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HomeMy WebLinkAbout06-0437 .. PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 PNC BANK, NA 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION TERM c; u ~ L J'Cfi..h]. v. NO.Ol... - J..f]'7 CUMBERLAND COUNTY DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, P A 17043 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 1,_1 File #: 129078 File #: 129078 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U,S,c' ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. c' IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE, 1. Plaintiff is PNC BANK, NA 11200 WEST PARKLAND AVE. MILWAUKEE, WI 53224 2. The name(s) and last known addressees) of the Defendant(s) are: DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, P A 17043 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 07/15/1996 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PNC MORTGAGE CORP. OF AMERICA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book: 1331, Page: 878. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 129078 '" 6. The following amounts are due on the mortgage: Principal Balance Interest 08/01/2005 through 01/20/2006 (Per Diem $7.89) Attorney's Fees Cumulative Late Charges 07/15/1996 to 01/20/2006 Cost of Suit and Title Search Subtotal $39,745.23 1,364.97 1,250.00 16.20 $ 550.00 $ 42,926.40 Escrow Credit Deficit Subtotal 59.35 0.00 $- 59.35 TOTAL $ 42,867.05 7. 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. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of$ 42,867.05, together with interest from 01/20/2006 at the rate of $7.89 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALL~ & SCHMIEG, LLP ". c<r~. /" ,-:;U~____ By: /sIFrancis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 129078 . LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County of Cumberland, Commonwealth of Pennsylvania, being more fully described as follows: BEGINNING at a point, said point being located on the legal right-of-way line of Fifth Street at the dividing line of Lot NO.9 and Lot No. 10, PreliminarylFinal Subdivision Plan for Michael Manning & Associates, Recorded in Plan Book 71, Page 136. Thence by said right-of-way line North 39 degrees 54 minutes 30 seconds West a distance of 42.76 feet to a point at the intersection of the legal right-of-way line of Fifth Street and the legal right-of-way line of Plum Alley. Thence by the legal right-of-way line ofplum Alley, North 50 degrees 05 minutes 30 seconds East a distance of 71.00 feet to a point at the dividing line of Lot No.6 and Lot No. 10, herein described. Thence by said dividing line, South 39 degrees 54 minutes 30 seconds East a distance of 42.76 feet to a point at the dividing line of Lot No.9 and Lot No. 10, herein described. Thence by said dividing line, South 50 degrees 05 minutes 30 seconds West a distance of71.00 feet to a point, the place of beginning. BEING Lot No. 10, containing 3,035.96 square feet, as shown on PreliminarylFinal Subdivision Plan for Michael Manning & Associates, recorded in Plan Book 71, page 136. BEING subject to a 15 foot wide driveway easement, parallel with the northern property line of Lot No. 10, in favor of Lot NO.6 and Michael Manning & Associates as shown on drawing number 91-76.10 attached hereto. BEING further subject to all easements of record. BEING PART OF THE SAME PREMISES which C. S. Willis & Sons, Inc., a Pennsylvania corporation, by its deed dated November 15, 1995 and recorded November 16,1995 in the office of the Recorder of Deeds for Cumberlantl, County in Deed Book 131, Page 415 granted and conveyed to Michael Manning and Associates, a Pennsylvania General,: Partnership. Cl I PARCEL NO. 12-22-0822-316 a PROPERTY BEING: 328 SOUTH 5TH STREET '1 ,:,-, d. " File #: 129078 I' VRRIFIrATTON FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing on the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c) and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ J M-,-- FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff DATE: .J ) D/Ob . () '"'f,Q. p ~ l/l \l- \0. l/l _ ..c "if! ~ "?- \)' V> \).J ~ ~ ~ ~ ~ ) ,i. --_.~ e ("". \~\ . c::- G,j SHERIFF'S RETURN - REGULAR CASE NO: 2006-00437 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK NA VS SHELLEHAMER DOUGLAS L DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHELLEHAMER DOUGLAS L the DEFENDANT , at 1200:00 HOURS, on the 26th day of January , 2006 at 328 SOUTH 5TH STREET LEMOYNE, PA 17043 by handing to DOUGLAS SHELLEHAMER 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 18.00 14.08 .00 10.00 .00 42.08 So Answers: ~L-;..";::/ . j~ r /?~,"':;''':->;1.~r;';':<, ..fr_~~ , . R. Thomas Kline 01/27/2006 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before By: p, ~;I! ~ Deputy Sheriff ~ me this ~O "f: day of A.D. y . PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 PNC BANK, N.A. 11200 WEST PARKLAND AVNUE MILWAUKEE, WI 53224 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against DOUGLAS L. SHELLEHAMER, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/21/06 to 3/1 0/06 TOTAL $42,867.05 $ 1,279.80 $44,525.57 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, co y ~ched. / I () I 1\, (, V ~1)llU[L DAN . S Mlli'P'/E QUIRE ..~or Plaintiff \ DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: '1-11-0' CU.,^'l.uJ f. ~U . PRO PROTHY cr . (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, N.A. 11200 WEST PARKLAND A VNUE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL Dl"lSION v. NO. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on 3-q 20~. If you have any questions concerning this matter, please contact: ----.,., ~ -'-. . D '----:.. (' , ANIEL G. SCHMIE, . '. Attorney.fpr Plaintiff f '01ilEPENN CENTER AT SUBURBAN STAT 1617 JOHNF. KENNEDY BLVD., SUITE 140 PHILADELPHIA, PA 19103-1814 (215) 563-7000 '.THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY..' - . ;>HELAN HALLINAN AND SCHMIEG By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 One Penn Ceoter Plaza, Suite 1400 Philadelphia, PA 19103 (? I ';) ';61.7000 PNC BANK, N.A. ATTORNEY FOR PLAfNTIFF J : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY DOUGLAS L. SHELLEHAMER Defendants : NO. 06-427 TO: DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, PA 17043 aE tOft DATE OF NOTICE: FFRRIl ARV 16.2006 TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO IDRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (800)990-9108 1Itnv ^^ 1\ l=!11~ NCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff - . PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PIllLADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY F'OR PLAINTIFF i PNC BANK, N.A. 11200 WEST PARKLAND A VNUE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DI"lSION v. NO. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/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. (b) that defendant DOUGLAS L. SHELLEHAMER is over l8 years of age and resides at, 328 SOUTH 5TH STREET, LEMOYNE, PA 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. " . ~ PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHlLADELPHIA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF I PNC BANK, N.A. 11200 WEST PARKLAND AVNUE CUMBERI.AND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DOUGLAS L. SHELLEHAMER is over 18 years of age and resides at, 328 SOUTH 5TH STREET, LEMOYNE, PA 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ , hJ ~~~ -..' , "'-. ......l U\ ~. ~ ~ ~J ~ <...r, .-.S:::\ "J & .....l ~ n ('. --> 'c" ,::--? d' :% -;;."" >'J ..- -l ff, --1 ~.{,~ <?t:9, .,j'._\' ,-)C... .J-;.'; ",-.,-, '2n ?,.).'1' -?,:.."" <, :.4 ...., -j. t.') \,_1 u-' ----- PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PNC BANK, N.A. Plaintiff, v. No. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $44,525.57 Interest from 3/10/06 to SEPTEMBER 6, 2006 (per diem -$7.11) $1,279.80 and Costs TOTAL $44,525.57 -------, Note: Please attach description of property.No. IMPORTANT NOTICE: Tnis property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. <'l '<t 0 l"- ,... < ~ ..s z ;;.- 0 ~ ...~ Z r..l ...l O~ 0 . .... ~~ "' Eo< ~ -d f;l;l...1 ~ U <,) ...1;;'- f;l;l'-" Eo< ~ ~VJ X ~ VJ ZZ '" :=: f;l;l = :=: <,) OZ ., .D ..( ::l ... Q Eo< ~~ i o"C If> i ...1 ., :=: ~ . ~ f;l;l Eo< ... O~ ,;, :=: S~ E-< '" ~ .. UZ ~ .. VJ ~~ '" ...~ ..l 0 g- OO = "'~ 00 p. ~ 0):: 00 '" E-<U U M i3 Z ... Q <'l "'~ ~ ...l f;l;l6 ~ ~~ " ........, ~ e: '" ~ 8; '" 0 U '" .. ~~ ~ ~ 131 \ ........1, ....., - \A Eo<~ ~ ~\ 1-1 Z~ \ ....U , ---r ~ cd 3 ~ ~ ~ ~ '-' &: ':'""') d PJ. '::: , ..... ~ "- J ::: - VJ t.:) --J~ ~ '-' 0--.J ry ~ ':. ~ - G; . , ~'0 Q- """- ;-- I (J 0 .::::t-- , <J , ..~ I:i. () ;] ~ 'G.. (J 0; D) t,\__ .() Q Uj () () &. ....::.:; VJ --. ~ 1: ':2::{ ti Q- I) ::)- \7;- Di C(; u "'1- ..... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-437 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, N.A., Plaintiff (s) From DOUGLAS L. SHELLEHAMER (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRITPION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $44, 525.57 L.L. $.50 Interest FROM 3/10/06 TO 9/6/06 (PER DIEM - $7.11) -- $1,279.80 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $124.08 Plaintiff Paid Date: APRIL 7, 2006 Other Costs CURTIS R. LONG (Seal) ProthonotaJY _ <~y: d;;n..vc. /<;) ~--2--1<I' ~ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 ALL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County ofCwnberland, Commonwealth of Pennsylvania, being more fully described as follows: BEGINNING at a point, said point being located on the legal right.of-way line of Fifth Street at the dividing line of Lot No.9 and Lot No. 10, PreliminarylFinal Snbdivision Plan for Michael Manning & Associates, Recorded in Plan Book 71, Page 136. Thence by said right-of-way line North 39 degfees 54 minutes 30 seconds West a distance of 42.76 feet to a point at the intersection of the legal right-of.way line of Fifth Street and the legal right-of-way line of Plum Alley. Thence by the legal right-of-way line of Plum Alley, North 50 degrees 05 minutes 30 seconds East a distance of 71.00 feet to a point at the dividing line of Lot No.6 and Lot No. 10, hefein described. Thence by said dividing line, South 39 degrees 54 minutes 30 seconds East a distance of 42.76 feet to a point at the dividing line of Lot No.9 and Lot No. 10, herein described. Thence by said dividing line, South 50 degrees 05 minutes 30 seconds West a distance of 71.00 feet to a point, the place of beginning. BEING Lot No. 10, containing 3,035.96 square feet, as shown on PreliminarylFinal Subdivision Plan for Michael Manning & Associates, recorded in Plan Book 71, page 136. BEING subject to a 15 foot wide driveway easement, parallel with the northern property line of Lot No. 10, in favor of Lot No.6 and Michael Manning & Associates as shown on drawing number 91-76.10 attached hereto. BEING further subject to all easements of record. BEING PART OF THE SAME PREMISES which C. S. Willis & Sons, Inc., a Pennsylvania corporation, by its deed dated November 15, 1995 and recorded November 16, 1995 in the office of the Recorder of Deeds for Cumberland County in Deed Book 131, Page 415 granted and conveyed to Michael Manning and Associates, a Pennsylvania Genefal Partnership. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas L. Shellehamer, by Deed from Michael Manning and Associates, a Pennsylvania General Partnefship Consisting of Michael C. Manning and James W. D'Angelo, partners, dated 07-15-96, recorded 07-17-96 in Deed Book 142, page 953. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Michael Manning and Associates, by Deed from C.S Willis and Sons, Inc., dated 11-15-95, recorded 11-16-95, in Deed Book 131, page 415. Premises: 328 South 5th Street, Lemoyne, P A 17043 - PNC BANK, N.A. CUMBERLAND COUNTY . Plaintiff, v. COURT OF COMMON PLEAS DOUGLAS L. SHELLEHAMER CIVIL DIVISION Defendant(s). NO. 06-437 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PNC BANK., N.A., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,328 SOUTH 5TH STREET, LEMOYNE, fA 17043 . I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, PA 17043 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HINDES FAMILY TRUST, WALTER E. HINDES AND JUDITH A. HINDES, TRUSTEE 28 WEST SIMPSON STREET MECHANICSBURG, PA 17055 EQUlCREDIT CORPORATION OF AMERICA 10401 DEERWOOD PARK BLVD. JACKSONVILLE, FL 32256-0503 .. 5. Name and address of every other person who has any record lien on the property: . Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) NICOLE L. SHELLEHAMER 47764 CALE ZAFIRO INDIO, CA 92201 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 328 SOUTH 5TH STREET LEMOYNE, PA 17043 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of WeIfare PO Box 2675 Harrisburg, PA 17105 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 ofI8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. L," April 3, 2006 DATE '.) '-il :--.,.,. -~ (,,) , PNC BANK, N.A. CUMBERLAND COUNTY Plaintiff, v. No. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). April 3, 2006 TO: DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, PA 17043 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at, 328 SOUTH 5TH STREET, LEMOYNE, PA 17043, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 6, 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $44.525.57 obtained by PNC BANK. N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN piece or parcel ofland situate in the Borough of Lemoyne, County of Cumberland, Commonwealth of Pennsylvania, being more fully descn1>ed as follows: BEGlNNING at a point, said point being located on the legal right-of-way line of Fifth Street at the dividing line of Lot No.9 and Lot No. 10, Pre\iminaryfFinal Subdivision Plan for Michael Manning & Associates, Recorded in Plan Book 71, Page 136. Thence by said right-of-way line North 39 degrees 54 minutes 30 seconds West a distance of 42.76 feet to a point at the intersection of the legal right-of-way line of Fifth Street and the legal right-of-way line ofPlwn Alley. Thence by the legal right-of-way line of Plum Alley, North 50 degrees 05 minutes 30 seconds East a distance of71.00 feet to a point at the dividing line of Lot No.6 and Lot No. 10, herein described. Thence by said dividing line, South 39 degrees 54 minntes 30 seconds East a distance of 42.76 feet to a point at the dividing line of Lot No.9 and Lot No. 10, herein described. Thence by said dividing line, South 50 degrees 05 minutes 30 seconds West a distance of71.00 feet to a point, the place of beginning. BEING Lot No, 10, containing 3,035.96 square feet, as shown on PreliminaryfFinal Subdivision Plan for Michael Manning & Associates, recorded in Plan Book 71, page 136. BEING subject to a 15 foot wide driveway easement, parallel with the northern property line of Lot No. 10, in favor of Lot No.6 and Michael Manning & Associates as shown on drawing number 91-76.10 attached hereto. BEING further subject to all easements ofrecord. BEING PART OF THE SAME PREMISES which C. S. Willis & Sons, Inc., a Pennsylvania cOrporation, by its deed dated November 15, 1995 and recorded November 16, 1995 in the office of the Recorder of Deeds for Cumberland County in Deed Book 131, Page 415 granted and conveyed to Michael Manning and Associates, a Pennsylvania General Partnership. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas L. Shellehamer, by Deed from Michael Manning and Associates, a Pennsylvania General Partnership Consisting of Michael C. Manning and James W. D'Angelo, partners, dated 07-15-96, recorded 07-17-96 in Deed Book 142, page 953. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Michael Manning and Associates, by Deed from C.S Willis and Sons, Inc., dated 11-15-95, recorded 11-16-95, inDeed Book 131, page 415. Premises: 328 South 5th Street, Lemoyne, P A 17043 oo'^"", ..- c....' (~) en .~~J ~ ,. .) PNC Bank, N.A. VS Douglas L. Shellehamer In The Court of Common Pleas of Cwnberland County, Pennsylvania Writ No. 2006-437 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Daniel Schmieg. Sheriffs Costs: Docketing Surcharge Prothonotary Law Library Poundage Share of Bills Levy Advertising Posting Handbills Mileage 30.00 20.00 1.00 .50 936.43 19.31 15.00 15.00 15.00 29.16 $1,081.40 l ~ '1l&~)()l. ~~ * R. Thomas Kline, Sheriff BydD~~ Real Estate Sergeant ~ {i) I. CtL5LJ~?J~ ~, 17 tr q4..3 ... PNC BANK, N.A. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS DOUGLAS L. SBELLEHAMER CIVll.. DMSION Defendant(s). NO. 06-437 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) PNC BANK. N.A., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .328 SOUTH 5TH STREET. LEMOYNE. P A 17043 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLASL.SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, PA 17043 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HINDES FAMILY TRUST, WALTERE. HINDES 28 WEST SIMPSON STREET AND JUDITH A. HINDES, TRUSTEE MECHANICSBURG, P A 17055 EQUlCREDIT CORPORATION OF AMERICA 10401 DEERWOOD PARK BL YD. JACKSONVILLE, FL 32256-0503 , 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) NICOLE L. SHELLEHAMER 47764 CALE ZAFIRO INDIO, CA 92201 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 328 SOUTH 5TH STREET LEMOYNE, P A 17043 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. April 3. 2006 DATE E I :E d II HdV qOOl \fd 'Alhnu:J G ,i;;nm~nJ .:l.:lIH3HS 3Hl .:10 3:JU.:JO i PNC BANK, N.A. CUMBERLAND COUNTY Plaintiff, v. No. 06-437 DOUGLAS L. SHELLEHAMER Defendant(s). April 3, 2006 TO: DOUGLAS L. SHELLEHAMER 328 SOUTH 5TH STREET LEMOYNE, P A 17043 UTHIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COllECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. Your house (real estate) at. 328 SOUTH 5TH STREET. LEMOYNE. PA 17043. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 6. 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $44.525.57 obtained by PNC BANK. N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. the sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN piece or parcel ofland situate in the Borough of LeInoyne, County of Cumberland, Colll1l1Onwea1th of Pennsylvania, being more fully described as follows: BEGINNING at a point, said point being located on the legal right-of-way line of Fifth Street at the dividing line of Lot No.9 and Lot No. 10, PreliminarylFinal Subdivision Plan for Michael Manning & Associates, Recorded in Plan Book 71, Page 136. Thence by said right-of-way line North 39 degrees 54 minutes 30 seconds West a distance of 42.76 feet to a point at the intersection of the legal right-of-way line of Fifth Street and the legal right-of-way line of Plum Alley. Thence by the legal right-of-way line of Plum Alley, North 50 degrees 05 minutes 30 seconds East a distance of71.oo feet to a point at the dividing line of Lot No.6 and Lot No. 10, herein descn"bed. Thence by said dividing line) South 39 degrees 54 minutes 30 seconds East a distance of 42.76 feet to a point at the dividing line of Lot No.9 and Lot No. 10, herein described. Thence by said dividing line) South 50 degrees 05 minutes 30 seconds West a distance of 71.00 feet to a point, the place of beginning. BEING Lot No~ 10, containing 3,035.96 square feet, as shown on PreliminarylFinal Subdivision Plan for Michael Manning & Associates, recorded in Plan Book 71, page 136. BEING subject to a 15 foot wide driveway easement, parallel with the northern property line of Lot No.1 0, in favor of Lot No.6 and Michael Manning & Associates as shown on drawing number 91-76.10 attached hereto. BEING further subject to all easements of record. BEING PART OF THE SAME PREMISES which C. S. Willis & Sons, Inc., a Pennsylvania corporation, by its deed dated November 15, 1995 and recorded November 16, 1995 in the office of the Recorder of Deeds for Cumberland County in Deed Book 131, Page 415 granted and conveyed to Michael Manning and Associates, a Pennsylvania General Partnership. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas L. Shellehamer, by Deed from Michael Manning and Associates, a Pennsylvania General Partnership Consisting of Michael C. Manning and James W. D'Angelo, partners, dated 07-15-96, recorded 07,,17-96 in Deed Book 142, page 953. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Michael Manning and Associates, by Deed from C.S Willis and Sons, Inc., dated 11-15-95, recorded 11-16-95, inDeed Bookl31, page 415, Premises: 328 South 5th Street, Lemoyne, P A 17043 (I :E d II HdV qOOl Vd ')'li-inuJ {Jr,\j''t(jj8WnJ .:l.:lIB3HS 3Hl :30 JJU.:W . . WRIT OF EXECJJTION,and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-437 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, N.A., Plaintiff (s) From DOUGLAS L. SHELLEHAMER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRITPION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $44, 525.57 L.L. $.50 Interest FROM 3/10/06 TO 9/6/06 (PER DIEM - $7.11) -- $1,279.80 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $124.08 Other Costs Plaintiff Paid Date: APRIL 7, 2006 CURTIS R. LONG (Seal) Proth.2 '---By: (2..p ~fJ.~/?/U11/ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 ~ @.g c::::::::J ~ ~ ~ Real Estate Sale # 01 On May 03, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, P A Known and numbered as 328 South 5th Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 03, 2006 By: ~~ Real Estate Sergeant E' :[ d l' l:IdV QOOl Vd 'AH~nU:J UI~V'IU38~nJ .:ljl~3HS 3Hl .:10 3Jl.:!.:lO