Cumberland, PA 17070 Action of Mortgage Foreclosure Term No, 05-2888-CIVIL Defendant(s) TO: NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 TMPORTANTNOTlr.F, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTIEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACf WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS 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 HIR1NG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCJES TIIA T MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 GOLDBECK McCAFFERTY &. Mc:KEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Menon Independence Center. 701 Marlett Street Philadelphia, PA 19106 215--627-1322 ~"" l -... {' 6" \'- €' ..j ~ \A 'l-> ~ ~ "'\ ~ ~" \ ~~ ~ (') ~.; ~~'-; c::::> .;:.n <- r.:.:: !.-~ <,,) N C;,? c..) UJ Goldbeck McCafferty & McKeever BY: Joseph A, Goldbeck, Jr. Attorney l.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T BANK FIK/A ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW NORMAN W. DANIELS (Mortgagor(s) and Record Owner(s)) 412 4th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. OS-2888-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 M&T BANK FiKlA ALLFIRST BANK, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jf., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 412 4th Street New Cumberland, P A 17070 l.Name and address ofOwner(s) or Reputed Owner(s): NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PENNSYLVANIA DEPT. OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name aud address of the last recorded holder of every mortgage of record: FULTON BANK 132 Old York Rd. New Cumberland, P A 17070 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 412 4th Street New Cumberland, P A 17070 1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation 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. GO DATED: Julv 19,2005 (") ~.., C) ,~ S~~ "-::'-::':r 'J Go,., c.. C". r-. r~ I" "'-t'; c.) ~.'- Cl OS-2888-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T BANK FIKI A ALLFIRST BANK II 00 Wehrle Drive 2nd Floor Williamsville, NY 14221 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW VS. NORMAN W. DANIELS Mortgagor(s) and Record Owncr(s) ACTION OF MORTGAGE FORECLOSURE 412 4th Street New Cumberland, P A 17070 Term No. 05-2888-CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT, ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DANiELS, NORMAN w. NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 Your house at 412 4th Street, New Cwnberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, December 7,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $69,933.30 obtained by M&T BANK FIKJ A ALLFIRST BANK against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: \. The sale will be cancelled if you pay to M&T BANK FIKIA ALLFIRST BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. jf 05-2888-CIVIL 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 NOT 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 price by calling the Sheriff of717-240-6390. 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 due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the 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 afterthe schedule of distribution is filed. 7. You may also have otherrights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 f Ii ~ \. , ~, r~:) ,-:.;::) <":.]'1 C) .1 :? ( I.?': I" ", N -.") (~, C:J Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T BANK FIK/A ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 Plaintiff IN THE COURT OF COMMON PLEAS vs, NORMAN W. DANIELS Mortgagor(s) and Record Owner(s) 412 4th Street New Cumberland, PA 17070 of Cumberland County CIVIL ACTION - LAW Defendant( s) ACTION OF MORTGAGE FORECLOSURE NO, 05-2888-CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certifY that I am the attorney of record for the Plaintiff in this action, and I further certifY that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. -' 'Cc"?, 'it" c~ .,. "," I'-" SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling, BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W, DANIELS TAX PARCEL #25-25-0006-45 ~ -. . 0-1 ~ \J ^" t- f' ~ L (\ \ t ~ \ t- "/t:>. - , 1-- ,-, c.. ~ f n a." ~ -. ~ >v ~~~~ . . ~ '~l.t\~:..t) \:, cs.v \ 80 ----- \.t-. , \ \ ~ ....... Vl ~ }v ~ f' ~ ~, ~ ~ " -...) 6~ 0 (:';;:1 Fn <.;..)'1 ",.) N G' J:"" PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.c.P 3180-3183 Joseph A. Goldheck, Jr. AttorneyI.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T BANK F/K1 A ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville, NY 14221 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW NORMAN W. DANIELS Mortgagor(.) and Record Owner(.) 412 4th Street New Cumberland, P A 17070 ACTlON OF MORTGAGE FORECLOSURE Defendant( s) No. 05-2888-ClVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $69,933,30 Interest from 10/18/2004 to 07/19/2005 at 9.0400% (Costs to be added) G B : Jo ph A. Goldbeck, Jr. A orney for Plaintiff ~ Ij, ~ z ~~ c:,~ 00 ~ob0 ~~~ \-,<,;,0 ~~ 7-0 o ~ '!l ~ ~ \-' 'g ';:; ~ <!, ~ "" ~ ~ ~ ~ "' :> ~ ~ c/)~ B ~O ';:; 7,oQ~<!' ~O~Q.< p~9,l 7~~ tl \i~~ o'il' % 7-~ 7- ~ '-' 6 ... ... G ~~ (;ol '" ,..,$ 0';1 ...'0 r: ~..: ,.... (;ol ~ u 1 ~ ~'+:l ';I.a ,tl,s "'~ "00 0"'" 4.~ e 1,.0 ,,~ '8'" ~ tl ",';; .. " to ;a ~ "" ..~ 0 ~~..,..-- ,e.. ~ 6) a- ~4)~-'~ %w..(("<'"I ?'~~""--: t.-.. ~ ...r-- ~~~..arJ u-;;.~J2:J.. " " ,- ~~'O~M ... \ r-- '$ ~g "" 'S'" ~~ 8, - - LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V, Block "J", in the General Plan of George W. Buttorff's Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest corner of Fourth Street and Reno Avenue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby Avenue; thence in an Eastwardly direction along said Ruby Avenue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place of BEGINNING, HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor under the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1180 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W, Daniels, IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W, DANIELS TAX PARCEL #25-25-0006-45 co, 0 C) C',) ( "'--;,) ~-r1 U'l =ft (--: \_~. ':: ~(\ \ "- \......:~ ~ V N t :\t\ ~ \ -, , ........ ~ ~ '" ~ \ co C,') , -.J ~~ \) {' ~ .r \ \ l>' \.> 0 ~ ~ .lv " lA } ~ v\ VI t' ".I ~k v () v \ (' \ J1 (' ~ r t' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK F/KIA ALLFIRST BANK Plaintiff (s) From NORMAN W. DANIELS, 412 4TH STREET, NEW CUMBERALAND, PA 17070 N005-2888 Civil CIVIL ACTION - LAW (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 ievied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himfher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,933.30 L.L..50 Interest FROM 10/18/04 TO 7/19/05 AT 9.0400% Atty's Comm % Due Prothy $1.00 Atty Paid $122.95 Plaintiff Paid Date: 7/22/05 Other Costs CURTIS R. LONG (Seal) 7/;1.,2/0J/ Prothonotary 1ft ~ By: 1~ I:.... t1:(' ., Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR - ESQUIRE Address: SUITE 500 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PIDLADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 U~/U~/~UU.\) U':b~ till ~.1b b~1 ((J4. c.:,UWbbl"..l\. -+ I"..UlUJ::lC1\Li\l'ljU ,:,V 19J UU.L GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION SUllE 5000 - MELLON INDEPENDENCE CENT!;R 701 MARKET STREET PHILADELPHIA, PA 19106.1532 (215) 627-1322 FAX (215) 627.7734 JOSE/lIH A. GOl.DBECK, JR. GARye. McCAFFER"TY MICHAEL. T. McKEEVER August 8. 2005 Cumberland R. Thomas Kline SHERIFF OF CUMBERLAND COUNTY Sheriff's Office 1 Courthouse Square Carlisle, PA 17013 RE: M&T BANK FIKJA ALLFIRST BANK V$, NORMAN W. DANIELS Term No.05-2888-cIVIL Proaertvaddress: 412 4th Street New Cumberland, PA 17070 Sheriff's Sale Date: December 07, 2005 Dear Sir/Madam: K1ndly stay the Sheriff's Sale with reference to the above-captioned matter and return any unused costs. I collected $8.123.39 towards my client's debt. Thank you for your cooperation, CjilrJ.(:h tJ,~~1ECK' JR. JAGAmb - Original writ returned to the Prothonotary's Office. 8/31/05 - Copy of writ and $1500.00 returned to Attorney GJldbeck. , 1 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-2888 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T BANK F/K/A ALLFIRST BANK Plaintiff (s) From NORMAN W. DANIELS, 412 4TII STREET, NEW CUMBERALAND, PA 17070 (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) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,933.30 L.L..50 Interest FROM 10/18/04 TO 7/19/05 AT 9.0400% Atty's Comm % Atty Paid $122,95 Plaintiff Paid Date: 7/22/05 Due Prothy $1,00 Other Costs (Seal) 7/;;'.:1./ oJ / ~- CURTIs R. LONG Prothonotary -dl 0_ . By: 1~ I.. ~e;:/tU~.. REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR - ESQUIRE Address: SUITE 500 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 110 :b 'V SZ lnr ~OOl /:.:: ';J\J~\. il.., .d.dleJ3HS ~::;"ij,::U ::~' !.:1.:! WRIT OF EXECUTION .nd/or A TT ACHMENT COMMONWEALTH OF PENNSYLV ANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due M&T BANK FfK/A ALLFIRST BANK Plaintiff (s) From NORMAN W. DANIELS, 412 4TH STREET, NEW CUMBERALAND, PA 17070 (I) Yon are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL N005-2888 Civil CIVIL ACTION - LAW DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as foJlows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defend.nt(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 $69,933.30 L.L..50 Interest FROM 10/18/04 TO 7/19/05 AT 9.0400% Atty's Carom % Due Prothy $1.00 Atty Paid $122.95 Plaintiff Paid Date: 7/22/05 Other Costs ~ (Seal) Prothonotary By: jl.l.~, 1~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR. ESQUIRE Address: SUITE 500. MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627.1322 Supreme Court lD No. 16132 T Rue COPY fROM RECORO In I d(>ill'llOffy \O'~~rocot. 1 hare> ijr1\"fJ :;et my Iiift;! and lhl seal m saIU Court at Carlisli, P'a. s ~,~~,~~. hO :b 'V 52 lor IOOl ". , h-:: /,_. ,: lJ .:::dl::l:1:-1:; . -'".1 ' :".>1":; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due M&T BANK FfK/A ALLFIRST BANK Plaintiff (s) From NORMAN W. DANIELS,412 4TH STREET, NEW CUMBERALAND, PA 17070 N005.2888 Civil CIVIL ACTION - LAW (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) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $69,933.30 L.L..50 Interest FROM 10/18/04 TO 7/19105 AT 9.0400% Atty's Carom % Due Prothy $1.00 Ally Paid $122.95 Plaintiff Paid Date: 7/22/05 Other Costs ~ (Seal) Prothonotary By: Il.1.~ . 1~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR - ESQUIRE Address: SUITE 500 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 TRUE COPY fROM RECORO In I d(>,L'tlI)/lj \O'l~rocot. 1 hare> "rIm :;et my Iiift;! and thl seal m saIU Court at Carlisli, P'a. ~,~: ~~~ tlO :b 'V 5Z lor ~OOI C J . ~..:: :,~' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005.2888 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due M&T BANK FfK/A ALLFIRST BANK Plaintiff (s) From NORMAN W. DANIELS,412 4TH STREET, NEW CUMBERALAND, PA 17070 (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 allachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $69,933.30 L.L..50 Interest FROM 10/18/04 TO 7/19/05 AT 9.0400% Atty's Carom % Due Prothy $1.00 Atty Paid $122.95 Plaintiff Paid Date: 7/22/05 Other Costs ~ CURTIS R. LONG (Seal) Prothonotary . ~ By: j l' 1 u tff . Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR - ESQUIRE Address: SUITE 500 . MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court rD No. 16132 n~ue COPY fROM RECORO In I d(>,ll'llo/lY \O'~~r(ll"Ji. 1 hare "rim :;et my Iiift;! al',d lhl seal m said Court at Carlisli, P'a. .rh~~~ ~~~'1:;; ~,.o Ii. . hO :b 'V 5Z lnr ~OOl " , j\ 1.'. ,: :',.; .:L:HU3HS ~, ~j_ _ ~<:'U..:' SHERIFF'S DEPARTMENT OF CUMBERLAND COUNTY SHERIFF SERVICE INSTRUCTIONS PLAINTIFF/S/ COURT NUMBER M&T BANK F/K/A ALLFIRST BANK 05.2888-CIVIL DEFENDANT/S/ TYPE OF WRIT OR COMPLAINT NORMAN W DANIELS NOTICE OF SALE I SERVE> AT NAME OF INDIVIDUAL. COMPANY. CORPORATION, ETC" TO SERVICE NORMAN W. DANIELS ADDRESS (Street or Road, Apartment No.. City, Bora. Twp., State and ZIP Code) 412 4th Street, New Cumberland, PA 17070 SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: PLEASE POST HANDBILL ADDRESS OF A TELEPHONE NUMBER (215) 627-1322 DATE July 19,2005 SIGNATURE 0 A GOLD ECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 SHERIFF'S DEPARTMENT OF CUMBERLAND COUNTY SHERIFF SERVICE INSTRUCTIONS PLAINTIFF 151 COURT NUMBER M&T BANK F/K/AALLFIRST BANK 05-2888-CIVIL DEFENDANT/SI TYPE OF WRIT OR COMPLAINT NORMAN W DANIELS NOTICE OF SALE I SERVE> AT NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE NORMAN W. DANIELS ADDRESS (Street or Road. Apartment No.. City. Boro. Twp., State and ZIP Code) 412 4th Street, New Cumberland, PA 17070 SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: PLEASE SERVE THE ABOVE DEFENDANT OR PERSON IN CHARGE TELEPHONE NUMBER (215) 627-1322 DATE July 19. 2005 ADDRESS OF GOL BECK McCAFFERTY & McKEEVER Sui1e 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 05-2888-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck. Jr. Allomey l.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia. PAl 9 106 215-627.1322 Attorney for Plaintiff M&T BANK F/KJA ALLFIRST BANK 1100 Wehrle Drive 2nd Floar Williamsville. NY 14221 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. NORMAN W. DANIELS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 412 4th Street New Cumberland, P A 17070 Term No. 05-2888-CIVIL Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DANIELS. NORMAN w. NORMAN W. DANIELS 412 4th Street New Cumberland. PAl 7070 Your house at 412 4th Street. New Cumberland. PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday. December 7.2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$69.933.30 obtained by M&T BANK FIK/A ALLFIRST BANK against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to M&T BANK F/K/ A ALLFIRST BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment. if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. II 05-2888-CIVIL 3. You may also be able to stop the sale through other legal proceedings. Yau 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 NOT 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 price by calling the Sheriff of71 7-240-6390. 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 due in the sale. To find out ifthis has happened. you may call the Sheriff of717-240.6390. 4. If the amount due from the Buyer is not paid to the Sheriff. you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the 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 schedule of distribution is filed. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle. P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PAl 70 13 ~ j . Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck. JT. Attorney 1.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia. PAl 91 06 215-627-1322 Attorney for Plaintiff M&T BANK F/K/A ALLFIRST BANK 1100 Wehrle Drive 2nd Floor Williamsville. NY 14221 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW NORMAN W. DANIELS (Mortgagor(s) and Record Owner(s)) 412 4th Street New Cumberland. PAl 7070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 05-2888-CNIL AFFlDA VIT PURSUANT TO RULE 3129 M&T BANK F/KIA ALLFIRST BANK. Plaintiff in the above action. by its allorney. JosephA. Goldbeck. Jr.. Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 412 4th Street New Cumberland. P A 17070 NORMAN W. DANIELS 412 4th Street New Cumberland. PA 17070 ,.." (~ 0 ':~-";'") .j (:.1"1 '- -l -,- m f'\) ", , - (-') " - 0 I.Name and address ofOwner(s) or Reputed Owner(s): NORMAN W. DANIELS 412 4th Street New Cumberland, P A 17070 2, Name and address ofDefendant(s) in the judgment: 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 170 I 3 PENNSYLVANIA DEPT. OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg. P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: FULTON BANK 132 Old York Rd. New Cumberland. PAl 7070 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 412 4th Street New Cumberland. P A 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of I8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Julv 19.2005 GO BY: seph A. Goldbeck, Jr.. Esq. Allorney for Plaintiff SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V. Block "J", in the General Plan of George W. Buttorffs Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest corner of Fourth Street and Reno A venue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby Avenue; thence in an Eastwardly direction along said Ruby Avenue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place ofBEGlNNING. HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor nnder the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1/80 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W. Daniels. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V. Block "J", in the General Plan of George W. Buttorffs Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest comer of Fourth Street and Reno Avenue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby Avenue; thence in an Eastwardly direction along said Ruby Avenue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place of BEGINNING. HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor under the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1/80 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W. Daniels. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V. Block "J", in the General Plan of George W. Buttorffs Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest comer of Fourth Street and Reno Avenue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby A venue; thence in an Eastwardly direction along said Ruby A venue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place of BEGINNING. HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor under the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1/80 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W. Daniels. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V. Block "J", in the General Plan of George W. Buttorffs Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest comer of Fourth Street and Reno Avenue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby Avenue; thence in an Eastwardly direction along said Ruby Avenue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place of BEGINNING. HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor under the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1/80 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W. Daniels. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006-45 LONG DESCRIPTION All THAT CERTAIN lot or piece of land situated in the Borough of New Cumberland, County of Cumberland, and State of Pennsylvania, being Lot V. Block "J", in the General Plan of George W. Buttorffs Addition to New Cumberland, as recorded in the Recorder's Office of Cumberland County in Book "N" Volume 5, Page 500, said lot being bounded and described as follows: BEGINNING at a point on the South side of Fourth Street, one hundred and twenty-five (125) feet West from the Southwest comer of Fourth Street and Reno Avenue; thence in a Westwardly direction along said Fourth Street, twenty (20) feet to the line property of Land & Improvement Company; thence in a Southwardly direction along said line of property of Land & Improvement Company, one hundred and forty (140) feet to Ruby Avenue; thence in an Eastwardly direction along said Ruby Avenue, twenty (20) feet to line of property of Lester Cook; thence in a Northwardly direction along said line of property of Lester Cook, one hundred and forty (140) feet to Fourth Street, the place of BEGINNING. HAVING THEREOF ERECTED a three-story frame dwelling house known as No. 412 Fourth Street, a frame garage in the rear. BEING THE SAME premises which Jon F. LaFaver, Executor under the Last Will and Testament of Leroy Sweigart, deceased, by deed dated 12/1/80 and recorded 12/3/80 in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Deed Book F29, at page 639, granted and conveyed unto Norman W. Daniels. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 412 4th Street New Cumberland, PA 17070 SOLD as the property of NORMAN W. DANIELS TAX PARCEL #25-25-0006.45