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HomeMy WebLinkAbout05-6377 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) NO. 6S' - 10317 c;o~L~~ COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AV1SO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMED1ATAMENTE, S1 NO T1ENE ABOGADO o S1 NO T1ENE EL D1NERO SUF1C1ENTE DE PAGAR TAL SERV1C10, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF1C1NA CUYA D1RECC10N SE ENCUENTRA ESCR1TA ABAJO PARA AVER1GUAR DONDE SE PUEDE CONSEGU1R AS1STENC1A LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address ofthe original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. Isl Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mellon Bank, N.A. Assignments of Record to: PNC Bank, N.A. Recording Date: 03/18/97 Book: 542 Page: 1094 Assignor: PNC Bank, N.A. Assignee: Washington Mutual Bank, FA Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g) The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 310 Virginia Road MUNICIPALITY/TOWNSHIP/BOROUGH: Hampden COUNTY: Cumberland DATE EXECUTED: 07/20/95 DATE RECORDED: 07/26/95 BOOK: 1273 Township PAGE: 364 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 11/18/05: Principal of debt due Unpaid Interest at 6.375% from 7/1/05 to 11/18/05 (the per diem interest accruing on this debt is $4.20 and that sum should be added each day after 11/18/05) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $161.30 and that sum should be added on the first of each month after 11/18/05) Late Charges (monthly late charge of $23.97 should be added in accordance with the terms of the note each month after 11/18/05) Reasonable Attorneys Fees $24,041.36 582.26 325.00 280.00 464.73 TOTAL 95.08 1.250.00 $27,038.43 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $27,038.43 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. \ fA) Mark J. Lrdren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 "II '" ;"1, TIlAT ClmTAIN tract of land sicuate in Hampden 'l'OWllshiP. Cumberland County, Pennsylvania, bounded and described in accordance nch a survey made by D.P. Raff8l1spergerAssociates, dated January 2.1979. ae follows,.to wit: : IlECINNINC at a point on the western side of Virginia Road, said point being 80.0 feet south of Delbrook Roadl thence along the we8te~ side of Virginia Road. South 04'00' east 63.40 feet to an iron pin; ehsnce lout:h 86.00' west, 120.0 feet to an iron pin. thence north 04.00' wese, 3.4 feet eo an iron pin; theQce along Lot No. 16 of hereinafter mentioned Plan, nort:h 24.26'30" !last, 68.23 feet to an iron pin; ehence alone Lot No.1, North 86'00' east, 87 . 50 feet: eo eM western side of Vir:l.gin:l.a Road. the place of BEGINNING. . HAV1NC thenonuect:eci.':.l lIt. storY brick and aluminum siding MIUng mown as'No. 310 V.irg1n:t.a Road.. . 'r' ." BEIlIG toc" No. 2. and t:he no~hern 3.4 'teet of Lot: 3; Block O. i , Plan Nil. 2. Del-Brook Manor,' recorded in E'liln. Book ,7. page S'",I ' CuniDerr.rii! County Records. " . .,'. ':' : ",Ill!!:., , r -., -, .,' . " ,. , " ,. " Washington Mutual P.O. Box 44118 Jacksonville, FL 32231-4118 III 5007800161 7100 4047 5100 2571 7106 October 17, 2005 001275/PA SHARON L FEESE 310 VIRGINIA RD MECHANICSBURG PA 17050 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT. AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5007800161 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Thi5 i5;m nffir:ial nntir:e th~t the rnortp'llP'p. on Your home i'l in default and the lender intend.. to foreclose Specific information about the nature of the clef-mil is nrovided in the attached pae:es The HOMFOWNRR'S MORTGAGE ASSISTANCE PROGRAM (HEMAPl ml\y he able to help to save your home This Notice exnlllins how the pro~am works To see if HEMAP can help YOll mnst MEET WITH A rONSlJMFR CRFDIT COlJNSELING AGENrY WITHIN ::\0 nAYS OF TAF nA TF OF THIS NOTTC:E Take ih].. Notice with you when you rnf'P.t with the Coun'leline- Agt'nC'y The name addres.'il and phone number of Consnmer Credit COllnselimJ Ap'encies servinI>' VOllT Connty :UP. listed at the end of this Notice If Yon have any (lut.'itions vou m:w {".all the Pennsylva.nia HOIl'iinp' Finance Ap'encv toll free at l-ROO-342-23Q7 (Per'ions with imnaired hearinQ can call (717) 7RO-1R6Q) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES 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 illPOTECA. PA ACT 91 EXHIBIT i HOMEOWNER'S NAME(S): Sharon L. Feese WAN ACCT. NUMBER: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 310 Virginia Rd Mechanicsburg P A 17055 5007800161 PROPERTY ADDRESS: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGffiLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND . IF YOU MEET OTHER ELlGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TRMPORARY STAY OF FORF.CLO~HRF. - 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 MRF.TING MUST orrUR WITHIN THF. NRXT (:lO\ DA YS IF YOI J no NOT APPLY FOR FMFRGFNCY MORTGAGE ASSISTANf:E YOU MUST BRINe; YOUR MORTGACiP l1P TO DATE THF PART OF THIS NOTIr:F CALLED "HOW TO ClJRE YOUR MORTGAGE DEFAIJT T" EXPI AINS HOW TO BRING YOUR MORTGAGE lIP TO DATF r.ONSIJMER CRRDTT mlTNSET ,rNG AGENCIKc; - Jf 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 addres.<;es and telenhone numhers of deshJTlated consumer credit connsp.1inr arencies for the cOlmty in which the property is locatf'd are set forth at the end of this Nntice It is only necessary to schedule one facewto-face meeting, Advise your lender immediatelv of your intentions, APPLICATrON FOR MORTGAGF. ASSrSTANCR - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program, To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLWW THE OTHER TIME PERIODS SET FORTH IN THIS LE,.rER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ArTrON w Available funds for emergency mortgage assistance are very limited, They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application, During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE, IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 001275fCOB26 HOW TO CURE YOUR MORTGAGE DEFAULT IBrio. it uo to date). NA.TlJRR OF THR DEFA1JLT. The MORTGAGE debt held by the above lender on your property located at; 310 Virginia Rd Mechanicsburg P A 17055 IS SERlOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments; 0810112005 09/0112005 10/0112005 $645.14 $645.14 $645.14 Other charges (explain/itemize); Uncollected Late Charges Uncollected Fees; Less Credits TOTAL AMOUNT PAST DUE, $4754 $0.00 $0.00 $1982.96 8. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $1982.%, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents mllSt he made either by ca..h ca..hier's check certified check or monev order made n:lvahle and sent to. Washington Mutual Bank Cash Processing P.O. Box 3200 Milwaukee. WI 53224 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter; (Not applicable): IF YOU DO NOT CURR THR DRFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intr.nd~ to e'l(r.r('i~r. it.1i ripht~ to accelerate the mnrtrai'e deht This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forr.clolie IIpon your mnrtl!'31!'ed nronertv *IF THR MORT~AGE IS FORECLOSRD UPON The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If VOl! ("lire th,. dr.f:1ll1t within the THIRTY 110) DAY neriod VOII will not he reollired to Dav attornev'li fees. OTHRR LENDRR R"F.MRDIRS - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PAACT91 RIGHT TO r.lIRR THE DRFAIII.T PRIOR TO SHRRIFF'S SALE. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, VOl) mav still have the rieJlt to cure the default and nrewnt the sale at any time IIp to one hour before the Sheriff's Sale You may do so lw payinf tbe tot.al amount then past due nlllS anv late or other charves then due rea.<;onahle attornev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as snecified in writinv by the lender and by nerforming any other reauirements under the mortP"aee Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F.ARI.1EST POSSIRI R SHF.RIFF'S SALF. DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would he approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO r.ONTAr.T THE "F.NDER: Name of Lender: Address: Washington Mutual Bank 7255 Baymeadows Way Jacksonville, FL 32256 866-92lHl937 904-281-3914 Collection Department www.wamuhomeloans.com Phone Number: Fax Number: Contact Person: EmaiI Address: RFFRrTS OF SHRRIFF'S SAI F.. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time_ ASSUMPTION OF MORTGAGE - You _ mayor X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY AL"O HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RiGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PAACT91 V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subj ect to the penal ties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. \Jf\D Mark J. Uaren, ESQUIRE UDREN LAW OFFICES, P.C. P 'i9.. -,:J~YA *- 'tT- . lfl _ ~ \:J ....1 '\) -J - "'v r ~ -- V1 - -4 ~ -L.. .-" ') ) ;-1 -~ ,_...." .. .re ,"-, ~~. ~-~ -- SHERIFF'S RETURN - REGULAR CASE NO: 2005-06377 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS FEESE SHARON L WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FEESE SHARON L the DEFENDANT , at 1044:00 HOURS, on the 27th day of December, 2005 at 310 VIRGINIA ROAD MECHANICSBURG, PA 17055 by handing to SHARON L FEESE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 11.52 .00 10.00 .00 39.52 ""......, ....::::.... , R. Thomas Kline me this 0<- J 1 c. day of 12/28/2005 UDREN LAW OFFICE ~ ~.. " ''1/?./>- P . puty ~iff By: Sworn and Subscribed to before (. A.D. . UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) , I I !ATTORNEY FOR PLAINTIFF \ I I , I I COURT OF COMMON I PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECL~SURE NO. 05-6377 Civ 1 Term PRAECIPE FOR JUDGMENT FOR FAILU E TO ANSWER AND ASSESSMENT OF DAMA ES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Pla'ntiff and against the Defendant(s) Sharon L. Feese for failure to file a Answer to Plaintiff's Complaint within 20 days from service thereof a for foreclosure and sale of the mortgaged premises, and assess P aintiff I s damages as follows: As set forth in Complaint Interest Per Complaint From 11/19/05 to 5/20/06 Late charges per Complaint From 11/19/05 to 5/20/06 Escrow payment per Complaint From 11/19/05 to 5/20/06 TOTAL I hereby certify that Defendant are as shown above, accordance with Rule 237.1, a $27, 38.43 68.60 ~43.82 ~ laintiff and een given in h reto. ark J. Udren, ESQUI E ttorney for Plainti f DAMAGES ARE HEREBY ASSESSED A INDICATED DATE: (fl';J'f JJ, -::l0/)"- "- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Washington Mutual Bank, FA Plaintiff ATTORNEY FOR PLAINTIFF v. COURT ~F COMMON PLEAS CIVIL IVISION Cumber and County ! Sharon L. Feese Defendant(s) NO. 05-6377 TO: Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 DATE of Notice: May 9, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 0 ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN W ITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAyS FROM THE DATE OF THI NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AN YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TA THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO 0 OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE OU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO IRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Associati n 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFlCACION IMPORTANTE US TED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HA ER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TO R LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DrAS DE ES A NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTE EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DE BE LLEVAR EST NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI US TED NO TIENE ABOGADO, SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA AJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL, SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Associati n 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRA FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR ICES ACT, THIS LAW ATTEMPT TO COLLECT THAT PURPOSE. s . ren, squlre Woodcrest Corporate Center III Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-36 0 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF iCOURT OF COMMON PLEAS CIVIL DIVISION Cumberland Coun y MORTGAGE FORECL SURE NO. 05-6377 Civ'l Term AFFIDAVIT OF NON-MILITARY SERV CE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and say that the averments herein are based upon investigations made and rec rds maintained by us either as Plaintiff or as servicing agent of the laintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 acted H.R. 100), and that the age and last known residence and employm nt of each Defendant are as follows: Defendant: Age: Residence: Employment: Sharon L. Feese Over 18 As captioned Unknown Sworn to and subscribed before me this 20th day ~y, 2006. \^J~j^ Notary Public CARA STEARS NOWVPlI8UC OF NEW JERSEY CornrnInIon Exp/les 4/16/~ K J. ATTORNEY UDREN LAW EN, ESQ. OR PLAINTIFF OFFICES, P.C. D "'o\.Q, (:, ~ ~ r-> ~ <2 ~ 9n = <:) a" ~ "3''''' % :'C"" -OCt", Q tJ: ':.: "P' ""F' .....<. ~ ,(.-----;..' ....dl-ri - t -J /~ \ 1" ;,'C;' 0; (n \"V t_~Cl\ -', ~," c' r , ;...--<1 ~ .:;~. -e ,'......-- ~ ~ ~/' -','" ':.',:~$~ ..c ':.:"~ ... '9 9\ ;pC \U - 1- -Z., JD :;2. s:- ::<. ..... R' r--- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff I I ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland Coun~y MORTGAGE FORECLQSURE v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) NO. 05-6377 civil Term , i , PRAECIPE FOR WRIT OF EXECUTltN TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $28 918.65 Interest From 5/21/06 457.80 to Date of Sale SeDtember 6. 2006 Ongoing Per Diem of ~ to actual date of sale including if sale is held at a later date (Costs to be added) $ "iJ ~ r Q <;t H ~ \\:- ~ -- \l --..) ~ '<::l> t, ~ - e. ...J- V ~ P-. ~ -(Q.. -- iq. ~ ~:-O~ \,)..l - :""'- - - .0 ~ Vi C> ~ vt \i V, V'l \) t \) \) l) () ),J \) I I r-.& I ~~ - ) - ::: :: - - ~E - - - - - - - w (') c: :;:~ -0\.'::5 a:'~:~ "::-f) /. {P,--.' ~ ~. '<:: ~,?- -;''''~':~ 6 -< :::; 0 ("~ -0 "'" -;:l:: ~;J;) ~ f11.r- - -0 rri ~ ~~~l!~~, ~ ~;~~~g :;:::;.. ;~Srn "-"' --"\ ~ r- '-< _I I WRIT OF EXECUTION and/or ATTACHME1T COMMONWEALTH OF PENNSYLVANIA) NO 016377 Civil COUNTY OF CUMBERLAND) ICIVIL ACTION - LAW I TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL ANK, FA, Plaintiff (s) From SHARON L. FEESE (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied pon in the possessiou of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the g ishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering y property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is ound in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $28,918.65 L.L. $.50 Interest FROM 5/21/06 TO DATE OF SALE 9/6/06 - $457.80 - ONGOI G PER DIEM OF $4.20 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT ALTER DATE Atty's Comm % Atty Paid $121.52 Plaintiff Paid Date: MAY 22, 2006 Due Prothy $1.00 Other Costs' (Seal) Prothonotary By: Dep ty REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.e. WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY ffiLL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ill No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 I I ~ORNEY I ! FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County MORTGAGE FORECLO~URE i I ~LEAS Plaintiff v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 NO. 05-6377 civi Term Defendant(s) C E R T I F I CAT E the not Mark J. Udren, Esquire, hereby states that h Plaintiff in the above-captioned matter and t subject to the provisions of Act 91 because i is the attorney for at the premises are is: An FHA insured mortgage ) Non-owner occupied Vacant X Act 91 procedures have been Over 24 months delinquent. This certification is made subject to the p alties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to a thorit'es. ark J. Udren, ESQ TTORNEY FOR PLAIN 0 ....., = 0 c: = ." :-.:::- =' "'D ~t ~ ~ rT1 J:>" n1:!J -;~ ~:~:' -< -aFn .c" -7 "c,. N :r'9 " r'~ ::.? N ~:: ';3 C) -,.:--r, j~ "'" '~~~~ ~<. , -r ( -- - ~~ E.i =:-1 ~ -< .J:'" ~ -' \r __ UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland Coun y MORTGAGE FORECLOSURE Plaintiff v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 NO. 05-6377 Civ'l Term Defendant(s) AFFIDAVIT PURSUANT TO RULE 312 .1 Washington Mutual Bank, FA, Plaintiff in the abov attorney, Mark J. Udren, ESQ., sets forth as of t for the Writ of Execution was filed the following concerning the real property located at: 310 Vir Township), Mechanicsburg, PA 17055 action, by its e date the Praecipe information inia Road (Hampden 1. Name and address of Owner(s) or reputed Owner( ): Name Address Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 1 055 2. Name and address of Defendant(s) in the judgme t: Name Address SAME AS #1 ABOVE 3. Name and record lien Name address of every judgment creditor who e judgment on the real property to be sold: Address is a None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. Central Ohio Mortgage Company 15 North Liberty Str et Box F, Powell, OH 43 65 It ~ I I I 10 South Market Squa~e Harrisburg, PA 17101j of every other person who has ~ny record lien on Mellon Bank, N.A 5. Name and address the property: Name Address None 6. Name and address in the property and Name of every other person whose interest may be Address who has any record interest affecte4 by the sale: Real Estate Tax Dept. , 1 Courthouse squarej" Carlisle, PA 17013 13 N. Hanover Stree Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue Bureau of Complianc , PO Box 281230 Harrisburg, PA 1712 -1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property wh ch may be affected by the sale: Name Address Tenants/Occupants 310 Virginia Road (Hampden Township) Mechanicsburg, PA 1 055 I verify that the statements made in this affidav't are true and correct to the best of my personal knowledge or i formation and belief. I understand that false statements herein are ma subject to the penalties of 18 Pa.C.S. sec. 4904 relating to uns orn falsification to authorities. DATED: May 20, 2006 ( (') ....., (') = c = -n "" < :x :r!.., -0(',' (1\1' :P- rn- ? -<: -oh1 "". N -:-1,]t_-.-' rn N ':"')(1 . ::J_~ .. "'" "L-r'j >J~:;;: , ':~(-') ~ ~- Z C.- .-;;.-. (~ITl .s.--; C' C5 =t.i 7" ~ &'" :u -.I .< ;( -- UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff IATTORNEY FOR PLAINTIFF v. COURT OF COMMON PLEAS CIVIL DIVISION I Cumberland coun9Y MORTGAGE FORECL~SURE ! Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) NO. 05-6377 Civil Term NOTICE OF SHERIFF'S SAL L P OPERTY TO: Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Your house (real estate) at 310 Virginia Road(Ham Mechanicsburg, PA 17055 is scheduled to be sold a on September 6, 2006, at 10:00 A.M. in the Commis 2nd Fl., Courthouse, Carlisle, PA, to enforce the $28,918.65, obtained by Plaintiff above (the mort If the sale is postponed, the property will be re Available Sale. den Township) the Sheriff's Sale ioners Hearing Room, court judgment of agee) against you. isted for the Next NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate act'on: 1. The sale will be cancelled if you pay to the mortgage the back payment, late charges, costs and reasonable attorney's fees. To fi d out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition sking the Court to strike or open the judgment, if the judgment was impr erly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other Ie a1 proceedings. You may need an attorney to assert your rights. The S oner you contact one, the more chance you will have of stopping the sale. (ee notice on page two on how to obtain an attorney.) ( -... YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND OU HAVE 0 ER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your pro erty will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set a ide the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pay the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid t remain the owner of the property as if the sale never happ Sheriff, you will 5. You have the right to remain in the property paid to the Sheriff and the Sheriff gives a deed buyer may bring legal proceedings to evict you. the full amount due is At that time, the 6. You may be entitled to a share of the money whi house. A schedule of distribution of the money bid for you the Sheriff within 30 days after the sale. This schedule wi receiving that money. The money will be paid out in accord unless exceptions (reasons why the proposed distribution is Sheriff within ten (10) days after Schedule of Distribution h was paid for your house will be filed by 1 state who will be nce with this schedule wrong) are filed with the is_ filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB. IF YOU 0 NOT HAVE A LAWYBR OR CANNOT AFFORD ONE, GO TO OR TELBPHONE THI! OFFICB LISTBD BBL Ii' TO FIND OUT WHBRB YOU CAN GBT LBGAL HELP. LAWYBR RBFBRRAL SBRVICB Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 . (") r-> 0 C'.=> r.;: = "T1 0"" ,- :x =:1.." -n l~{ t.:r; ~. , ::;r... rllp -< :Z -om l" ~~ (j) N ::D" '- 3': C__ 0 2 ~~ ':;,.. .r:- S:l -< ..... '-< ... , .-. UDRBN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant{s) NO. 05-6377 Civil Term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.ROLE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date{s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant{s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant{s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". This Affidavit is made subject to relating to unsworn falsification BY: All Notices were served within the time limits set 3129. Dated: September 1, 2006 '-. "... UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOOD CREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Washington Mutual Bank, FA 1270 Northland Drive Suite 200 Mendota Heights, MN 55120 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 05-6377 Civil Term v. Sharon L. Feese 310 Virginia Road Mechanicsburg, PA 17055 Defendant(s) DATE: May 20, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER{S): Sharon L. Feese PROPERTY: 310 Virginia Road (Hampden Township) Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the cumberland County Sheriff r s Sale on September 6, 2006, at 10: 00 A. M., at the Commissioners Hearing Room, 2nd Fl., Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A .2 ~. 1S. lilt! 0: Ii Dlae . f i a. Ilsl 0:100'" . DODD I t I ~ S J ~ CI) - I ;- II: 8:l2 II i~ ."Iw ~ i 8 =i z :;: I~ ~:r ~ wI.. tc - 1'7 N ~ i~ a u &... ~ ... ;:. Q; co UW I i rB!;J - t:: ea:to- ~ ~g;~S~~ 2 .. "'t 1 ;~ IE i... ..I ~ I_ -if :~ ,I I ' IIii 1= :) ::~ z 51 '! f2 J;;!~! . .J i~lS 'Q:i zlfl Ii l! Ii l&; ZII ~ ! 0 ('I "" . 1ft U :::;..... ('I "" . 1ft co ,... co 01 ..... ::: .... ..... .... .... ... .~ l~ ~I '1lt0: 0: ~I (/)U. · . }ol i~! oi, <Ii u. .15i ~ . \D .- ~'a l:l.~ \D !Ii_. ! 0: u. f.......!....'.. 1..! II! 1.,is III ~8~ i. .2 ~ r1j J i1li III;: XO I ... ~ ... i . '" :.,. ~-_. -" .; ""~a~'i1~, : .~, .,: ; :,..; ffi IDa as z z w x L'<':: ~~ ~~:. ;. ..is! .J~:J -~. (,'N ..... I Il-Ji . l!j'lt ,filM ~11h! h~i ntN Itl~f! B.,~. ; It,i I .I" I , "~ i ! ~ I ! .... E I. 0 J c\ '" l.~~ l.~ 5:) iF~ I I lL ~I t l~~ i e.a 0 II ~ ......J a. a. EXHIBIT A ". .-,11 Washington Mutual Bank, FA VS Sharon L. Feese In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-6377 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 3, 2006 at 2:28 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sharon L. Feese, by making known to Sharon L. Feese, personally, at 310 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 2:28 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Sharon L. Fesse located at 310 Virginia Road, Mechanicsburg, Pennsylvania, 17055 according -to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Sharon L. Fesse, by regular mail to her last known address of 31 0 Virginia Road, Mechanicsburg, Pennsylvania, 17055. This letter was mailed under the date of July 13, 2006 and never returned to the Sheriffs Office. So Answers: r-~~ R. Thomas Kline, Sheriff ByJ~~J~~ Real Estate S rgeant EXHIBIT B (") ~ .~: C~ L- -.j -{. "'" = c;:;> 0"" ~:2 ;; ! 'J I CO o -n ~ II] 01 r- -a~ -U-"'-,.l ~) v l~~? ~~ .< r....) w t. '0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which William Enck is the grantee the same having been sold to said grantee on the 6th day of Sept A.D., 2006, under and by virtue of a writ Execution issued on the 22nd day ofMav, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 6377, at the suit of Washington Mutual Bank FA against Sharon L Feese is duly recorded in Deed Book No. 277, Page 1414. IN TESTIMONY WHEREOF, I have hereunto set my hand cX~ da y 0 f and seal of said office this t~~ ~^'- , A.D. (;f-f)O ~ ~ fJ, &o.~ ") Recorder of Deeds AICOfdIr at 0eedI. Cumbtrland Cotny, CIdIsII, PA My Co.5lftiasbl &pi8I1he Fill Monday of JIn. 2010 Washington Mut~al Bank, FA VS Sharon L. Feese The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-6377 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 3,2006 at 2:28 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sharon L. Feese, by making known to Sharon L. Feese, personally, at 310 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 03, 2006 at 2:28 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Sharon L. Feese located at 310 Virginia Road, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Sharon L. Feese, by regular mail to her last known address of 31 0 Virginia Road, Mechanicsburg, Pennsylvania 17055. This letter was mailed under the date of July 13,2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 06, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $88,000.00 to William Enck. It being the highest bid and best price received for the same, William Enck of 131 Lee Ann Court, Enola, P A 17025, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $92,405.98. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge $30.00 1,760.00 15.00 15.00 30.00 10.00 .50 1.00 10.56 15.00 20.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 305.00 267.20 19.31 25.00 39.50 $2,563.07 V J/- 2 7-0~ Y- So Answ~rs: ~~-~<~ R. Thomas Kline, Sheriff '( . . ,( \ . - J I BY ,) C C v~X ~ltC \, ."1 Real Estate'Sergeant ~ ,[lJ ~ 3D. s1> /. Ut!.. :/t o{ f L- / j'~br)J' f. I 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 andlor Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #64 ('\ ~~ iU S~~~.;~. :~';~~;~~~':f+r&' tl1 ; ~~~~,,,,,,,, "LVANIA . Teny L. Russe~, NotarY Public City Of H mSlAJrg, Dauphin County My Com Ission E.xpi~ une 6. 2010 // M.~be', "7aoi~' "'''i~ari.S ( CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 REAL ESTATE SALE NO. 64 WItt No. 21864377 CIvIl Tenr l< WaehIngIan IIutu8I ....k, FA ' v. Sharon L. Feese Atty: Mark J. Udren DESCRIPTION ALL TIIAT CEKfAIK tract of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described in accordance with a s.urvey made by D.P. Raffensperger Associates, dated January 2, 1979, as follows, to wit BEGINNING at a point on the we~ side of VrrgiDia Road, said point being 80.0 feet south of Delbrook Road; thence along the western side of VrrgiDia Road, south 04'00' east 63.40 feet to an iron pin; thense south 86'00' west, 120.0 feet to,an iron pin; thence north 04'00' west, 3.4 feet to an iron pin; thence along Lot No. 16 of hereinafter mentioned Plan, north 24"26'30" east, 68.23 feet to an iron pin; thence along Lot No. I, North 86"00' east, 87.50 feet to the western side of Vrrginia Road, the place of beginning. Having thereon erected a I 1/2 story brick and aluminum siding dwelling known as No. 310 Vuginia Road. Being Lot No.2 and the northern 3.4 feet of Lot 3, Block C, Plan No. 2 Del-Brook Manor, reconled in Plan Book 7, page 8, Cumberland County Records. Being known as: 310 VrrgiDia Road (Hampden Townsbip) Mechanicsburg, PA 17055 PROPElITY ID NO.: 1(}.21-O279-334 Title to said premises is vested in Sharon L. Feese, a single woman by deed from Paul W. RueIe, Jr. and Blaine T. Roese, his wite, dated 101 718311C01ded 1004183 in Deed Book 1(-30, page 891. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July 21, July 28, and August 4,2006 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. o AND SUBSCRIBED before me this day of August. 2006 SWO 4 \;t-A ~j) ~ - ~tL~/Jf'Ij'./,-- "-":~~t,tllr' ",'?f' REAL ESTATE SALE NO. 64 Writ No. 2005-6377 Civil Washington Mutual ~ank. FA vs. Sharon L. Feese Atty.: Mark J. Udren ALL THAT CERTAIN tract of land situate in Hampden Township. Cumberland County. Pennsylvania. bounded and described in accor- dance with a survey made by D.P, Raffensperger Associates. dated January 2, 1979. as follows. to wit: BEGINNING at a point on the western side of Virginia Road. said point being 80.0 feel south of Delbrook Road; thence along the western side of Virginia Road. Sou th 04000' east 63.40 feet to an iron pin: thence south 86000' west, 120.0 feet to an iron pin; thence north 04000' west. 3.4 feet to an iron pin; thence alollg Lot No, 16 of hereinafter mentioned Plan. north 24026'30" case til').2;j leel ~o iron pin; thence along Lot NO.1, North 86000' east. 87.fJO feet to the west- em side of Virginia Road, the place of BEGINNING. HAVING thereon erected a I 1/2 story brick and aluminum siding dwelling known as No, 310 Virginia Road. BEING Lot No. 2 and the north em 3.4 feet of Lot 3, Block C. Plan No.2 Del-Brook Manor. recorded in Plan Book 7. page 8. Cumberland County Records, BEING KNOWN AS: 310 Virginia Road (Hampden Township) Mechan- icsburg, PA 17055. PROPERTY ID NO.: 10-21.0279- 334. TITLE TO SAID PREMISES IS VESTED in Sharon L. Feese, a single woman by deed from Paul W. Ruese. Jr. and Elaine T. Ruese. his wife dated 10/7/83 recorded 10/24/83 in Deed Book K-30 page 891.