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Home My WebLink About05-5709SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 86727, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy A] Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: b S" - S'/Oq VS. Joseph Adams and Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 DEFENDANT(S) COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT 1 F YOU FAI L TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAYBE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 86727, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 PLAINTIFF vs. Joseph Adams anc Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: r a" ?d 7 7 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Roy Al Finance and Loan Company, the address of which is, 3900 Capital City Boulevard, Lansing, MI 48906, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: National Home Loan Corporation Mortgagor(s): Joseph Adams and Maureen Adams (b) Date of Mortgage: September 16, 1998 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1487 Page 693 Date: October 5, 1998 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: National Home Loan Corporation Assignee: Riverway Bank Effective Date: May 8, 2002 Assignor: Riverway Bank Assignee: Roy Al Finance and Loan Company Date of Assignment: December 27, 2001 Recording Date: May 9, 2002 Book: 687 Page: 383 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 122 Old Mill Drive„ Camp Hill, Pa 17011 and is more specifically described as attached as part of Exhibit "A": 4. Each Mortgagor named in paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as Exhibit "B." The name and mailing address of each Defendant is: Joseph Adams, 122 Old Mill Drive, Camp Hill, PA 17011; Maureen Adams, 122 Old Mill Drive, Camp Hill, PA 17011 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of Apri 123, 2005 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of October 9, 2005: Principal of Mortgage debt due and unpaid $42,505.12 Interest currently due and owing at 12.99% per annum calculated from March 23, 2005 at $14.17 each day $2,848.17 Late Charge of $26.34 per month assessed on the 16th of each month from May 9, 2005 to October 9, 2005, (6 Months) $158.04 Title Search/Report Fees $250.00 Attorneys' Fees and Costs $1,500.00 TOTAL $47,261.33 9. Interest accrues at a per diem rate of 14.17 each day after October 9, 2005, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 10. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "C". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. Date: 2 SHAPIRO & KREISMAN, LLC BY: 1,?w ? w- Ilana Zion U Attorney for Plaintiff S & K File No. 05-24856 twomm IV T-540 P.008/019 P-041 e,. v- yxr 0"?1-i// p// dA.y' (a • s yr) 1',?{ Jto. lioy Al €i114/KC tn4(4 -.kc i'l irc(BI(ba'7?.3b"3 (5 nxTl¢wL NTS Ions anwRnvTw 110 14FIS F?1AL HTRNPT DE..d. , 62srnlrny,aa§.1 MORTGAGE 7po- 5 'I TIIISMORTGAG9 hmdemh I61h 61" SEPTFMSOR 1996 al.rven rm NVI[;w. TOSSIN ADAMS AND MAURBEN ANNE, HuNUND AND HIVE 132 = HEX, M.' CNIF IOU, M 17011 . meal ?mmme-). .N to Nowpp«. NATIONAL NONE LOAN CORPORATION, A FLORIN OORPOPATION r wrprotion aMq'°r °M euhJeS v,W<r I0. Inral FLORIDA rnpH.mr.w is 116 NORTH PEDNi NICNNAY OEGRFI6L0 DMCH, PIAAIOA ])441 IAHJN 'L<Mer'1. WNE--. ftI .IhIIWLW Io Il-, nIOr PNIII'nM VIU.i.f 15,000.Dp .nw memmwml I. OWN,mn by 6mro.wt Nw ww, SIMMS. 16, 1990 W o .m. W I.. o-f m.^' le'LPrvvglP[ H,-ably hood. IF prinriptl. WHEN. WIF 0[ ,.H-'JU W[peOnm. Il ol w aw lp.III I. IN mHN vv 96pTCMBCR]1, 2010. TO SCCUR6 lu I.:.1, IM 111.11111-11. 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NdQ?a e? suvten /'?°^'1 n. uwv?icnm arrs.,.rc?x?.IlY muwme kqw me for nNr¢unt9 Vm¢nl m le mr [enan .m IS / nx6 uluvfztl m Ne r:Wr nM rcbroweey44u p£ f SIZE / THEY .nualM l]e x?m lnr apuTwe lartw a wnlvm. IN WnxLSi WHEI1fiOF. ln4tunlo 'myApd rrvi ellkM1lril. .?° WrrrM??WvYY+m "f Y.m uxvYb emu.. Ixba er. n,m cur 100 T-!40 P 012/010 F-041 loon No.: Dolt: Aaeflaa l tit, Ivan PoHW4Y ANlrtae: 122 OLD MILL DRIVE CAMP HILL. PE WSYLVANIA 17D1y LallLit "A" Lo,ol Deio;,dioo ALL Olo TFlL PARCCL o[Iund dmaw W Inwar Allen Towmldp, Cum+botlaad County. Poinallond., bounded and do.aribed ao Wllowo, W in BLGSNNINC as u.wiw ou thin ...thwt.ox. aid. bf Old MID nrivc m the southern lino of Lot Nn. 30: thence olonC the northwo leto side of Old Mill Drive, uoothwurdly by an etc having a radius of five hundred ....ty mad oiglataaft ona.hund.dUm (680.18) Wet, u d9 L.I. of oighty-tlvea and sixty oix ono-hand.dthe (83.13G) [Got to a btaka; change continuing sa¢thwardly by the said lino of Old Mill Drive by mere having a tattoo mf nutty (60) Iliac, a distan. of twenty-two and fifty-sight can hundredths (22.56) foot. a pin at the dividing Una botwoon Lot No.0 slid Let Ne. 8; they. along the dlyfidin; line botwoun let No. 0 and Lot No. 8, south 80 dagones 8 mhiu.a west, ono hund.d ed, hlyoovon and foorwan ono.b¢edendtha (187.14) foot to a atalro at lands now or Nrmorly aE 11ampt Brethren.; than. along said Ianda, north 0 dogreoa 43 snots. waat, brtysix and foonono n. haud.0h. (4414) lest W a pin at lands new or fatmarly of hfempt B.tlpra,and TUcl,ued Bair, thancn along snfd lands, north 14 depict 12 minmww oo.t, fortyeavan and two ono-hundeadehs (47 02) W.¢. ¢long said dividing Una, north 70 dogroac 63 olmah,. co.C o c ' hundeed eevm.ty lint ninv?yhve onc•hundmdtlu (170Afi) [sot m u stakeai soon. aloonj Jo, duo pointoftbLaw Nor 10e ndg the dividing lino beowii oan Got No. 0 and d LuC Na, 10, south 70 dognati 28 ea oar0. a Lho int -and io to ld t onm pun h Dirit" h (39,Z6) pfee, t to l¢ . a nala. o on thu narthwost-crn oiJc of Old Mill Dciv¢, the plate ofBLCINNI INNINC. 1 c.amvmc nmr• rv r 4'u" lo" Ii. I ew+ w IA - wn JAO t4 N Mlr h I l ?tWVT.,? P e Y ?l 4a s Pet 1- r r ll f'`l`: Gr PA, estd497rf¢ ,697 SEP. 7.2005 3:18PM LOAN SERVICING CTR NOTE NO. 504 P.4 SEPTEMBER 16, 198 DEERFIELD BEACH FLORIDA 1Datej City _ State 122 011) MILL DRIVE, CAMP HILL, PENNSYLVANIA 17011 property Address I City Sam - Zip Code I. BORROWER'S PROMI TO PAY In return for a loan that I have received, 1 promise w pay U.S. $ 45, 000. 00 (this amount will be called "principal"), plus Inte st, to die order of the Lender, The Lender Is NATIONAL H014E LOAN CORPORATION, A F ORIDA CORPORATION . I understand that the Lender may transfer this Note. The Lander or anyon who takes this Note bytransfer and who is entitled to receive payments under this Note Willits: called the "Now Holder." z. INTEREST %. I will pay interest at a year) rare of 12.990 Interest wllibe charged on t et part of principal which has not been paid, Interest willbe charged beginning on the date of this Note and continuing until the ill amount of principal has been paid. 3. PAYMENTS I will pay principal and Inner st by making payments each month of U.S. $ 526. 89 I will make my payments on the 21st day of each month beginning on OCTOBER 1998. I will make these payments ever V month until I have paid all of the principal and interest and any other charges, described below, that l may owe under this Nom. If, on SEPTEMBER 21, 2018 , I still owe amounts under this Now, I will pay all thou amounts, in full that date. I will make my monthly pay idids at 116 NORTH FEDERAL HIGHWAY, DEERFIELD BEACH,.., FLORIDA, 33441 or at a different place if required by the Now Holder. 4, BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Over, us Payments If the Note Holder has not ceived the full amount of any of my monthly payments by the end of 15 calendar days after the dam It is due, I will pay a I e charge to the Now Holder. The amount of the charge will be 10.000 % of my overdue payment, but not leas than U.S S 5 . 00 and not mom than U.S. $ 52.69 I will pay this law charge and once on any lam Payment. i (B) Default If 1 Ido not Pay the full amo m of each monthly payment by the dam stated in Section 3 above. I will be in default Even if, at a time when 1 a in OCfahic, the Note Holder does trot require me w pay immediately in full as described below, the Note Holder will still have the ight w do so if I am in default at a later time. (C) Notice From Note Hill ler If I am in default, die Now older may send me a written notice telling me that ifI do not pay the overdue amount by a certain dam, the NOW Holder may malt. ire me ro pay immediately the full amount of principal which liar not been paid and all the interest that I owe on that amount. Tha data roust beat least 30 days after the dam on which die mdce is mailed to me or, Ifit isnot mailed, 30 days after the dam on whicl it is delivered to me, (D) Payment of Note Hal er's Costs and Expenses ' If the Nom Holder has requ red mew pay Immediately in full as described above, the Note Holderwill have t1iiflght W be paid hack for its coats and expense to the extent not prohibited by applicable law. Those expenses include, for example, reasonable auorneys' fees.:'' S. THIS NOTE SECURED A MORTGAGE - In addition to tilt promcoon; given to the Nate Holder under this Note, a Mortgage, dated SEPTEMBER 16, 1998 , protects the Note He der from possible leases which might result if I do not keep the promises which I make in this Nom, That Mortgage describes how a d under what conditions I may he required to make immediate payment in full of all amounts that I owe under this Note. 6, BORROWER'S PAYMFN S BEFORE THEY ARE DUE I have the right to make p merits of principal at any time before they are due. A payment of principal only is known as a "prepayment." When I make a prepayment, I will tell the Note Holder in a letter that I am doing so, A prepayment of all of the unpaid principal is known me a " pll prepayment." A prepayment of only part of the unpaid principal is known us "partial prepayment." 1 may make a full prepayment Ora partial prepayment without paying am penalty. Tim Note Holder will use all of my prepaymmh to reduce the amount of principYl6'I that I owe under this Nom. If 1 make a partial prepayment, them willbe no delays in dm due data or changes in the amounts of m monthly payments unless the Note Holder agmes in writing to those delays or changes. I may make a full prepayment at any rime, f I choose to make a partial prepayment the Note Holder may require me w make the prepayment on the same day that one of my monthly Payments is due, The Now Holder may also require that the amount of my partial prepayment he equal to the m un1 of Principal that would have been part of my next one or more monthly payments. 7. BORROWER'S WAIVE . I waive my rights w require the Now Holder m do certain things. Those things are: (A) to demand payment of amounts due (Known as "presemmem"); (0) 13 give notice that amounts due have not been paid (known as "notice of dishoifort(am obtain an official certification of nonpaym nt (known as a "Protest'), Anyone else who agrees w keep the promises made io'I W?Iore ut'vrbb agrees to make payments to tilt Now Holder If I fail w keep my promises under this Nam, or who signs this Now to transfer it to someone also also waives these rights. These persona are known as "guarantors, sureties and endorsers." 8. GIVING OF NOTICES Any mime that must be giv, n to me under this Note will be given by delivering it or by mailing it by certified "mail addressed to me at the Property Address abo e. A notice will be delivered or mailed to me at a dlffamnt address if I give the Now Holder a mute of my different address. Any notice that must be giv n in the Nate Holder under this Note will be given by mailing it by certified mail to the Note Holder at the address stated in Section 3 above. A notice will he mailed to am Note Holder at a different Rod=& If I ant given a notice of that different address. PRNNSYLVANIASECOND ORTGAGH •I(ed4114MAIMII.MC UNmORM INSTRUMENT page 1. at2 Perm 3939 NO. 584 P.5 -- SEP. 7.2005 3:19PM LOAN SERVICING CTR 9. RESPONSIBILI'fV OR ER6,/ IDER THIS NOTE - ,? If mare than one person Igm this . .u, each of us 13 fully end personally obligated to p,,,, the full amount owed and W: keep'all of the promises made in dtis ate. Any guarantor, surcry, or ondorser of this Now (as described )p Section 7 above) is also obligate) W do these things. The Now older may onto= its rights under this Note against each of to indiVldually or against all of us together. This means that any one of u may be required to pay all of the amounts owed under this Note. Arty person who takes over my rights or obligations under this No will have all of any rights and Must keep all of my promises made in this Now. Any person who takes over the righM or obligations f a guarantor, surety, or endorser of this Now (as described in Section 7 above) is also obligated w keep all of me promises made in Its Note. has executed an acknowledges reeeipt of pages 1 and 2 or this Note. ADAMS I -? Borrower W MEN ADAMS Borrower »orrowel Borrower Borrower 1 PENNSYLVANIA-SECOND M*TGAGE -1100-PNMAM1114C UNIPOBM RISM4UWMNP J Page 2 oft Farm 3939 uaar Nit! SEP. 7.2005 2:20PM LOAN SERVICING CTR ASSIGNMENT OF NOTE WITHOUT RECOURSE r NO. 504 P.6 For valuable conside 'on, receipt of which is hereby acknowledged, the undersigned hereby sells, transfers, endorses, assigns and elivers to: PALADIN FINANCIAL, INC. All of his rights, ride, nd interest in and to the attached promissory note dazed: SPP'rESNnFR 16, 1998 in die face amount of $45, 000. 00 The borrowers in said promissory note are: JOSEPH ADAMS, MAUREEN ADAMS Said promissory now seeored by a security instrument of me sauce dare on real property located at: 122 O ID MILL, DRIVE, CAMP HILL, PENNSYLVANIA 17011 NATIONAL HOMLOAN CORPORATION, A FLORIDA CORPORATION (Beneficiary) transfers all rights ace led or to accrue under said note and securing security instrument in which the undersigned is the Ben ficiary and borrowers are uustors. .. . Dated: qI'v, S BENEFICIARY: NAT; AL FL I A By. Name and Tide LOAN '9UNE CASTAGNOL^ VICE ?PESIDENT l `? ?Vgpq c w%`t} §L ?1, Date: ?-d?_b I Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions you may call the Pennsvlvania Housing Finance Agenev toll free at 1-800-342-2397 (persons with impaired hearing can call (7177) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 AFECTA 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 SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Joseph Adams and Maureen Adams PROPERTY ADDRESS: 122 Old Mill Drive„ Camp Hill, PA 17011 LOAN ACCT. NO.: 73681384/RTL ORIGINAL LENDER: National Home Loan Corporation CURRENT LENDER/SERVICER: Celink LAW FIRM FILE NO.: 05-24856 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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 FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS.IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT'- EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES- If you 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 designated consumer credit counseling agencies for the county in which the property 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 immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have 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. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE 1S FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. f you have filed bankruptcy, you can still apply for Emergency Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 122 Old Mill Drive„ Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: April 23, 2005 to September 23, 2005 @ $526.89 = $3,161.34 Other charges (explain/itemize): Late Charges: May 9, 2005 to September 9, 2005 @ 26.34 = 131.70 TOTAL AMOUNT PAST DUE: = $3,293.04 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not ap lin cable): 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 $3,293.04, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check, certified check or monev order made pavable and sent to: Celink 3900 Capital City Blvd Lansing, Michigan 48906 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment 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 foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the creditor 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 attorney'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 you care the default within the THIRTY (30) DAY period you will not be required to pay attornev's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default andprevent the sale at anv time uro to one hour before the Sheriffs Sale You may do so by paving the total amount [hen past due, plus anv late or other charges then due reasonable attornev's fees and costs connected with the foreclosure sale and any other costs contected with the Sheriffs Sale as specified in writine by the lender and by performing anv other reauiremenis under the morgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 2520 Renaissance Blvd. Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 Contact person: liana Zion EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs 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 Sheriffs 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 X may or _ may not (CHECK ONF) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO 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 (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Counseling Agencies CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Lingleslown Road Harrisburg, PA 17102 888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 800-342-2397 Page 1 of 1 http://www.phfa.org/prograins/heniap/tenders/heaPage2l .html 9/19/2005 Date: q- t? VC6 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. The name address and phone number of Consumer Credit Counseling Agencies serving 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 ArECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMF,NTE 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 SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: LAW FIRM FILE NO.: Joseph Adams and Maureen Adams 122 Old Mill Drive„ Camp Hill, PA 17011 73681384/RTL National Home Loan Corporation Celink 05-24856 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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. 'T'EMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS.IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES- If you 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 designated consumer credit counseling agencies for the county in which the property 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 immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have 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 012 IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE. ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. L you have tiled bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin¢ it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 122 Old Mill Drive„ Camp Hill, PA 17011 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: April 23, 2005 to September 23, 2005 @ $526.89 = $3,161.34 Other charges (explain/itemize): Late Charges: May 9, 2005 to September 9, 2005 @ $26.34 = $131.70 TOTAL AMOUNT PAST DUE: _ $3,293.04 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if 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 $3.293.04, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable nod sent to: Celink 3900 Capital City Blvd Lansing, Michigan 48906 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the tender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the creditor 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 attorney's fees actually incurred by the tender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the tender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personalty for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-if you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, You still have the right to cure the default and prevent the sale at anv time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus anv late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing anv other xeauirements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-it is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) 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. If money is due, such payment must be in cash, cashier's check, certified check or money order made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER: Name of Lender: C/O The Law Firm of Shapiro and Kreisman Address: 2520 Renaissance Blvd. Suite 150, King of Prussia. PA 19406 Phone number: 610 278-6800 Fax number: (610) 278-9980 Contact person: liana Zion EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MOR'T'GAGE-You X may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO 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 (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Counseling Agencies CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 511, Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 800-342-2397 Page 1 of 1 http://www.phfa.org/progrms/hemap/tenders/beaPage2l.litml 9/19/2005 3 9048 L 3OOOdlZ WO213 031IVW SOOZ 9Zd3S 681.9££b000 006'00 $ v) z9 S3MOe A3N1H Cz ,V lt? 5 'sbd o-0 O z tO N ] W S d z p z Q Q LL+ a? 9 O t` zE ¢O o d N Q: 01 oz o CO c1l, a°y, o ? > b?A a - N E o w m O> V a ti O N .-r LL N >o Ea a U.S. Postal Service,e, CERTIFIED . i M (Domestic -0 ra Postage $ N ru Certified Fee O Q O Return Receipt Fee (Endorsement Required) e .? ` q o IT Restricted Delivery Fee O j t0 M (Endorsement Required) 37Lp f ^ ty1W f L C $ Cf r Total Postage & Fees Ln O 123 enf TO {j/? r' A/! /( CERTIFIED MAIL. RECEIF (Domestic Mail Only; No Insurance Covers, N Postage $ . O C3 Certified Fee hh V 1SQ? ?- 4 O O etum fleceipl Fee 11=M Postmadc\ \ Hem rsemenf Requiretl) (Entlo Om' (Endarsem Cnf RequireFee d) ?yl ? Y SCP 2 6 c/W? CO Total Postage 8 Fees \ (_ k5ent To T . ?f ?• h.... __________________ .. ;Po?N. I ?. ni 9Gh5L 3000dtz lydOcld 031lb'W ?n(z Yt'. d_? ? _ o06-00$ n-7n ?. sin a 3uir z ?_'Zr? ?^ fttdi? C 0 z y w 0 0 Ky ?z E 00 ?LL wo mj a' o ri V C O a a R U. V. >ti 4-a O biG s 0 N Z N 7 N M O VERIFICATION Rana Zion, Esquire hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiff's verification could not be obtained within the time necessary to file this pleading, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 19 Pa.C.S. Sec. 4904 relating to unworn falsification to authorities. SHAPIRO & KREISMAN BY:-SIIlana Zion, uire Attorney for Plaintiff Dated: I I -I-" ?. Vt Lrt ;. C r`-C7 ^? 1 J u SHERIFF'S RETURN - NOT SERVED CASE NO: 2005-05709 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROY AL FINANCE AND LOAD COMPAN VS ADAMS JOSEPH ET AL R. Thomas Kline Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: ADAMS MAUREEN unable to locate Her in his bailiwick but was He therefore returns the COMPLAINT-MOAT FORE the within named DEFENDANT NOT SERVED , as to , ADAMS MAUREEN 2 OLD MILL DRIVE CAMP HILL, PA 17011 DEFENDANT FILED 1-04-6525 Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 16.00 So answers:_ - c- R. n R. Thomas Kline Sheriff of Cumberland County SHAPIRO & KREISMAN 11/09/2005 Sworn and subscribed to before me this _A? day of aOOS A.D./ Prothonotary SHERIFF'S RETURN - NOT SERVED CASE NO: 2005-05709 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROY AL FINANCE AND LOAD COMPAN VS ADAMS JOSEPH ET AL R. Thomas Kli Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: JOSEPH but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT-MORT FORE NOT SERVED , as to the within named DEFENDANT ADAMS JOSEPH 122 OLD MILL DRIVE PA 17011 FILED BANKRUPTCY. 1-04-652 Sheriff's Costs: So answers, Docketing 18 .00 Service 14 .40 Affidavit .00 'R. Thomas Kline Surcharge 10 .00 Sheriff of Cumberland County 00 42 .40 SHAPIRO & KREISMAN 11/09/2005 Sworn and subscribed to before me this ??pfh day of A. 1). Prothonotary SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy At Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & KREISMAN, LLC BY: lti L- Grp J Ilana Zion, Esqui Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., JOSEPH REJENT, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 86727, 59621 & 87137 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 PLAINTIFF VS. Joseph Adams and Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 DEFENDANT(S) n C r o n 7i i C ' Ur C - W - j C?J tl COURT OF COMMON PLEAS cn CUMBERLAND COUNTY NO: 0.9 -,5767 li I 'U cC-7-E[2 ? COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 3J South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN - REGULAR ? r CASE NO: 2005-05709 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROY AL FINANCE AND LOAS COMPAN ADAMS JOSEPH KENNETH GOSSE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ADAMS JOSEPH the DEFENDANT VS , at 2006:00 HOURS, on the 29th day of November , 2005 at 122 OLD MILL DRIVE CAMP HILL, PA 17011 JOSEPH ADAMS by handing to 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 .00 Service 14.40 Affidavit .00 Surcharge .00 .00 14.40 Sworn and Subscribed to before me this (,°2 day of 'Ob 11/ A. D. c Pro_ o ary / So Answers: R. Thomas Kline 11/30/2005 SHAPIRO & KREISMAN By: u y r'f i SHERIFF'S RETURN - REGULAR t CASE NO: 2005-05709 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROY AL FINANCE AND LOA COMPAN VS ADAMS JOSEPH ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ADAMS MAUREEN the DEFENDANT at 2006:00 HOURS, on the 29th day of November , 2005 at 122 OLD MILL DRIVE CAMP HILL, PA 17011 MAUREEN ADAMS by handing to a true and attested copy of COMPLAINT - MORT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 00 00 Sworn and subscribed to before me this 4!' day of {A/. a do-S' A. D. r rot o ary So Answers: R. Thomas Kline 11/30/2005 SHAPIRO & KREISMAN By: e u "7 ff SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company ; PLAINTIFF VS. ; Joseph Adams and Maureen Adams COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY DEFENDANT(S) ! NO:05-5709 CIVIL TERM PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $48,560.97 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $42,505.12 Interest at 12.99% from March 23, 2005 to January 6, 2006 (289 days @ $14.17 per diem) $4,095.12 Late charges (for certain months prior to default and every month after at a rate of $26.34 per month) $210.72 Title Search Report Fees $250.00 Attorneys Fees (As stated in Complaint) $1,500.00 TOTAL AMOUNT DUE n BY: $48,560.97 t/1/ld?b?i? Joseph Rejent, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $48,560.97. 05-24856 1 Pro. rothy. SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company ; 3900 Capital City Boulevard Lansing, MI 48906 PLAINTIFF vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY 05-5709 CIVIL TERM Joseph Adams and Maureen Adams DEFENDANT(S) STATE OF: COUNTY OF THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. SHAPIRO & KREISMAN, LLC By:_ ?d L?xl Jos h Rejent, squire Sworn to and subscribed before me this day of 2006. ?G/L 7 ry Public Nl1fYLVANIA L DAc otKY Pu om?1' CWMY _ - 50ii SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF vs. Joseph Adams and Maureen Adams DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Joseph Adams DATE OF NOTICE: December 20, 2005 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 (10) days from the date of this notice, a Judgment maybe entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la action requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o 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 usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 ` 46 Wept ent, Esquire Shapiro & Kreisman, LLC Attorney for Plaintiff 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 la fecha de esta notifrcacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en so contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a on abogado immediatamente. Si usted no tiene abogado o si no tiene dinero sufrciente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Jos ph Rejent, Esquire Shapiro & Kreisman, LLC Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Joseph Adams and Maureen Adams DEFENDANTS NO: 05-5709 CIVIL TERM CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, December 14, 2005 to the following Defendants: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Marquita S dl el Legal to Joseph ejent, Es re for Shapiro & Kreisman, LLC SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:05-5709 CIVIL TERM CERTIFICATE OF SERVICE I, Joseph Rejent, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Date mailed: SHAPIRO & KREISMAN, LLC BY: U (?k Jose h ejent, squire Attorney for Plaintiff 05-24856 SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Joseph Adams and Maureen Adams DEFENDANT(S) j NO:05-5709 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 SHAPIRO & KREISMAN, LLC BY: `w U Jo eph Rejen , Esquire Attorney for Plaintiff 05-24856 fLll` O l?) u? n n T T 11. . .A? r_ ?? C_1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEASCumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Roy Al Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:05-5709 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the abov? proceeding as indicated below. C TIS G Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY JOSEPH REJENT, ESQUIRE AT (610) 278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEASCumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Joseph Adams and Maureen Adams DEFENDANT(S) NO:05-5709 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as µrdicated below. g TIS Ir Lonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY JOSEPH REJENT, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Roy Al Finance and Loan Company Plaintiff ( ) Confessed Judgment (>() Other File No. rv vs. Joseph Adams and Maureen Adams Defendant TO THE PROTHONOTARY OF THE SAID COURT: Amount Due $ig,56p 97 Interest U7/n6 to 6/7/06 $2.626.56 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of rr.,,mh Prlanrl for debt, interest and costs, upon the following described property of the defendant(s) County, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 71 (Indicate) Index this writ aoainst the oarnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. n Date Signature: ?l Print Name: Joseph Rejent. Esq. Address: Shapiro & Kreisman LLC 2520 Renaissance Blvd., Ste 150 lting-el-Prussia,--RA 14406- Attorney for: Roy Al Finance & Loan co.. Plaintiff (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). m (A v) If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. cc? GQ f_ ti ?i L1 • Ci WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5709 Civil CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ROY Al FINANCE AND LOAN COMPANY, Plaintiff (s) From JOSEPH ADAMS AND MAUREEN ADAMS (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 $48,560.97 Interest 1/7/06 TO 6/7/06 - $2,626.56 Atty's Comm % Airy Paid $154.80 Plaintiff Paid Date: JANUARY 31, 2006 L.L. $.50 Due Prothy $1.00 Other Costs Pr thonotaryc (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH REJENT, ESQUIRE Address: SHAPIRO & KREISMAN, LLC 2520 RENAISSANCE BLVD., STE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 59621 ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one hundreths (590.18) feet, a distance of eighty- three and sixty-six one hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an are having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. W SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Roy Al Finance and Loan Company, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 122 Old Mill Drive, Camp Hill, PA 17011. Name and address of Owner(s) or Reputed Owner(s) Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 4. Name and address of the last recorded holder of every mortgage of record: Roy Al Finance and Loan Company, Plaintiff 3900 Capital City Boulevard Lansing, MI 48906 GMAC Mortgage Corp. 3451 Hammond Avenue Waterloo, Iowa 50702 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 122 Old Mill Drive, Camp Hill, PA 17011 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: Id C??t J se h Rejen , Esquire 05-24856 ?, ?') rrs ? c lJ ? "f I ?.? ? T _ l {71 W ?? T1 ,T '? J ? 1 ^ ??{?{ .? ti "=i .? ;U ?? -G SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on June 7, 2006 at: Cumberland County Sheriffs Office I Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one hundreths (590.18) feet, a distance of eighty- three and sixty-six one hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. <., '? ' r_7 <>> -,i _' C ; ? ? '?! ? 1 CJ ?. ? ??} -i i C? ?.?CCi _? - `aJ C? 'C SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy A] Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on June 7, 2006 at: Cumberland County Sheriffs Office I Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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. You may 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 of 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 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. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one hundreths (590.18) feet, a distance of eighty- three and sixty-six one hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. ?1 L L '?1 V +, T 00 ' 1? SHAPIRO & KREISMAN, LLC ?BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company ; COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY VS. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANT(S) CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Heather Doyle, Legal Assistant for Shapiro & Kreisman, LLC, attorneys for the Plaintiff, Roy Al Finance and Loan Company, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on March 9, 2006, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & KREISMAN, LLC BY: C Heather Doyle Legal Assistant 05-24856 ?, r. ?,TZw t o N W ? A N 6 tP ? ? ra y O O ?". ZT y N .? N O (SI N a • ( N ? `, tom- ? , ' 1 w ? v ^l` ` r - G> 3 w ? .Z W r. ? fry a 3 ?: I r DDD z Cr- -' 9 c > n - . 9='3 ° `` c?.. O m o `?, n 9 G W 3 ° ? p m .n w - c S N ? . ? ? N ? w O V. m 6 ao? N O ^` d m'w ;°a m 2.O° ws'smm? ? ? r . p03C?Np'O H _... ?u?a Yi4m 7 m m 6 A3 '° n 3 ? ? mC C j A N? ?m » 3 4 oat.N? m o 3 a gi t0nm ?3? 1woa X25 f N??KOd. 4.?f m2a K C}To m' NN°?d3 i?=moz nv?m?d ?P vN c3 ? 69... 7 . ra???EC'tP,`ly 1 Ate" DD $m F ?. Z ? 6 o N N c ? w. W N d.n 9 n 0.w O 1] J W N n[P w ? ? O N I . n (b 3 no TN '31 x- m? C m a T9 m O m m N 1_ Roy Al Finance and Loan Company VS Joseph Adams and Maureen Adams In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5709 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph Rejent. Sheriffs Costs: Docketing 30.00 Surcharge 30.00 Prothonotary 1.00 Law Library .50 Poundage 17.14 Advertising 15.00 Levy 15.00 Posting Handbills 15.00 Postpone Sale 20.00 Certified Mail 1.83 Mileage 28.16 Share of Bills 19.57 Patriot News 328.40 Law Journal 353.00 $ 874.60 So Answers: R. Thomas Kline, Sheriff B63"_ Real Estate ergeant /, S`° j?aLgq M SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Joseph Adams and Maureen Adams DEFENDANTS NO: 05-5709 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Roy Al Finance and Loan Company, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 122 Old Mill Drive, Camp Hill, PA 17011. 1. Name and address of Owner(s) or Reputed Owner(s) Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 t 4. Name and address of the last recorded holder of every mortgage of record: Roy Al Finance and Loan Company, Plaintiff 3900 Capital City Boulevard Lansing, MI 48906 GMAC Mortgage Corp. 3451 Hammond Avenue Waterloo, Iowa 50702 Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 122 Old Mill Drive, Camp Hill, PA 17011 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: (Aqk*=== zVemmug J se h Rejen, Esquire 05-24856 SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on June 7, 2006 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. 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 (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land. situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an are having a radius of five hundred ninety and eighteen one hundreths (590.18) feet, a distance of eighty- three and sixty-six one hundreths (83.66) feet to a stake;. thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake, at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on June 7, 2006 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone : 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land. situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one hundreths (590.18) feet, a distance of eighty- three and sixty-six one hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake. at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 05-5709 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ROY Al FINANCE AND LOAN COMPANY, Plaintiff (s) From JOSEPH ADAMS AND MAUREEN ADAMS (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 $48,560.97 Interest 1/7/06 TO 6/7/06 - $2,626.56 Atty's Comm % Atty Paid $154.80 Plaintiff Paid Date: JANUARY 31, 2006 L.L. $.50 Due Prothy $1.00 Other Costs Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH REJENT, ESQUIRE Address: SHAPIRO & KREISMAN, LLC 2520 RENAISSANCE BLVD., STE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 59621 Real Estate Sale # 13 On February 08, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 122 Old Mill Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 08, 2006 By: ^ ^? J ],, :yV Real Estate Sergeant b O :b V Z - 93.E Vol J? 83HS 3141JO 3 1ij00 0 Una f V4 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#13 .................... J?'' .......................... Sworn to and bs r' a ore me this 18th da of May 2006. A.D. NOTARIAL SEAT Terry L. Russell, Notary Public City of HaVisburg, Do phin County My Comnj(ssion Exp June 6, 2006 Member.Pef?nsvl ni a?ocfalionotNotarie! ,ail h / /? - - - NOTARY PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 I? tt? At ,A#M h AILOFIMFAR 0f leadsidwmL w p ``AWud&so*adarfoW"t0 wit BAG at a Ok. as dr aide c[ ?? Ltctta ? ? Soadeoa'liee of I.ot rro.la; ti>?,i?:? rleam aide ofOld ? 1)rise, SootL+1?' 1+9 an ar ba?vue6a a,?'iae of sae h? ? ? ? °'e htodadha (59018) fed; a d?t+oce of esalt}? ? ?'" 6x ow h=&eft (8366 fat to 1 state; d"m :by the acid fora of VA ME Dan by irWt a radon of way (00) dstaat?p d u'ir°Sf a!° si.f>m feet, x between I.d N0.4 a? t:0t rro. a a?cc:?s.a. i?ia<8 alal i+K1ik$, &Vift SM& 80 dr8eeea 8 orturw hwideed ,_,,m ad iooMS 00 hordeet?{18714) fad to a lalee????? BtotiKta: tiles +dlae6 43 c WON . y + :atad IaYA0Ai/ we d(4614) iat to & Pig At W& am -bf bmkWs b*w B* &=w ? ,, U' 14 &Vm 12 ,WW9 Hut, fadb vm MPI tyro aae 00" s (479a) ties*" ug Toe,N 7d I,". l1w lw W, ti7s951 bd ID & state puipt of Ae 1oea of Ld No. 9,10 and i tie?l? bae ww" lot No. 9 adt ELat ? 28 mimetea Beat, &ittyame and thirty-aa 0®e hm*edu ("A f* tp a adz an the Mail W Mew aide d CM Ma D'M 'the place of B • PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 7, 14, 21, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Covne! Editor 1K TO AND SUBSCRIBED before me this 21 day of April, 2006 V.- ,11,AR!A 1- TEAL ?, , Curr,-,ryr? 't (.i County REAL ESTATE SALE NO. 13 Writ No. 2005-5709 Civil Roy Al Finance and Loan Company VS. Joseph Adams and Maureen Adams Atty.: Joseph Rejent ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hun- dred ninety and eighteen one hundreths (590.18) feet, a distance of eighty-three and sixty-six one hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty- eight one hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 de- grees 8 minutes west, one hundred eighty-seven and fourteen one hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers an Rich- ard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one hundreths (47.02) thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line be- tween Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty- nine and thirty-six one hundreths (39.36) feet to a stake on the north- western side of Old Mill Drive, the Place of BEGINNING. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Roy Al Finance and Loan Company PLAINTIFF vs. Joseph Adams and Maureen Adams () Confessed Judgment (x ) Other File No. 05-5709 Civil Term Amount Due $48,560.97 Interest February 1, 2006 to March 7, 2007 is $6,912.00 Atty's Comm Costs DEFENDANTS TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a I defendant(s) described in the attached exhibit. / Date: - - Signature:( Print Name: Address: ns against Lauren R. Tabas, Esquire 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # 93337 f D Iv- C?L w LA w 00 4 C", a o C C C Q?? 6D u> a -- -- " .y w w? SHAPIRO & KREISMAN, LLC BY: JOSEPH REJENT, ESQUIRE ATTORNEY I.D. NO: 59621 2520 RENAISSANCE BLVD., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY 05-5709 CIVIL TERM VS. Joseph Adams and Maureen Adams DEFENDANT(S) STATE OF: ke- I ] V? ?2 COUNTY OF: AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. SHAPIRO & KREISMAN, LLC By: cli Jos h Rejent, squire Sworn to and subscribed before me this day of 2006. o Pub is COMMON yyEl?LTIi OF PENNSYLVANIA NpTARU1L SEAL Nuf?rr W,tJAW D. MAAYALL, Pubic UPW M . Comb ., Co L ,_ C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5709 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ROY Al FINANCE AND LOAN COMPANY, Plaintiff (s) From JOSEPH ADAMS AND MAUREEN ADAMS (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 $48,560.97 Interest 2/1/06 TO 3/7/07 IS $6,912.00 Atty's Comm % Atty Paid $1041.90 Plaintiff Paid Date: SEPTEMBER 28, 2006 (Seal) L.L. Due Prothy $1.00 Other Costs C s R. Lon otary By: Deputy REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 ! I SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 Roy Al Finance and Loan Company, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 122 Old Mill Drive, Camp Hill, PA 17011. Name and address of Owner(s) or Reputed Owner(s) Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 ,t 4. Name and address of the last recorded holder of every mortgage of record: Roy Al Finance and Loan Company, Plaintiff 3900 Capital City Boulevard Lansing, MI 48906 GMAC Mortgage Corp. 3451 Hammond Avenue Waterloo, Iowa 50702 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 122 Old Mill Drive, Camp Hill, PA 17011 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. Section 4904 relating to unsworn falsification to authorities. KREISMAN, LLC BY: Tabas, 05-24856 C? r-a iT 1-l --7 - r' - C:7 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: 93337 3600 HORIZON DRIVE., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has.happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT ?A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 w ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one-hundreths (590.18) feet, a distance of eighty- three and sixty-six one-hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one-hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one-hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one-hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers, and Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one-hundreths (47.02) feet to a pin at the dividing line between Lot No. 9 and Lot no. 17; thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one-hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one-hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. BEING the same premises which Patricia A. Shillow, widow, by Deed dated May 8, 1998 and recorded in the Cumberland County Recorder of Deeds Office on May 20, 1998 in Deed Book 177, page 624, granted and conveyed unto Joseph Adams and Maureen Adams, husband and wife. C.. -TI co ?. L- D Sim C f a SHAPIRO & KREISMAN, LLC BY: LAUREN A. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar #93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM Joseph Adams and Maureen Adams DEFENDANT(S) CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Heather Whitman, Legal Assistant for Shapiro & Kreisman, LLC, attorneys for the Plaintiff, Roy Al Finance and Loan Company, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on January 16, 2007, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & KREISMAN, LLC BY:WC1 - Heather Whitman Legal Assistant 05-24856 N ? m a N K ?I . ? I m N `?-vl 6 C 61 cT? I .P I I 1 Z m NI I ??, ? -' W O N CD W ? Z N X j ? I J r (t m °w % F UG J (17 1 0 C) co c, m v 3 lJ 10 Y o? OD N - _ 1 N ? ? - l l J 1/ J ?? 7 CG 1 1 N A ro ro v ? ? ? w O /'1t I I ? o? CD 0 t CI'D m W N m -? - vc 1 ? ? m GI - ? m m ID nl ? -? ? O ut?tfi?ps T o 0 to ? ? 2 (n W 3' 'S1 ? _ _? 1 W CI as n m . -- ?6 ;, ? i o fD -_ i - i O ZQ 0, U N O N n_ N O O N Z N LL Roy Al Finance and Loan Company VS Joseph Adams and Maureen Adams In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5709 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 13, 2006 at 1810 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Joseph Adams and Maureen Adams, by making known unto Joseph Adams personally and husband of Maureen Adams, at 122 Old Mill Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2007 at 1420 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joseph Adams and Maureen Adams located at 122 Old Mill Drive, Camp Hill, Cumberland County, 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: Joseph Adams and Maureen Adams, by regular mail to their last known address of 122 Old Mill Drive, Camp Hill, PA 17011. These letters were mailed under the date of January 12, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Lauren Tabas. Sheriffs Costs: Docketing 30.00 Poundage 20.36 Posting Bills 15.00 Advertising 15.00 Prothonotary 1.00 Mileage 26.40 Certified Mail 5.34 Levy 15.00 Surcharge 30.00 Law Journal 419.00 Patriot News 404.66 Postpone Sale 40.00 Share of Bills 16.83 nn 7?j??d ' $1,038.59 ? ?` ?.uo ? 5 8319 So Answe R. Thomas Kline, Sheriff BY dn j Real Estate rgeant Ah SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Roy Al Finance and Loan Company, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 122 Old Mill Drive, Camp Hill, PA 17011. 1 Name and address of Owner(s) or Reputed Owner(s) Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 2 3. Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Name and address of Defendant(s) in the judgment: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Roy Al Finance and Loan Company 3900 Capital City Boulevard Lansing, MI 48906 4. Name and address of the last recorded holder of every mortgage of record: Roy Al Finance and Loan Company, Plaintiff 3900 Capital City Boulevard' Lansing, MI 48906 GMAC Mortgage Corp. 3451 Hammond Avenue Waterloo, Iowa 50702 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 122 Old Mill Drive, Camp Hill, PA 17011 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. Section 4904 relating to unsworn falsification to authorities. KREISMAN, LLC BY: Tabas, 05-24856 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: 93337 3600 HORIZON DRIVE., SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY Vs. Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. 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 (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has.happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one-hundreths (590.18) feet, a distance of eighty- three and sixty-six one-hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an are having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one-hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one-hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one-hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers, and Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one-hundreths (47.02) feet to a pin at the dividing line between Lot No. 9 and Lot no. 17; thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one-hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one-hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. BEING the same premises which Patricia A. Shillow, widow, by Deed dated May 8, 1998 and recorded in the Cumberland County Recorder of Deeds Office on May 20, 1998 in Deed Book 177, page 624, granted and conveyed unto Joseph Adams and Maureen Adams, husband and wife. SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. ; Joseph Adams and Maureen Adams NO: 05-5709 CIVIL TERM DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 Your house (real estate) at: 122 Old Mill Drive, Camp Hill, PA 17011 13-24-0805-085 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00 AM, to enforce the court judgment of $48,560.97 obtained by Roy Al Finance and Loan Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Roy Al Finance and Loan Company the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. 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. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. 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. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Telephone: 717-249-3166 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 05-24856 ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hundred ninety and eighteen one-hundreths (590.18) feet, a distance of eighty- three and sixty-six one-hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty-eight one-hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 degrees 8 minutes west, one hundred eighty-seven and fourteen one-hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one-hundreths (46.14) feet to a pin at lands now or formerly of Hempt Brothers, and Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one-hundreths (47.02) feet to a pin at the dividing line between Lot No. 9 and Lot no. 17; thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one-hundreths (170.95) feet to a Stake at the junction point of the lines of Lot No. 9, 10 and 17 thence along the dividing line between Lot No. 9 and Lot No 10, south 70 degrees 28 minutes east, thirty-nine and thirty-six one-hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGINNING. BEING the same premises which Patricia A. Shillow, widow, by Deed dated May 8, 1998 and recorded in the Cumberland County Recorder of Deeds Office on May 20, 1998 in Deed Book 177, page 624, granted and conveyed unto Joseph Adams and Maureen Adams, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5709 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ROY Al FINANCE AND LOAN COMPANY, Plaintiff (s) From JOSEPH ADAMS AND MAUREEN ADAMS (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 $48,560.97 Interest 2/1/06 TO 3/7/07 IS $6,912.00 Atty's Comm % Atty Paid $1041.90 Plaintiff Paid Date: SEPTEMBER 28, 2006 L.L. Due Prothy $1.00 Other Costs - 2"- ( 4 74 - Curtis . Long, Pro o ry (Seal) REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 By: Deputy Supreme Court ID No. 93337 Real Estate Sale # 06 On October 31, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 122 Old Mill Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. am r Date: C ktober 31, 200 9GOl By: it, fmu, ? Real Estate Sergeant THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and the 7th day(s) of February 2007. 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 Sworn to and su cri a re me this 26th of February 2007 A.D. S A L E #6 COMAAONWEALTH OF PENNSYLVANIA Notarial Seal Terry L. Russell, Notary Public City Of Hari burg, D hin County My Commi ion Ex June 6, 2010 kas... - Pnn QAAAn' ssociation of Notaries NOTARY CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 to ??aq?a?11??SdC: Of li?rail?tlo A. ?liaaf? Md. to M 6D r wAh t0 lw fsrleeu mm t pis 14' X ad two Sl ddi ?"? "` (1 Ibex to a Walt #i 1Yq loos taf t9e Ban of Ld No. 9, l? ted' 7 pr?p??g tic br;ft ]m¢ 6etaea? 7Ni..?artR?'9? as #? MEta?ir e(! ?e ?eplpeaf PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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: January 26, February 2 and February 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. e?-- ,z' a Marie Co ,Editor SWORN TO AND SUBSCRIBED before me this 9 day of February, 2007 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 6 Writ No. 2005-5709 Civil Roy Al Finance and Loan Company VS. Joseph Adams and Maureen Adams Atty.: Lauren Tabas ALL OF THE PARCEL of land situate in Lower Allen Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the northwestern side of Old Mill Drive at the southern line of Lot No. 10; thence along the northwestern side of Old Mill Drive, southwardly by an arc having a radius of five hun- dred ninety and eighteen one- hundreths (590.18) feet, a distance of eighty-three and sixty-six one- hundreths (83.66) feet to a stake; thence continuing southwardly by the said line of Old Mill Drive by an arc having a radius of sixty (60) feet, a distance of twenty-two and fifty- eight one-hundreths (22.58) feet to a pin at the dividing line between Lot No. 9 and Lot No. 8; thence along the dividing line between Lot No. 9 and Lot No. 8, south 80 de- grees 8 minutes west, one hundred eighty-seven and fourteen one- hundreths (187.14) feet to a stake at lands now or formerly of Hempt Brothers; thence along said lands, north 0 degrees 43 minutes west, forty six and fourteen one-hun- dreths (46.14) feet to a pin at lands now or formerly of Hempt Broth- ers, and Richard Buir; thence along said lands, north 14 degrees 12 minutes east, forty-seven and two one-hundreths (47.02) feet to a pin at the dividing line between Lot No. 9 and Lot no. 17; thence along said dividing line, north 70 degrees 51 minutes east, one hundred seventy and ninety-five one-hundreths (170.95) feet to a Stake at the junc- tion point of the lines of Lot No. 9, 10 and 17 thence along the divid- ing line between Lot No. 9 and Lot No 10, south 70 degrees 28 min- utes east, thirty-nine and thirty-six one-hundreths (39.36) feet to a stake on the northwestern side of Old Mill Drive, the Place of BEGIN- NING. BEING the same premises which Patricia ,PL Shillow, widow, by Deed dated May 8, 1998 and recorded in the Cumberland County Recorder of Deeds Office on May 20, 1998 in Deed Book 177, page 624, granted and conveyed unto Joseph Adams and Maureen Adams, husband and wife. SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. Joseph Adams and Maureen Adams DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on January 31, 2006 in the above entitled action vacated without prejudice to Plaintiff. BY: & KREISMAN, LLC R. Tabas, Esquire I* . CERTIFICATE OF SERVICE I, LAUREN R. TABAS, ESQUIRE, hereby certify that on - 0-11 served a true and correct copy of the within Praecipe to Vacate Mortgage For losure Judgment upon the following parties via first class mail, postage prepaid: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 & KREISMAN, LLC BY: LAUREN R. TABAS, E: Attorney for the Plaintiff 4CL 7"W C t r4a _? SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 05-24856 Roy Al Finance and Loan Company PLAINTIFF VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 05-5709 CIVIL TERM Joseph Adams and Maureen Adams DEFENDANT(S) PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. BY Lauren R. Tabas, Esquire Attorney for Plaintiff DATED: 3Q(&O-? ti CERTIFICATE OF SERVICE I, Lauren R. Tabas, Esquire, hereby certify that on jj It - - I served a true and correct copy of the within Praecipe to Settle, Discontinue and End upon the following parties via first class mail, postage prepaid: Joseph Adams 122 Old Mill Drive Camp Hill, PA 17011 Maureen Adams 122 Old Mill Drive Camp Hill, PA 17011 0 & =-A r- Ldaren R. Tabas, EA Attorney for Plaintiff s" ?? -r7 47, Sti, `r ?'3