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Home My WebLink About05-5553 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Robert S. Reed, Sr. Rae Ann Reed NO. o/ttJ)- 5,S3 685 State Street Lemoyne, PA 17043 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 717-249-3166 800-990-9108 l NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.c. Is! Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g) The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 685 State MUNICIPALITY/TOWNSHIP/BOROUGH: COUNTY: Cumberland DATE EXECUTED: 06/14/96 DATE RECORDED: 06/21/96 BOOK: Street Borough of Lemoyne 1327 PAGE: 227 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 10/12/05: Principal of debt due Unpaid Interest at 7.875% from 10/1/04 to 10/12/05 (the per diem interest accruing on this debt is $6.54 and that sum should be added each day after 10/12/05) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $118.71 and that sum should be added on the first of each month after 10/12/05) Late Charges (monthly late charge of $24.90 should be added in accordance with the terms of the note each month after 10/12/05) Corporate Advance Attorneys Fees (anticipated to 5% of principal) $30,331.54 2,460.59 325.00 280.00 1,238.30 522.90 150.14 and actual TOTAL 1. 516 .58 $36,825.05 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $36,825.05 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \irwJ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 I I!"~:'/ , LL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED. SITUATE IN THE BOROUGH OF LEMOYNE. CUMBERLAND COUNTY. PENNSYLVANIA. BOUNDED AND DESCRIBED AS FOLLOWS: BEING THE EASTERN om-HALF OF LOT NO. 21 IN THE PLAN OF LOTS KNOWN AS PLAN NO. 2 OF NORTH RIVERTON. SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN DEED BOOK "X", VOL. 5, PAGE 601; RAVING A FRONTAGE ON STATE STREET (ALSO KNOWN AS GETTYSBURG ROAD) OF 22.5 FEET MORE OR LESS, AND EXTENDING AT AN EVEN WIDTH, 125 FEET, MORB OR LESS, TO A TWENTY FOOT ALLEY IN THE REAR; BEING IMPROVED WITH THE ~STERN om-HALF A DOUBLE FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 685 STATE STREET, LBMOYNE. PA. UNDER AND SUBJECT TO ANY AND ALL RESTRICTIONS, OBJECTIONS, ETC., AS TREY APPEAR OF RECORD. i if" " " ~ " 111111111111111111111111111111111111111111111111111111 7100 4047 5100 2446 7491 September 6, 2005 017158 /PA ROBERT S REED SR 685 STATE ST LEMOYNE PA 17043 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5918826206 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mnrtl!al!e on Your home is in default and tbe lender intends to foreclose Specific infonnation ahout the natnre of the defuult is provided in the attached paee; The HOMFOWNER'S MORTGAGE ASSISTANCE PROGRAM fHEMAP) may he ahle to heln to save your home This Notice exnhlins how the vrn~am works To see if HEMAP can heln VOll mllst MEFT WITH A rONSOMFR CREDIT COUNSELING ACiFNf:Y WITHIN 30 DAYS OF THE DATE OF THIS NOTIrE Take this Notice with VOll when VOll meet with the Counseling Al!ency The name address and nhnne numher of CnnSllmer Credit rOlm"E'!]im" AQ"encies servinp" vour rOlmtv are li..ted at the end of this Notice If vou have anv Qlle..tions VOll mav call the Pennsvlvania Hom.in". Finance Ae'encv toll free at l-ROO-342-23Q7 (Persons with impaired hearinll can call (7]7) 7RO~lRfiQ) 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECfA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA ACT 91 EXHIBIT '" tlUMEUWNE.l(':') l"\A1V1E(':'): l<ooen:::>. xeea ':'r. LOAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 685 Slate Street LeMoyne P A 17043 5918826206 PROPERTY ADDRESS: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE 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 ELIGmLE 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 PENNSYLVANIA HOUSING FINANCE AGENCY. TFMPORARY STAY OF FORRC:I.OSITRR R 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-facell meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST Oc:r.UR WITHIN THR NRXT (31)\ DAYS IF YOIJ DO NOT APPLY FOR EMERCiFNrY MORTGACiE ASSISTANCE YOU MUST BRING YOUR MORTGACiE UP TO DATE THF PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTCiACiF DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CoONSIJMRR CoRRDn CoOIINSRI ,ING AGRNr.JFS - If you meet with one of the consumer credit counseling agencies listed at the end of this 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~:lted consumer credit connselinr :lfenci~ for the county in which the pronertv is located are set forth at the end of this Notice lt is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPl.lC:ATION FOR MORTGAGF. 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 of the 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 face-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 LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGRNCoY Ar.TION. 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 PROTECfED 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 ATIEMPT TO COLLECf THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) IIO:liL.CJQLO HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it no to date\. NATURE OF THE DF-FAln T - The MORTGAGE debt held by the above lender on your propeny located at; 685 State Street LeMoyne PA 17043 IS SERIOUSLY IN DEFAULT BECAUSE, Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 11/01/2004 12/01/2004 01/01/2005 02/01/2005 03/01/2005 04/01/2005 05/01/2005 06/01/2005 07/01/2005 08/01/2005 09/01/2005 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $625.73 $625.73 $625.73 Other charges (explain/itemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE, $498.00 $0.00 $0.00 $7308.39 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): 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 $7308.39. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavment'i must he made ei.ther hv cash cashier's check certified check or monev order m:ule navahle and sent to. Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee, WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT r.URE THF. DEFAULT - If you do not cure the default within THIRTY (30) DAYS ofthe date of this Notice, the lender intends to exerril'le its ri2ht.!i t.o accelerate t.he mortl1ape debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclolie npon your mortllai!'ed nronertv. *IF THF. MORTGAGF. IS FORF.r.I OSRD UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys. but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even 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 yOIl ellre the default within thr. THIRTY (3m DAY nerind VOl) will not he reauired t.o nav attornev's fees. OTHF.R [ RNDER REMEDIF.S - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 ""71' 1 1 ~I , .in." ""'. l.I"." "'01'.' ,n'\ln "I ~IILn....' , ~ - _ 'V'" HU'''' .CUl "'...J........ CH", ...."'.."...u, ""CHJ.L1 ,U", ,<U..., < C 'J\JJ J.Jrl J. ......' lVU and foreclosure proceedings :tave begun, YOl! ffi:lV still h:lve the fifTh! to {'me the default :lnd nrevent the sale ;n any time un Tn one hour hefore the Sheriff's S:l]e You m:lV do so hv n;lVinl' the total amount then m~t due nllls any late or other charees then due reasonahle attornev'.; fees and costs connected with the foreclosure sale and any other COStS connected with Ihl' Sheriffs Sale a.,> specified in writine hv the lender and hy performin~J any other reQuirements under the mort[>al'e Curing your default in the manner ~et forth in this notice will remore your mortgage to the same position as i.f you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE nATF. - It is estimated that the earliest date that such a Sheriffs Sale of the mongaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the ~ale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281.3914 Collection Department www.wamuhomeloans.com Phone Number: Fax Number: Contact Person: Email Address: RFFRrI'S OF SHERIFF'S SALE. - You ~hould realize that a Sheriff's Sale will end your ownership of the mortgaged propeny and your right to occupy it. If you continue to live in the property after the Sheriffs Sale. a lawsuit to remove you and your furni~hing~ and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor Xmay not sell or transfer your home to a buyer or transferee who will assume the mongage debt, provided that all the outstanding payments, charges. and attorney's fee~ 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 THE 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 DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTrrUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACfION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACT 91 "...."'~'>.uu..y.u"'. ~ "-- _,....____..-..,., ,U :11111111111111111111111111111111111111111111111111111 7100 4047 5100 2446 7507 September 6, 2005 017159/PJ. RAE A REED 685 STATE ST LEMOYNE PA 17043 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5918826206 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an officiHl notice that the mortl1ap.e on VOllT home is in default Hnd the lender intends to foreclose Snecific information about the nHtllre of the de:Clult is nrnvided in the attached nares The HOMFOWNER'S MORTGAGF ASSISTANCE PROGRAM (HFMAP) mav he ;ahle to helD to savp vour home This Notice explains how the DTOPTam works To spe if HEMAP CHn help you must MEET WITH A rONSUMER CREDIT rOUNSEI ING AGENrY WlTHIN 30 DAYS OF THE DATE OF THIS NOTICE T;ake this Notice with you when vou meet with the COllnselinp' Ap'encv The nHme address ;and Dhone numher of Consumer rredit Counseling Al1encies serving VOllT C:ounty are listed at the end of this Notir:e If Vall hHve anv Questions vall mav call the PenDwlvHoia Housinv FinHoce Ap'encv toll free M l-ROO':~42-23Q7 (Persons with imnaired henrinp can call (717) 7RO-1R6Q) 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 an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFEcrA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA ACT 91 l"'1VL),lJ1.UVl'f'lJ1.!\:> L"fi.LYml~}: Ka~ .'!>.. .K~~U PROPERTY ADDRESS, 685 State Street LeMoyne P A 17043 5918826206 LOAN ACCT. NUMBER: ORIGINAL LENDER, CURRENT LENDERfSERVICER, Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE 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 ELIGmLE 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 PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORRrT.OSlJRE - 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 consumer credit counseling agencies listed at the end of this Notice. THIS MRRTING MTJST OCCUR WITHIN THR NRXT (3m OA YS IF YOU DO NOT APPI Y FOR FMERGENCY MORTGAGE ASSISTANrE YOU MUST BRING YOUR MORTGAGE UP TO DATF THE PART OF THIS NOTIrF rAI I ED IlHOW TO CURE YOUR MORTGAGE DFFAlJI TlI EXPLAINS HOW TO BRING YOIJR MORTGAGE UP TO DATE CONSIJMRR CREDIT COUNSRLING AGRNCJRS . If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telenhone numbers of desienated consumer credit cOllnselimJ :HJencies for the countv in which the pronertv is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGR ASSISTANrF. - 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 of the 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 face-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. AGRNCY 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 ATIEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin. it nD to date). NATURE OF THE DEFAIlLT - The MORTGAGE debt held by the above lender on your property located at: 685 State Street LeMoyne P A 17043 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 1110 112004 1210112004 0110112005 0210112005 03/0112005 04/0112005 05/0112005 06/01/2005 07/0112005 08/0112005 09/0112005 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $616.65 $625.73 $625.73 $625.73 Other charges (explain/itemize): Uncollected Late Charges Uncollected Fees: Less Credits TOTAL AMOUNT PAST DUE, $498.00 $0.00 $0.00 $7308.39 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACfION (Not applicable): 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 $7308.39. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments mllst he made either hv ca.'ih cashier's check certified check or monev order made pavahlp. llnd sp.nt to' Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee, WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU no NOT r.tJRF. THF. DF.FAIJI .T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intend1.: to exp.rci!ie it.Ol ri2'hts tn 3('('elerate 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 the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foredO-Ole IInnn "ollr mortl!31!ed nronert". *IF THF. MORTGAGF. IS FORF.r.J .OSF.n UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even 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 VOII "ure the default within the THIRTY (3m DAY nerind. "011 will not he rennired tn nay attorney's fees. OTHF.R I.F.NnF.R RF.MF.DIKli;: - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 ,~"In I 1~1 ~ .1 nl' 11l',l'f'lIHd r~nJJ~ -\1 ~nl'~..::1ft.LtL - '1 ~'UU '_dVe HUl L.U.l~'U ll1t: ..t:ldUll wlLllUl ,,11:;: . LlI.l'>.l t ',.JUj l..JK I ~-'CjjUU ami [oreclosure proceedings have begun, you may still h:lVe the ri~htlo cure the default. and nreveIl1..L~e sale at ;mv time un to one hour before the Sheriff's Sale You may do so hv pavinp The total amount then oast due olus any late or other chan!es then due rcasnnahle anontev's fees and COStS connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as snecified in writin? hv the lender and hv nerforminl> any other re(lllirements under thE! mnrtl':we 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. F.ARLlFST POSS1RLF. SHF.R1FF'S SALF. DATE - It is estimated that the earliest date that such a Sheriff's Sale uf the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs 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 may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281-3914 Collection Department www.wamuhomeloans.com Phone Number: Fax Number: Contact Person: Email Address: F.FFRCTS 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 ~ mayor Xmay not sell or transfer your home to a buyer or transferee who will assume the mongage 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 THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATIACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACT 91 V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subj ect to the penal ties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. ren, ESQUIRE UDREN LAW OFFICES, P.C. SHERIFF'S RETURN - REGULAR CASE NO: 2005-05553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS REED ROBERT S SR ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REED ROBERT S SR the DEFENDANT at 1519:00 HOURS, on the 4th day of November, 2005 at 39 HAZEL CIRCLE MECHANICSBURG, PA 17050 by handinq to ROBERT REED a true and attested copy of COMPLAINT - MORT FORE toqether with and at the same time directinq His attention to the contents thereof. Additional Comments DEFENDANTS ARE STILL LIVING AT 685 STATE STREET LEMOYNE, BUT ARE CURRENTLY STAYING AT 39 HAZEL CIRCLE. Sheriff's Costs: Docketinq Service Affidavit Surcharge So Answers: 18.00 13 .44 .00 10.00 .00 41.44 j",,-1:>;P'~i;':-,~, ':.:' , R. Thomas Kline .0~4" <,> 'L:;;~,,~.~<J: 11/07/2005 UDREN LAW OFFICES me this IS'!'- day of By: 4';1'~'Vr~ < v Deputy Sheriff Sworn and Subscribed to before f4.w. A.D. SHERIFF'S RETURN - REGULAR . CASE NO: 2005-05553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS REED ROBERT S SR ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REED RAE ANN the DEFENDANT , at 1519:00 HOURS, on the 4th day of November, 2005 at 39 HAZEL CIRCLE MECHANICSBURG, PA 17050 by handing to ROBERT REED, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 .~"Il"',^.:,... ""~~: " R. Thomas Kline 11/07/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: 4~~ ~r~ . Deputy Sheriff me this ,('S;. day of A.D. SHERIFF'S RETURN - REGULAR ~ CASE NO: 2005-05553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS REED ROBERT S SR ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly swo~n according to law, says, the within COMPLAINT - MORT FORE was served upon REED ROBERT S SR the DEFENDANT at 1519:00 HOURS, on the 4th day of November, 2005 at 39 HAZEL CIRCLE MECHANICSBURG, PA 17050 by handing to ROBERT REED a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 10.56 .00 10.00 .00 26.56 w._j.,.~:" "1' R. Thomas Kline 11/07/2005 UDREN LAW OFFICES Sworn and Subscribed to before vP me this /5 ~ day of 7~~ )U7i7~/ . A.D. f:L~ / Prot tary By: 4~ Deputy v/ Sheriff SHERIFF'S RETURN - REGULAR .. CASE NO: 2005-05553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS REED ROBERT S SR ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REED RAE ANN the DEFENDANT , at 1519:00 HOURS, on the 4th day of November, 2005 at 39 HAZEL CIRCLE MECHANICSBURG, PA 17050 by handing to ROBERT REED, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ."'1Y~ 1" R. Thomas Kline 11/07/2005 UDREN LAW OFFICES Sworn and Subscribed to before By: ~;;{ Deputy v~ Sheriff me this J$''IC of A.D. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FOREC]~OSURE v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) NO. 05-5553 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Robert S. Reed, Sr. Rae Ann Reed for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 10/13/05 to 12/15/05 Late charges per Complaint From 10/13/05 to 12/15/05 Escrow payment per Complaint From 10/13/05 to 12/15/05 $36,825.05 418.56 74.70 237.42 TOTAL $37.555.73 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN Mark dren, ESQUIRE Attor ey for Plaintiff PRO TED ~ (!~ PRO(I'HY - . f ~~ DAMAGES ARE HEREBY ASSESSED AS INDI DATE: p-dlt)~' "'" ~ ~ ~ > ~ ~ 0 r-.> 0 I'll = C = -n ~. U' ~- ,'- 0 3:l ~ , P1 n':O '\;- ~ " r: -om '- ~ . N ..-)~ t. f" ~} ,) .x" ~ -'c" ~T\ J -0 ~-n ~, W z '~';~ ("J ;';-'~rn ,- -;:-" 3S -< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 05 -5553 TO THE SHERIFF: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount due $37,555.73 Interest From 12/16/05 to Date of Sale June 7, 2006 Ogoing Per Diem of ~ to actual date of sale including if sale is held at a later date (Costs to be added) 1.137.96 $ UDREN LAW OFFICES, P.C. ( Mark J, U ATTORN~Y \ V\ ren, ESQUIRE OR PLAINTIFF "-. ~ ~ ~, ~ b~. ~. r) , IJ'\ '8. ""- dO:-. V""'\ B <- l; ~~Il..J~ ,~\.r\'0~. ~~ "- ~~\s~'\~~~ ~\)",K . ..;; ~ " t ' ;- " ;- ~ " f ~ ~ "'~ ~'" ~ . .. ~ . ~~ ,. ~, :t S\ l' v ,..., 0 = c"-'> ~n I;.:,n c::> -< 1"1 X..,..\ CJ rllp-; ,0 "l"J1T: S6 C ,., -0 -n ::r.: ,.;:t:,) -".-rTI .".. U ~~J ;n .< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-5553' Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America Plaintiff (s) From Robert S. Reed, Sr. Rae Ann Reed 685 State Street, Lemoyne, P A 17043 (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $37,555.73 L.L.$.50 Interest from 12/16/05 to date of Sale June 7, 2006 ogoing Per Diem of $6.54 to actual date of sale including if sale is held at a later date Atty's Conun Atty Paid $185.00 Plaintiff Paid Date: December 21, 2005 % $1,137.96 Due Prothy $1.00 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: Woodcrest Corporate Center 111 Woodcrest Rd., Suite 200 Cherry Hill, NJ 08003-3620 Attorney for: Plaintiff Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVn DIVISION Cumberland County v. Robert S. Reed, Sr. Rae Ann Reed NO. :>5-5553 Defendant(s) Robert S. Reed, Sr. 39 Hazel Circle Mechanicsbrug, PA 17050 DATE of Notice: November 28, 2005 IMPORTANT NOTICE TO: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEG1\L LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLE ION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND HIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINEDWt11BE SED FOR THAT PURPOSE. MarJ~. Udren, Esqulre Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-.3620 ,...., =' =' .:;:.:' c::> r'1 " N :g ~'".. o 41 ..... ::I:-r. rl1f:;':: ~39 ;~A S;~ (:}?"') 7Sri1 ~-,' .1 ?E ;< .r.:: UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO.04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05 -5553 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: ____A. In Assumpsit (Contract) ____B. In Trespass (Accident) --X-C. In Mortgage Foreclosure ____D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: ____A. An individual --X-B. Tenants by Entireties ____C. Joint Tenants with right of survivorship ____D. A partnership ____E. Tenants in Common ____F. A corporation III. The Defendant(s) is (are): --X-A. ____B. ____C. Resident in the Commonwealth of Pennsylvania Not resident in the Commonwealth of Pennsylvania If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: Mark J Addre ESQUIRE # as above r-' .~ c::::> <." c:J rr\ n N -0 ::1::' o -1'1 .-1 ::C-n nip': -om :~? '1~ ~:~;~ :?J~ ,.-::\ "T','" ~Q, ,[:- .-- - UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05-5553 Defendant(s) C E R T I F I CAT E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: An FHA insured mortgage Non-owner occupied Vacant X Act 91 procedures have been fulfilled. Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Mark ATTO dren, ESQUIRE FOR PLAINTIFF 0 ,,-> 0 c::..~ c: (";,;:;l -n ,-" . .. c:l ::;:1-1'1 ('1\ n1-::::::. '" -ntn 'v -,~ \ 'J :.-.1 \ "---~C1 ...J-'C, -0 c:~: ~;, .,..:l... ;,~,~ <-"') .":::-,n1 Jc.- ...-' ::.:,:'~ :':1 N -< UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. NO. 05 -5553 Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Robert S. Reed, Sr. Over 18 As captioned above Unknown Defendant: Age: Residence: Employment: Rae Ann Reed Over 18 As captioned above Unknown Sworn to and subscribed before me this 15th day ::luCW005. n IY1 pnd'1 No ary u i L Name: Title: Company: J. UDREN, ESQ. TT RNEY FOR PLAINTIFF REN L,AW OFFI CES, P. C . rl11SrrN AW;Eln PLUCK N:>rARY PUSUC OF NEW Jll':llY Comml:slon fx;;!:!J$ 5/J I/~;I;} ~'] '--c:;- :,:" I . ~ '-' c:.::' = ,-" Cl '" c-> N o "n -l ::r:::n n1~ -0 CD -"u cjl_ ~'::i '::'-Fi ~--n :::>C) ~nl -< " :;;: '" . \ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05 -5553 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 685 State Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s) : Name Address Robert S. Reed, Sr. 685 State Street Lemoyne, PA 17043 Robert S. Reed, Sr. 39 Hazel Circle Mechanicsburg, PA 17050 Rae Ann Reed 685 State Street Lemoyne, PA 17043 Rae Ann Reed 39 Hazel Circle Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE . ( 3. Name and record lien Name address of every judgment creditor on the real property to be sold: Address whose judgment is a PNC Bank National Assoc. Fifth Ave and Wood Street Pittsburgh, PA Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606-0674 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PNC Bank National Assoc. 4242 Carlisle pike Camp Hill, PA 17001-8874 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address in the property and Name of every other person whose interest may be Address who has any record interest affected by the sale: Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 . , 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 685 State Street Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: December 15, 2005 Mark\J. U ren, ESQ. Atto ne for plaintiff 0 .-' 0 c? ,.:-, -= '-\1 <.n c:l ::;:I p" f'n:JJ c-> -rJ M=: N :"9 - i~C,l -0 ~;-i ; ::r; ::~~~g L- orn --\ ..". :,:J N .< UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05 -5553 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert S. Reed, Sr. 39 Hazel Circle Mechanicsburg, PA 17050 Your house (real estate) at 685 State Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $37,555.73, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney1s fees. TO find out how much you must pay, you may call, (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until paid to the Sheriff and the Sheriff gives a deed to the buyer. buyer may bring legal proceedings to evict you. the full amount due is At that time, the 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 ,'our house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 o ~:; ",- r-, ,...., = G:'l "" c:> rn " N o -n :r" rnp --tJp:; -;J~ ;-, 1 .--:';t.) -.i~ ~ll 2i:'5 ,en ~l S:J -< ::z .... r- N UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMMON PL AS CIVIL DIVISION Cumberland County v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) NO. 05-5553 ATTORNEY FOR PLAINTIFF AMENDED AFFIDAVIT OF SERVICE PURSUANT TO Pa. .C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, that: 1. A copy of the Notice of Sheriff's Sale, a true which is attached hereto as Exhibit "A", was sent t lienholder and every other interested party known a filing of the Praecipe for the Writ of Execution, 0 on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defenda and certified mail on the date appearing on the att which was signed for by Defendant(s) on the date sp Return Receipt. Copies of the said Notice and Retu hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, th personal service on the date specified on the attac attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof 0 Order is attached hereto as Exhibit "B". All Notices were served within the time limits set 3129. This Affidavit is made subject to the pe relating to unsworn falsification to aut Dated: May 23, 2006 BY: squire, hereby verifies and correct copy of every recorded of the date of the the date(s) appearing t(s) by regular mail ched Return Receipt, cified on the said n Receipt are attached n service was by ed Return of Service, compliance with said orth by Pa Rule C.P. .C.S. Section 4904 n, EsquJ.re Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) TTORNEY FOR PLAINTIFF COURT OF COMMON LEAS CIVIL DIVISION Cumberland Count MORTGAGE FORECLO URE NO. 05-5553 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank, FA f/k/a PNC Mortgage Co . of America, Plaintiff in the above action, by its attorney, M rk J. Udren, ESQ., sets forth as of the date the Praecipe for the Wr't of Execution was filed the following information concerning the re 1 property located at: 685 State Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Name Address Robert S. Reed, Sr. Robert S. Reed, Sr. Rae Ann Reed Rae Ann Reed 685 State Street Lemoyne, PA 17043 39 Hazel Circle Mechanicsburg, PA 17050 685 State Street Lemoyne, PA 17043 39 Hazel Circle Mechanicsburg, PA 17050 ! I \ I I \ 2. Name and address of Defendant(s) in the judgmeJt: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor wh se judgment on the real property to be sold: Address is a PNC Bank National Assoc. 249 Fifth Avenue Pittsburgh, PA 1522 2707 Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606-0 74 4. Name and address of the last recorded holder 0 every mortgage of record: Name Address plaintiff herein. See Caption above. PNC Bank National Assoc. 4242 Carlisle pike Camp Hill, PA 17001 8874 PNC Bank NA 2730 Liberty Avenue Pittsburgh, PA 1522 c/o Marlene J. Bern Bernstein Law Firm 707 Grant Street, S Pittsburgh, PA 1521 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address in the property and Name of every other person whose interest may be Address who has any record interest affecte by the sale: Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property wh'ch may be affected by the sale: Name Address Tenants/Occupants 685 State Street Lemoyne, PA 17043 I verify that the statements made in this affidav't are true and correct to the best of my personal knowledge or i formation and belief. I understand that false statements here' ar mad subject to the penalties of 18 Pa.C.S. sec. 4904 rel nuns orn fal ification to authorities. DATED: May 23, 2006 M k J. Udren, Esquire Attorney for laintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTO Y FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff COURT OF COMM N PLEAS CIVIL DIVISIO Cumberland Co nty NO. 05-5553 v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 Defendant(s) DATE: March 10, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): ROBERT S. REED, SR. AND RAE ANN REED PROPERTY: 685 State Street, Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled t be sold at the Cumberland County Sheriff I s Sale on June 7 I 2006 at 10: 00 A.M., in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTH USE, CARLISLE, PA. Our records indicate that you may hold a mortg ge or judgment on the property which will be extinguished by the ale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with t e schedule unless exceptions are filed thereto within 10 days afte the filing of the schedule. EXHIBIT A -----------~ ~/- !! ~i I): :t,t ",,,, 11" C\t ~1i ",'" 115i" \~'\5 (1<,.. ill f.... \i"~ \,1~ 0\ I!" .I . /f>J~ 1-., \ ; ,. j \nrt ~'\ ~' "", <\ ~. I, 1.01 (::J "q ,J I....' . ,~ 'I.~~' ~,,'W,.,~. 'ii.,.;_l~', -- ' , \ ",~".' ,~~""",': : ",,", \ -', :yi \'\ ;";\ ".':':" U '. ',- ,.J~.:,;':'" -;~:;::;:::-~i""" ' ,''';/- \ o ... ... ... \l\\\\' i"l1 \il~\\ \~\,\ \~\ \\f\\ 1 \~!'1 \,\lil '1.1\'1 i \\\\~ i \t,,1}\ i ,,~~td ~ jilt" t ,,~\\ \" ~t\lt "" \1 B r-- u ! ~'ll ~1 ~~ 1 I~i l ;~v; a. , i 1 u-. i\~ \ iA" U- ~ ~\ 'f1. ... '" .. ... ... ... EJ \-\\8\\ A I~I~I ~ '" 2l ~ '0: if ="$ criu. I 0$ ~llo~ "icriLL -.(4 'l1 o:.c Q::: a:: I j~:s ~ a: u. ';~~ ~ iJ~8 rc ~.!I~ ~ j8 trJ.2 E!l- ~!~ ~ c <0'" ill ~ ~~ ,g 8~- l iijJQ)-:- ~ ~ :::J ftI 41 ~='a.~ - .~, >if. ~~1il <i 8-2"8 <_ i'io.S id~~ ~i!>nh Gif.DD:l!U - ,g ~ I ~ 1~ ~ Elo:i ~ ~~~ D::;Dl: t IS i 0. .!Ii I :.: c h8~ if t DOC][; I 3J 8l 0. < ~ 5t ffi ~ ~ ii:. c~ ~ ! l ~ Ii OW III ~ < -;!l a:iCca: "' ~ lR'" uf~ a ~ ! w i~ WlLa:~(Jl.3 ::;~ ~~lii~ ! g 0" lI."w - 11;; Ul:; o 11:..1 <... ~liiu:;! ~:2 zu~ cwc_ ~ "o.:jl ..I5.8~ 01 ~~ ~ E_ ZC;s:a: ",[ll "'U:~ Wg. wO..... u ~C\I a:":J: z<z~~ g;t:::o a..a.. a.. A- S! ~ .~ e c ;;; ~:f \tl 0 -g~~ a: '" I!! C L'" ~ .... Q)'C~ '" E-oo :5 .. ~< I I I I I I I 1 1 , . . i., '''_ i~l~..'...-.' en-~;'~JI.:,)J\ L~' 0;"':$ ....1 't:::;'1;I . . . ..~~_!~~~ .. . -::;;;;. ".~""'!'""'''''-~- ~~ ... '''''l;(.m""~,,, .., . . r ~~,= -I-::L! .1 I I / ~ ~p ...l .. r'l-.... a: Z W '" "'e z III ::;~ W "7 a J: :g ... CD 10> '" 1.<0 i ~ J? '" .... .. .. .. 0 .. .. EXIjiISIT A , \.. -.s I U"H" ~~I~j I l"~, . - U~llhi 11- "" ~ 8 - J;; - H .i~! ~h8~i - lii!.18J -}~hit i!gHg> ~Ultl ht~p - l~~"ol ~1~~8= 'ad!i! '~~i=g - 12CDa.:l:i~1ll :!t1i"!I._ Ii U~.:!lm" ,;~~h"i . 8"~ .~ 'j'5~.5~~ iiln~ d~hl ~:i8~= !.. lil~ ... ~ I -J w ~ :~ - ~ II: ~ ~ ~ ~~ I~ "8 0. U ~"8 ~ ...0. 1l1ii ~1 H ,..0: i II. C '0 II. Ii m ~ o ... .5 ~ ! "I ~ ~ 1 c. E 8 II J:l .. ::l :& E ~ o II. .... 0> 0> .. i .0 CD ~~~ i U'~ ~ -d J fr I~ ..-::J L - . , , ~ Washington Mutual Bank FA flk/a PNC Mortgage Corp. Of America VS Robert S. Reed, Sr. and Rae Ann Reed The Court of Commo Pleas of Cumberland County, ennsylvania Writ No. 2005-5553 ivil Term Brian Barrick, Deputy Sheriff, who being duly sworn accor ing to law, states that on March 15,2006 at 6:17 o'clock PM, he served a true copy ofth within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitle action, upon the within named defendants, to wit: Robert S. Reed Sr. and Rae Ann eed, by making known unto Rae Ann Reed, personally and wife of Robert Reed, at 39 Hazel Circle, Mechanicsburg, Cumberland County, Pennsylvania, its contents an at the same time handing to her personally the said true and correct copy of the sam . Robert Bitner, Deputy Sheriff, who being duly sworn accor ing to law, states that on April 05, 2006 at 1:05 o'clock P.M., he posted a true copy ofth within Real Estate Writ, Notice, Poster and Description, in the above entitled action, on the property of Robert S. Reed, Sr. and Rae Ann Reed located at 685 State Street, emoyne, 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' the following manner: The Sheriff mailed a notice of the pendency of the action 0 the within named defendants, to wit: Robert S. Reed, Sr. and Rae Ann Reed, by re lar mail to their last known address of 39 Hazel Circle, Mechanicsburg, P A 17050. se letters were mailed under the date of April 03, 2006 and never returned to the eriffs Office. Sworn and Subscribed to Before Me so~: ~ ..-t: This _ Day of 2006, A.D. Prothonotary EXHIBIT B 0 ,,~ 0 c::.:> ,:: (;;::;) .,., ,:;., -c1! :r,,,. :r (-,...., .. n1~ -< -ncn C) ~:-Jy ::~() ,""-r, ::;:-... () :n ~- >0 6 ::irn s! . S:J 1'0 -< 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 Land Holding LLC 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 21 st day of Dec, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 5553, at the suit of Washington Mutual Bank FA against Robert S Reed Sr & Rae Ann is duly recorded in Deed Book No. 275, Page 3589. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /9 day of n j '-~ . AD '}'c- 1,_, ~_ ,. .Tv".1I. if r)\,ft~J I.J ;j);..~.-c ( ,-L~F-cL-- lecorder 0 f Deeds ~~ of Deeds. Cumberland County, CIIIIII. PA My ea.........., ExpirH... FiIt MaIIdIr of_1D1O The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5553 Civil Term Washington Mutual Bank FA f/kla PNC Mortgage Corp. Of America VS Robert S. Reed, Sr. and Rae Ann Reed Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 15,2006 at 6:17 o'clock PM, he 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 defendants, to wit: Robert S. Reed Sf. and Rae Ann Reed, by making known unto Rae Ann Reed, personally and wife of Robert Reed, at 39 Hazel Circle, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 1 :05 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 Robert S. Reed, Sf. and Rae Ann Reed located at 685 State Street, Lemoyne, 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 defendants, to wit: Robert S. Reed, Sr. and Rae Ann Reed, by regular mail to their last known address of 39 Hazel Circle, Mechanicsburg, PA 17050. These letters were 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 $49,400.00 to Attorney Daniel Schmieg for Attorney Brett Solomon for Land Holding, LLC, c/o PNC Realty Services. It being the highest bid and best price received for the same, Land Holding, LLC, c/o PNC Realty Services of Two PNC Plaza, 19th Floor, 620 Liberty Avenue, Pittsburgh, P A 15222, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$50,588.00. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary $30.00 988.00 15.00 15.00 30.00 10.00 .50 1.00 Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 23.76 4.64 15.00 30.00 281.00 308.00 19.57 25.00 40.50 $1,836.97 ,/ (J.~~ So Answers: r'~~/~ R. Thomas Kline, Sheriff B\\ JucLch-SrnXth Real Estate 'Sergeant 7 !21~.& ().;.J<./ J)..tA JD 30. . lO ( J .. .'- , (If._ 5LJ f::.) ~o(- < J P tJ 't 3 ~ ~ ../ . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD; SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05 - 5553 Defendant(s) AFFIDAVIT PURSUANT TO RULE '3129.1 Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 685 State Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s) Name Address Robert S. Reed, Sr. 685 State Street Lemoyne, PA 17043 Robert S. Reed, Sr. 39 Hazel Circle Mechanicsburg, PA 17050 Rae Ann Reed 685 State Street Lemoyne, PA 17043 Rae Ann Reed 39 Hazel Circle Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE w ~ . , 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address PNC Bank National Assoc. Fifth Ave and Wood Street Pittsburgh, PA Boscov's Department Store Inc. P.O. Box 4274 Reading, PA 19606-0674 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PNC Bank National Assoc. 4242 Carlisle pike Camp Hill, PA 17001-8874 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 ~ f 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name "Address Tenants/Occupants 685 State Street Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: December 15, 2005 U ren, ESQ. for Plaintiff r . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05-5553 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert S. Reed, Sr. 39 Hazel Circle Mechanicsburg, PA 17050 Your house (real estate) at 685 State Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $37,555.73, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ( . , UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE plaintiff v. Robert S. Reed, Sr. Rae Ann Reed 685 State Street Lemoyne, PA 17043 NO. 05-5553 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Rae Ann Reed 39 Hazel Circle Mechanicsburg, PA 17050 Your house (real estate) at 685 State Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on June 7, 2006, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $37,555.73, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) -669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff1s Sale is ~ot stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheri~f within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ',i,;":" ALL THAT CERTAIN LOT OF GROUND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE BOROUGH OF LEMOYNE, CUMBERLAND CO~I, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING THE EASTERN ONE-HALF OF LOT NO. 21 IN THE PLAN OF LOTS KNOWN AS PLAN NO. 2 OF NORTH RlVERTON, SAID PLAN BEING RECORDED IN THE OFFICE OF TEE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN DEED BOOK "X", VOL. 5, PAqE 601; HAVING A FRONTAGE ON STATE STREET (ALSO KNOWN AS GETTYSBURG ROAD) OF 22.5 FEET MORE OR LESS f AND EXTENDING AT AN EVEN WIDTH, ~25 FEET, MORE OR LESS, TO A TWENTY FOOT ALLEY IN THE REAR; BEING IMPROVED WITH THE EASTERN ONE-HALF A DOUBLE FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 685 STATE STREET, LEMOYNE, PA. UNDER AND SUBJECT TO ANY AND ALL RESTRICTIONS, OBJECTIONS, ETC., AS THEY APPEAR OF RECORD. BEING KNDWN AS: 685 STATE STREET, LEMOYNE, PA 17043 12-21-0267-303 PROPERTY ID NO. ; TITLE TO SAID PREMISES IS VESTED IN ROBERT S. REED, SR. AND RAE ANN REED HIS WIFE BY DEED FROM RHONDA CAMPBELL DATED 10/28/94 RECORDED 11/2/94 IN DEED BOOK 114 PAGE 389. WRIT OF E~CUT~ON and/or A TT ACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) N005-5553' Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America Plaintiff (s) From Robert S. Reed, Sr. Rae Ann Reed 685 State Street, Lemoyne, P A 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell see legal description. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $37,555.73 L.L.$.50 Interest from 12/16/05 to date of Sale June 7, 2006 ogoing Per Diem of $6.54 to actual date of sale including if sale is held at a later date Atty's Comm Atty Paid $185.00 Plaintiff Paid Date: December 21, 2005 % $1,137.96 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name Mark J. Udren, Esq. Address: Wood crest Corporate Center 111 Woodcrest Rd., Suite 200 Cherry Hill, NJ 08003-3620 Attorney for: Plaintiff Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale # 03 On February 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Lemoyne, Cumberland County, PA Known and numbered as 685 State Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 03, 2006 By: cetL(~. \vvlctL/l \ Real Estate Sergeant lO :QI 'V LZ 330 SOOl Vd 'AH~nUJ U,Hld.:.kur-Hi:J j:JI~3HS 3H.l .:10 3JI.:L:lO ~~ ,.....~~J ._~ -.,~:~~<v -~ v~;::>',,<) ";'~)' >~ SCHEDULE OF DISTRIBUTION SALE NO. 03 Date Filed: July 07, 2006 Writ No. 2005-5553 Civil Term Washington Mutual Bank, FA f/k/a PNC Mortgage Corp of America VS Robert S. Reed, Sr. and Rae Ann Reed 685 State Street Lemoyne, PA 17043 Sale Date: Buyer: Bid Price: June 07, 2006 Land Holding, LLC c/o PNC Realty Services $49,400.00 Real Debt: Interest: Attorney Costs: $37,555.73 1,137.96 185.00 Total: $38,878.69 DISTRIBUTION: Receipts: Cash on account (02/03/2006): Cash on account (06/07/2006): Cash on account (06/21/2006): Cash on account (07/06/2006) $ 1,500.00 4,940.00 44,060.00 1,588.00 Total Receipts: $52,088.00 Disbursements: Sheriffs Costs Legal Search Faith Nicola, Tax Collector Lemoyne Borough Attorney Mark Udren Washington Mutual Bank Land Holding, LLC $1,836.97 200.00 811.38 1,576.48 1,500.00 38,878.69 7,284.48 Total Disbursements: ($52,088.00) Balance for distribution: 0.00 So Answers: c~.~~?-(( R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO.3 Held Wednesday, June 7, 2006 Date: June 7, 2006 T AXES: Receipts for all taxes for the years 2003 to 2005 inclusive. Taxes for the current year 2006. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2006, and recorded , 2006, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Rhoda Campbell by deed dated October 28, 1994 and recorded November 2, 1994 in the Office of the Recorder of Deeds for Cumberland County in Deed Book 114, Page 389, granted and conveyed to Robert S. Reed, Sr. and Rae Ann Reed. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of State Street and an unnamed public alley. 6. Rights in party wall along the boundary line of a portion of the subject premises. 7. Building conditions, restrictions, and easements as shown on or set forth with the Plan of North Riverton recorded in Plan Book "X", Volume 5, Page 601. 8. Mortgage in the amount of $52,500.00 given by Robert S. Reed, Sf. and Rae Ann Reed to PNC Mortgage Corporation of America. dated June 14, 1996 and recorded DeJune 21, 1996 in Mortgage Book 1327, Page 227 Complaint in Mortgage Foreclosure filed on October 26,2005 filed by Washington Mutual Bank, FA, formerly known as PNC Mortgage Corporation of America. as Plaintiff against Robert S. Reed, Sr. and Rae Ann Reed as Defendants in the Office of the Prothonotary to file number 2005-5553. Judgment in the amount of $37,555.73 entered. 9. Mortgage in the amount of $75,000.00 given by Robert S. Reed, Sr. and Rae Ann Reed to PNC Bank, N.A. dated February 4, 2000 and recorded February 28, 2000 in Mortgage Book 1597, Page 804. Said mortgage was assigned to Land Holding LLC by instrument recorded in Miscellaneous Record Book 727 Page 4191. 10. Judgment in the amount of $ , entered by Boscov's Department Stove, Inc. as Plaintiff against Robert S. Reed, Sf. and Rae Ann Reed as Defendants in the Office of the Prothonotary to file no. 2003-4361. 11. Judgment in the amount of $82,437.80 entered by PNC Bank, N.A. as Plaintiff against Rae Ann Reed as Defendant on August 8, 2003 in the Office of the Prothonotary to file no. 2003- 3863. Said judgment may be a lien on the subject premises in the event of the divorce of Robert S. Reed, Sr. and Rae Ann Reed or in the event of the consolidation with 2003-3864. 12. Judgment in the amount of $82,437.80 entered by PNC Bank, N.A. as Plaintiff against Robert S. Reed, Sr. and Credit Ranch Auto Sales as Defendants on August 8, 2003 in the Office of the Prothonotary to file no. 2003-3864. Said judgment may be a lien on the subject premises in the event of the divorce of Robert S. Reed, Sf. and Rae Ann Reed or in the event of the consolidation with 2003-3863. 13. Judgment in the amount of $26,756.75 entered by PNC Bank, N.A. as Plaintiff against Robert S. Reed, Sr. and Credit Ranch Auto Sales as Defendants on August 8, 2003 in the Office of the Prothonotary to file no. 2003-3864. Said judgment may be a lien on the subject premises in the event of the divorce of Robert S. Reed, Sr. and Rae Ann Reed. 14. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 15. Real estate taxes accruing on and after July 1,2006 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be valid until countersigned by an authorized signat REAL ESTATE SALE NO. 3 Writ No. 2005-5553 Civil Washington Mutual Bank. FA f/k/a PNC Mortgage Corp. of America vs. Robert S. Reed. Sr. and Rae Ann Reed Atty.: Mark Udren 'ALL TIlAT CERTAIN lot of ground with the improvements thereon erected. situate In the Borough of Lemoyne. Cumberland County. Pennsylvania. bounded and de- scribed as follows: BEING the eastern one-half of Lot No. 21 In the plan of lots known as Plan No.2 of North R1verton. said plan being recorded In the Office of the Recorder of Deeds for Cumber- land County In Deed Book "X-. Vol. 5. Page 601: having a frontage on State Street (also Imown as Gettys- burg Road) of 22.5 feet more or less. and extending at an even width, 125 feet. more or less. to a twenty foot alley In the rear: being Improved with the eastern one-half a double frame dwelling house known and numbered as 685 State Street. Lemoyne. PA. UNDER AND SUBJECT to any and aU restrictions. obJections. etc.. as they appear of record. BEING KNOWN AS: 685 STATE STREET. LEMOYNE. PA 17043. PROPER1Y ID NO.: 12-21-0267- 303. TITLE TO SAID PREMISES IS VESTED IN Robert S. Reed. Sr. and Rae Ann Reed. his wife by Deed from Rhonda Campbell dated 10/ 28/94 recorded 11/2/94 In Deed Book 114 Page 389. 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 Jounlal, 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. TO AND SUBSCRffiED before me this day of April. 2006 ~-d~~b~M/ NOTARIAL SEAL ! LOIS E. SNYDER, Notary Public I I Carlisle Boro, Cumberland County I , Mv Commission 1:::<P1r8:, ,v:ar::h 5. :2009 ~ ~~~~~~D~'~~-a~:.lIo;:..o.:a',"~ REAL ESTATE SALE NO. 3 Writ No. 2005-5553 Civil Washington Mutual Bank, FA fjk/a PNC Mortgage Corp. of America vs. Robert S. Reed, Sr. and Rae Ann Reed Atty.: Mark Udren ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEING the eastern one-half of Lot No. 21 in the plan of lots known as Plan No.2 of North Riverton, said plan being recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book "X~, Vol. 5, Page 601: having a frontage on State Street (also known as Gettysburg Road) of 22.5 feet more or less, and extending at an even width, 125 feet, more or less, to a twenty foot alley in the rear; being improved with the eastern one-half a double frame dwelling house known and numbered as 685 State Street, Lemoyne, PA. UNDER AND SUBJECT to any and all restrictions, objections, etc., as they appear of record. BEING KNOWN AS: 685 STATE STREET, LEMOYNE, PA 17043. PROPERTI ID NO.: 12-21-0267- 303. TITLE TO SAID PREMISES IS VESTED IN Robert S. Reed, Sr. and Rae Ann Reed, his wife by Deed from Rhonda Campbell dated 10/ 28/94 recorded 11/2/94 in Deed Book 114 Page 389. ..... 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 smce; 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 #3 Sworn to and subsc , CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 .... __MUUIO. 03 ...... U. U L<CIwII.... Wasllt..............FA .. PNCIIIl'.JI eo.por....... - Roa.rt& -]..~~"Rae" -"l_.*~ . ,'". '",.'," "- . '.I.I'U}'jL.J ALL 1HAT CFRI'AIN.lot of plUIId with the iapE- ., ~""Iiaite in dae ...... .. ~, (; I !~ ~, r~. ..iW::.~_""",.",,: . !be"'" CJJ>>.bIIf of Lot No. 21 in the pla8 It Lou iIl8wn as Plan No. 2 of North ~.'''''.mcorded in the office of the ReconJet. ofDeilllJtJr CwnberIand County in Deed Book T, Vol. 5, Page 601, having a frontage on Stare Slreet (also bowD as Gettysburg R0a4) of 22.5 fi:ct.,~ J!l\d enc:nding at an eveD" ... 'JDl twenty foot aUey ill.... wiIIl.the Easb:i:t' . ...t.Juse k1towJr '$rect, ~.P4, ~'.i$t~'lD. any ....all ~ ~..;..._... of RlCClllI. . 1lWtG, ~. M__ ~, ~...I184: '.. ........^' ....~ ~IIf)No.: u.~- 1&' ASSIGNMENT OF MORTGAGE FROM: ROBERT S.REED, SR. AND RAE ANN REED, Mortgage dated: 02/04/2000 Mortgagors Mortgagee Mortgage Recorded at Mortgage Book VoL 1597, Page 804, et. seq. in the Recorder's Office of Cumberland County, Pennsylvania TO: PNC BANK, NATIONAL ASSOCIATION Assigned to: LAND HOLDING, LLC, Debt: $60,227.00 Assignee THAT PNC BANK, NATIONAL ASSOCIA TION (hereinafter "Assignor") for and in consideration of the sum of One Dollar and other good and valuable consideration, the receipt whereof is hereby acknowledged, and intending to be legally bound, does hereby grant, bargain, sell, assign, transfer and set over, unto LAND HOLDING, LLC (hereinafter "Assignee"), and Assignee's successors and assigns, all of Assignor's rights, title and interest in, to and under the above Mortgage dated as of February 4, 2000 made by Robert S. Reed, Sr. and Rae Ann Reed as mortgagor, to Assignor, as mortgagee, together with the note or obligation in said Mortgage and all moneys, principal and interest due and to accrue thereunder, and all rights accrued or to accrue therefrom. TO HAVE AND TO HOLD the same unto the said Assignee, and to direct the recorder of said County to note upon the margin of the record of said Mortgage, this Assignment thereof. WITNESS the due execution of this Assignment as of this S-' day of ~"5v '''-€-,2006. WITNESS the due execution of this Assignment as of the day and year first above written. ASSIGNOR: By: Name: amella Ganaway "- ~ Title: Assistant Vice President ~ Certificate of Residence The undersigned hereby certifies that the precise address of the Assignee herein, Land Holding, LLC, c/o PNC Realty Services, Two PNC Plaza, 19th FI r, 620 Liberty Avenue, Pittsburgh, Pennsylvania 15222. BANKJlN276344-1000011-128676 '. ACKNOWLEDGEMENT STATE OF PENNSYLVANIA ) ) ) SS: COUNTY OF ALLEGHENY --tl\. I Before me this ~ day of uutll.. , 2006, appeared Damella Ganaway who after being duly sworn, deposes and says that she is a Assistant Vice President of PNC Bank, National Association and that she, as such officer, being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of the Bank by herself as such officer. c;;;fqu C2c 111. a/CurfO Notary Public Seal My Commission Expires: J{... 8'''' 3..0 I 0 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Angela M. Vicario, Notary Public McKees Rocks Boro, Allegheny County My Commission Expires Apr. 8, 2010 Member, Pennsylvania Association of Notanes BANK_FIN:276344-10000II-128676 . ~. COMMONWEALTH OF PENNSYLVANIA ) ) ) SS: COUNTY OF ALLEGHENY Recorded on this _ day of Mortgage Book, Vol. , page A.D. 2006, in the Recorder's Office of the said County, in Given under my hand and the seal of the said office the day and year aforesaid. Recorder BANKJIN276344-1 000011-128676