Loading...
HomeMy WebLinkAbout02-1271WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. WALTER E. COVERT A/K/A WALTER COVERT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL HOME LOANS, INC SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. ACTION OF MORTGAGE FORECLOSURE WALTER E. COVERT A/K/A eZ ?a ?? V WALTER COVERT, Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., a corporation whose address is P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53201. 2. Defendant, WALTER E. COVERT A/K/A WALTER COVERT, is an adult individual whose last known address is 20 EAST JACKSON STREET, YORK, PENNSYLVANIA 17403. 3. On or about, September 17, 1998, the said Defendant executed and delivered a Mortgage Note in the sum of $93,070.00 payable to MORTGAGE INVESTORS CORPORATION, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1484, Page 858 conveying to original Mortgagee the subject premises. The Mortgage was further assigned to Fleet Mortgage Corp. and was recorded in the aforesaid County in Mortgage Book 592, Page 914. Washington Mutual Home Loans, Inc. is successor in interest by merger to Fleet Mortgage Corp. Said Mortgage and Assignment are incorporated herein. 5. The land subject to the Mortgage is: 807 FAIRVIEW ROAD, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on October 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $15.99 per day From 09/01/2001 To 04/01/2002 (based on contract rate of 6.5000%) Late Charges $24.25 From 10/01/2001 to 04/01/2002 Escrow Balance (Credit) Attorney's Fee at 5% of Principal Balance TOTAL $89,775.64 $3,389.88 $145.50 ($28.64) $4,488.78 $97,771.16 "Together with interest at the per diem rate noted above after April 01, 2002 and other charges and costs to date of Sheriff's Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclosure and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Pennsylvania Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6.5000% ($15.99 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's a and for foreclosure and sale of the property within described. By: PURCELL, KRUG & H LER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., Plaintiff VS. WALTER E. COVERT A/K/A WALTER COVERT, Defendant CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof , is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA F=70238.tit (1696x2800x2 titt) L91 _,: = "oan # ; 058281 OAN A PROVALL OF AFFAIRS OR ITS UUyfagqcs-? Case # 527981e2C NOTE NOT ASSUMABLE WITHOUT THE THE DEPARTMENT OF VETERANS AUTHORIZED AGENT. Septe tlbee? 17, 1998 Carlisle PA 10tyl (soft) 807 Fairview Road, Carlisle, PA 17013 I. BORROWER'S PROMISE TO PAY 1PMJPM gmu) In rattan for a loan that f have received, I promise to pay U.S. S "Pdacipall- plus ioteteat, to the order of the render. Tho Candor is Mort 93,070.00 (this amount is called f undentaad gage Investors Corporation that the lender may ftnsfer'Ws Nom The reader m anyone who tslw cola Note by tnnsFer and who is entitled to receive payraema under Note e caged ad the Note Holder." 2. XWEREST Interest 6 5? 0O %. on unpaid Imoetpal until the foil a rateof Count Of principal has been paid. I will pay httcrat at a yearly 6(B)Ilan Interco rate required by this Section 2 fs the rate T of this Note *W Par both befosa and after any default de:=-bad in Section 3. PAYME S (A) Tinto mind Ph" of psy nose f w11t pay Pdncipd and interest by making Payments every moaut. I will tmke'ay monthly Payments on dw 1st day of each mondt beginuiaa oat Noveaaber 1 beow titeae payments everndyamoarh until !have paid all of the 1 will makel I illtxd that I PdDc*W and in119 and an ' 1998 . October 1 2028 mayowett this Note. My monthly pnY tantta will be y other °haq , I stiff owe amounts under this Kate, applied to iaamtmunta is is in p?ypal. If, on which is called the "Mattuity Date.' I will pay than atnou full an that date, 33707 ?mcA?yPaynaamal 6090 Central Avenue St, Petersburg, SL (B) Amount otMoaa ft Paymeaw nr m a dUrCMt place if requhM by tlteNote molder. My monthly 1MYmcat will be fa the amount of U.S. $ 586.27 L BORROWER•sRrGTTormAy d hoot thereof credit la" duat the ed on the date m?ln7ent' Or SI is 19115. Any this Note or the any mod, and no intmm May be Y P'ePaYmmt is fttII of rho dept ahaU he than an larta haent due date need not be modkod mail theCam folloarhtg inatWimeot due daPa"Ymm te ?o On any day other mid P1eMyt+?. whlchever is rattfiiQ• or 30 ri after the date of the l`41 MTATSFDtaa RATE NOT[-rft%?'-Ily. V-0-r, In9n mM asaaagr Salt) . fPareJyfJyaryl Naaa4a enatn,trq? t'sCaaataaat-nm EW 161-1 11 ??'l F=70238.tit (1696x2800x2 titt) L101 S. LOAN CHARGES If a lsw, whims applies to thin loan and which sets ether loan charges collected to o collected maxuntou toad Charges, is'll"RY interPracollected in coaneefon with this loan exceed the Potmttted lin'M that collchargeected snail from be me wreducedhich by the a exeeaded mrootmt oft-Min of y permitted ecew limits tery Wllrebedd rttc. thueed to char mIIee. [o the Denttiued limit: and ii by reducing the Principal I one under at Not. Holder may choose to any sums already rcdmdon will be treated as a partial this Note or by tmicing a direct paY+n-'at to M. If a refu ape this refund Prepayment nd reduces PrinciPa,, the 6. BORROWER'S FAILURE TO PAY AS REQUIRh11 (A ) Late Charge for Overdue Payments If the Note of' s after the date Holder due I not re ceived the full amount Of 84Y moatlIIY payment the and of I ill y my overdue payment. I Will payay this a lalate te charge charge to the \ooa Holder. The amount of the charge will be calendar* (B) Delimit apromptly but only once on each late payment. 6.000 gM If I do not pay the lbl amount of each monthly paytoont on tin data h is due I w81 be in default. (C) Notice ofDefnWt 'r' &m'Q default- the Note ccruti w I oweeHolder Hoider may tend me a written aWY l omotmt tf I do not Pay the Overdue amount by a the 'ater'st that Y require me to the mated to me acct thatmaamount. lo date must be at Ieast 30 days after the datenou whwhich has not ich the notice ids delc1vered and oall (D) NoWWvWByNote $oWe, r Even if, at a thne when I am in default, the Note Holder dots not require rte to pay lmmediatc! in above, the Note Holder will still have the right to do so if I am in default at a later time. W) Pgment of Note Holdees Y full as deaenbrd If the Noce Holder has Costs and Expenses me to be paid back by me for all off its costs and Y "pnses iturnediatelY enforcing fug as described to I above the note Holder will have me Thou expcusee include, for example. reasonable attomoy: this Note to the extent not prohibited by aPPlkable latw. T• GIVING OF NOTICES Unless erg n mailing n by first clan maG tome at the notice that must be given to me under this Vote will be &nn by de8veriHolder a notice of my different address, Property Address above or at a different address if 1 give tae Note Any notice that must be given to the Note Holder under this Note will be given by mailing it by first mass mail Nola Holder at the address stated in Section 3(A) above or e a different athftsa if I am address, to the given a notice of that different 8. OBLfGAT'IONS OF PERSONS UNDER TAMS NOTE this pf mom then one person signs this Note, each paean 15 &My and ote, 3s also obli galn al he Promise to PRY the full amount o Any p?n?ss ao gu?or keep w of the promises tide to uuoty or aaated t do thew Not gx. Any person who takes over ibeae ob ' y or eadeaser of this Nobe e? guarantor ha rigtua under thin i Note against enea person imtretv&?y all ofd all of m a e to 06 N? Ththe e Note Homer a requited to pay amounts owed tinder this Not.. or enforc gether. Thin, mane that any one of m may be 9. WAIVERS I and any Other Pawn who has ON the *ht to bban?? the Note o to require the fatuous under this Note Holder to edamad Waive payment o amount. due. -N and mine of dishonor. otjOc to give notice to other Pm=uthat amounts dun)?? oftt?0n0J+moans been p&4 Mennen astir .. f+'w2?.1p,tMq r.erect'prarPWtOeinneitata?i.°.°ic pR F=70238.tit (1696x2800x2 titt) L111 a3,b?a 10. REFERRED RIDER, ADDENDUM. ATTACH M-4T OR OTHER NIOD1FICATION REFERRED TO AS ALLONGE) TO TIOIS NOT][ If an allonge providing for paym1erur ad' ( NAFTBR wilt this Note the covenants of the all Jestmenta or for any other supplemental inf Note as if the Wlange werea part of this N ? IChcck e?mted into and 1W amend and supplement is mcpt We?cobveo a?tso applicable box.) Graduated Payment Allungc 13 Other [alter] ? Outer [VOeifyj IL UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some Mittlkuom, In addition to the Note- tmxeYHtcWer under ties Note. ldcrfions 1> le losses Which Deed (the 'Seaaity Instrument'), du ins am to the l=S the Nots That ty Ttutrttmcat de,wiya how and on might result if I do not keep the same data as der full of all amounts 1 owe under this Now S what conditions I may be ? prO°"? "nadi I make in this Transfer of the o= of those oaatditioea are described as fopowst to make humtediatc payment is MAY property securing such loan to any traWerx amigo t}1C ared immediately due and payable upon transfer of the Pursuant to Section 3714 of f3tapter 37D rule 38, Ueitod States Code. of the assumption of the 1 If Leader exercises this oar is esablis> ed Period of not lass than 30 dam Leader slunk give awrower notice of aceekration. The aotice shalt pro vide a sums +xumW by this Security 8'bm the date the notice is delivered or mailed within which Borrow Leader ru re invoke any Inssm rnsaL If Borrower fails to pay those sums prior Borrower must pay all Borrowe Lender r. P tramtal by this Smanity tastruatant wititmutto ? ?potice of em p on . fttrtlxr notice or demand d on BoMo w has sweated and acknowledges mocipt Of paw I through 3 of this Note. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDpASIGNED. l o iw Wa eer E. Covert fS..J rowv ) (Seat) f?0 /Sfpr Orlgbw Ontyl Paylotheorderof WWW Reooutee Fleet fttpepe Cap. LW" rarrta S wuti (Pere 3vrs WMrI ner,rac r?wgwsurgra ?•wtrn °„ Walter Reoouree Pay To The oraw bf Fmc70238.tit (1696x2800x2 tiff) (191 EXHIBIT "A," wrtll+? rAPOn?ro?„ VICE CON .248 Drv, TINUA gY 77M NOS, 9 NA 4, ON SRN BLDG oAf (VIEW ROAD, Al .. 7N7ERS RMWU OF 16434 j.j $j, AN ARC LINg Ofi.PAIRVMW ROAD oN AlLtW?SMU MENTIONED PLAN OPF 7H8 SA?9p o 3 LINE ?0 baoxi 4150.01 FEMTTO OF 16 . LiT q ppMl ONTM LIST F LpO t CURVWG TO WL _ ANDLNAVM A T19H; I'C' 1'nYNUrNaBYs OP LOTNO.7N R .3MNLA,CE50 OR C5iM Evr7 J;IMT SETo ? CONDS POINNTOONTfM ALONG TIM LINZ ON r _ N0.3-THWC,Bja9 R 77M VNEOF Xsco,WE = PREMr90Eij BEMO LOT morwIN°. SST 146.41 FEET TO A PIO NO.;17 8 AypNO FA'JtVMW PE 60 AN NN yLy N 'rlre oPPltal T4i$ REC LLN oc ORBOOS IN AND POR CPUMB ° ANDUCOC vBLp _ ,'... T asY:'. ?RN ?'ROVCD W WN AND N11Mtis .C _ _ State of Pennsylvania (.1 :r;cti 0; Cumberland1 86 cadlsle, PA this Acoxl4841m X64 HH-181*7 u ?s7 VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for the Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: March 13, 2002 4'? Leon P. Haller, Esquire n ? C/ v ( j ? C1 } 7 I W ,L -C SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-01271 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS COVERT WALTER E AKA WALTER R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT COVERT WALTER E AKA WALTER COVERT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT , COVERT WALTER E AKA WALTER COVERT 807 FAIRVIEW ROAD CARLISLE IS VACANT. WALTER COVERT DECEASED AS OF SEPT 2001. Sheriff's Costs: So answers Docketing 18.00 Service 3.45 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County nn 36.45 PURCELL KRUG HALLER 04/10/2002 Sworn and subscribed to before me this /a 1?- day of .2 Un.2., A.D/.? Pr t onotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-01271 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS COVERT WALTER E AKA WALTER COV R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: COVERT WALTER E AKA WALTER COVERT but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On April 10th , 2002 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep York County 16.73 nn So answers: R. Thomas Kline Sheriff of Cumberland County '1 . '5 04/10/2002 PURCELL KRUG HALLER Sworn and subscribed to before me this /a,? day of L%n?t0 aav ?- A. D. A4 n ,F I Prothonotary' ' .: - •,?s.?rra?exrnessacvatic•/.n.oz vesmeu ??/ 2/? COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN 1. PLAINTIFF/S/ 2. COURT Nl M VL-16/1 O1V11 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDAN / Notice & Complaint in Walter E. Covert a/k/a Walter Covert Mortgage Foreclosure SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Walter E. Covert a/k/a Walter Covert 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 20 East Jackson Street, York, PA 17403 7. INDICATE SERVICE: ? PERSONAL ? PERSON IN CHARGE CKDEPUTIZE ? C T. IL 1 ST CLASS MAIL ? POSTED ? OTHER NOW March 15 20 I, SHERIFF OF COUNTY, PA??}o hereby depu iz the sheriff of -uz York COUNTY to execute mak tur rding to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF OUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Curnberland OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof, 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED T ___ n ri_11 ___ 1 ?1 n ,.,_._,l_ r.T____- ni rt______ _l_.? 1 -11 nn 1" nni 11 -i 3-15-02 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed-if notice is to be mailed). Kare?)JnB?laLr?VinCO. S1k f{ F orth Front St. , Harrisburg, PA 17102 „i . 13. I acknowledge receipt of the writ 1 1 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as indicated above. Re AHRENS 3-18-02 4-14-02 16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. ? 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 18. NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20. Time of Service 21. ATTEMPTS ?a(e ? m Mites Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. D-e c.enoed MC 9/OI SERVICE CALL (717) 771-9601 j"S' 7, i-ek 23. Advance costs 24. Service Costs 25. N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 31. Surchg. 32. Tot. Costs 33. Costs Due Refund ec k No. 75.00 9.00 5.00 .73 14.73 2.00 16.73 58.27 1!i 34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Postage/Not Found 39. Total Costs 40. Costs Due or Refund *hi 4rrrH So ANSWERS 41. AFFIRMED e •p qq }y .?? ,L S FAL Signature of 45. DATE 42. day of ?p •y 7 ? H ' A$ P. Sheriff Ar rt QZ of York, Yor" Cou t) TAY Signature of York 47. DATE Gomm County Sheriff WILLIAM Me HOSE 51 4/4/02 48. Signature of Foreign 49. DATE County Sheriff 50.IACK VVLtUtit KtGtlPl0t IKh5HEKIFhYtft IUKNSIkiNAIUKt 01. UA I t KLkLIVtU OF A HORIZED ISSUING AUTHORITY AND TITLE r r (*A r r t'4 ^, ?W4 rt. 11 n. /1. ..;. m. , ILL. E -ITT fc?IT) ,i j f =1 ! O ymit '. I ""I An 411k M7?A3 8S f r ' %,c 11 T?a F, , C I` .i' 1 iT aA;3?l w7T'.,?lu T irj 41A J ? tL?yp F :Jj,'v TA Ltf.P. C 5frf}'''?:.o-.. .1 ,?.?fi •.', a ?r, Cla rCl4 .? ,, r 3±, t.?."17N ?'. woo 771 ski OV bra iserpporl Bill W ebam #4 rn#sinisvft qul) vm. , tc3 (-,I ilt T_ M 'T 'WI `I'MT Jk J.A iT IT?1F Jt,. nM'tFJ?NM Niq 1?IttR4r')t l`7 fii AA 5?4 ?ti s l' a t" . tNt ? Y :'?i, .c to 7 3t: ytMl - Yk'?di'4:]YAV' 0''"?'Tt 1b ?.l/; Mr ,.t :.. 9') f l?',': i1tl. 7 IgiA ?IJ94gi JNI:! ?$OM Iin Ri Itw, o{?I,IQm -.Ct!,, Sit i?s,?alµ ..Ia.,' 9ynst~liplt r.,...n:,jAmRr)ft* atJoR.4 ' 1t t?Ij1 # xt?c,.y 1w lq qna x ai ) 'q k;nWllseHD , Ftts"dt 111et.0 I I aail?tr v;.w ?? t .t V) II 1 :'. t? 1 1 44111 awry W l A OKA Haul v4f?*ry?d 3` 7 M awl i rm. '--. ? ? 1 .- '--••--?-?T._yrAt In fig, N.?LWgtvi7ml .?I ' '. sl 1!I'P31- f HBi??Q`d9tr? i[Y +'AL71t8', [ YaioR s ) IN Og 7.7Ft x"230 ) SAWO Q 7 i6rA$o Wt ,;A :8? LOMW .J'F) YooWM*,WLft4W 9rd ift-, w 911wo tnn t =ai s. d GALJOI TOM s 1,w.ltnt xw 000 N%Wu l I t,. 'i fit µ,rf»kir `? rr.?;As P"`C.1 f 'i Pf7hp.?aC3"'^+.. r'?11': `. '+LK!hA!)I? l!`3.?'?f°!.'AU.. q f K ?f . r . ,.ertHt<t s, seCysrn r -'ttllN tsb+•o Q . ,sb ! r 1144t, yrlr?r .a ®M 10 f h4 r Y , l 9 'fill( - i} F } tt i Y' ` spr l-" i { ) I0 fi tel: ,Ic r Y ...! {} 17 I( Aft ut. {` pmlp?+dtp?tnittac?-4c_LL'?? ?? 7? ?*?t'YIrY'IrFIRWt.?SI ? i?i^tl??W ?r}?t °1'a .'.t1YlIYYi a,.aL --- ITAO A r [I,? .• ePf"• ?t.. I lMlktB yr tt? _ I ... „'' nr tt*rAtti ti+gWWo bU PPORI 49A. lP WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP PLAINTIFF VS. WALTER E. COVERT A/K/A WALTER COVERT DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NO. 02-1271 CIVIL TERM IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF PROCESS IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 410 & 430 OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Washington Mutual Home Loans, Inc. Successor in Interest by Merger to Fleet Mortgage Corp., through its counsel, Leon P. Haller, Esquire, hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by the Defendant located at 807 Fairview Road, Carlisle, Pennsylvania 17013. 2. Defendant, Walter E. Covert a/k/a Walter Covert, died September 8, 2001. No known estate has been opened. Any heirs or assigns of Defendant, Walter E. Covert a/k/a Walter Covert, are unknown. The Cumberland County Sheriff's Office has reported the property vacant, a copy of the Sheriff's Return attached hereto and made a part hereof as Exhibit "A 3. The Death Certificate lists an informant, Michael Covert, with a listed address of 1335 Wood Brook Lane, South Lake, Texas 76092. 4. Plaintiff believes that the above individual may have an interest in decedent's Estate. 5. Plaintiff requests an Order directing service upon the unknown Heirs and Assigns of Defendant, Walter E. Covert a/k/a Walter Covert, by posting a copy of the original Complaint on the most public part of the property, by mailing a copy of the Complaint to the property address and by publication pursuant to Rule 430(b)(2), said Rule allowing for service upon unknown heirs by publication and by forwarding a copy of the Complaint by certified mail and ordinary mail (service to be completed upon mailing) to Michael Covert at 1335 Wood Brook Lane, South Lake, Texas 76092. 6. Plaintiff avers that the method of service sought here is the most likely method to achieve the notice requirements of due process, while at the same time permitting the Plaintiff to proceed with its in rem action. WHEREFORE, Plaintiff requests that your Honorable Court direct service as above requested. Dated: May 24, 2002 PURCELL, G s LLER B Leon P. Haller PURCELL, KRUG & 14ALLER 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP VS PLAINTIFF WALTER E. COVERT A/K/A WALTER COVERT DEFENDANT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NO. 02-1271 CIVIL TERM IN MORTGAGE FORECLOSURE SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Process Pursuant to Rule 430, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That Defendant, Walter E. Covert a/k/a Walter Covert, died September 8, 2002. The Sheriff has advised that the property is vacant. Michael Covert is shown as an informant on the Death Certificate with an address of 1335 Wood Brook Lane, South Lake, Florida 76092. PURCELL, KRUG, & JJAWR BY: Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 (717)234-4178 Attorney for Plaintiff Attorney ID# 15700 Sworn to and subscri.,bed before me on this?y?-day of / v?lu 2 02. L otary Public NotvW %W My commission expires: qfty HaffWxrg q ttyy NyCAmvnle W Expi? 252605 (SEAL) Member, Fe mrft a r&A"o*Awo(NoWdw H105.905 REV.(09/00) This is to certify that this is a true copy of the record which is on file in the Pennsylvania Division of Vital.Rec6r&'in accordance with Act 66, P.L. 304, approved by the General Assembly, June 29, 1953. WARNING: It is illegal to duplicate this copy by photostat or photograph. Robert S. erman, Jr., MPH Secretary of Health '.9'13)G No. k? 'C•/ N,DS.w Rea. vaT TTPF/PMNT IN PERiiutt, NT a M" 9LR! 087540 ' SEa SDCML SECURNY NUMBER DRE OF OEATN:Mwah. N.'ar.l Walter E. Covert ] _ •GEIL..9.h p UNDER, YEAR UNDER, ON OREwe, ? 177 16 - ,' Myna NRTRPI.[C'E Ch.b PL tlcl)E.ntt -----e-sbnauu[mamGn. adal 67 Da,e Ny1a . MNwee PMmw. pa.eal Same. lw.wC YR, aPIE0,1934 Mari onv. le,PA i,,calleeek] ERIQapaliaM? DDA? MT w alb, ' CWNnaDERN E' T. Y N°^. ? Myean[ ? ISPHII? r.BOIeO.TWPOi DERH FACERY NaMEIfrolnwue[r.,MSneelwraanesr YMS DECEOEM OF NISPANRpIX31M MLE.amrkan Cumberland Gda RM HM...[. w Carlisle Nep ,,, ?f,...P.yryDm.,, rsp.m r ,lisle Regional Medical CentNer M..N.Lw.MRI?,r..[ OELEDEM'S USUR OCCUPaTipl N U. +. ,,. White (!raa YaNdagrp awvq[vgnml WOOF WSINESSRNpM3TRY LWSDfCEDENT EVEP p, DECEDENTS EDUCISMI MAPIML SWU3 M Ideate, MwrMq ISPIX ?GDn. uxrWtoI U.S. HF NIMEDFORCE3T 1Mry M.r4a.WWiwe. OIx4 gwman,irwn `j M E'?'^^+MM'S[mMw Cattle Ohaacee oa m ++, A/2C P „uS Air Force ? 2 „ Divo c DECEOENT3uRUMG aD0RE33ryrwL0N/[y.o,9 ZO00ON DECEDENT'S 1+. 807 Fairview Rd. ACTUA T..SRb m „[.?YbG.yd.e+.G. Carlisle, Pa 17013 S:.y. O[rv YMl L.e.r. 'A Cumberland b-MVT R, GReG FRNER'SINMEIFan.MeW.Lap ,Ta®.ilwrayuMmmeat Nrr[ab- (]a 7' 7 G»eare MOTHER'S NAME1Fin. Mgge, MyUn SVrveyl ,L Francis Marion Covert nIFOF TS RM.E(T,P.P ,s. Jean Michael Covert NN°RM""'TS""E,"°woaESS,s.+.CF„M-r.3M+. rbcro.r METNDDDF nsPOSITN]R ]+.. 1335 Wood Brook Lane oaEaF asPO3lTlo„ BuW Q[m.b,? Rmwblmm3wF? pbalr. Da, yl wdlw? 10NWma MCam.wY.Gwabry LOCRIDN-CiMT[.rr, 31M, Zb tPi OwMbl? Qirr 1 PI di ], n antown Gap ? ]'a Sept. 12, 2001 am. ]u EWFUNERM 3ERVICFy,C2ySEE ORPERSDNACUN0 h48UCM / LICENSE MIMBER L ` L?A IMMEAMDaDORESSO I Hoffman-Roth Funeral Home- T, ? m.21 l Gwreyyc . 9 N M^w. a.bww..aMIMRr.. e.FMMy.[.wl.e MlwON?a""w 0mb Net °'a' bb y . LIDENX NDM3ER DRF SaNEO aw • N1 p,y.r, n+. Reel a, Garr. ]b]+aNNtMCwrbM eeq OFOFRN DRF PRONOUNCEDDEADpFyral. DM 2ftm Faraarr a. PrywMw U[allr. 0 hear, V . M S CASE REFERNEOTO MFDCALE]AM,NEMCdgNERi y/ ]A I M. ]F. 09 fal 0) 1M ? u,.pD ]T. RVIT is Emwm[OwaFa, iyrngw[yrbY[F,bry.NOr aryp YyyFarn. IlO op H' Y'\ .lMnby l LW - e pryq, rOa[w wrRyMnuaFm Fayliy. reapvabryarW.arbt.w Man laiwe. rapy[am.a MRT R: pNyyyMMp MIYyMmMNylyybbaN put . lathaean MdMMgerr9p+eb PNRT L r?Tw Ec lutataat p. - :y..leudeech mreerrfllpi,M rarbp baeMl-. t ? GIE a3 ENCE Of} p i E ae,, aeateceal ' y'? WEWpRA3aCON5Eg1EN0E 0h. ? 1 CYIfE(O.b.a p 4 DUE NIOR a.5ACd5EWENCE OEy ,... ' var4+raw?i WT I a. YM4ARearm 3Y WEREAUlDP3YFElDNp3 1yNNERCF DERV ' IERFORMEp] AYRIABLE PRXNI R) DREOF NUIHIY TIME Ci NUURY 84RMYRYaMNT DESCRIBE IIDwpLMR]'OCC111111E0. CpFRETpROFCAUSE Repeat oft lead ? N.vy Rylu[tla ? hb6rR M1ranp keeal9.iyr ? Ka ? W ? 1L ? M Yn ? W ? Socha pL M. CauMnw MOalarmu,tl ? RACECFI1LIWiY-RMma 9rm a,n. IFn B . . . y%y [a LOCRION pateum C.^,, ]N. M. kart. ISpcMI SMb CERTNIERIChedr ] ? RT •CFRTIFYPp FN ENA .MIPI.Tfc?ancmrynq[yAay mnm xtyn Fnylyr qNR aNODTLEOFCE RTNIER T0IM MM O1IrW LmNaIPa Caam MWninMayywwW Oeyh yb [yMneOlbn 2]I o[evrraa e . w b w.eau.ala) aM manmr n aMw ................. ' 'FRONODNCIIq ANOCEIITIFYINOIMY y L E E ? DRE I wcuq Ge.h.H _ nn. Ts,MbF,el myYroaRGga. Leap, p[MMNBr a Mny,Gale, yq pia[F aM YUato n . aa(barq mar,n waaa,alH .......................... ? ]t[. NAMEaRDADDAE' OF vdi COMPLFTEDCAUS O R 'MEDICAL UANINEMCORONER / (ham]T)TYOace PrvN .Eyylr a LT ?I M IM pa,if o1 eaamirvDOn aM/aimef119alien, inmy op,nwo Ll OI . death «[ mM E VKi7+L .t? . + unG na[ u rtMW ............. ? ate! M the, Home. Oala, and place. Mtl due to the cauee(F) aho / ............ REGISTMR"S SIGNRURf ANON Yl. ]]" A. ORE MED IRmwr. Dry Charles Hardester State Registrar MAY 2 2002 Date COMMONWEALTH OF PENNSYLVANIA a DEPARTMENT OF HEALTH a VITAL RECORDS CERTIFICATE OF DEATH aooI cr ?=- r, LIJ ).T L)` i _ [iF- 1 O o U WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF VS. WALTER E. COVERT A/K/A WALTER COVERT DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NO. 02-1271 CIVIL TERM IN MORTGAGE FORECLOSURE ORDER FOR SERVICE AND NOW, to wit, this Ired day of Uk„? 2002, upon consideration of the within Affidavit, is appearing that a good faith investigation and effort to locate the Unknown Heirs and Assigns of Walte3 Covert a/k/a Walter Covert has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 807 Fairview Road, Carlisle, Pennsylvania 17013, and by forwarding a copy of ' Complaint by certified mail and ordinary mail (service to be completed up, mailing) to Michael Covert at 1335 Wood Brook Lane, South Lake, Florida 76092, and by publication pursuant to Rule 430(b)(2); AND FURTHER, that i the event this case should be reduced to judgment and execution shall be issued, service upon the Defendant pursuant to Rule 3129.2 (C) shall be effected by posting a copy of the Notice of Sale or Sheriff's handbill on most public part of the premises and by publication by the Sheriff pursua to Pennsylvania Rule of Civil Procedure 3129.2 (d). BY E COUR e. he the at J 01 1 s1 c_ .,1 LO i. ii WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Plaintiff VS. WALTER E. COVERT A/K/A WALTER COVERT Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1271 CIVIL TERM PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: June 25, 2002 PURCELL, KRUG, & HALLER BY T719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 c? U ` J Ca ? j;\r1 WASHINGTON MUTUAL HOME LOANS, : INC. SUCCESSOR IN INTEREST BY : MERGER TO FLEET MORTGAGE CORP. : Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1271 CIVIL TERM WALTER E. COVERT A/K/A WALTER : CIVIL ACTION - LAW COVERT IN MORTGAGE FORECLOSURE Defendant AFFIDAVIT OF SERVICE I, Leon P. Haller, hereby certify that a true and correct copy of the Complaint in the above captioned action was forward to the following individuals by regular U. S. Mail, first class service, postage prepaid, and by certified mail, return receipt requested, postage prepaid, on July 1, 2002, addressed as follows: Unknown Heirs of Walter E. Covert a/k/a Walter covert 1335 Wood Brook Lane South Lake, FL 76092 Leon P. Haller SWORN to and subscribed this 1 1? day of , 2002. fn l lJ otary Public My commission expires: (SEAL) NOTARIAL SEAL ANGELA J. GLASS, Notary Public City of Harrisburg Dauphin County My Commission Expires May 12, 2003 r? ?? c? _ f t"_f 1 C_T' t-? __ ? rv C7 L ?= , ? r -?,__ ? . - . v.? ;:- - -- ?_, ? ;;; ? ?- ?y .1 J N CASE NO: 2002_01271 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL HOME LOANS VS COVERT WALTER E AKA WALTER COV RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania who being duly sworn according to law, says, the within COMPLAINT MORT FORE was served upon VNRT WALTER E Axn UTATI,,- _ODEFENDANT the at 0800 HOURS, on the 28th da at 807 FAIRVIEW ROAD Y of June 2002 CARLISLE, PA 17013 POSTED PROPERTY AT by handing to 807 FAIRVIEW ROAD CARLISLE a true and attested copy of COMPLAINT,- MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriffs s Costs: Docketing So Answers. Service 18.00 Posting 63.45 .00 Surcharge 10.00 R. Thomas Kline 00 37.45 07/01/2002 PURCELL KRUG HSworn and Subscribed to before me this ? By. day of C 2" ? A.D. rothonotary WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1271 CIVIL TERM WALTER E. COVERT A/K/A WALTER CIVIL ACTION - LAW - COVERT IN MORTGAGE FORECLOSURE Defendant PROOF OF PUBLICATION PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA. 17102 (717) 234-4178 Attorney ID # 115700 Attorney for Plaintiff PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF vs. WALTER E. COVERT A/K/A WALTER COVERT DEFENDANT MORTGAGE FORECLOSURE NO. 02-1271 CIVIL TERM TO: THE UNKNOWN HEIRS OF WALTER E. COVERT A/K/A WALTER COVERT: You are hereby notified that on March 15, 2002, Plaintiff, WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 02-1271 CIVIL TERM wherein Plaintiff seeks to foreclose its mortgage securing your property located at 807 FAIRVIEW ROAD, CARLISLE, PA 17013, whereupon your property would be sold by the Sheriff of Cumberland County. You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or a Judgment will be entered against you. You have been sued in Court. you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses of objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other right import to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Name: Lawyer Referral Service Address: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone number: 717.249-3166 Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102 717-234-4178 June 27, 2002 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. July 1, 2002 Sworn to and subscribed before me this 1 st day of July , 2002. Notary Public My commission expires: NOTARIAL SEAL SHIRi.EY 0. DURNIN, Notary Public Car?sle Boro., Cumberland County _ My Commission Exflirf,; Aug. I. 2003 WASHINGTON MUTUAL HOME LOANS, IN THE COURT OF COMMON PLEAS INC. SUCCESSOR IN INTEREST BY CUMBERLAND COUNTY, PENNSYLVANIA MERGER TO FLEET MORTGAGE CORP. Plaintiff vs. NO. 02-1271 CIVIL TERM WALTER E. COVERT A/K/A WALTER CIVIL ACTION - LAW - COVERT IN MORTGAGE FORECLOSURE Defendant PROOF OF PUBLICATION PURCELL, KRUG & HALLER eon . Haller, Esquire 1719 North Front Street Harrisburg, PA. 17102 (717) 234-4178 Attorney ID # 1.5700 Attorney for Plaintiff PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz JULY 5, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are Roger . Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 5 day of JULY 2002 LOIS E. SNYDER, NOWY t CarbW Boeo, Currib&W4 e; My Co m: Exores Mardi 5, CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, PA Civil Action-Law No. 02-1271 Civil Term WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF VS. WALTER E. COVERT, A/K/A WALTER COVERT DEFENDANT MORTGAGE FORECLOSURE TO: THE UNKNOWN HEIRS OF WAL- TER E. COVERT, A/K/A WALTER COVERT: You are hereby notified that on March 15, 2002, Plaintiff, WASH- INGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 02-1271 CIVIL TERM wherein Plaintiff seeks to foreclose its mort- gage securing your property located at 807 FAIRVIEW ROAD, CARLISLE, PA 17013, whereupon your proper- ty would be sold by the Sheriff of Cumberland County. You are hereby notified to plead to the above referenced Complaint on or before 20 DAYS from the date of this publication or a Judgment will be entered against you. You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment: may be entered against you without fur- ther notice for the relief requested by the Plaintiff You may lose money or property or other rights impor- tant to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawver Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LEON P. HALLER, ESQUIRE 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 July 5 NOTICE WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. WALTER E. COVERT A/K/A NO. 2002 1271 WALTER COVERT, DEFENDANT IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant WALTER E. COVERT A/K/A WALTER COVERT for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $89,775.64 Interest $ 3,389.88 (Per diem of $15.99 from 9/1/01 to 4/1/02) Late charges $ 145.50 ($24.25 per month to 4/02) Escrow Credit $ 28.64 5% Attorney's Commission $ 4,488.78 TOTAL $97,771.16** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & H By Leon P. Haller PA I.D. 415700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K WKF\DOCS\OUMBERLA\OOVERT.P WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF VS. WALTER E. COVERT A/K/A WALTER COVERT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 1271 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on August 2, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I 415700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 WASHINGTON MUTUAL HOME LOANS, INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP Plaintiff vs. WALTER E. COVERT A/K/A WALTER COVERT Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-1271 CIVIL TERM IN MORTGAGE FORECLOSURE A M E N D E D N 0 T I C E To: MICHAEL COVERT and Unknown Heirs of Walter E. Covert a/k/a Walter Covert 1335 WOOD BROOK LANE SOUTH LAKE, FLORIDA 76092 WALTER E. COVERT a/k/d WALTER COVERT 807 FAIRVIEW ROAD CARLISLE, PA 17013 DATE OF NOTICE: AUGUST 2, 2002 IMPORTANT NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS 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. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717)249-3166 (800)990-9108 PURCELL, KRUG & HALLER By: Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF VS. WALTER E. COVERT A/K/A WALTER COVERT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 1271 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before e this/,,? day of T 200a No ry ub is LEON P. HALLER, ESQUIRE AL , Notary public phin C ounty Aug. 8, 20pg imk p 44. 7v 4D V c_. r, C-7 -01 F7 m U: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 1271 WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTERESET BY MERGER TO FLELET MORTGAGE CORP., PLAINTIFF Vs. WALTER E. COVERT A/K/A TOTAL AMOUNT OF JUDGMENT $ 97,771.16 Interest at $15.99 per diem to sale date $ 3,917.55 Late charges at $24.25 per month to sale date $ 169.75 Escrow Deficit $ 2,000.00 TOTAL $103,858.46* WALTER COVERT, *SALE DATE: WEDS.,DEC. 4, 2002 DEFENDANT(S) (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: September 10, 2002 Attorney for Plaintiff 1719 North Front Street Leon P. H ler Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 807 FAIRVIEW ROAD, CARLISLE, PA 17013. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K\ MKPDOOS\CUMBERLA\COVERT. W ?P-_ u ? O n I?j w ALL THAT CERTAIN lot of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern line of Fairview Road, at the intersection of same with the line dividing Lots Nos. 3 and 4, on Block "D", on the hereinafter mentioned Plan of Lots; thence continuing by the southern line of Fairview Road on a line curving to the left and having a radius of 164.54 feet, an arc distance of 16 feet to a point; thence continuing by same North 64 degrees 7 minutes East 41.15 feet to a point on the line of Lot No. 5; thence by said latter line South 25 degrees 53 minutes East 150.01 feet to a point on the line of Lot No. 19; thence along the line on Lots Nos. 19 and 20, South 70 degrees 20 minutes 50 seconds West 75 feet to a point on the line of Lot No. 3; thence along the line of Lot No. 3 North 19 degrees 4 minutes 20 seconds West 146.41 feet to a point on the southern line of Fairview Road, the place of BEGINNING. SAID premises being Lot No. 4, Block "D" on a certain Plan of Hamilton Development as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60, and being improved with a dwelling known and numbered as 807 Fairview Road, Carlisle, Pennsylvania. HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 807 FAIRVIEW ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Ruth M. Kratz, now by marriage, Ruth M. Brown, and David Brown, her husband, by deed dated 8/27/96 and recorded in Deed Book 145, Page 168 granted and conveyed unto Walter E. Covert. The said Walter E. Covert a/k/a Walter Covert is believed to be deceased and title vests in the unknown heirs and assigns, if any. TO BE SOLD AS THE PROPERTY OF WALTER E. COVERT A/K/A WALTER COVERT, HIS UNKNOWN HEIRS AND ASSIGNS. ASSESSMENT #06-19-1641-211 EX and #06-19-1641-211 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1271 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL HOME LOANS, INC., SUCCESSOR IN INTEREST BY MERGER TO FLELET MORTGAGE CORP. Plaintiff (s) From WALTER E. COVERT A/K/A WALTER COVERT (1) You are directed to levy upon the property of the defendant (s)and to sell SEE ATTATCHED LEGAL DESCRIPTION.807 FAIRVIEW ROAD, CARLISLE, PA 17013. (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 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$97,771.16 L.L.$.50 Interest AT $15.99 PER DIEM TO SALE DATE $3,917.55 Late charges at $24.25PER MONTH TO SALE DATE $169.75 Atty's Comm % Due Prothy $1.00 Arty Paid $187.63 Other CostsEscrow deficit $2,000.00 Plaintiff Paid Date: September 11, 2002 CURTIS R. LONG Prothonotary (Seal) By: 7?/!nw Deputy REQUESTING PARTY: Name Leon P. Haller, Esq. Address: 1719 North Front Street Harrisburg, PA 17102 Attorney for: Plaintiff Telephone: 717-234-4178 Supreme Court ID No. 15700 WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. WALTER E. COVERT A/K/A NO. 2002 1271 WALTER COVERT, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 807 FAIRVIEW ROAD, CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 121335 Wood Brook Lane South Lake, Florida 76092 Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 807 Fairview Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TEL Casualty Unit Estate Recovery Program P. 0. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Citifinancial Inc. 4 Neshaminy Interplex Suite 209 Trevose, PA 19053 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relati to unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 10, 2002 CJ c= -, <n hiltll -'L! - - ( ?1 fi t, WASHINGTON MUTUAL HOME LOANS IN THE COURT OF COMMON PLEAS INC., SUCCESSOR IN INTEREST BY CUMBERLAND COUNTY, PENNSYLVANIA MERGER TO FLEET MORTGAGE CORP., PLAINTIFF CIVIL ACTION - LAW vs. WALTER E. COVERT A/K/A NO. 2002 1271 WALTER COVERT, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 4, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) 'THE LOCATION of your property to be sold is: 807 FAIRVIEW ROAD CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $97,771.16 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 1271 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: WALTER E. COVERT A/K/A WALTER COVERT A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment aga_nst you. You may also file an petition with the same Court if yoti are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be servred on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. if a specific return date is desired, such date must be obtained from the Court Administrator's office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern line of Fairview Road, at the intersection of same with the line dividing Lots Nos. 3 and 4, on Block "D", on the hereinafter mentioned Plan of Lots; thence continuing by the southern line of Fairview Road on a line curving to the left and having a radius of 164.54 feet, an arc distance of 16 feet to a point; thence continuing by same North 64 degrees 7 minutes East 41.15 feet to a point on the line of Lot No. 5; thence by said latter line South 25 degrees 53 minutes East 150.01 feet to a point on the line of Lot No. 19; thence along the line on Lots Nos. 19 and 20, South 70 degrees 20 minutes 50 seconds West 75 feet to a point on the line of Lot No. 3; thence along the line of Lot No. 3 North 19 degrees 4 minutes 20 seconds West 146.41 feet to a point on the southern line of Fairview Road, the place of BEGINNING. SAID premises being Lot No. 4, Block "D" on a certain Plan of Hamilton Development as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60, and being improved with a dwelling known and numbered as 807 Fairview Road, Carlisle, Pennsylvania. HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 807 FAIRVIEW ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Ruth M. Kratz, now by marriage, Ruth M. Brown, and David Brown, her husband, by deed dated 8/27/96 and recorded in Deed Book 145, Page 168 granted and conveyed unto Walter E. Covert. The said Walter E. Covert a/k/a Walter Covert is believed to be deceased and title vests in the unknown heirs and assigns, if any. TO BE SOLD AS THE PROPERTY OF WALTER E. COVERT A/K/A WALTER COVERT, HIS UNKNOWN HEIRS AND ASSIGNS. ASSESSMENT 406-19-1641-211 EX and #06-19-1641-211 n ? ? -, ?- ? -:, ?? rn T?? "'l ?'y' "77 ?. ' __ Cil f .? r°-- i ??? - -• =i r' ? c- ' - w : WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. PLAINTIFF VS. WALTER E. COVERT A/K/A WALTER COVERT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 1271 DEFENDANT IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that have de osited in the U.S. Mails at Harrisburg, Pennsylvania on - , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 121335 Wood Brook Lane South Lake, Florida 76092 Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 807 Fairview Road Carlisle, PA 17013 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Citifinancial Inc. 4 Neshaminy Interplex Suite 209 Trevose, PA 19053 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By B PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 JOHN W. PURCELL TELEPHONE (717) 2344178 HOWARD B. KRUC FORECLOSURE DEPT. FAX (717) 234-1206 LEON P.HALLER JOHN W. PURCELL JR. BRIAN.I. TYLER JILL M. WINEKA (717) 533-3836 NOTICE TO: Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 121335 Wood Brook Lane South Lake, Florida 76092 Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 807 Fairview Road Carlisle, PA 17013 Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. 0. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 Citifinancial Inc. 4 Neshaminy Interplex Suite-209 Trevose, PA 19053 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that have an opportunity to protect your interest, if any, by notified of said Sheriff's Sale. BY= Leon . Haller PA .D.15700 Attorney for Plaintiff WASHINGTON MUTUAL HOME LOANS INC., SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP., PLAINTIFF vs. WALTER E. COVERT A/K/A WALTER COVERT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 1271 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, DECEMBER 4, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 807 FAIRVIEW ROAD CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $97,771.16 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 1271 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property WALTER E. COVERT A/K/A WALTER COVERT A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN lot of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern line of Fairview Road, at the intersection of same with the line dividing Lots Nos. 3 and 4, on Block "D", on the hereinafter mentioned Plan of Lots; thence continuing by the southern line of Fairview Road on a line curving to the left and having a radius of 164.54 feet, an arc distance of 16 feet to a point; thence continuing by same North 64 degrees 7 minutes East 41.15 feet to a point on the line of Lot No. 5; thence by said latter line South 25 degrees 53 minutes East 150.01 feet to a point on the line of Lot No. 19; thence along the line on Lots Nos. 19 and 20, South 70 degrees 20 minutes 50 seconds West 75 feet to a point on the line of Lot No. 3; thence along the line of Lot No. 3 North 19 degrees 4 minutes 20 seconds West 146.41 feet to a point on the southern line of Fairview Road, the place of BEGINNING. SAID premises being Lot No. 4, Block "D" on a certain Plan of Hamilton Development as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60, and being improved with a dwelling known and numbered as 807 Fairview Road, Carlisle, Pennsylvania. HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 807 FAIRVIEW ROAD, CARLISLE, PENNSYLVANIA 17013. BEING THE SAME PREMISES WHICH Ruth M. Kratz, now by marriage, Ruth M. Brown, and David Brown, her husband, by deed dated 8/27/96 and recorded in Deed Book 145, Page 168 granted and conveyed unto Walter E. Covert. The said Walter E. Covert a/k/a Walter Covert is believed to be deceased and title vests in the unknown heirs and assigns, if any. TO BE SOLD AS THE PROPERTY OF WALTER E. COVERT A/K/A WALTER COVERT, HIS UNKNOWN HEIRS AND ASSIGNS. ASSESSMENT 406-19-1641-211 EX and #06-19-1641-211 LAW OFFICES J CGXCCL?' - •JG%CLfz, , l ? ?.LCPj/t ? Q ? ? 1719 N. FRO STREET HARRISBURG; PA. 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 233-1149 WASHINGTON MUTUAL HOME LOANS, IN THE COURT OF COMMON PLEAb INC. SUCCESSOR IN INTEREST BY MERGER TO FLEET MORTGAGE CORP. CUMBERLAND COUNTY,PENNSYLVANIA PLAINTIFF vs. CIVIL ACTION - LAW WALTER E. COVERT A/K/A WALTER NO. 02-1271 CIVIL TERM COVERT IN MORTGAGE FORECLOSURE DEFENDANT ORDER FOR SERVICE AND NOW, to wit, this 3)'`- day of 2002, upon consideration of the within Affidavit, is appearing that a good faith investigation and effort to locate the Unknown Heirs and Assigns of Walter e. Covert a/k/a Walter Covert has been made by Plaintiff, it is hereby ORDERED that service of the Complaint be made by posting a copy of the original Complaint on the most public part of the property located at 807 Fairview Road, Carlisle, Pennsylvania 17013, and by forwarding a copy of the complaint by certified mail and ordinary.mail (service to be completed upon R mailing) to Michael Covert at 1335 Wood Brook Lane, South Lake, Florida 76092, and by publication pursuant to Rule 430(b)(2); AND FURTHER, that in the event this case should be reduced to judgment and execution shall be issued, service upon the Defendant pursuant to Rule 3129.2 (C) shall be effected by posting a copy of the Notice of sale or Sheriff's handbill on the most public part of the premises and by publication by the Sheriff pursuant to Pennsylvania Rule of Civil Procedure 3129.2 (d). BY THE COURT J 71i0 3901 %44 9047 4064 TO: WALTER E COVERT A/K/A WALTER COVERT HIS UNKNOWN HEIRS AND ASS=3NS 807 FAIRVIEW ROAD CARLISLE PA 17013 SENDER: REFERENCE: RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail POSTM4f* 09 , ??. as a ?l by ONn95`?a? ?160 3901 9844 9047 405? TO: WALTER E COVERT A/K/A?PRIVATE ? WALTER COVERT HIS UNKNOWN HEIRS AND ASSIGNS 121335 WOOD BROOK LANE SOUTH LAKE FLORIDA 76092 SENDER: REFERENCE: RETURN RECEIPT SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ---------------- ------- , f S m ?, c r bd ?tinss`a Re: WAMU vs. Covert Cumberland 12/4/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 121335 Wood Brook Lane South Lake, Florida 76092 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Walter E. Covert a/k/a Walter Covert His Unknown Heirs and Assigns 807 Fairview Road Carlisle, PA 17013 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addre Department of Revenue Inheritance Tax Division Strawberry Square Harrisburg, PA 17105 Postage: Postage: a$ U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Department of Public Welfare TPL Casualty Unit Estate Recovery Program P. O. Box 8486 Willow Oak Building Harrisburg, PA 17105-8486 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Citifinancial Inc. 4 Neshaminy Interplex Suite 209 Trevose, PA 19053 U. S. POSTAL SERVICE CERTIFICATE OF MAILING ?E?Fg9 (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail address Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 Y Postage:f18S??`aa 1 'f U....• •\J' ("'? ?.. i=- ? . "' i _.-i :a '.-, r- .__. • • Sri - ? ?' ca -- EALTH OF PENNSYLVANIA SS: COMCO TY OF CUMBERLAND Recorder of Deeds in and for said County and state do hereby certify that I, Robe P. grantee the same Secretary of V eterans Affairs of W shin on D C is the the Sheriffs Deed in which virtue of a writ been sold to said grantee on the 4th day of Dec A.D., 2002, under and by having th da of Sept, A.D., 2002° out of the Court of Common Pleas of said County Exec issued on the 1= y against W_ a ivil Term, 2002 Number 12711 at the suit of Washin on Mutual Home C as of Loans Inc is duly recorded in Sheriff's Deed Book No. 255, Page 1257. E Covert aka W -alter IN TESTIMONY VMEREOF, I have hereunto set my hand day of 8 and seal of said office this A.D. 2001 of Deeds Recorder of Dmde. Cumbeeff4 ?CmWe PA My Wm,sW ExW0 V1 FYI Cf .M. 200 Washington Mutual Home Loans, Inc. Successor in interest by merger to Fleet Mortgage Corp. VS Covert in The Court of common Pleas of Cumberland County, Writ No. 2002-1271 Civil Term Walter E. Covert a/k/a W alter duly sworn according to law, states that he dantto wit: Walter . R. Thomas Kline, Sheriff, who being Y ent search and inquiry for the within named defen, made a dilig as to as 2002. of r 01, rt a/k/a Walter Covert, but was unable to locate him in his bailiwick. He therefore overt. Defend t, Nori e and Description c NOT FOUND, Cove Septemb returns the within Real Estate Wri alit is duly decease as ed ac states that to law, Walter E. Covert a/k/a Walters eriff, who being of t e within Real Estate Jason Vioral, Deputy osted a true copy o on the property of on October 31 2002 at 8:46 o'cloc on the above entitled action, upon the e, ion, Carlisl Writ, Notice, Poster and Descript E. Covert a/k/a Walter Covert located at 807 Fairv iew R nd to law, states that Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according iven according to law, exposed the within described after due and legal notice had been g premises at public venue or outcry at the Court House, Carlisle, Cumberland Coun y, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the samtaor t e su or The Secretary of Veterans Affairs of Washington of $1.00 to Attorney Leon Halle DC. It being the highest bid and best pri ce received for the same, The Secre ry Veterans Affairs of Washington DCbeof is icko nfh•snexecutio paid Sheriff R. Box 807, Philadelphia, PA 191O Thomas Kline the sum of $944.59, it being costs. Sheriff s Costs: Docketing 30,00 Poundage 18.52 Posting Bills 15.00 Advertising 15.00 Acknowledging D eed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Certified Mail 2.07 15.00 Levy 00 20 Surcharge Law Journal . 372.35 Patriot News 318.55 Share of Bills 25.20 Distribution of 25.00 Proceeds Sheriffs Deed 39.50 $ 944.59 Sworn and Subscribed to Before Me SO Drs: This Day of R. Thomas Kline, Sheri?f(f A.D. }1a.,? B?cc N 2003, ro onotary Real Estate eputy N !b 4Yj ly C,k- 39"). 26 Pa-, Real Estate Sale # 41 On September 16, 2002 the sheriff levied upon the defendant's interest in the real property situated ill Carlisle Borough, Cumberland County, PA known and numbered as 807 Fairview Rd., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 16, 2002 By: Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), R. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 25, NOVEMBER 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 41 Writ No. 2002-1271 Civil Washington Mutual Home Loans, Inc., successor in interest by merger to Fleet Mortgage Corp. vs. Walter E. Covert, a/k/a Walter Covert Atty.: Leon P. Haller ALL THAT CERTAIN lot of ground situate in the Fifth Ward of the Bor- ough of Carlisle, Cumberland Coun- ty, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point on the southern line of Fairview Road, at the intersection of same with the line dividing Lots Nos. 3 and 4, on Block "D", on the hereinafter men- tioned Plan of Lots; thence continu- ing by the southern line of Fairview Road on a line curving to the left and having a radius of 164.54 feet, an are distance of 16 feet to a point; Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of NOVEMBER, 2002 ptq* my ?t Slur, k ,ss Larch 5, 2005 thence continuing by same North 64 degrees 7 minutes East 41.15 feet to a point on the line of Lot No. 5: thence by said latter line South 25 degrees 53 minutes East 150-01 feet to a point on the line of Lot No. 19: thence along the line on Lots Nos. 19 and 20, South 70 degrees 20 minutes 50 seconds West 75 feet to a point on the line of Lot No. 3: thence along the line of Lot No. 3 North 19 degrees 4 minutes 20 sec onds West 146.41 feet to a point on the southern line of Fairview Road, the place of BEGINNING. SAID premises being Lot_ No. 4. Block "D" on a certain Plan of Haim ilton Development as recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60, and being im proved with a dwelling known and numbered as 807 Fairview Road. Carlisle, Perrnsvlvania. HAVING THEREON ERECTED dwelling house known as 807 Fairview Road. Carlisle. Pernnsviva nia 17013. BEING THE SAME: PREMISES WHICH Ruth M. Kratz, now by mar- riage, Ruth M. Brown, and David Brown, her husband, by deed dated 8/27/96 and recorded in Deed Book 145, Page 168 granted and conveyed unto Walter I?. Covert. The said Walter E. Covert, a/k/a Walter Covert is believed to he deceased and title vests in the unknown heirs and assigns, if any. TO BE SOLD AS THE PROPER TY OF WAIXER E. COVERT. A/K/A WALTER COVERT- HIS UNKNOWN HEIRS AND ASSIGNS, ASSESSMENT #06-19-164 1 211 EX and #06-19-1641-211. r ,E 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October and the 5th day(s) of November 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Pa triot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ^,.- ..- ::.........? ?..... .. ......................... :.................... COPY L. -'Sworn to and subscribed before me.- p 14th day of over 2002 A.D. SALE #41 Notarial Seal REAL ESTATE SALE No. 41 Terry L. Russell, Notary Public ' Writ No. 2002-1271 Washington Mutual Home City Of Harrisburg, Dauphin County O ARY PUBLIC NOT'ARY Loans, Inc. successor My Commission Expires June 6, 2006 My commission expires June 6, 2006 In interest by merger to Member, Pennsylvania Association Of Notaries Fleet Mortgage Corp. vs CUMBERLAND COUNTY SHERIFFS OFFICE Walter E. Covert a/k/a Walter Covert CUMBERLAND COUNTY COURTHOUSE Atty: Leon P. Haller CARLISLE, PA. 17013 DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Fifth Ward of the Borough of Carlisle, Statement of Advertising Costs Cumberland County, Pennsylvania, bounded and described as follows: To THE PATRIOT-NEWS CO., Dr. BEGINNING at a point on the southern line of Fairview Road, at the intersection of same with For publishing the notice or publication attached the line dividing Lots Nos. 3 and 4, on Block "d", hereto on the above stated daites $ 316.80 on the hereinafter mentioned Plan of Lots; thence continuing by the southern line of Fairview Road Probating same Notary Fee(s) $ 1.75 on the line curving to the left and having a radius Total $ 318.55 of 164.54 feet, an arc distance of 16 feet to a point; thence continuing by same North 64 degrees 7 minutes East 41.15 feet to a point on Publisher's Receipt for Advertising Cost The Patriot News Co. , publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledg e receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... the line of Lx \ dtnc? <n said Ianci fire, South 25 degrees 53 minutes East 150.01 feet to a point on the line of Lot No. 19; thence along, the line on Lots Nos. t 9 and 20, South 70 degrees 20 minutes 50 seconds West 75 feet to a point on the line of Lot No. 3; thence along the line of Lot No.3 North 19 degrees 4 minutes 20 seconds West 146.41 feet to a point on the southern line of Fairview Road, the place of BEGINNING. SAID premises being Lot No. 4, Block "D" on certain Plan of Hamilton Development a recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12. Page 60, and being improved with a dwelling known and numbered as 807 Fairview Road. Carlisle, Pennsylvania. HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 807 Fairview Road. Carlisle, Pennsylvania 17013. BEING THE SAME PREMISES WHICH Ruth M. Kratz, now by marriage, Ruth M. Brown, and David Brown, her husband, by deed dated 8127/ 96 and recorded in Deed Book 145, Page 164 granted and conveyed unto Walter E. Covert. The said Walter E. Covert a/k/a Walter Covert is believed to be deceased and title vest: in the unknown heirs and assigns, if any. TO BE SOLD AS THE PROPERTY OF Walter E. Covert a/k/a Walter Covert, his unknown heirs and assigns. ASSESSMENT #06-19-1641- 211 hX and 906- 19-1641-211