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Home My WebLink About05-6523 MceABE, WEISBERG AND CONWAY, p.e. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 HSBC, a London Corporation. slb/mla of Household Finance Consumer Discount Company P.O. Box 8604 Elmhurst,IL 60126 v. Lewis E. Williams 440 Millrace Road Carlisle,PA 17013 and Joyce E. Williams 440 Millrace Road Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number {w.:J 0:; i?5:,)] CIVIL ACTION/MORTGAGE FOREeLOSURE 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, 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Race falta asentar una ccnparencia escrita 0 en persona 0 con un abcgado 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 defiende, 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 listed. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO T1ENE A UN ABOGADO, V A A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND eONWAY, P.c. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 Attorney for Plaintiff HSBe, a London eorporation, slblmla of Household Finance eonsumer Discount Company P.O. Box 8604 Elmhurst. IL 60126 eumberland eounty eourt of eommon Pleas v. Lewis E. Williams 440 Millrace Road earlisle. PA 17013 and Joyce E. Williams 440 Millrace Road Carlisle, P A 17013 ,..,.... Number 05. (,j',23.('.w;.( /~ CIVIL ACTION/MORTGAGE FORECLOSURE I. Plaintiff is HSBe, a London Corporation, slblm/a of Household Finance eonsumer Discount eompany, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Lewis E. Williams, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last -known address is 440 Millrace Road, Carlisle, PA 17013. 3. The Defendant is Joyce E. Williams, who is one of the mortgagors and real owners ofthe mortgaged property hereinafter described, and her last-known address is 440 Millrace Road, Carlisle, PA 17013. - 4. On 02/19/1998, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office ofthe Recorder ofeumberland County in Mortgage Book 1433, Page 758. 5. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 440 Millrace Road, Carlisle, PA 17013. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 02/24/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest through 11/30/2005 (Plus $ 19.39 per diem thereafter) Attorney's Fee Cost of Suit Appraisal Fee Title Search $ 88,489.61 $ 20,197.75 $ 4,424.48 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $ 113,661.84 8. The attorney's 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 Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 9. Notice ofIntention to Foreclose as required by Act 6 of 1974 (41 P.S. 9403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 P A Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. - WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $113,661.84, together with interest at the rate of $19.39 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~/Vl/t/VI.~ j!,/Jlr ,(~ TERRENCEJ. McCABE, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, Dina Barsotti, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, _lI-::'I,-'~t ) 1\ l r, /\ci ';:J(~ ( c' (' (Jr, ( (' \ \ (, (\ , , and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subj ect to the penalties of 18 PA. C. S. ~4904 relating to unsworn falsification to authorities. j)C/JU PaA'Jtf!tt' Dina Barsotti .N~TIONAL REAL ESTATE 2-12-1998 19:02 PAGE 5/5 RightFAX EXHIBIT A ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF SOUTH MIDDLETON IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A DEED DATED 01/30/91 AND RECORDED 02/01/91, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN DEED VOLUME Y34 AND PAGE 820. ADDRESS: 440 MILLRACE RD.; CARLISLE, PA TAX MAP OR PARCEL 10 NO. : 40 -22 -0485 -070 ~ ~ ~- ~ '- ':. -. ..j '\J \:) W "0 ~ ~ ~ CJ ~ V\ ~ ~. '\;. ~ 1>:, ~ . iJ', \.r-\10 ~~ \.~ .~ ~ () <;~ -o;.~ ~f": 0--> ~g <--.... <-, , ~) . / '.-.-/ = p' n C) -n .-\ X-n nlf-~; -nLlJ ~;}l_j \:!~~: , ,~" ':;: () :"C~lrn ..I ~~ <.,'" -0 ::;: W en CO CASE NO: 2005-06523 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC VS WILLIAMS LEWIS E ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE WILLIAMS LEWIS E was served upon the DEFENDANT , at 1441:00 HOURS, on the 30th day of December, 2005 at 440 MILLRACE ROAD CARLISLE, PA 17013 LEWIS WILLIAMS by handin9 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: Docketin9 Service Postage Surcharge 18.00 4.80 .37 10.00 .00 33.17 Sworn and Subscribed to before me this 11"'- day of " , f '(!'~ : ~tar A.D. So Answers: .,~ . .-'/ " _,!y;t~",P' R. Thomas Kline 01/03/200{. MCCABE WEISBE By: .t ~ I . . SHERIFF'S RETURN - REGULAR CASE NO: 2005-06523 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC VS WILLIAMS LEWIS E ET AL SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILLIAMS JOYCE E the DEFENDANT at 1441:00 HOURS, on the 30th day of December, 2005 at 440 MILLRACE ROAD CARLISLE, PA 17013 by handincj to LEWIS WILLIAMS, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 /.;",f j$$~);~~~~.,~.~,.:~,-~---,,:-.. R. Thomas Kline /..~~,;;f" '.'t~ 01/03/2006 MCCABE WEISB CONWAY By: <" Sworn and subscribed to before ------- me this ~ 11 . day of C}. ") J~~D {A .'. 17iotl} ary MceABE, WEISBERG AND CONWAY, P.C. BY: TERRENeE J. McCABE, ESQUIRE Identification Nnmber 16496 123 Sonth Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff HSBC, a London Corporation, sfblmla of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above- captioned matter for failure to answer eomplaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 12/01/2005 - 03/07/2006 $113.661.84 $ 1,880.83 TOTAL $115,542.67 /. .! ! ~,."'-V' c"'- (/. 11/],- (. {~.(~ TERRENCE J. McCABE, ESQUIRE AND NOW, this ,..J1.-. day of ~ ,2006, Judgment is entered in favor of Plaintiff, HSBC, a London Corporation, sfb/mla of Household Finance Consumer Discount Company, and against Defendants, Lewis E. Williams, and Joyce E. Williams, and damages are assessed in the amount of$115,542.67, plus interest and costs. BY THE PROTHONOTARY: (! '!~ W& -'. . . /"- / / MceABE, WEISBERG AND CONWAY, P.c. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff HSBC, a London Corporation, s/b/m/a of Household Finance Consumer Discount Company eumberland County Court of Common Pleas v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Lewis E. Williams, is over eighteen (18) years of age and resides at 440 Millrace Road. Carlisle. PA 17013; and that the Defendant, Joyce E. Williams, is over eighteen (18) years of age and resides at 440 Millrace Road, Carlisle, PA, 17013. SWORN TO AND SUBSCRffiED BEFORE ME THIS ~.fIDA Y OF ~ 2006. ~/ W).Y1JC~ Nfry~~C i"--"'-'~";"'--::-:5D' "'c/.; }.&\.::...~ _ - t > ~. .._,."1 _I / / ---; /(/\..-l~-C-'I.--l c/--' y-. !},\ '" t. /~'I, ----L_ TERRENCE J. McC:ABE, ESQUIRE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, p.e. BY: TERRENeE J. McCABE, ESQUIRE Identification Number 16496 123 Soutb Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 HSBC, a London Corporation, sfblmJa of Household Finance Consumer Discount Company v. Lewis E. Williams and Joyce E. Williams Attorney for Plaintiff Cumberland County Court of Common Pleas Number 05-6523 CIVIL CERTIFIeATION Terrence J. McCabe, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit nAn. SWORN TO AND SUBSCRIBED BEFORE ME THIS 1 J"'DA Y OF M fMu0, 2006. ~. . t<nA.o) '.!&l N TARYP~~ rw-~--'--'-- .,__~~_w'-_"""'__"_"'_ ..; ~'.L , ~A:.;':Y P',ln\ic r', h < . " Ccunt~( , . - ;.c, ,.;'J.;'-,~:l ~~. 2007 ~:.;.;.~J.::' I :.._'---,,' ---. 'J I . / /' .......(1 "\ -f "/"-1 ( ././ Ii _ /vl / /J;~[-<--r' TERRENCE J. McC:ABE, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, TERRENeE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 P A.C.S. Section 4909 relating to unsworn falsification to authorities. / /' 1 / I // /j r / ./ T'~~~~7. ~aBE,/Es~JI~~v-L OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS eumberland County Courthouse, Carlisle, PA 17013 eurt Long Prothonotary February 23,2006 To: Lewis E. Williams 440 Millrace Road Carlisle, P A 17013 HSBC, a London eorporation, slblmla of Household Finance Consumer Discount Company vs. Lewis E. Williams and Joyce E. Williams Cumberland County Court of Common Pleas Number 05-6523 CIVIL NOTICE, RULE 237.5 NOTIeE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORT ANT NOTICE YOI! ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER :\ WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR "OBJECTIONS TO THE CLAIMS SET FORnI AGAINST VOU. UNLESS YOU ACT WITHIN TEN (10) DA YS FROM THE DATE OF THIS NOTICE. A JUDGMENT MA Y BE ENTERED AGAINST YOU WITI lOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. You SHOULD TAKE THIS PAPER TO YOUR LAWYER ATQNeE. IF YOU DO NOT HAVE A LA WYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFIrE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING ^ LAWYER. IF YOU CANNOT AFFORD TO IllRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITI] INFORMATION ABOUT AGENCIES THATMA YOFFER LEGAL SERVIC'[S TO [],]GIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty A venue Carlisle. PA. 170]3 800-990-9108 TJM/cmo NOTIFICAeION IMPORT ANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFEN5AS U OBJEClONES A LOS RECLAMOS FORMULADOS EN CONTRA SUVO. AL NO TOMAR LA ACCION DEBIOA DENTRO DE DIEZ (10) OIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIOAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENctA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORT ANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. 51 LISTED NO TrENE A UN ABOGADO, VA A 0 TELEFONEA LA OFlClNA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERC A DE EMPLEAR A UN ABOGADO. 51 USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE i'ROPORCIONARLO CON INFORMACION ACERC A S AGENCIASQUE PUEDEN OFRECER LOS SERVICIOS LEGALES NAS ELEGlBLES EN UN HONORARIO REDUCIDO NI NING' Cumberland Coun 2 Liberty Avenue Car]isle, PA, 17013 800.990-9108 Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.c. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 OFFICE OF THE PROTHONOTARY eOURT OF COMMON PLEAS Cumberland County eourthouse, Carlisle, P A 17013 Curt Long Prothonotary February 23, 2006 To: Joyce E. Williams 440 Millrace Road Carlisle, PA 17013 HSBC, a London Corporation, slblmla of Household Finance Consumer Discount eompany VS. Lewis E. Williams and Joyce E. Williams Cumberland County Court of Common Pleas Number 05-6523 CIVIL NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JllDGMENT BY DEFAULT IMPORT ANT NOTICE NOTIFICACION IMPORTANTE You ARE IN DEFAULT BECAUSE YOU HA vI: FAILED TO ENTER A WRlnEN APPEARANCE PERSONALLY OR BY ATTORNEY AND ftLE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORni AGAINST you. UNLESS YOU ACT WITHIN TEN (to) DAYS fROM THE DATE QFTHIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU Villi-lOUT A HEARING AND YOU 1'vlA Y LOSE YOUR PROPERTY OR OTllER IMPORT ANT RIOHTS. You SHOULDTAt.:.E THIS PAPER TO YOUR LAWYER AT ONCE. IF VOU 00 NOT HA VE A LA WYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE ('AN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOUC'ANNOT AFFORDTOHIREA lAWYER. THISOFFIC'E MAY BEABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMA YOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUC'ED FEE OR NO FEE. USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA CQMPARECENC'lA ESCRITA, YA SEA PERSONALME)\''TE 0 PQR ABOGAOO Y POR NO HABER RADle ADO POR EseRITO rON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUVO. AL NO TOMAR LA ACC10N DEBJDA DENTRO DE DlfZ (I 0) OIAS DE LA FECHA DE EST A NOTIFIC'ACION. El.. TRIBUNAL POORA, SIN NECESIDAD DE (OMPARECER U5TEl) EN CORTE U OIR PREUBA ALGUNA, D1CTAR SENTENCIA EN SVCONTRA Y VSTED PODRIA PERDER BIENES U GTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE, SI USTED NO T1ENE A UN ABOGADO, VA A 0 TELEFONEA LA OFlCINA EXPUSQ ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABQGADO. SI USTED NO PUEDE PROPOR('IONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERC'A DE LAS AGENC1AS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARia REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty A venue Carlisle. PA, 17013 800-990-9108 Cumberland County Bar Association 2 Liberty A venue Carlisle. PA, 17013 800-990-9108 Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & eONWAY, P.c. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 TJMlcmo G ;:cJ () ~ \" il1 ~ +- ~ C> 0- ....... ~ C> r e;; ~ :-U ~ ~~P-=- t ~ J~ .j '-;1 (,:. 1"".1 (,.1 .' OFFIeE OF THE PROTHONOTARY eOURT OF eOMMON PLEAS eumberland County Courthouse, Carlisle, P A 17013 Curt Long Prothonotary To: Lewis E. Williams 440 Millrace Road Carlisle, P A 17013 HSBC, a London Corporation, slb/m/a of Household Finance Consumer Discount Company Cumberland County eourt of Common Pleas v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL NOTIeE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. ~' ~, L::.- i (J~, j Prothonotary . ..K- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. " OFFIeE OF THE PROTHONOTARY COURT OF COMMON PLEAS eumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary To: Joyce E. Williams 440 Millrace Road Carlisle, P A 17013 HSBC, a London Corporation, slb/mla of Household Finance Conswner Discount Company Cumberland County Court ofeommon Pleas v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL NOTleE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. (I ~2i2, ~ Lon;Y~O Prothonotary --X- Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Esquire at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION FILE NO.: 05-6523 CIVIL Civil Term HSBe, A London eorporation, sIb/mla of Household Finance eonsumer Discount eompany v. AMOUNT DUE: $115,542.67 Lewis E. Williams Joyce E. Williams INTEREST: from $3.475.173/8/06 - 9/6/06 Date of Sale at $18.99 Per Diem ATTY'S eOMM.: eOSTS: TO THE PROTHONOTARY OF SAID COURT: 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. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff ofeumberland County, for debt, interest and costs upon the following described property of the defendant(s) 440 Millrace Road. Unit 66. earlisle. P A 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of eUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named gamishee(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 gamishee(s). (Indicate) Index this writ against the gamishee(s) as a lis pendens against real estate ofthe defendant( s) described in the attached exhibit. DATE: -1/ ,"",<.J. !fJb I I Signature: j""~.,... G. Ih(~ Print Name: TERRENeE J. MceABJ:f, ESQUIRE Address: 123 S. Broad Street. Suite 2080 Philadelphia. P A 19109 Attorney for: Plaintiff Telephone: (215) 7901010 Supreme eourt ill No. 16496 t:J C I ~ ^( ~ ;, -+- ~ ~ n r--.... i .'i ?) ~ () 'it '- ?.J ~ --0 so ....:t (,-.J -.a \.)..~ :c... ~ -- ~ 6 () C I'- r-Q:J -. w -- -.. ~ I - - - - ll..J err -- -L-- , ':'CIV)~ V\J ~ Vl C . . .w t.I'( ocV,o --C> c () -..? 0 1 I '-0 , ~~ ... ~ ~ ... ~ _~,-~i? - - .Yf1- r-~ ~:...:.') 0 ~~ -n :;:;"" 4-;,J ;:i;.) ...., OJ ~ ill :..5 ::;-,~ .r.:- :n ,"0 -< ~ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 215 790-1010 HSBC, a London Corporation, s/b/m/a of eOURT OF eOMMON PLEAS Household Finance eonsumer Discount Company eumberland eOUNTY v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. Mceabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 440 Millrace Road, earlisle, PA 17013 (40-22-0485-070 (U66)), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Address 440 Millrace Road Carlisle, PA 17013 440 Millrace Road earlisle, P A 17013 Lewis E. Williams Joyce E. Williams 2. Name and address of Defendants in the judgment: Name Address Lewis E. Williams 440 Millrace Road Carlisle, P A 17013 440 Millrace Road Carlisle, P A 17013 Joyce E. Williams ~ 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Robert E. Goodling and Judy S. Goodling, husband and wife, and Peifer and Gross, Inc., A Pennsylvania eorporation Address 204 Stone Mill Drive P.O. Box 506 Elizabethtown, P A 17022 S. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants Domestic Relations eumberland eounty eommonwealth of Pennsylvania Address 440 Millrace Road, earlisle, P A 17013 P.O. Box 320 earlisle, P A 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, P A 1710S ~ eommonwealth of Pennsylvania Inheritance Tax Office eommonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL easua1ty Unit Estate Recovery Program Internal Revenue Service 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, P A 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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 ofl8 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. April 24, 2006 DATE --T' ~ <-<- (). /L.1 r ~ . TERRENeE f. MceABE, ESQUIRE Attorney for Plaintiff \ I ,..., ec" {':.':':> cr' :;;.~. -"~~i :::\) i".) CJ o ~i'1 ::1!. --n ~~.: C~~, -~, \'f-.: ~ , :, '::,:~ ~;;S ::< cO) . " McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaiutiff HSBC, A London eorporation, slblm/a of Household Finance eonsumer Discount eompany eumberland eounty eourt of eommon Pleas vs. Number 05-6523 eIVIL Lewis E. Williams Joyce E. Williams NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lewis E. Williams Joyce E. Williams 440 Millrace Road Carlisle, PA 17013 Your house (real estate) at 440 Millrace Road, Unit 66, earlisle, P A 17013 (Tax Parcel #40- 22-0485-070(U66))), is scheduled to be sold at Sheriffs Sale on September 6, 2006 at 10:00 a.m. in the eommissioner's Hearing Room located on the 2nd Floor of the Cumberland eounty eourthouse,l Courthouse Square, earlisle, Pennsylvania 17013, to enforce the court judgment of $115,542.67 obtained by HSBC, A London eorporation, slblm/a of Household Finance Consumer Discount eompany 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 canceled if you pay to HSBC, A London eorporation, slb/m/a of Household Finance eonsumer Discount eompany, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you maycaU Terrence J. Mceabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the eourt to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) . . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. Mceabe, Esquire at (215) 790-1010. 2. You may be able to petition the eourt to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. Mceabe, Esquire at (215) 790- 1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 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. 7. You may also have other rights and defenses, or ways of getting your real estate 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. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE eARLISLE, PENNSYL VANIA 17013 (717) 240-6200 OR CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 o c- < ", C-:'.~ c::> c;;" C") " ;;:j :::u "" OJ ::~ ill 0':) LEGAL DESCRIPTION , ALL THAT CERTAIN Unit, being Unit No. 66 (the "Unit"), of Willow Crossing, A Condominium, located in South Middleton Township, Cumberland eounty, Pennsylvania, which Unit is designated in the Declaration of eondominium of Willow erossing, A eondominium (the "Declaration of eondominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland eounty, Pennsylvania, in Miscellaneous Book 386, Page 889 and Plan Book 61, Page 62 ana FirSt Amendment To ueclaration of eanaariiinium for Wi11a\\t-~~ " 'erossing, A eondominium (the "First Amendment to Declaration of ;eondominium") and Declaration ~ts!9d Plan all.." ~!jOrded in the O~ce ?f the Recorder of Deeds of:~erland County, Pennsylvama In Miscellaneous Book 388, Page 412 and Plan Book 61, Page 97. TOGETHER with an undivided 2.50% interest in eommon Elements as more particularly set forth in the aforesaid Declaration of eondominium and Declaration Plats and Plans. TOGETHER with the right to use the limited common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of eondominium and Declaration of Plats and Plans, and amendment thereto. Being known as 440 Mill Race Road. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office . , the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and eommon Elements would disclose. TAX MAP PARCEL NUMBER: 40-22-048S-070(U66)) BEING KNOWN AS 440 Millrace Road, Unit 66, Carlisle, P A 17013 Being the same premises which Robert E. Goodling and Judy S. Goodling, husband and wife and Pfeifer and Gross, Inc., A Pennsylvania Corporation, by deed dated the 1/30/1991, and recorded 2/1/1991 m the Offi~e ofthe Recorder in and for Cumberland County in Deed Book Y34, Page 820, granted and conveyed to LeWls E. Williams and Joyce E. Williams, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6523 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfY the debt, interest and costs due HSBC, A LONDON CORPORATION, S/B/M/A OF HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From LEWIS E. WILLIAMS AND JOYCE E. WILLILAMS (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $115,542.67 L.L. $.50 Interest FROM $3,475.17 3/8/06 - 9/6/06 DATE OF SALE AT $18.99 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $131.17 Other Costs Plaintiff Paid Date: APRIL 28, 2006 CURTIS R. LONG (Seal) Protho:)Z p By: ~O,/_ Deputy ~>>&V REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 VlcCABE, WEISBERG A:\ID CONWAY, P.c. BY: TERUENCE.J. McCABE, ESQUIUE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-10 10 Attorney for Plaintiff HSBC, A London Corporation, s/b/m1a of Household Finance Consumer Discount Company Cumberland County eourt of Common Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce F. Williams A}<'FIDA VIT OF SEUVICE I, Terrence J. McCabe, Esquire, attorney for the PlaintilIin the within matter, hereby certify that on the 30th day of June, 2006. a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". eopies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." J}/ll L l'EI~CE J. McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 30TH DAY OF JUNE, 2006. tiuCjJ~dil( NOTARY PUBLIC 8~ . ~Il, eu;e-t "\ COMMONWEALTH OF PENNSYLVANIA ! . NOTARIAL SEAL Chrissandra Shaye Hamilton, NOlary Public City of Phillldelphia, Phila County My Commilliion Expires January 4, 2009 McCABE, WEISBERG AND eONWAY, P.c. BY: TERRENCE J. MeCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 215 790-1010 HSBC, a London Corporation, s/b/m/a of COURT OF eOMMON PLEAS Household Finance Consumer Discount Company Cumberland COUNTY v. Lcwis E. Williams and Joycc E. Williams Number 05-6523 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 440 Millrace Road, Carlisle, PA 17013 (40-22-0485-070 (U66)), a copy of the description of said property is attached hereto and marked as Exhibit "A." I. Name and address of Owners or Reputed Owners: Name Address Lewis E. Williams 440 Millrace Road Carlisle, PA 17013 Joycc E. Williams 440 Millracc Road Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Name Address E hi b I,t "^ " 440 Millrace Road X I f'\. Carlisle, PA 17013 Lewis E. Williams Joyce E. Williams 440 Millrace Road . earlisle, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record licn on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage ofrecord: Name Plaintiff herein. Robert E. Goodling and Judy S. Goodling, husband and wife, and Peifer and Gross, Inc., A Pennsylvania Corporation Address 204 Stone Mill Drive P.O. Box 506 Elizabethtown, PAl 7022 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants Domestic Rclations Cumberland County Commonwealth of Pennsylvania Address 440 Millrace Road, Carlisle, P A 17013 P.O. Box 320 Carlisle, P A 17013 ~6a~:e~~~;pubIEelfarhe I bit Harrisburg, PA l7Il:.X I I "!it' Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau ofIndividual Tax Inhcritance Tax Division Dcpartmcnt of Public Welfare TPL Casualty Unit Estate Rccovery Program Intcrnal Revcnue Service 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg. PA 17128 Willow Oak Building 1'.0. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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.e.S. Section 4904 relating to unsworn falsification to authorities. June 30, 2006 DATE ,:ifJt~ ESQUmE Attorney for Plaintiff Exhibit '~' :vJeCABE, WEISBERG Al'ID CONWAY, P.c. BY: TERRENCE J. McCABE, ESQUIRE Identification Number \6496 123 South Broad Strect, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff r--- HSBC, A London Corporation, s/b/m/a of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce E. Williams DATE: June 30, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Lewis E. Williams and Joyce E. Williams PROPERTY: 440 Millrace Road, Unit 66, earIisle, PA \7013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, earl isle, Pennsylvania 17013. 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'""OO\g~ (1l . 0 a. "" > 8 ,,-t8 g 0 .' , ~>":4" - 0 0 = 0 'O..,g.oCl:l F " ~("l " 0 ~ 0::>"013:1 , " 0 O\(/)- ...... ~ ~ ::t to~ ~ ,,~" ." 's ,,1'0. 0 ~. . ~qq ." " . = - - ~~_~Jt ~~H~ ~11 ~f~~ Hrj~ l!t.gnf. ;~it~ [oj,; a~iM~- ~;,n _o:.~,~ ~!i.!: liU --I" H ~i" ~ - sit ihi~ 'lill h~t ~~,i;~ i~~; l;o!~ ~~~-~ ~oJif ~J f~ WI U~J ~~ ~ ~ ~H~ ilU jlU - - ~ =:T -- cr -- - I - - OJ - ::J -n :',;:1 "1 cO> (,) en McCABE, WEISBERG AND CONWAY, P.C. BY: TERR!:NCE J. McCABE, ESQUIRE Identification Number 16496 Pirst Union Building 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff HSBe, a London eorporation, slb/m1a of Household Finance Consumer Discount Company eumberland County eourt of Common Pleas v. Lewis E. Williams and Joyce E. Williams Number 05-6523 eIVIL PRAECIPE TO MARX JUDGMENT AND WRIT OP EXECUTION TO USE PLAINTIPP TO THE PROTHONOTARY: Kindly mark Judgment and Writ of Execution to Household Finance Consumer Discount Company, Use Plaintiff. l1E t: ~stL ESQUm Attorney for Plaintiff 1( ~ ~ '- Y\ 8 - ~ ~ -J ~ei -4 F :.~J 8 f' \i'l f.J.J f f"" - -I... - .. C) - c.'; .V1eCABE, WEISBERG AND CONWAY 1'.<:' BY: TERRENCE.I. IYh'CABE, ESQUIIU: Identification Number 16496 123 South Broad Street, Suite 20S() Philadelphia, 1'A 19109 (215) 790-1010 Attorney for Plaintiff HSBC, A London Corporation. slblmla of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas vs, Number 05-6523 eIVIL Lewis E. Williams Joyce E. Williams SUPPLEMENTAL AFFIDA VIT OF SlmVICE I. Terrence J. \i1cCabe, bquire. attorney Illr the I'laintilTin the within matter, hereby eertiCy tilat on thc 14th day of July, 2006, a true and correct copy orlhc Notice of She rill's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". eopies afthe letter and certilicate afmailing are also attached hereto, made a part hereof and marked as Exhibit "R" ,~lc{T~:ABE-.f~QUlRE Attorney for Plaintilf SWORN TO AND SUIlSCRIBU) IlEFORE ME TII[S 14111 DA Y 01' cJ:006 a Stv /LIh ~-----~---------- NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CMssandra Shaye Hamilton. Notary Public City of Philadelphia, Phila. County My Commission boifes January 4. 2009 McCABE, WEISBERG AND CONWAY, P.C. IJY: TERRENeE J. MceABI~, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South BrOlld Street, Suite 2080 Philadelphia, PA 19109 (215 790-1010 HSBC. a London Corporation. s/b/m/a of COURT CW COMMON PLEAS Household Finance Consumer Discount Company Cumberland COUNTY v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL SUPPLEMENT AL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire. attorney for Plaintiff in the above action, set forth as of the date the Praccipe for the Writ of Execution was filed the following infonnation concerning the real property located at: 440 Millrace Road, Carlisle, PA 17013, a copy of the description of said property is attacl1cd hereto and marked as Exhibit "A." I. Name and addrcss of Owner or Reputed Owner: Name Addrcss Joyce E. Williams 440 Millrace Road Carlisle, PA 17013 440 Millrace Road earlisle, PA 17013 Lewis E. Williams 2. ::::,.' ,ddre" ofD<foo',., ill :::::~'"'Exh i b it "P\' Lewis E. Williams 440 Millrace Road Carlisle. PA 17013 Joyce E. Williams 440 Millrace Road Carlisle. P ^ 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Willow erossing Condo Association 2] S. Pitt Street Apt.lStc. I Carlisle, PA 17013 4. Name and address of the last rceorded holder or cvelY mortgage of record: !\amc Address Plaint!I'!' herein. Robert E. Goodling and Judy S. Goodling, husband and wife, and Peifer and Gross, Inc., A Pennsylvania Corporation 204 Stone Mill Drive P.O. Box 506 Elizabethtown, PA ]7022 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address or every otherpcrson who has any record interest in the property which may be affected by the sale: 1\ame Address None Exhibit "~' 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsy Ivania Inheritance Tax Office Commonwealth of Pennsylvania Bureau ofIndividual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Address 440 Millrace Road, Carlisle, PA 17013 P.O. Box 320 Carlisle, PA 17013 Department 0 r Publ ic W el t(lre P.O. Ilox 2675 Ilarrisburg. P A 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg. P A 171 05-8486 Technical Support Group, William Grt'en Federal Bldg. Room 3259. 600 Arch Street Philadelphia, PA 19106 I verify that the statements made in this Al1idavit arc true and correct to the best of my personal knowledge or inlormation ancl belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. July 14,2006 ~--()10~ . DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Exh i bit "tit' r McCABE, WEISBERG AND CONWAY, r.e. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Brolld Street, Suite 2080 Philadelphia, Pennsylvanhl 19109 (215) 790-1010 A Horney for Plaintiff HSBC. A London Corporation, s/b/m/a of Household Finance Consumer Discolll1t Company Cumberland County Court of COmI11011 Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce E. Williams DATE: July 14,2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL I'IWI'ERTY OWNER(S): Lcwis E. Williams and Joyce E. Williams PROPERTY: 440 Millrace Road, LJni166, Carlisle, P^ 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on September 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. ^ schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 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. E, .f.'! I, XrllLj~ ~~ 8 " : I!--} :....'~-... xl~j~~~.-.'.~_ ~'I :.,. I I I ; ~ J I 0" , I I .' ! I I ! I I I I f 5 ~ tJ, " o 3 "0 :r . ~ -; '" " . ,. ~ " o S ~ ,& " Q '" g ;: -" ;- r ~ " ~ IC ;; l c' a' ." . = " -:: -',,",, ~m l~!.lj .ilH-a. .H~~ iihf ~lQ ~ ;,.,U~ !1.~;:i~ I.~." "'f' Hih.; nn~ !1m ,~ c. Ie';," T' '~" ',,:t -,-,..,: ?'5 . . ~" ~:H !-H_~ . ~ 0 HH ~.t~J .H~f -I .. - - C' ~ :> ~'.::-<'Z 3E~:~ ot[t~ ~ :~~~~ "": ~~ r;;... -- ,.....:;. '4!' ~-. :../'!O 'J g ~~ ~~ 3: ~~g ~ 3.~~ -f.' r :E ~. , ~ '"' v, v, '" " r :;.' n>N>-::;;: ~'"O -C/l..... ""'t_(/)Ul_ ~~. go- (;(t ~~.~ . . ;::t~'n -o_(/JC~ ):> .......~O ~ w ('t VJ ~ Q: 5' - (JC DO i]C' 01') !fT~r,~~ .,.", :co- C::I.'" i ~ 5 0 t:: ::S::"l ~ '"-.'l l1l -? :J ~ 3 ~ ;j o ;Jlf n:; ,r: ,0<: ~ ~ 3 i"r. R ~ ~ 1 ... ., ~ ~ ~" , ntHrr ~ g;; UN"t-o E i?,-> J,.~ <5'", o 0:1:" 2=~~ ''!.I - '." m ;;:- r' " ~~, ~~\J,hQ ^! ~I< "f) ~ .,.,. ~ = !~, g 1-=0 ~ ~ r; ,:~ ~ ~,~ (0 f;i CD _~ -fR : 'o'Q" 1m ;0::; Q i , , .-l :.1-= , :"j r,' -...~ c-"'\ - , .e :< .--...- -.... McCABE, WEISBERG, & CONWAY, P.c. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 S. Broad Street Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff HSBC, A London Corporation, slb/m/a of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce E. Williams MOTION TO ADJOURN SHERIFF'S SALE Plaintiff, HSBC, A London Corporation slb/m/a of Household Finance Consumer Discount Company, by and through its attorney, Terrence J. McCabe, Esquire, moves this Honorable Court for an Order adjourning the Sheriff's Sale scheduled for December 6, 2006 and avers as follows: 1. Plaintiff filed a Writ of Execution, as well as the Affidavit required by Pa.R.C.P. 3129, in order to list the property known as 440 Millrace Road, Carlisle, P A 17013 for the September 5, 2006 Sheriff's Sale. 2. Said sheriff sale for September 5, 2006 was postponed until December 6, 2006 pending a bankruptcy that was filed, . -.II 3. Plaintiff is now requesting the December 6, 2006 sale be postponed until the March 7, 2007 sheriff sale as the bankruptcy has since been dismissed and terminated as of 10/4/06 and our client had no idea about same. At this time said client needs to obtain a new value of said premises and also an occupancy status. 4. Plaintiff has complied with all the pertinent statutory and procedural rules of court governing the listing of real property for Sheriffs Sale. 5. Neither the parties hereto nor the parties previously set forth in the Affidavit Pursuant to Rule 3129 will be prejudiced by the adjournment of the Sheriffs Sale. 6. Concurrence of opposing counsel has not been sought, insofar as the Defendants are believed to be pro se, and in light of the expedited nature of this motion. Concurrence of opposing counsel is deemed to be withheld. 7. There is little or no prejudice to the Defendants if the motion is granted; whereas, if the motion is denied, Plaintiff will be without knowledge sufficient to reach an informed position regarding the protection of its interest. WHEREFORE, Plaintiff prays that this Honorable Court grant an Order adjourning the Sheriffs Sale of the property known as 440 Millrace Road, Carlisle, P A 17013 to the March 7, 2007 Sheriffs Sale with no additional advertising of said Sale and no new notice to the parties previously set forth in the Affidavit Pursuantto Pa.R.C.P. 3129 being required, except that an announcement be made at the sale currently scheduled fOr[D cember 6,. 2006. rZ. IS' t.6 MATIHEW J. ESHEL N, ESQUIRE CO Counsel for Plaintiff, Id No 72655 Gates, Halbruner & Hatch, PC 1013 Mumma Road, Suite 100 Lemoyne, Pennsylvania 17043 (717) 731-9600 (fax) 731-9627 VERIFICATION The undersigned, MATTHEW J. ESHELMAN, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 P A.C.S. S4904 relating to unsworn falsification to authorities. /JJJJlii- iz/~/~ MATTHEW J. ESHELMAN, ESQUIRE CO Counsel for Plaintiff j, ,--. MCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff HSBC, A London Corporation, slb/m/a of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce E. Williams CERTIFICATION OF SERVICE I, Matthew 1. Eshelman, Esquire, co-counsel for the Plaintiff, hereby certify that the office oflead-counsel of the Plaintiff, McCabe Weiberg and Conway, P.c., has served a true and correct copy of the foregoing Motion to Adjourn the Sheriff Sale, by United States Mail, first class, postage prepaid, on the 5th day of December, 2006, upon the following: Lewis Williams 440 Millrace Road Carlisle, P A 17013 Judy M. Nichols 440 Millrace Road Carlisle, P A 17013 Ik.J/f/L ~tLO Matthew J. Eshelman, Esquire Co Counsel for Plaintiff o c ^-~.... ~:>. ~ c.? cf"' c.? ~^\ C"J \ U" --0 :> ~ ~:.D ~ -0'- '"'\) '",,) ~?\ <-,; ~. . <-:.~ c:::: C1' '~._2(:::) 5 ,'\l .~\ '?i - . -" McCABE, WEISBERG, & CONWAY, P.e. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 S. Broad Street Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 HSBC, A London Corporation, s/b/m/a of Household Finance Consumer Discount Company vs. Lewis E. Williams Joyce E. Williams /1\ I Attorney fqr Plaintiff I DEe 05 2006 fYI.~ Cumberland County Court of Comn: on Pleas Number 05-65 3 CIVIL ORDER \~ AND NOW, this) day of ~(.c... ,2006, upon consideration of Plaintiffs Motion to Adjourn the Sheriffs Sale currently scheduled in the Ibove-captioned matter for December 6, 2006, it is hereby ORDERED that the Sheriffs Sa e of the property known as 440 Millrace Road, Carlisle, P A 17013, is adjourned to the March 1, 2007 sheriffs Sale, or any future sale date provided the sale date is announced at any sUbSeqUen~ sheriff's sale. It is FURTHER I I ORDERED that no additional advertising of said Sale is necesfary and no new notice to the parties previously set forth in the Affidavit pursuant to Pa.R. clp. 3129 is required. I iJ. - tj- O~ r ~~J- ~ Vij\!ltl\l/..8II1N3d 1 P.lnl'i"j '"";', "/");.;"1'"liAln"" 1\J..i\; \ ,,".' '.' 'j ",>'.!'. 1..1 gC :8 t~d g- :J3a 900Z 1 WI-I1C"" "0, i' "'L'd :)Hl JO Au V.J. JIIJ';i")J..l..kJ... oJ 3C)I::f.~O-CJ31!:1 6 HSBC a London Corporation VS Lewis E. Williams and Joyce E. Williams In the Court of Commo Cumberland County, Pe Writ No. 2005-6523 Ci i , states that state d William Cline, Deputy Sheriff, who being duly sworn according to la on May 26, 2006 at 8:42 o'clock PM, he served a true copy of the within Rea Writ, Notice and Description, in the above entitled action, upon the within na defendants, to wit: Lewis E. Williams and Joyce E. Williams, by making kno Lewis E. Williams, personally and husband of Joyce E. Williams, at 440 Mill Unit 66 Carlisle, Cumberland County, Pennsylvania, its contents and at the s handing to him personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to I w, states that on June 30, 2006 at 1 :43 o'clock P.M., he posted a true copy of the withi eal Estate Writ, Notice, Poster and Description, in the above entitled action, upo t e property of Lewis E. Williams and Joyce E. Williams located at 440 Millrace oad, Carlisle, Pennsylvania, 17013 according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, st served the above Real Estate Writ, Notice, Poster and Description in the folIo ng manner: The Sheriff mailed a notice of the pendency of the action to the wit i named defendants, to wit: Lewis E. Williams and Joyce E. Williams, by regular mai 0 their last known address of 440 Millrace Road, Unit 66, Carlisle, Pennsylvania, 17013. hese letters were mailed under the date of June 26, 2006 and never returned to the e riffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, st s this writ is returned STAYED per letter of instruction from Attorney Terrence McCab unto e Road, e time Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Levy Surcharge 30.00 19.98 15.00 15.00 .50 1.00 8.80 15.00 30.00 Law Journal Patriot News Share of Bills Postpone Sale 455.00 369.20 19.31 40.00 $1018.79-/ ,u.1 I' J.~;t-.f' So Answers: _.>~--~~~ R. Thomas Kline, Sheriff BY Real Estate ergeant -~ /D $\;10:;? 6 tlpil . ~~\ D ~-! I , .. McCABE, WEISBERG AND CONWAY, P.c. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 HSBC, a London Corporation, s/b/m/a of COURT OF COMMON PLEA Household Finance Consumer Discount Company Cumberland COUNTY v. Lewis E. Williams and Joyce E. Williams Number 05-6523 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set the date the Praecipe for the Writ of Execution was filed the following information cernmg the real property located at: 440 Millrace Road, Carlisle, P A 17013 (40-22-0485-07 copy of the description of said property is attached hereto and marked as Exhibit" A " 1. Name and address of Owners or Reputed Owners: Name Address Lewis E. Williams Joyce E. Williams 440 Millrace Road Carlisle, P A 17013 440 Millrace Road Carlisle, P A 17013 2. Name and address of Defendants in the judgment: Name Address Lewis E. Williams 440 Millrace Road Carlisle, P A 17013 440 Millrace Road Carlisle, P A 17013 Joyce E. Williams 3. Name and last known address of every judgment creditor whose ju record lien on the real property to be sold: Name Plaintiff herein Address ent is a 4. Name and address of the last recorded holder of every mortgage ofr ord: Name Plaintiff herein. Robert E. Goodling and Judy S. Goodling, husband and wife, and Peifer and Gross, Inc., A Pennsylvania Corporation Address 204 Stone Mill Drive P.O. Box 506 Elizabethtown, P A 17022 5. Name and address of every other person who has any record lien on Name None Address property: 6. Name and address of every other person who has any record interest n the property which may be affected by the sale: Name None Address 7. Name and address of every other person of whom the plaintiff has kn ledge who has any interest in the property which may be affected by the sale: Name Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Address 440 Millrace Road, Carlisle, P 7013 P.O. Box 320 Carlisle, PAl 7013 Department of Public Welfare P.O. Box 2675 Harrisburg, P A 17105 Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau ofIndividual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service 1400 Spring Garden Street Philadelphia, P A 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PAl 7128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, P A 19106 I verify that the statements made in this Affidavit are true and correct to the personal knowledge or information and belief. I understand that false statements h subject to the penalties of18 Pa.C.S. Section 4904 relating to unsworn falsification April 24, 2006 DATE -r' vt..A--1/1 C<-. (" TERRENCE . McCABE, ES Attorney for Plaintiff , McCABE, WEISBERG AND CONWAY, P.c. BY: 1;ERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff HSBC, A London Corporation, s/b/mla of Household Finance Consumer Discount Company Cumberland County Court of Common Pleas vs. Number 05-6523 CIVIL Lewis E. Williams Joyce E. Williams NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lewis E. Williams Joyce E. Williams 440 Millrace Road Carlisle, PAl 70 13 Your house (real estate) at 440 Millrace Road, Unit 66, Carlisle, P A 17013 (T~} Parcel #40- 22-0485-070(U66))) , is scheduled to be sold at Sheriffs Sale on September 6, 200~ ( 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumbe I nd County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the COUl udgment of $115,542.67 obtained byHSBC, A London Corporation, s/b/mla of Household Finarc~ Consumer Discount 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 canceled if you pay to HSBC, A London Corporatiop., s/b/mla of Household Finance Consumer Discount Company, the back payments, I te charges, costs, and reasonable attorney's fees due. To find out how much you n Ll st pay, you may call Terrence J. McCabe, Esquire at (215) 790-101 O. 2. You may be able to stop the sale by filing a petition asking the Court to ~ tl'ke or open the judgment, if the judgment was improperly entered. You may also: s the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the mon hance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bi find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1 2. You may be able to petition the Court to set aside the sale if the bid pric inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount d To find out if this has happened, you may call Terrence 1. McCabe, Esquire 1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain th property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to t Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal r ceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by t Sheriff not later than 30 days after sale. Distribution will be made in accordance with t e schedule unless exceptions are filed thereto within 10 days after the filing of the sche e. 7. You may also have other rights and defenses, or ways of getting your real estat act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ON IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OF FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATI HIRING A LAWYER. ESET ABOUT IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY B PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR BLE TO FFER FEE. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYL VANIA 17013 (717) 240-6200 OR BAR ASSOCIA TI 2 LIBERTY AVE CARLISLE, PAl (717) 249-3166 LEGAL DESCRIPTION i ALL THAT CERTAIN Unit, being Unit No. 66 (the "Unit"), of Willow Crossing, A Condominium, located in South Middleton Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Willow Crossing, A Condominium (the "Declaration of Condominium") and Declaration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Miscellaneous Book 386, Page 889 and Plan Book 61, Page 62 and First Amendmenf-lo Declaration of C()uaolllinium for Willow Crossing, A Condominium (the "First Amendment to Declaration of cCondominium") and Declaration Plats and Plan as recorded in the Office of ~,'''> ,.!:',t -', ' " _":: the Recorder of Deeds of'-Curl11:>erland County, Pennsylvania in Miscellaneous Book 388, Page 412 and Plan Book 61, Page 97. TOGETHER with an undivided 2.50% interest in Common Elements as more particularly set forth in the aforesaid Declaration of Condominium and Declaration Plats and Plans. TOGETHER with the right to use the limited common elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration of Plats and Plans, and amendment thereto. Being known as 440 Mill Race Road. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights-of-way, easements and agreements of record in the aforesaid Office , , the aforesaid Declaration, and matters which a physical inspection and survey of the Unit and Common Elements would disclose. TAX MAP PARCEL NUMBER: 40-22-0485-070(U66)) BEING KNOWN AS 440 Millrace Road, Unit 66, Carlisle, PA 17013 Bein the same premises which Robert E. Goodling and Judy S. Goodling, husband and wife ? Pfeifer and Gros~, Inc., A Pennsylvania Corporation, by deed dated the 1/30/1991, and recorded 2/1/19 1 ill the Office of the Recorder in and for Cumberland County in Deed Book Y34, Page 820, granted and con yed to LeWIS E. Williams and Joyce E. Williams, in fee. WRIT OF EXECUTION and/or ATTACHMENT ., COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-6523 Civil CIVIL ACTIO - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC, A LONDON CORPORATION, SIB /A OF HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From LEWIS E. WILLIAMS AND JOYCE E. WILLILAMS (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 pos e sion of GARNISHEE(S) as follows: and to notify the garnishee( s) that: ( a) an attachment has been issued; (b) the garnishee( s) is en 0 ned from paying any debt to or for the account of the defendant (s) and from delivering any property oft e defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the pos sion of anyone other than a named garnishee, you are directed to notify him/her that he/she has been a ded as a garnishee and is enjoined as above stated. Amount Due $115,542.67 L.L. $.50 Interest FROM $3,475.17 3/8/06 - 9/6/06 DATE OF SALE AT $18.99 PER DIEM Arty's Comm % Atty Paid $131.17 Plaintiff Paid Date: APRIL 28, 2006 Due Prothy $1.00 Other Costs (!~/l. _ CURTISR: LON~~"""'7 Prothonotary By: (Seal) Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQillRE Address: 123 S. BROAD STREET, SillTE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Real Estate Sale # 36 On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, P A Known and numbered as 440 Millrace Road, Unit 66, Carlisle, more fully described on Exhibit "A" \J <J filed with this writ and by this reference incorporated herein. ....... \-l- \L Q Date: May 22,2006 By: J~~ Real Estate Sergeant o ( :\... V S - }\\!ll qQOI j,- v \Jr\ ~),}~ii I "':" >J-' < '/.~\ j_:!;'_:"!~);'J;"""',J ", 1\' I :itl (' '.)." 1 j iJ .:\ ,.I \ ;:; ;JlJ ..:1.:l~:.J-l110 ...Ji I ~ t 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 'sting under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher f he Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 8 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-Ne sere established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuo I published ever since; That the printed notice or publication which is securely attached hereto is exactly as pr' t d and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day( f July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject ma e of said printed notice or advertising, and that all of the allegations of this statement as to the time, place d character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empow statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unani and adopted severally by the stockholders and board of directors of the said Company and subsequ recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellane Volume 14, Page 317. to verify this usly passed ly duly Book "M", PUBLICATION COpy S ALE #36 ..................0.. ..d .lffx411{~.. ................ .. .... ..... Sworn to and su~~e me this 1 iai:Df{)6 YLVANIA " - . Notarial Seal REAL ESTATE SALE NO. 36 Writ No. 2005-6523 Civil Term H8IIC al..OndOn c:orpor.tIGn. fIIbI mIa of HoueehoId Ftn8nce ="'~:::=.: ':: Will of Ally: Terren McCabe 11 DESCRIPTION g f ./ Ib CUMBERLAND COUNTY SHERIFF'S OF I CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 ALL THAT CERTAIN Unit, being Unit No, 66 (the "Unit"), of wmow Crossing, A Condominium, located in South Middleton Township, Cumberland County. Pennsylvania, -. . - '-'--.1 i" the Declaration of 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 County and State aforesaid, being duly sworn, according to law, deposes and says that the C berland Law Journal, a legal periodical published in the Borough of Carlisle in the County and t te aforesaid, was established January 2, 1952, and designated by the local courts as the fficial legal periodical for the publication of all legal notices, and has, since January 2, 1952, en regularly issued weekly in the said County, and that the printed notice or publication att ed hereto is exactly the same as was printed in the regular editions and issues of the said C erland Law Journal on the following dates, VIZ: July 21, July 28, and Au st 4,2006 Affiant further deposes that he is authorized to verify this statement by th Law Journal, a legal periodical of general circulation, and that he is not interested i matter of the aforesaid notice or advertisement, and that all allegations in statements as to time, place and character of publication are true. umberland the subject foregoing REAL ESTATE SALE NO. 36 Writ No. 2005-6523 elvil HSBC a London eorporation, slblmla of Household Finance Consumer Discount Company vs. Lewis E. Williams and Joyce E. Williams Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT eERTAIN Unit, being Unit No. 66 (the "Unit"), of Willow erossing. A Condominium. located in South Middleton Township, Cumberland County. Pennsylvania, which Unit Is designated in the Dec- laration of Condominium of Willow erossing. A Condominium (the "Dec- laration of Condominium") and Dec- laration Plats and Plans as recorded in the Office of the Recorder of Deeds of Cumberland County. Penn- sylvania, in Miscellaneous Book 386, Page 889 and Plan Book 61. Page 62 and First Amendment to Declaration of eon dominium for SWORN TO AND SUBSCRIBED befo 4 day of August, 2006 e this 10- I NOT ARIAL SEAL '~:: C:WDEFt Notary Public " . ", 'C Cumberland County t i~.~ ~:re~.:, h:~a(~:h 5\ 20(F't ~ .".....lH'"~~.~.,;.'-A..".'.'