HomeMy WebLinkAbout06-1434SHAPIRO & KREISMAN, LLC
BY: KEVIN DISKIN, ESQ., ATTORNEY I.D. NO. 86727
JOSEPH REJENT, ESQ., ATTORNEY I.D. NO. 59621
ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137
MEGAN D.H. SMITH, ESQ., ATTORNEY I.D. NO. 84047
2520 RENAISSANCE BLVD., SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
1270 Northland Drive, Suite 200 CUMBERLAND COUNTY
Mendota Heights, MN 55120
. PLAINTIFF NO: OL - I L{
VS
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
DEFENDANT
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH
IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS
COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY
PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT
WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR
OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS
AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
Telephone: 717-249-3166
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PRE VIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Telephone: 717-249-3166
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
SHAPIRO & KREISMAN, LLC
BY: KEVIN DISKIN, ESQ., ATTORNEY I.D. NO. 86727
JOSEPH REJENT, ESQ., ATTORNEY I.D. NO. 59621
ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137
MEGAN D.H. SMITH, ESQ., ATTORNEY I.D. NO. 84047
2520 RENAISSANCE BLVD., SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200 ;
Mendota Heights, MN 55120
PLAINTIFF
v5.
Kenneth Green aWa Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
/? 7
NO: O(o - l.:lc??? l EQ.rv?
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, Washington Mutual Bank, FA, the address of which is, 1270 Northland Drive,
Suite 200, Mendota Heights, MN 55120, brings this action of mortgage foreclosure upon the
following cause of action:
1. (a) Parties to Mortgage:
Mortgagee: Mortgage Electronic Registration Systems, Inc. as nominee for
Transland Financial Services, Inc.
Mortgagor(s): Kenneth E. Green
(b) Date of Mortgage: December 23, 2004
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County
Mortgage Book 1893 Page 4994
Date: January 10, 2005
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Assignments:
Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for
Transland Financial Services, Inc.
Assignee: Washington Mutual Bank, FA
As Recorded
2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original Mortgagee, or is the present holder of the mortgage by
virtue of the above-described Assignment(s).
3. The real property which is subject to the Mortgage is generally known as 209 1/2 South
Second Street, Wormleysburg, Pa 17043 and is more specifically described as attached as
part of Exhibit "A."
4. Each Mortgagor named in paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as
Exhibit "B."
5. The name and mailing address of each Defendant is:
Kenneth Green a/k/a Kenneth E. Green, 209 1/2 South Second Street, Wormleysburg, PA
17043
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both.
The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of October 1,
2005 and have not been paid, and upon failure to make such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of February 28,2006:
Principal of Mortgage debt due and unpaid $66,205.89
Interest currently due and owing at 5.375% per annum
calculated from September 1, 2005 at $9.75 each day $1,764.75
Late Charge of $19.04 per month assessed on the 16th of each
month from October 16, 2005 to February 16, 2006, (5 Months) $95.20
Escrow Balance (Credit to Defendant) ($210.58)
Title Search/Report Fees $250.00
Attorneys' Fees and Costs $1,500.00
TOTAL $69,605.26
9. Interest accrues at a per diem rate of 9.75 each day after February 28, 2006, that the debt
remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other
expenses, costs and charges collectible under the Note and Mortgage.
10. The attorneys' fees set forth above are in conformity with the Mortgage documents and
Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs
sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be
charged based on work actually performed.
11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S.
§ 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and/or
11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S.
§ 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and/or
the mortgaged property address by first-class mail and certified mail. Pursuant to the act of
December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information
required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and
separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached
hereto as Exhibit "C."
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against the Defendant, in the amount set forth in paragraphs 8 and 9,
together with interest, attorneys' fees and for other expenses, costs, and charges collectible under
the Note and Mortgage and for the foreclosure and sale of the mortgaged premises.
SHAPIRO & KREISMAN, LLC
Date: :J 1
i icG
BY:
Attorney for Pl ' i 'ff
S & K File No. 06-26302
4
42600321
(E) "Note arws dam promitam note dpA4 by Borrower end dated MOM 23, 9004
Mm Note states that Bomw'er owes Lander
SIXTY-LII TLOLSh" RM ILXMM TMLIM-TM AM 00/100
Dol(azs(U.S. S 66, 929. po ) plus im rat Borrower lea ptonmsod to pay this debt in
r0gulsr l4riotde Payoments and to peythe debt in full sot later than AWAIT 1, 2035
(F) "Property" montbe propctty mat is docribad below under the heading "TranaferofRiglao is the Property." '
(G) "Saar' tan"""s the debt ovidowd byths Now, Phu h msr, uryprNpquacat dturA and Iota ebwm due
under *v Note, and all amm due undo to lictWity Inattanm%4 plus idcte$L
(11) "Alders" meets all RWn lo We Swusity h omantOut am txecrued by Borrower. The fallomft Rlden are
to be exe mod by Bcmgwrs (checkbox as appliwbie).
(] Aayuswbk kart Rid" ? Cmdomimmum Rider Q Seoosd.Nam Rider
Bepoomliidec QPlannedvdtDsrdapmmtAidar ?sfweewPaymentRuder
1.1 Fmtily Ride: ? 011344) (specify)
YARIder
(1) eApouble Law" means all coavWling applicable federal, sum and local amuses, rtauladow, ordmmocs and
admmisnadve riles add orders (thtt We ibe effect of low) as well as all applicable final, nemappmaablo judicial
op'mio0s.
(3) "COMMOSty Almdation Asa, Fans, and Ammaeob" moans av duo, Zee, asscoursau and other charges
that Ke imposed on 8mower at tlu Property by a candmoiaium assaaadoq bomaow= association or similes
M "Maaonlo Funds Tmmfere means say namft of funds. cdw than a ounctan orippetad by check, drag
or similar paper intmsoeeat, Which is mtitiow mrongb ate daebtortio wmh4 Idtphmio Wwwnwt, aomptast. or
tmgmdo rape so as to order, Wnmc , or ate wen a 5 "taw iastgtdtom to debit of "edit an SCMML Such tan
kx dos. lone is ant limirod t0. potm-0f-solo Aamdrn, sutnmawd taller nmchim awasodom MOM taftad by
talephone, wb* ttanstm and u mmawd deartmoouo trumm
(L) "Emvw Items" newt Arose hems mat an dasm*4d in goo" 3.
(M) "MLcallamww Precteds' meant say comobsstim sawUN14 award of damage, of proceeds paid by any
third parry (adw tben uutensn prommis pahd under the covetagw decdbed lo Section S) for. (r) damage w. or
destruction a4 the Property; (11) ooademoadon or giber Wads *(ad or any part of the Property; NO gomysymn im
Hew ofeoodetmadoni of (5v)alrc?aemdgos of, or matfieme u to, the value and mcoodidoa of the property.
M "Mmum Issurame" mcatM Insurance proactimg I-eaderagamarbe nonpayment of, or default an, the Lam.
(O) "Perlode PaymeW mete the rogulary scheduled imam due fa (i) principal sod imagist mader the Note,
Plus 61) any Unease tadr section 3 of des Searky Icso mt.
M " %WXR mans the Raai IIaeu sedcamet Prooedoaa Act (12 U.S.C. ;2601 at w(-) and its implametiog
ieguLdam Re;oletian X (24 C.F.R Pan 3300), a drey 0dght be amended from dm to fm* or my addidomel tar
tuom or legislation or ragtdetien that gosems tbo soma sulymct moor. As used in tb4 Scocrhy Lmnamen4
"AP.SPA" is&n to tII ragtdmmants and motiodoo, U am fmgoaed'm reprd w a "kdaeaUy relstud mortgage load'
riven if doe Lou does not gtably me "fedarallyrelated tmtrgaga low' under RMA.
(W "Smocessor In harm of Domwere teems ay pasty dear has taken title to the Ptq", whether or nor that
Puy has asetmsed Borrower's obligations under ths Nee and/or rids Security basormnant
. TRANSFER C RI RIGI S IN MB PAOPEffTY
This Serauity l MMVM attunes to Lpmder; C1) the «psymeot of the Lean, aid all renswsls, axwnaioas and
modifmdom of do Now; and (i() rite pcrMname of Bonawces coyamma and apeemron order this Seumity
Inamumerx amd the Not,. For Otis purpose, Romwar doe bwaby mortgsga, yet std convey to bM9 (sokly u
aomlow for Lander and bender's succomm end udps) ad to the wccsson std arrlgor of WM ma f6gowing
4,udkod LwMer0, loaatd In the oA ootwy (T)pe of Reootdloy Joasdicdon)
wan NSC stet of ]tarardmg3urisdietion)
15lRLRL OLBCRIPfION ATTAt9tED tbLltlif0 AM atllDi A PART !lEIt40
.. VeNV YLV MLA-Sups FSmOy-)' state msvlwd#w mm vXWORM prsiAUmn FMMSMAI
Meddled fer VA
a r?ia . e.nrma (V IV02po w1
5f I693PG4995
42000127
which cww dy has the SUM% of
`'ntOltdgYF917A6
'(Cieyl 17043
Sag 119 soars gltn7= BTR6$7'
fstroa)
Pawaytvania
(Zip Cods)
TOCIR11 R 1VM Wi the im MVVWrea row Of laatler etestrd on the Pmpeny, VA Sit eammnmM
appwWomes, and Rxo= now of betoah r a peer of lac Property. AU tgluomee4 and sddlcans spilt alw bet
covered by thb Saclt * tasawneat AR of the ftasgdag is 7e6tel d to ro ibis Soeway lms XWM as %be Tiapa,<y,"
Soettvsar tmdaestaadt and agrees that MIMS bolds only legal *Is to tb0 Wmato grams by Borrower is this
Security loemnaaa, bat, if tmoateary to somply wbb law ce cunt, MM fat nominee for Leader sod Lender's
aucammra sad smoi 1s) has the sight to mrereim say or all of these Warcr4 Iori A*& low sot limited io, the doe
to foreclose and wU the PropstT. sad to aloe any aaioe mgWmd of LaAet ir0ndudb0g, but act limilod to, mleasieg
sad canceling this Somw lnawomes.
BORROAt81i COVENANTS that Bonuttat is hwtblly soiled of the elate bereby conveyed std has at
n& to mortgage, Seam cod calveythe Propaefy and tbsr the property U Mom=dxfsd, aroapt ibr mawbraroct of
.record Banowa wrtraaes and wpt de cV d Morally sloe Me to the ptopary $90had all clslan and demands, aWr w
.n say aoeumheamOOS ofreevnL
T7319 SKMTY RISTRI:JMFM combines uWotm cove ms for naeiand use and nos-tmitbrm
cow:nanis with ] ouW variations byJnaieMakoa to eoucum a ua& m security inenwwW conringtaal property.
IINIItORM COVENANTS. Gomm rand Leodwcovonaet and agree as follows: _
'*PUPayw dua ePrkcpWaaL rvid$M4 by IMYPMPVYVWN dMV4and
Imo charges due inkier den Note. Boerower"also pay facts be Furrow Item patrim to Section 3. %yormts
due tinder the Nos and this Smoky tetmmaem shell be made so U.S. altmoalt• liowovec, (f say deck or ammum tmoived by Leader as psymtm corder the Hats or de Sorudty instrument Is mined to Leader tmpother
a a,
Lefler racy reosire ft aanayy or a9 wbse*m Pgzscl to dun QWW the Note and dds Satuory Imtrumantbe testa in
we ar moue of tlta follewSag fbCM as mkcaod by Laodor. (0) 0* (b) mosey order; (e) cudW check baale
check vasserer's obeek oreashiets sheds, provided say web check it dnwa um tm iordmioo wbcee d epode as
iaaustl by a Mud apicy. iaslnmo moft, or amity; or (d) 8lsetroai0 Funds Transfer,
PaYmeaa 0ro dasmod teudved by Lendot *boa rect hid W to location demilptu d In the Nom or ar such
other leaaim as MY be ttsalgasted by laudef in maadanae vatb tie Rod" provulom is serodoa I S. Leader coy
n t m my Mynx ae or value, poyataat Itdw payment orpsraW peytnmm in WAdacieat so bf4 the Lam em ov#4
Laser rosy Z=V UY PWSU* If PW W Paymtat irwlSdeat to bring the Ltas atmm willow %mver of aw
rimer heaamdde o 131111 dice m is itgla to Wm arch M121at or Par i0l syclar a inthe Oemb, bat (seder is nor
W%atsd to apply snit mmrma ar the time such paymm are accepted. Tf snob Pariodk pwmm is applied ar of
itsascheduleddoedats,them LeadorDeed sotpsYkaterestOn%oppliod8mds.Lemdorweybotd each cords
tmdU 8ntr0W makes payaana to bebg to Loan a m% if Borroame does not do so w" a reasomble patWd of
time. Lancet ibWl etdmt apply such halo Or return 11210 to bamw1m . If IM AWI$d saber, suds Surds wm be
applied to the moadiag Pei 4 W kkm under the Now ianmd nerY price to fereckearo. No offset or slain
which Borrower rtteg6t bwe sow or in the Rnute sgsimt Leader W rolieve Ba owlet ft m making paymeay duc
under the Nos sad this Soewi y Immmws or po fa miag the covenants tad smeemana seaaod by eis Secir ky
Lo6mm at.
2 APpii lan of paymwu or Reswda Bxccpt as comwiae eleseribed in chic Seed" 2, all paymem
acmFkod and "Phod by Londe shall be applied ke lb; following order of poiaiky.' (a) interest due latter at Nan;
(b) priswlpal due wider the Note; (s) aww,tns dae under Section 3, Such psymmets sMU be apptisdti ? io me
faymem m the ads Ut which it basics duo Ahll tt maidttg atrottos shall bet fast to la¢e e
say odor mm m due 140149 thk SooWlY WW MA rod than to sedum da priaoipai bal0om of else Note,
U Lender reedva a paymm em Borrow for a delimmim Ponodit Psymnm whkh inohkdee a arkicat
wom to pay any We champs duty ttm paymsot may be applied to the delinquent paymat at the am caakgs. u
:acre than 00 Pexiodic Paymm is oumso 'mg. Leader may apply any parsent tecolved from Sorrower to the
ttpsyamn of dm Pa"c Paytttwa K sad to Ow exeme tbm, cub paymam can be paid IA fdL To the extent that
spry ctceas exists after the Is applied m the full Paymat of Otte of mom por ame Psyvwm such excess
racy be amlied m say We =4ttc.. Vohmtary Pmpsym ms sbal( be appltea No to any ptepayutect ehugw and
then as cucnWd in the Note
"Wm3VLVAN(M.5katc remits-Fegxk m"'FI &)AM k1NVeass 11qatagadtt Fora3m1101
i." Wtee VA
00CU (Pore J ulltlogev
mina ..ANmum
8KI893PG4996
41004227
Any appliatioa of papaenn, ionuanoe proceeds, m MiueOMMU Fratxeds to priuc* duo Under dic
Not Shan ace Mead or p nom tba due date, or ohms the amow0. ofthe Periodic Paymaes
3. Farms ferttaoer ImA. Bmrotter alrll pay to Lewder as the dg Pedodio Myaseaea are sae under the
Note, venal The NOW is paid in iglu a arm (We FUmda ? to provido for papry1mametlt of aawunta due for. (a) ww and
2RAL ^ M awd other intma which can atria priority over die SaCVttty la$Mwr a as alien or eacwtbince or, the
Property; (b) kasehold pW== or gre,md roads an the Ptopaty, if say; (c) premiums lb: aoy and aU beaavace
roquhed by Latdar under Seddon 5; ad (d) Mortgage bAwAnce premium, if any, or say wall payable by
Bo=war w Lender in lieu of the payment of Moatgap lesuroaoc pmmhm in auaddaaee w;tb the provisioaa of
Section 10. These items are Cg W "Bsotow tame." At cripiaatiou at at any tia o dwkg the tam oftbe Loaa, L.tade7
may r4mm w61 Co amuluty Amciallou Dues. Fees, dad Amanazaca , if roar, be escrowed by Borrower, and arch
400, Am and aaaeae"'""'° IhO be as Escrow !mm Bo rower" promptly Awalah eo Leader an eatioat of
atraoasa to be paid fader eds Seadon. Banouver doll pay Leader the Funds for Escrow forms uakaa La xier ww;vea
Borrower's obllptim to pay the FU* foraoy or all Escrow Items. Leader may Waivs Bomwer's eblig4@oa to pay
to Leader Funds for any or all Eaorow items a say time. Any such waiver may only be b wddog. to drt amt of
soak waiver. BorrowersiaBpaydcaNy,whenaddwhere payable, thoAMWddueforsay Escrow Item forwmeb
@aYWM of Ftmds bas been vnivcd by Leodee "if Leader requites, doll furaidr w Lender rectipu widcacmg
saoh payment witbio such time paiod as l cedar may rogWre. Boerowa'a oblip Lion to aka pwh pgmeWS and to
provide reeolpm ahdl for di purposes be deemed to be a coveowt dad agreement ooacsiaad it %hit Security
Instrument, ss the phrase "covenant and ageemeor is used in SoWke 9. If Borrower is obligated to pry Farrow
hear directly, pmauat to a waiver, cod Borrower full to ply dw amo mr due fir m Eaaaw Item, Leader may
exartive its roll cadet Sacdolt 9 and pay such atwum and Bo wv= gall then be, obApred Yoder Soction 9 to
repay to Under day such smgat Loader may revake the waiver as dray or all Escrrow lewtn at may mac by a
notice givra in aaaatdwA M& Section 15 rod, upon such tevoo ticA Burrower "pay to Leader all Fords, and
m such smatatts, that an dtea required trader this Section 3.
Under Fords ar the rims ape' at
under . collect and lauld AFSPA, Funds and Cb) ot to ex"W the andatum stWU so wimt aMeador wa nquhra ansount
uWar
RESPA Latdar foal! aatimtle the amount o<Ftaada doe oa to bads of aarem dad and rea+arabk csriroaxs of
expaoditun: of future Escrow nom or adlavvise in anuatdoaae with Applietble Law.
The Funds ahsB be odd m as laSOtunioa wbasa aapoa is are bwnvd by s tmlent agrxy, bsatmteatshry, or
S+diaY Leader iF Lmdae is as iaadaalos w!>me depasit9 era ao thruied) "o" Federal Liomc Loos
Beak. Leads Ihan spply the Funds w pg ffis Etaow nerve m lair too the dma specifiadr R1iSPA. Leadr
dhsB not chacgo Hoaoaer for hn4lhtg std applybg the Fwmda aamwuy sbalyabg tb esaavr aacem; 4rvt aiylpt
Lto essureast
abe Farrow mars uahaec Loadr pays laorrowr" mi?
Fand Appliaabk Law permit ,rake agrean dm s a aide in harwqu¢ea tatereat a M pr00 IF
W wr, r nhow ton be lid @W give w Basrowsr, w&" tdrargq a
annual acewating of the Ftada AS required by REV.& IPthere n a awphn of Funds bold in escrow. as defmcd
trader RESPA, Lender aball &mot to Bonowr for rho eras Odds in seoordanci with RESPA V there is a
slanago of Ftmda bid is escrow, as defined order RESTA. Laadrr ahaa ratify Burrower as required by AMA,
epd Soaewer stall pay to Ladder Ox amramt WAs+vy Uo slake up ON shorug is aaordaae wt1h BUPA, but is ao
move than 12 mmddy psymeoas, If thaw [s a &*dmcy of Fads bold k eurow, m defimd under RBSPA, lender ahdl
nosy Borrower as r44uited by RESPA, and Borrower Asll pay to Leader a,a amount wewday to males up+dw dofi6mey
in sraordrsee with RESPA, but is an mole than 12 =M* payrrata. Upper payment in Ul of 4A dads secured by tots
Stawia lnwwanca4 [+edtt shag pmrrVIV redid in Borrower say Funds bald by Leader.
4. Cwwps; Ewes. Borrower sha0 pay all taxes, assesamcaq, charges. Fries, =4 impositions atmbwtable to we
Pnpeay whvah an 4eain priority w4t add SeomitY hanument, lea bold paymane of Vowd any ou tb¦ property, if
sta. and Cowmmiq Asaovladm Dud. Foes acid Asfessmmti, it any. 74 a o t7 mei gat tboe hatra a e Paawrr items,
)?orrower akin pg mesa b die rraaaer pteridad in 5eteioo 3. Btnrower shell pnmvpdy d'acbggr any Lim which bas
pr,ority over this Seciairy Inanwrnea anus Hanawet: (i) agtaa is wT'oeS m the psYmam of the obllgarioo eacorW by
tot ganv is s masher 1lcuphable m Leader. but Daly so gag se, B4lrownr id pmfmaaug suehagiocmeaK {bj co4uau the live
in good fink hY, or ddmdr agafu l4lbeeeateat of the dim I0. kgU prtaxedinga which in l ender's opidiw operate to
pUevem We anforoetncat ofthe lien while those proefe6wgt m ending, bar asly cote a0hpewwedinga Ors eottdutind; or
(c) dagae3 from tbo hoida of ate lire m aleeeemeat rsusArtory re Imdet subardmariag the Sea to aria Senaity
b>56aaaac If trader deteaniaes slut day part of dw Propery u m3>fea W s lice wh{cb ore aaais priority over this
Sraurity hUenwaumt, Lawdtr ruaY give Bottowrt a iMdee idemifyiag the Itae. 1Vithiw la days of art duo O4 wbie6 that
notia is givaq Botratver 6haA doss me A®r take ono or more of der scrione des thfrlr above k thin Section 4. Lauder
,tidy re, pare Bortewa re, pay a oaen de ctUaea for A. cal to Max vai5gdoe ataror epart erg derv ct used by Londe in
eonnecdoe with this Laaa
PTAIIYLVAR1M Ul)v t"OY-1'aank Mr7Mdir Mar CNIFORM rNMUMST star!." veal
tppdifma ter VA
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6K I893PG4997
S. Propt'ry Ummee. Demeter shall keep the am provememe now odmag or buou"& etucmd as the
prppury inroad aBadax Mae by Am bnu* included within the tom "mantled wva M' and soy other hazards
laeiurbmg, but not Is" to, arthtpnloa sod 6ooda, hr which Leader squires bumar3nm Me ioaaruxm shall be
maintained in the atmounu (incbtdiag dcbaP* levels) zed fbr the periods that Lender moires. What Lettda
. Tagttitta Pmwant to the preceding smtmtros an dmp drinp the card of cite lain The Wramee caste
provid4 the immmuoe shall be chosen by Booower subject to Lauder': right to diatpprow Borrower's tboico,
which right shall not be atmdted tmoasoubly. Lmder may tetpdte Beracwer to pry, is connection wish this Loan,
either. (a) a oaatiom clump for flood was detm dm8ou, catiButim and trwolft savim, or (b) a ammime
:dwp for flood zone deamdnaftan zed outi6tadoo aermcm and ribuquent ckmos each tit= mmappinp or
;sicd* obso" oewr w'bid3 twaoaby might effect ¦tcb dommadradeo or ard6adoa Borrower shad she be
nrpoaaibM r the payauat of trey fop umpttaad by the Pedaeal MMU*prmt Aptcy in cooneadiob with
the tovtew of my fdead was deaemieadonramldag from an obJaction by net r.
it8otrower lhite to maltt? say of the aoveeeges desaibad above Leatlertray obtain bsurnmoa Covermgo,
st Leader's option and 13oeowea ezpease. Leadali ttmdofao ebligntim to io ?'w auYP utieelu 47k ar amoum
of avenge. Therefore, such coverage dud" cover Laid:, but night er val mot protect Borrawor, Benowers
oqu( ksoparIN or the Contents otthe Property, going to titl4 hLmd at S** ad bright provide gruftr
or n Wversd then was IMMWY to eff&A Boeowee ackmowledps that rho cast of 66 its"We coverage so
obtained two slVdcately erm ed the acct of lnsmmae that Borrower endd have obained. Any unuma
disbursed by under tmdar One Section S shall become ulMo t dabs of Botrower wooed by drier Security
Iastr MOM TWO aeouna shmU bear imwen a the 14M raft from the dace of "oar servant and stair be payable,
with auehiaeereA open notice gram Loadarm Boteowermquadagpqumaa
All insommem pokcks re**W by Leader and remwels of attcb peLaea"be v*act to Letdce rigdu to
.disspprova muh poliaiea, shall imohude a standard mortgage dime, and dM new Leader es etmigagec andlor u m
-additional toss payee. Cruder shill have 9a tight to bold dw policies and renewal crMc tw. If t ender rQQWmr,
Borsomr shill promptly give n Leader all moeim of paid pmutimn and vmrwal mousse, if 8ormwer obtiiu my
'harm of ism arm bovmaga, Oat otMnvise ngmhad by Leader, for dsmmp to. or destruction of. the pro". suob poffay
shat] terraria a ataadetd raongmga elmut sari rba? emcee tedsder et tnmpgea aaYot err m sddideaal loos masc.
In the event of lot, Rmvver react( Stare prompt nador to die Irwvaaaaa aria and L ode. Larder say
make proof ofIm if mot made pumpty by Bmrewer. Unlom Loader aadsommor vehowdn agno to vrikhtm :try
destaams, proceeds, whmhar of sat d*a wdaiylag imimsm was tequa & by Lwdm, dW1 be applied to tea m&n
or repair of the property, if the resmntiam or repair is moaomically fvamble and lAadW% gVA* is cot WWUd.
Dtaimg such cepa4 and resnntim period, [.canter Wag tavo tta right m ]told writ ittaurrea proeoede vmdl La,der
his bed m oppotwmry to respect retch ft eanae the weak bas bate cot?1sttd m Lemdds ta[b(Siadom,
ptwvidod tMt xtcb iemtpeedan Wall be ?m ptomtptly. Gender tray dlsbtsrre ptoau6 for tfr rtpain and
tair0Aai0tl (m a ilmg'(e paynwot err iq a taeiq ofptogrcea Deyroacrt m t)K trertt it aamlp1e07d. Llalma m agsaemant id
tads m wriciag rr Appltnb]t Lsw ngttins Wemat m be paid w web ieYaeaCG ptaoeedn, Leader s4ali oar be
eegWred to pay Harawar any kaoner of eafniup ea stri Pmaoek Pool !be pttblk atbttmterq or odtar third pndas,
tttained oY Boaotvar slx? rent a paid its oftbe intucanoe proceeds end shall be Iha wiz o611pden of BoetvwtiT. If
the reatorstlwt or rept6 is not atxaotmkaly feasgde orLttrtder's eoariry tveuki be iteaaned, rite imuranae proeads
iha? he applied m e13e wens BCpnOd by th16 Security Iacnanlee4 whrgtCr a met ttm due at5d3 tlm atcoect. if my,
paid m Brnrmwxr. Such insurane4 proeada tdtall he applied ire the order ptmvided fit io Saesiat 2,
UBvto set ahendoea the Pwpmy, Lmottr my Me, megntuft sad xWe any avaWbb butuance cwm and
related metiers if Bol to - cs does not fame w$hk 30 days to a aatiee iioem Lewder that the ipaaface casdet)tas
?iffemd to taste a claim them Leads may aosoliaro and settle the elalm. The 30- ry period will bcsk when the
codce it given, In atlw event, or Pf Lcu&r ugtdmi the Propmty coder Swim 71 of otherwise Borrower bareby
amgps n Leader (a) Borrowers rigbta to any irouramce pcooeede in sec ,motor not to eztaed the movers unpaid
tender the Note or this t ecmity Intnmeett and (b) say other of Borower's rlglov (other then the eight to say refund
of Warned PfcOmIm Paid by Betraw n) order all teataaocr pegcke Wverimg the Psoparty, ka her as such rubs
are gtpliab ere The oo mega of the property taador ray we dw insurers ptxeede either to rep* or r stow the
Property or to pay amoo m uopoid uwwdm Note or this Se"Iylnmtanest, whether or not than der.
6 Oecupaacy. Somovwr shift ooaupy, z"4k, and we the Property u &mowtes mineipd residence Within
50 dsye aarr the eucudon of ilia Staurirl dnttrum m and sball co dwo to oocapy the Pmpdty u Bmewetrs pdaoipai
reddo m for it twat one year doer da date ofocupamy, unless Leader orbmwise ggmer in wddeg, *UA conscot shtall
nor be umcumaby witbbald, or uelmt otetequadag eireuousnmas ranter wki& m bcyood Borowe's ommol.
I Pnaervatlor, Mamattaaoe and Protection of the Property; lapecticas, eorrower :hall sot dcsuoy,
damp or itrpa'v Abe property, allow the Property to 4mdomm or rosoapit waste on the Propary. Wbedw or sat
Borrower is "ding in me Aopety, Borrower Shall ma imna the Property in order to prevent the property from
detcriotadog or decreasing in valve due to is coadeien. LWm is is deterroived pummot to Section S that repair err
rENNaY4V,?NA-$lykpwily-faae4 MuMpecdkMeUWOIM VVISUMENT reM2039 trot
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OKI893PC4998
43000777
roatoratlea is not emwookAlly k"MC Borrower shall promptly ropek as Fig"" if dmmted to void fiatha
dmwtW= of damays. if ittsumoa oreand xmdom psoeteds etc pad to ward m wlrb dune ps ro, or tko toldng
of, the Propmry, Borrow 64 be tegoasible ft ropatibg or rteoa* tbt PropaW otdy if Lwekr has iota"
proceeds for mok pwpom, finder may d6w" proceeds Act ebt "pout and momstiom ia? Awk paymmlt w im, a
strics of ptetma paytmau as the wodt b ewmpkwd. If ttte msansict Of a ks mica procaca are not "Alaient
.ter repsit of tutors rbe Proptm. Bonowar is not nuoved of ammwer's oblipntim for die ooropkdm of such topait
or tosootuion.
Leado or hs atant may rob racanable atones neon and impoctiou of the Property. if it has rouoaable
"We. Leads may hgteet dro I wdm of *0 bvmvwrenot oo dte property. Lemdet "I ON Born nodes ?t
dw Cbae of orpriarto such as iaww iospCedOaspodf t such vmwmble Carty.
& Borrower's LAIR AwIloodon. Bo=wtr SW bs is dsthub it dwwt the Loan appUmuon process,
tsoaower or any pasoat or etetiaes aFtlmj K the dimcciob tlf 80aawnr m odds Bmrwvet'a latOwlsdp or ooasapt
tare ttuaarially ftte, tnitdeattittg, err inaeomste mfomYtiAR a slatcalPd6 ro Lcmda (err tht?ed t0 provide Leader
with ersted+t bedoemtaioo) is twnaactfon with dre Lan 1•fale+ial nprsatrrtadoas IaettWq but see tot Ibmimd %
9. I3veestia oagr of ieoderk'alaea7ae Pr tl sda ddsBsaar, [nstwsaenc if (a
Borrower tiUt to perfomr the eovaaao6 sad sgtaQnemr anasiaed 1n?thts Segv4y Iatawo wet (b) them is a tees!
pront?ttint ? ?g1d gdpifmaadY affect Leader's itde[ut b tlta PropettY andtx nldete vada thin SeauritY
fasoament (such x a ptoeeetbnt m probak, for aadsomasioa err ibrlbfltar, fm t sdaCaemmrt of a ilea
which maY terabr prioury ever tbls $e imateaeat a to ewfOroe laws a ntutrdons), m (e) Baatevkr lua
abtttrdo?ed the Raparl, dreg Larder may do and psy fbr witaavtr ii esawaabk a spprepriate m proasCt tondor'a
Wow m On Property aad dthat undo dds Sesa y Imansmok iaeketiag i dot lower ussaiog rhs owe of
the propemy, sad senora "&Or repaia 019 the PrK&W. Lenders actiom Can toowde, but are tot ihtmod a: (?)
psyint say sins ra0raed by a lien Mhish Hu ptkdtty ova this Seetdty it>acrttmem; (b) appsar]ot to coati sad (C)
payist teataaabk atemasyC' free m Proker ib bnaat in the >'mpttti' astVer tlthb uador this Ssturay haacaraer.
meladmg in scored potidoa is t ptaCSadlpt• Sanaat the Proparry inntady but v not Umiud lo,
oohdin; rho tRgtedy m smite mpMtb thanpe ]aura, apiscs or bond W+docn rod r mdowa rhaia r r Rom pipta
s7imiaak fadldlat err other eodr vidNiam a tleatOtnu omdidoru, sad haver Adllees Wined On Os o!£ Ahhootls leader
uuy raise esker coder d# guttian 9, Lssdrt dos net hive m do w aedh ta% uedot racy dory or abligrda 1o do so. h is
atteed that Lsadar Lacttu eve liatdUry fm sot oklnt say or sU sddem sutbonzadoedat A4 SeetioO 9.
Any tm'uan0 thabaaed.by Lsadat teteda' 8eia Setdon 9 stall became additkuul dust of lsarower sectaed
by this 5eeurlq Iasmsarmt. 1 has attoansa etutU bear inkrest st die Nsde r?re loom nc? dam of disbtassaoeat and
sltaittseP?IfdY?dakSeCrr4Yitxoaamt 1weMld Borrow" " tts?ie?
on a ="l y wuhaD Ow provlaims of the la+vt.
Baaowm call! ace awrtmdse the leatahold tuft sod l basin eonveyW or tetmimu ar aaacel a* $road
lug. tsatmwer sMU 11A tvdhom die tntpcas writmn consent of Lesdu, attar m mteod tbt: grotmd leave, if
Botrowar sequ{ees fee Arlo to the Property, rho lowbold and On fa title a1bi1 nor ao rge woks IAndtr OHMS m the
mugsisw -
A Morttats Itboraaars If Lott tegtdtod ModW Ioatwmm u a Coodiriea of tnsidot the Loan,
8onowm shop pry titt prWimu mgahed to mous?in the Mw%Mt hum= in erfae. If. for a{y teaam the
Moffpp Laurence co required by Lender oaseta ro br avmlbk ikom dto tmrttsgr iaetrts t1p t ptevloavty
ptovitkd mcb tnaz ww sad S*=wff wa agaited to Web separately desitaatsd P?Ynw$ towd lho putenjurm
farMo vo Tattuanos, Boaowar tdtaU pry the prtsdwss t?9 d ro obhio covsbte utltmtadsAy etpdvaltat to the
Montage lostasaCe pre KOiWy Sn e![as K a act 1sa0madaUy sgaivaleat a Om oat W Smtowet of rho T detttage
]oatrmos m eEflta, Rom an alestoate moa8ap htauter eaktmed by Leader. V tttkwacsity egulvaltmt
outrage ?mvetsQa if ttx avsi]abla, emrower stall Matuatta to psyto Lender the amoaot oftbe sapattWy
iletigraLCd psyarmts rivet were dw vthCO she imutante wvtraje Ce?ted m be N eflba lender wUl aCapg ua and
rstaiatlteae pgvemttts as s nmrtebm0etbk loo tesesve in lieu of Motttate lmw?.a. State Lac tetetva edtaU 6e tae,
natadsble, aotwithpt diet the fact tot the [um is drlmaetY Pa d ht fuU and latdrr a1tsU not bs tsq tired to poy
8arrooer sty aleters m aattdnas an seteh (era teaava Leader teo m kata require Loss mtarn psytoeto if
tdonpip Ins 4 mover (m the amouhs sad far rlteperiod ttrat Ltadrr Esquires) ptovidad by na adse+ed
by Laodor ow k4 ma avdisbtc 4 obteiasd and Leatda tegedtm aeperemaiy dsaigmted psytatbts ttta std the
pmn"ms fr werwr ]source. 7 Lander requited Manp75e itnet ;e ac A. coditi" of m idat the Lou sad
Bonowm wet required w =Ae upmakly dui fnsad pWwm rowans for pteatiums tot Moil" Innmaace, gamwar
shat] pay tee WOW= rogWvcd to makbim MoMW lscutsaee iu drm. or to pro Ur ? %n4ctw&hje far rasm
uetii LemW* roqukomw for Motctap wouw t erode ip seoardmae vrirh sty' wrinn woftoom bcteesa Borrower and
Leader pmvidiag far nah termisstia or mm7 remdhaia is requked by Appliubk Lary. Noolnq in ddr Updoe to
afft m awwwer's obliptiaa to psyiAtwom u rtes me plemded it rtes Not;.
s¢XttsYLVxNr tvttWtrA?ty-iswtDewFwertwr%MwP tant1Ltatratr f4m300111ro1
Warsaw ter vti
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asmtsar,m a/a/rsaf
BKI893PG4999
4100023'7
Mmttafe lumaoce mirtbwmes Under (or any entity that purchases the Nato) for esnain losses it may
incur if borrower dots sat repaythe Lou as agteod. 6tumwar it not a parry to the MM@ige iasaraoee.
h(MVge hem avaluem their tool ddt oe aU atilt karance is force from came to time, sad may e>ua
into agreements wkk other psrdes sat sham w modify thaw sisk er .ndmm lenses. These agreements are oa um
and conditions that are sahefeaofy to the Oaatptge imrerer and der; Otter party (or pntrs) as *An sgreemnm-
These agreomenu may roquite the mortgage hamer to tusks psymmu ::alas try smote of feeds tut the votgge
iaturerm y have stwtLble (which rosy icloda fiords obtained OwnMortgags Insurance Premiums).
At a taw]: of Ilse sVbWMMZ k Lender, try ptndraar of the NOW 4W6Qr tam, any aelawaar, any tether
entity, or MW mfg OM of any of the fongoiag, say motive (directly w indim*)i atWnnts thin derive ftmm (cc
might bo e9tarumbed at) a portion of soirnwer's Payments for Mortgage Immasoce, in exciptntle for Arcing or
modifying dw trac" iosteer'a riak, of teducing )whoa. V auob agmemcat provides Mat an s11IUom or Lander
taken a share of the Inwer's risk in cue bap ten a gar of tba premiums paid to the im m, tw arrenpmw is
often homed -captive mumira»es "further;
(a) Any nth ageecmdmta will sat a1Wt the amounts t?at Burrower ?am agreed to pay for Mortgage
Tamu ass, or soy other scree of ft Loran. Such spespecout will W increase the amount Nomwor will ewe
for Mortgage Oauraeea, and they win oat sotto Borrower to say rtdrma,
(b) Amy march apumaots will amt affect the rk?ts Nornwer has - if any - with rempaer to the
Mortgage Iaenro t ubr the 8omeatroen Protection Aot of I"I or any etbar law. 'these rights may
include do right ere reeelve tartdn disesesures, to request and obtain esmaW rion of the Mortgage Insuraaar,
to have the Moatpp Iewesa terminated ndationli achy, and/or to recd" a rd"d of guy Mortgage
lastn ace pra dame that was manned at the daw stanch aas"No ea or Wasleatson.
11, Aulgaoom ofM]sed lowtut Prtucsedsi Formime, AB Ddlaeesaoaous Pecamb are bcnby assigned
w and sUl( be paid to Leader.
If tba Prop ty is darm14 such W*41aneous Proceeds shall be applied to restnvtation a mpair of the
penperty, if tbt rmtontoa or cepar is somatically >istsible ad Leader's smwNy is not lesoened. During such
repair and temtaatotr period Lender shat! have t,a rigen to hold such Mixesaaeow Proeet dm anti Lender het had
an apportuoity m iaapeet euth Ihoperq p eann't the vvmlc has tsfea ttttmplesod t0 Lender's aatafatmi0n, provided
tans 044th inspoedaa shall a uadetulrea premptY. Leader maY pay far ttM ttpNn and mpmratea in a shot
diabutsetrnst m ie • temie6 of pttrpwtt peymeos u tbs work ss aampletad Umleas m agroemsu >a trade in, ttiitittg
=C airet fntcsue m be pod oa sorb hswceOsoeas t?tooadx Lender than mot be ree(udtad to pay
say interest or aeahwp m such hGwcUaaeow 1'toeeatffi 3f the nesmr2tlae m repair is roc enonomit aUY
Atsahe or Isudefs aattrry would be lenened rite Ivfiaxllamom Peosroede .Cali h .ppliedto the acme second by
Otis Stxudty launrtatrd. whether or rot there due, with ate tzasr, if a?? paid a Boaower. arts et'1uaUamcou7s
Proceeds allU be sppliad in the wW pmvidtd for in Sactoa 2.
To the "M of a urw taYpm? destruction, or loo In value oft w hope % the Mlseellaaeous Proccodt W
be applied to to twin setaaad by Ors Security Insaummt, wbmha or nor then due. with the eaccat, if any, paid to
Borrower
In *a avmtt of apudel taking, Gawadon, w loss in value of lbo pea perty inwldde tba fair market "bu of
the Pmpcrty immedlaap•befwc the perils] trdmeg, dentumoz, or loss in Yalu:: is eett%pu11 to or pe0or than tlw smowd
of the am fecund by this Statity Instrument imatediamly Wm the portal eking, dnaweton, ar bus In value,
artless Bmgvvr tad IRodt atbawist spec in write& rho stmt seemed by :bit llwa ty Maaument shalt be reduced by
the amount of to edisalincona hoods multiplied by abo following faction; (a) the tout mom of der sow seewed
ImnAwely bathes the pattid tape`, dem ucka. err loss is value 41MM by (b) the fair madoet value of us Pmpww
ioe mlivadybritne the pietist taking daamedoe, or lost in Wv, Any balsam shall be paid to BOtsowor.
In the event of a patW aft destruction, or lost in value of tla Property is which the fair rnadtet value of
doe Pteperiy immediately before des partial t aft dtyavctoo, or Ion in value is less tlam to mmae= of the sham
semed im u4stu ly before the pedal ukk& daattetea, or loss in vdae. udess Bomowsc and Leader otsorw'ilte
agree is wsift the lAwalbewous Proceeds sbal) be applied to tba sum; secured by U Satuity lest un e t
whether or trot the auras see thentiue.
Ifthe Property is almtde modby Sa¢ocret, or it aAer eat ere by leader m Borrowerthat the Opposing Party
(as ddtatd in the neat smaenoe) offers to mttm an awed to settle a claim far tlumga, BonwwnrAtlls to r"pood to
Lender witch 30 dsys after de due to notice Is given, Lwder is aammi;cad to collect od only to lsfaeCUsecom
Proctods Cidwr m:%matiton ertopaft Ofthe Ptopmtyorin the atoms secured by thin Security ]nsmdneas, whether or
not an due. Vppwitg PAW, mans tba third potty that waves Bmrewa Miscellaneous Proceeds m the pony
agaiost wbamBoerower Eats a dgla of action is regard mo Midcetdatous ]roads.
7. Dor owes" be is Wait if try ambo at pratca ttg whatier civil of trimin], is begtm that, in Ltodees
ladgacOt, tome MWt in ietfeimrs of Ow Pmpaty or tabor material imp:mmat of Leader's isteren is the Ptt WM or
lighn uadtt obis SOowfty lnetrwtou boerewst can cure mob a defsuh sad, if emetwati n hu ot:emead, reinstate a
f'gNNSYLYANIA-Singe Ferwy-ramie aW?nd& MN UNIFORM a FMI',W NT 17. 3410ve1
Msdtnm far Ya.
tecarlhr (Putt Y r01 pµ0/
w.vav.?rr unrhow
SK { 893FGS000
42000227
provided in Section 19. by naming the nation or pmcceding to be diataisscd witb a rolkil they in Undoes )udgntaac
precludes bdchure of the pmperry or other material btpahotetn of Landa's tatctsat is the Propetry or n0 ft under this
Security 1nst towdL lbc proceeds of ay award OF claim for damega that am atrtibeaeble to the Impairment of I-&es
tourect in the Property as bovity assiprd and ,born be paid to Leader. Ace Niscalaw" lerooeem that are not applied to
raauration xtcpai.t o4tbc ibali be appTiod is tea order providrd for is ttectioa t•
12. Borrower Net Rdamed;i1striesavesetv By Leader Not a Walser, Exiatioo Of the time for payarmt
or toodiieacioa of maotdtaAam ofths sums mead by this Security Inerewot jitaurod by lender to Borrower of
say Successor in loverea of Borrower shah tat ttperate to release ten liability of Borrower or any Successors in
iateraet of Borrower. Leader shall not be reafairQQ to oooeaaee proaediogtt ttpioo ary Sure nor in interest of
Borrower or to refuse to Lasted time for payment or otherwise modify aeorr):atlo t of the stmt eemod by this
ItOlliry Itearuocat by reason of SOY domstd mods ley the 06OW Borrower of any gheQeiaana to WNW of
Boarvwa. Any forboar®ce by Leader in axorciaiq sty risk or sm94 toeluamg. wrthax limitatica, Leadds
as eptaaee of pmymeab Aom third pandas entities or Su00enaera in iaecrest ofHoxrawer or In amounts toss rhea the
ao»mm eheh due. ahaS1 natbe a avaiver od or praitde the ceareier of any Fight of remedy.
13. John and Several LiabI&ty, Co4pcM gtsceteann ad Antilles Bonn& Borrowa covenants sad
agraol that Baaowees obtigrtioas tad b"ry shall be-*a and aevcrA However, shy Boerowar wbe txHlgns this
security Iutrumetd but doea nos etmust the Note (s "co-eigoet j: (a) is o"*mins thin Satwhy bamomeat a* to
mortgage, gut red Canvey the ardgnot's interest in the property rmdor tiro meant d" Security imaumetr (b) is
tot poeuaaay, obligated to pay the a m% accu el by this serity InsaumNtq ash (e) was that Lender std any
other Bommar can egao 0 attend, modify forbear at min say actohtllodations with regad to the teas of tMa
Sacm* lndm=Ut or the Noon WAWA the oo.sipoes rumant.
Subject to dw peovhiano of Section is. any Successor is interest of Borrower who assumes Boaoam'u
ablutions weds this Seetuitr immamoot is writinr, and is approved by Landa4 stall obtain ell of Botmwe s Ngha red
bersa&s under this Sectairy Instrument Burrower seas nor be rnleaud from Hormwm e, obblio nee andHablity uadverWe
Sacudty Increment Iwo" trade agars to ouch wleesa in writing, lbc covaaamr ad sgreew"M of this Swurity
Instrument shad bind (except ore provided is Maine. 20)end banedt the soeaesson and stsiens of leader.
11. Lean Charges, Leader may charge Borrower fees for servbea terf6med in eoenectioa wttb
Borrower's dafwlt, for the purpose of p vtoodog Lade 's Wessm in the property, aad rights under this Ucemity
Instrianoms mcluditj, but not Nadted to, womeys' foes, popstty inspoctima and valaaloa fens It mgani to any
other face, the absenee of expross ambocty in this Saasity htnhaunat to charge a spe do fa to Borrower owl not
be wnsawd as a probtbhtiat on the; elw&s of arch fee Linder may rot awp foss that ate eVeaady psobibited
by this Setw* lbstmmimt or by Apphiabie Law.
If tea Loan is aabject to a law which am ovetimum tom cherysS, and situ law is finally imarpremd so Fiat
?e mt rest or whew loan chagp acllected or b be collizCted m mnaocdaa veldt slat lam esoaed the permind
limits, tittea: (a) may such loan Warv shall be eedmod by wan amount oacataryro led= 6t chop to One pamlnad
limit; and (b) any sums goody collected kor Hommor which exceeded Pumiaed limits will be refimdad to
Borrower. Loder may dooso to arks this refund by reducing the principal owed under the Now or by maw" a
direct paymtd to Borrower. If a rdWnd radueo psiodpel, the rodautioa will be teetad as s partial prepayment
uitlatn my leMarymmet dwp (whorl w or dA a psepayteeot charge is provided for under the Noon). Borrower's
acceptance of say such refasd me& by dkw pgmeat to Borrows will oonstltute a walrer of any right of action
Barran might have wising outef tech ovooehatae,
15. Notices, All todod @iren by Bwrowcr or Lender in eonmatea with tit Security lasumscat asst be
w w Wog. Any notice to Borrower in eaunacdoa with tlds Sanctity instances: aWll be lord to have beers given
to Bacroww when tailed by first dam mail or who uctwtly delivered to Belsoaeses notice sddrean if sew by area
meas. Notice to nary one Borrower shall setstiane notice to an Bortwort tsleH Applicable Law tapaamy
roguitns omawise. 'Tee arotiee addmnt 16aA 1>e the property Addramr talent Sortower fors dongusrd a .mbadMet
rsotiee addnas by aetia ro Luke fl0aower abaB promptly euotity Leodar Of Borroave'c rkaoga a4 address. If
Lando ipaei5es a ptoeethae far teportinj Sotrowds tLaage et tddlMs, tbta Harrower shag only repots a ehmoga
of addtent through that apotified pmaAue 'lbae may be only ore designated notion address ruder refs Searito
Intatmtseat at any ate time. Argr nena to Gods, mail ban given by deliva(ing isaby ?tling a by Ant olus mail to
La:ndcr't addtent stead herein tmiced Lehda lw dargnmd axo?sr addtaa by ?? to Hocowror, Any wotim in
eoaaeetion wait thda Semaiy ltetsmaat (hull rot be deemed to haw beers given m Leads? untll aoawBy received by
1 endow, rf sty aetia inquired ity $if Searity lmemtement s alto rages sad ender Appianbk Law, Etc Applilicable
Law requieanser wdA aetaty rte eeaetpomdiag ogakemem umdu Chia Security tnsawras.
16. Gr+erriog Law{ SrvetaMlyl ktiu of Cmtatvedoa lLis seeudq Ituors more ahmil be govnaed by
federal Lw and the law of tea jmi>dietim to tvhkh the Ptoptrry, is located All tWo ad obligation; canntlnad in
this security lasermasat ma au4jea to say sages s sad limitmiom of Appho" Law. Applicable Law at ghat
expliddy or implicitly allow the parciso to agree by epOQac or is m4ft bo IBM but meh aflenee shall nos be
KNnnvA.YLw4toakfamily-r¦vakstawromAxUUN6'0 miN8'tPUM a Fs NSWIM
sdo"Gd ter VA
OCCVY" (rear a y0rlraer)
eacmraa.rra COMMON
8K 1893PGS001
42000317
renamed as a podbibbian against speement by contract. tR dud event that my pronsmn or clause of this Security
Instrument or the Note conflicts with Applicable Law, such conflict shall not afl'ea other provisions of thin Saniy
hustr urneut or the Note which can be Siva offset without den cmnflaing provision
As used in this Scomity 60trA oem; (a) words of the masetd id reader stall mean and include
corresponding agora words or woods of the famieiat ceder (b) words in tht singtdar ftU man and include the
plural and vice varat; and (t) the ward "may' gives Iola diScrodoo without any obb9stimto take say adios
17. Borrower's Copy. Borrower :ball be given one copy of the None and of thle Security huammtent
18. Tnwkr of the Propo ty or a Buwftd Tatar.t to Borrower. As used in d,ia Section IS, "Iwteteat
iv the Property" mew any legal or bensfledd interest In *a Property, imble4 g, bud net Bmita to, throe booddal
itrtereos tranakcr ed m a bond for dosed, conUsct 8or dad, i.aWbaem sake noncan or eterow, agmemcat, the Iraart
of which Is the under of title by borrower at a fdaae Men to s purvilasor.
If an or anypert ofthe Property or soy Imemst It the PrW.M is sold or trwfknad (or ifbostowa fa not a
natural pamm and a beoeticial Interest in Borruwa Is wed or underrod) wilbotn LMdlr's pew ww(r ut coosem;
limier my asquha bumedlets paymoat is M of all amt secured by ibis Sedrity lmowmlent However, this option
;'"U tot be eemcised byLeMsrif nob entrain k prohibited by Applicsb(e Law.
If Lends ozaoises dds option, Lender shall give Borrower eutia of acceleration, IU nod" shall provido
a period of rat less than 30 days Isom W Mkt doe notice is given in aecordasee with Soatien 15 within which
Borrower tome pay all taro secured this Saourity leamrneae if Betrower fails to pay than memo prior to the
.aspiration of ids period, Linda may invoke any lea pew by this qy intmamem widsout firtYer
mtice or demand on Borrower,
19. Borrower's Rfgbt to S P.Mk After Aeaakrstioo. If Borrower meta certain condiriam, Borrower
,shall have Ott njU to have ea6oroftwot of this Security Instrument discordimied at any time pronto the, esrgat of
(a) five days beforo ask of do Property ptareatto any poem of sole counbled in this Soestity, imnumest; (b) each
oiber period u ApploabL Law ®ght specify for the tormmation of Berrowe's right to rebmsarr or (e) easy of a
judgarcat enforcing this Security Intro se 11ima canditioos are that Borrower. (a) pays Leader all awns *Wch
then would be duo under this Security Isstrumem ad the Now w if no acceleration tad occizodi (b) puma soy
default of any other covaoaaat or agreements; (e) pays all eapeows incurred in os famlas this Sseauity Insnunnent.
todudm. but not limbed to. ressomble nonloys' fcea, property impeodea and valuation fees, and other f:es
Incurred for the Purpose of protoodeg hods Wooten in the Property sodrigiaa under this Security Imnvmat; and
(d) takes such action as Leader may ma molly sequin: m .auto the ladder's purest m the PMperry and rights
under this Security Imkaanco4 and Barmwm's obligidcm to pay the uses secured by this Sacurny lastamont, da0
e aftie uochujed. Landau may mgeam that Botralwor pay so* mUntimmaat rams and eufrases in ono or mote of
eke following foetus, is Warred by Leader. (a) also; (b) annoy order; (c) certified cheek, book ehsk, kasute r s check or
asbler's cheek, provided any and check is drawls upon as, mstivttim whose deporhs err mewed by a fbdnal aSmty,
enanwmenellity or matt'; or (d) Alemannic FWM Tneura. Upon reinstatement by Sonow", this 6eetvity lorttwrom and
obligations named hereby shad ere sWa silty effective a it no socdaradm bad eecearad However, this right to reiname
shall out etpptyin the asocf aaddranion valor Soedoe 11.
M Aak Of Nowt yoga d Lean Service; Notice, of Grievassu. The Note or a perod ettezvA in the
Note (tosedaw with 91111 SwWky Instrument) ma be told out or some times withot prior notion to Bo rwwar. A ak
adght malt in a abates in to emlty owes: u tsa "Loan 9ervicdry that colleen periodic Payments due under tho
Now and this 9staity Ins d and parfotms other muttgage loan savicin8 obli®uons under the Note, Otis
Saarity Itstrwnsat, and Appllcoble taw. Tbem oleo %WSM be one or moan ahwga of the Lose Servieer uomhated
tb a solo of be Noe. If theta is a change of the Loan Servitor, Boaowa will be Siva written satito of the dango
vddch will two the most gad address of9a now Low SeMeer, the adtbeaa to which lays should be meek and
any other fafiumada RBSPA rtrqubea in connection with a notice of tranek r of sarviems. It the Now is sold and
thereafter the Loan is serviced by a Loan Servitor odors than the putchaa of den Note, elan morlgsgn Into servicing
obligations to Borrower will mmain wkb As Loan Sevitoa or be tranddared to a successor Loa Servitor and are
rot arsmoed by the Note pandas adea otherwise provided by the Now putdaser.
Neither Rormwcr nor Leader say ecrmtence, join, or be jo(ooll all soy jiAciat action (as aicber an
individtod litigant or to mourber of a dWl dot arias i'tom ate *am party's actions pu roamed to Otis Sown y
Iastrumed or that alt that too other party has breaehad any provision at or my duty owed by mum ale this
Security bast uoult until sock Boroww at Leader Wen nodfiad *a omen paty (witb such notice given In
compliaw with den requirements of Section 11) of such aRaged broads sad sflorded Ole other party hereto t
M mabte period after tiro glviog of Ind. notice to We atradve action. If Appdica Ao Law provides a *M period
si'biah rtant elapse before attain $poon can be taken, that time period will be desisted to be raoateablo for pmpoacs
o#tbit paragrapb.71M nodco of soatdratlon and opportunity to else given to Bunoaer peuruant to Section 22 ud
toe nodac of aaelereuoa givdh W Sowower putauaar to Station 19 shell be demmad to satisfy the notice and
Opportunity marks corrective wren provisions afthis Section 20.
PL+T/rrr.YeJn,:..amab 1e, 4-7aaW Nwaloral, our WOORM L-N-URV IIMr PWPM$1001
Mediae for VA
tipCCrrsa. 6$11"13413 (Polio r rNrr read
mmrru.
BK l 893PG5002
42000277
21. Hazardous Substances. As used in skit Section 21: (a) "lazardous Subxrsooce" at those substances
defined u toxic or hazardous suhamucc% pobank, et woo by Eta trocatat Law ad *6 fallowing strbaancea
psohm. Uroacau, odor fwuu* or toxic petroleum pmduds, uxle pesticide and babkidek wladk soivmts,
metwialt eontaim" osbeama or Maddshyde, sad megoaadve mtderi* (b) "8avlrVW WWat 1400 mcam Laden?
laws and law of the jurisd'iddon wkere 60 Praputy is IOMW to MUM to bealb. Why m errvitormamsl
prowdoa. (C) "Emvosmeahf CICLV* includes any uepooss tacos, remWW aetim or removal action, W
defined in buvisomnnnl Law, and (d) an "BnvismovenW Condmon* moans a cmditon that can crust. cmmlburc
to, or otherwise trigger soEavimmomul Cleanup.
Borrower shin sot causO or pm k the presence, use, dkpossL hangs, or mousse of any Harardaux
SuW%vAe, cetbreden to reissue trey liiavardous Sabstsum odor in the Psopciv. 6o"= shall oat do, nor allow
anyone else to des, "ddug a8aedng tbo PrtRnrty (a) that is is violation of ay Enviratmaeaml Law. (b) whieb
emotes an Uvaotaaand! Condition, or (c) whisk do to the praaanee, use. or svkw of a Hazardous Subanurco,
traces t condition ,bat adva idy afibcts the value of the Propmy- The preceding two ooarmas shad not apply to
the preaenae, Oug, or amp an the Property of smell gasatltes of Ham rdam Subamaas that em generally
reoagetzcd to be appropt5ose m mrmal residential use and n ra rateaance of the Peopetty (including; but sot
lurtited t0, bAZUdDM tab3la BM in COW nmef pmdUSM)•
$onowar shall promptly gave 1.00 WAVAn nonce: of (a) any MV01MIg16096 Claim, demand, lawsait of
other satins by say govammmud or tegalasory agency or ptiv to Way iavoWing the Property ad any Hazardous
Substme or Ebvironmmnl Law of whieh Borrower ka scbd bowkdge, (b) any FsvboomostJ Condition,
including but not limited to, say Lpilliteg, lukb& disalettc, release to mrat of mlosse of any Hawdous Substance,
and (e) any oondition oaWed by the presmcq an or release of a Haatdow Subomace whkb adversely affects the
value of the Property. If Burrower lemur or U notified by any gavestdnemai or ragolatary authority, or any Private
party, that any removal or othes mmediatioa of any Hezatdoa Sr#mace a1fx7img List Property is necessary,
Borrower shall p"dy W¢ all accessory retu did actions in accordance whhEsvimameaml Law. Nothtrtg herein
stall cnam ray obligutan on Lands for" Fitimssfo NA Closm*.
NONAMORM COVBNANIV. Bomwor and [.scalar fitrther w vow sad agree as follows:
22. Aeaderstlost Aemedlu. Lender sbal) give sotka as Borrower prior to oeeeMranan fotlowlog
Bortowerh breack of any avousat ar aCreemaW b tbh Security instrument (bat sot prior to seederadoe
under Swdux 18 *Wan Applicable Law provides otlsv wiaey Lauder shall sadly Borrower ot, among cdbvr
tMagst (a) the ddadp (b) the so" required to cure the dobulr (c) when the def vok must be eared, sad (d)
that failure to cam the defews a speed may result W acoekndoo of the am MUM4 by this 9orarity
lastrumaey foreclosure by JudkW proceWng and ask of the Properly. Leader aWi funbw inform
Borrower of the right to Mostam saber as dervino and the rigist to suers he the feraaloatrs p oceedisg the
eamealetance of a Aebok or any other "rove of Borrower to auatcrotles sod fesedurmes U the Adult is rot
surd u speat0ed, Leader sties spans may regaha homodiw peyareM la fulldab cams aaaaro' by grit Smw*y
instrument without former dusaad and my ferecieee.this Satuft levervmeat by Judicial proeeadlog. Leader
slut be eadded to collect w exosesae hand In panolog me nandtapmsidd in tW Sectias 22, ladadlag, but
not Waited w aaornew- fa and o"k of dale oWeave oatasuareat poraWad by Applicable Law.
23. Release, Upon paytsem of all arm secured by We Stauriry lsssmtmw% this Security htstrmpesi and
ettate eeoveyed abed Lemtlaw and beo0ma void After such ocem ence, Lender sW Allow a and sandy this
Sem:rity lowumm BOawwer droll pay say recordation nom undue may ehuge BaTowee a he for "laving ads
security lnstruneat, but only if the he is paid to a 0*4 parry for strview readerd cud ba darft of the fee is
permhad under Appliabb Law.
24. Waivers. Bofrowot, 10 the exI psaniaed by Applicable Law, waives and relaxes any ow or
deface in promed np to estoru this Security lasnumom, and busby wum the beaefit of soy preaam or ilxme
11as providing for MY of aaudou, camadoa of ti m, eatetnptae born umdmwA kvy sad afe, and bmsexta l
25. Rdsxtattmmt Per" Bmrowtes time to remsesce pwiww bt section, 19 shall extend to one how
prior to the coavasrsement of bidding at a shatiffa We to otber sale pursnootn this security lasau cued.
M Purchase Massey Mortgage. If auy ofthe debt seemed by this Seatsky bsetrmem is lest to Borrower
,a aequirc use to the Ptopeay, Ws Security insnummsball be a p xchue money mortgage.
27.1assrest Russ After Jwigmaae laamewer.pest do am interest me payable Likes aiudgmess in, votee d on
tba Nee or to as arden of mortgage finealomre sang be bC ram payable ftomdo" to time aud4 the Note.
,
P
xr:tvtofVLVA.vU-SinzaxLairy..Fanab MWMOOk a[tc I11/6'OR.N R,71'gUattOtt 9"3630 1"01
MOW faVA
aOeMMa (?era 70 oJ7rpae4
rsoor.vn unLn..r
OKI893PG5003
49000::7
BY SmNm BSLCSW, Boafty uupa ad agm a m ft telmt and ow nanL o ammd in %is secu ft
lamu meat W in my Ridwc mead Bcn+v2r and ramded with it.
- SORROMR - >< S. WJ= - DkTR -
"'CVNav vANL Bleak FwA4-Faaak mawrmadk alas I1tnaw innunaNT Pommolml
m6d" M VA
oaaNTM? MW 1I.1ji auf
w4w.u.-n onus...
HK 1893PG5004
410002!7
R On this the a day of `8cczytil?;q/t ao?{ . before me, 4 K.) off. ub 1 Cr
. tlto uadastped oi&c P
Keau4u A-'C. Gree,\%
bNM m me (or wattactorifty Proverb m he 6A person(s) WbW Some V) sumedbod to the within birmamot
and aelmowM1edpd mat l i . e%eeated the acme for the pmposm tomin comet W.
th wimess wbdtoof, l hetemtoo sseet t SW b""offlo 1 ual.
CO
HOM
NO AL
KATHLEEN 10t1'bemtsryryPu k Tide of Of ca ?-
r Nw Cmnhsnahd Bmo. Gtsttbdebnd 6a
Commission trdslNe.S 2006
* Commissioe Egitm
CERTIFICATE; OF RESD)FNCE: 1 do hereby mtifyilatthe mrrect adarom oftbe wtWtFawod larder is
9761 MITLAID CUM Mr. Sts. mo. jwm m, n s2753.7294
Wimeaampbatd46 933W daYSf DacRtmen. 9006
Apes DMeW
rf W4 6v,Nil -Wt FuWy-swaie ltatl "d& Ku MORN ISMO tF.1r7 ftrw i i mal
+oedows ter Vn
m ac!m lerrvaaaa ..?a(t la yl:/Vol
OKI893PS5005
!4
F'
MZNG Tfaf MM ISMS UK= Clinton Archer and Evelyn Archer,
husband and wife, by their Deed dated April 30, 2002, recorded it
the office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, on May 03, 2002, in Record Book 261, Page 2854,
granted and conveyed unto Kenneth E. Green, single, Grantee
;herein.
I Certify this to be recorded
in Cumberland County PA
Recorder of ]deeds
O{ I893PGS006
V.A. GUARANTEED LOAN AND ASSUMPTION POLICY RIDER
NOTICE: THIS LOAN IS NOT ASSUMABLE
WITHOUT THE APPROVAL OF THE
DEPARTMENT OF VETERANS_ AFFAIRS OR
ITS AUTHORIZED AGENT. = s° ieeasiieoafoeoxf+a
Ciao of 11.10-4-oSe4e22
nM V.A. GUARANTEED tj00 AND ASSUWnON POLICY R1DSe it made this 2230 day of
1019CAm3R, 2004 , sad is locotponeed imo and shall be deetmed to coxed and
supplematt to b(mlipmge, Deed of Trost or Dead to Seeme Debt (tareca "Sauuity bad") dstod of even
Asa bhvwldr, givem by the nud:7i8ned (baeis Sorrowee) to moure Dormwe6Woa to
T3A17636m FISUMI" li nvIC33. Inc.
205 1 Z 3?1'R ! gsiliti'. r1eiNC+411 D7RO•174G1a'?ommdtoeaceda
v.A. GUAROTM LOAM COVENANT: Is o4 tiomtA o?Wee omosms sod itucements made is the Security
tnstn=m; Actroaeraad Larder Av6srcoveaaoramd sptm as follows;
If the t idebmdmas second benby be golnmmed or inooted under Tice 18, United Sates Code, such Title and
RAInIslifts imead dtotensdor sad is o5tat oa the dam immof sbaU govam the sights, tidies tmd liabilities of
Bcmv a and Leader. Any provisions of t e Seourky bosCmeant or other inttttm m *XWA d t6 ctmroccsint
with add iadebtedmas which am lomaaisreta with said Title or RspWoos, WW &16 but ate 8lnitad %, to
ptovW= for paytoaas *tow sm0 is co¢tmetioa wilt pepsymost oftbe w mad btdeb6tdmse std *a provision
that the Lander easy eeedemor paymeac of the accured ladcbtrdoess parsuutt to Covemost 19 of %be smutiry
Umer men, are hereby amoaded or ocgaod to tba aatear accessory to onfle m sob imat>mena to raid Tice or
Reguladom.
LATE CHARGE; At LendBY option, Bomwor will pay o 'hoe chitge" not tusedfng fourper cemmn (a%) of
the overdue paymeot whin psid man than fiheo (1S) days diet the due don theroofto cover oho axon ofpewc
tDwivod in hsodling delhquot psymm% but t xb 'bte chase" shall cot be payable our of the pwcmda of my
sale merle to unary the indobtodneoa teemed henby, taetess such proceeds ere sutficieat to dischcgc the entice
indebtednexs and alt proper com sad expeoset secured hctoby.
VA?,, aMy?AA24NI -LD LOAN A" AS3WVTaf)tt MACY AMER
'tlCe.Ydrll.tR nryahlM PIQe t art
SKJ893PG5007
GUARANTY: Slauld de it 43400221
Deparmsear of Veterans A$0its fail or tefese to imps isaot its gnaaory m full amount
wtdtin 60 days Elam the data that this lain would musally Wwme eNVUe floe suck ttamtnty eonamtted upon
by the Depasinsm of Veteran A? hiss under Om pmviaioas of Tide 38 of the U.S. Code Wetusss Haaef o
the Mor"m may, dealut the ittdahrodaees booby mmad u orta duo atx! payable and vary foreclose
idaoediaaly or any cssmiss any other 6SW bw%ttode or ttke any odta proper action as by law provided.
TRANSVXX OF TBE PROPERTY: This Iota may be declared immediately due and payable upon transfer of
the property saearictp s» ah Ions m any usacfstes, unless the acceptability of the assumption of the loan is
established pewmt to Section 3714 of Chapter 37, Title 38, Unted Stave Code.
An tttdaslred transfer ('asautWtitn•) of the property obeli also be aubjoa to additional oovonatos and
agaeemaett as act forth below-,
(t) A 1StIdsP9TOI I FUNDIIQO FEE; A fie altel m ens-half clone patcedt (0.30%) of tits balsnce of
dill loan at of the date of sremfer of the property "be pay" N the time of nodar to the loan holder or its.
aadwrlpW heat, is wugu for the DepummtK of Vesnsas Aftm if the asaumer fails to pay this fee at the
time of transfer, the he WWI ocastixot as additional debt to that shady seotand by tills basnsam? shall but
imereat at dte rue harew pmvi" sad at de option of the payee of the indehednass hereby sacred or any
aanderee thannF shall be -Mdiafoly duo and payable, This The is aotunnticatly waivcd if the asuacer is
oxesrtpt under the provisions of 38 U.S.C..3729 (e).
(b) ASSIIWrWN PROCESSWO CHARGE Upon applk== for approval m AVOW a asstion and
umfer of ibis loan. s processing fee may ba charted by the loss hailer or its authorial tgest for deotmoialng
the ersditwmtprisra of the aaQM sad lWoquaady twining the boldWs otvneuhfp wards wbon as appeared
nnasfor is oongdamd. The kmotmt of Ibis cheap shall not aacnod to maxinam a abliahtd by the Deporbnoat
of Vctr mas Affairs for a loan to whisk Section 3714 of Chapter 37, Title 38, United Stan Code sppli"
(c) AS&tAslplIQj?,,gyp)3iW?11iY ISa9t?tTM?,_ U des obb pnos is auumed, than Ilea %uumer hereby
agrees to assume W of die ob5t+doss of 0o veiyan tinder rho terms of the iest Utooua creating and seetuiog
the lava Too assumor father agrees to lsdmmlfy the Deparorent of Von= Aftaiea to the extent of any olaim
payment edsial fmn the r anty or issranoc of the lodabtedoow crated by ibis i amostaos.
NA t3UAAAXMW LOAFA:YO A19uaOM14 POUCYlUO6n
WWWM rvl+nea rays i dJ
BK1893PGSO08
42000221
7N W11NaGF ?htt oxmumd tbk V.A. Gawancaed Loan and Awxmpdml Policy Ridm.
• na tnrllft - 7[lflbiTlZ E. elm - DATE -
=&j Wj,124o, 4,30!3
OK l893PG5009
r 0
i11119JL111111
NOTE
NOTICE: THIS LOAN IS NOT ASSUMABLE
WITHOUT THE APPROVAL OF THE
DEPARTMENT OF VETERANS AFFAIRS OR ITS
ORalsr
LQIkH N??' 20.0.17004200092rs
AUTHORIZED AGENT.
Calla NOM, 10-10-6-0 584822
DECEMBER 23. 2004 NSW COKEISRLMM PENNSWMANIA
[Date] [City) [State]
209 1/2 SOUTH SECOND STREET, WORMEYSBDRO, PA 17043
[Property Address]
1. BORROWER'S PROMISE TO PAY
In return fora loan that I have received, I promise to pay U.S. S 66,51 zo r (this
amount is called "Principal'j, plus interest, to the order of the Lender. The Lender is TRANSLAND FININCIAL
SERVICES, INC.
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer
and who is entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged unpaid principal until the full amount of Principal has been paid. I will pay
interest at a yearly rate of 5.3 %.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in
Section 6(B) of this Note.
3. PAYMENTS
(A) Time and Place of Payment
I will pay principal and interest by making a payment every month.
I will make my monthly payment on-the 1ST day of each month beginning on
PEBRQRRY 2005 / . I will make these payment every month until 1 have paid all of the
principal and interest and any other charges described below that I may owe under this Note. Each monthly payment
will be applied as of its scheduled Sue date and will be applied to interest before Principal. If, on
TANUARY 1, 2035 , I still owe amounts under this Note, I willp y those amounts in full on that
date, which is called the "Maturity Date."
I will makemymonlhly payments at 270114AITLANO CRNTER,PRWY, STE. 300, XAITLIIND,
PL 32751-7294
MULTISTATE FIXED RATENOTE-S,,?l Family-Fannie M.cFre4dleafae UNIFORM INSTRUMENT Farm3100 Vat
°wn ov,enene (Page l of 4pases) Modified for VA
] - ]f6ft ?I, l )i _ --
or at a different place if required by the Note Holder.
41000227
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.S. S 374.,7'4
4. BORROWER'S RIGHT TO PREPAY (/
I have the right to make payments of Principal at any time before they ere due. A payment of Principal
only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I em doing
so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note,
may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note
Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note
Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying
my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes
in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum lose charges, is finally interpreted so that the
interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits,
then: (a) any such loan charge shall be reduced by the amount necessary at reduce the charge to the permitted limit,
and (b) any soma already collected from me which exceeded permitted limits will be refunded to me. The Note
Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct
payment to me. Ifa refund reduces Principal, the reduction will be treated as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any ntldy payment by the end of 35 calendar
days after the date it is due, I will pay a late charge m th ote Holder. The amount of the charge will be
4.000 Y of my overdue payment. I will pay this I e charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I am in ddault, the Note Holder may send me, a written notice telling me that if I do not pay the overdue
'amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which
has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on
which the notice is mailed to me or delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as
described above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required not: to pay immediately in full as described above, the Note Holder will have
the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent net prohibited by
applicable law. Thou expenses include, for example, reasonable attomeys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that roust be given to me under this Note will
be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different
address if 1 give the Note Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing
it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am
given a notice of that different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the
promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor,
surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations,
including the obligations of a guarantor, surety or endorser of this Now, is also obligated to keep all of the promises
made in this Note. The Note Holder may enforce its rights under this Note against each person individually or
against all of us together. This means that any one of us may be required to pay all of the amounts owed under this
Note.
MULTISTATE FIXED RATE NOTE-Singlc Family-Fannie atae/Freddie aLc UNIFORM INSTRUMENT Form 32M V01
wav f.vo, ernaneao (page 2 of 4 pag.) Modified for VA
°OC
42000227
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of
Dishonor. "Presernlnent" tll"Ils the right to require the Note Holder to demand payment of atrounts due. "Notice of
Dishonor" means the right to require the Note Holder to give notice to other persom that amounts due have not
been paid.
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in sonar jurisdictions. In addition to the protections
given to the Note Holder under this Note, a Mortgage. Deed of Trust or Security Deed (the "Security Instrument"),
dated the same date as this Note, protects the Note Holder from possible losses which might mutt if 1 do no keep
the promises which 1 make in this Note. That Security Instrument describes how and under what conditions I may
be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are
described as follows:
If all or any pan of the Property or any Interest in the Property is gold or transferred (or if
Borrower is not a natural person and a beneficial interest in Borrow" is sold or bansferred)
without Lender's prior written consent, Lender may require immediate payment in full of all sumac
secured by this Security Instrument. However, this option shall not be exercised by Lender if such
exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The
notice shall provide a period of not less than 30 days from the date the notice is given in
accordance with Section 15 within which Borrower most pay all sums secured by this Security
Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender my
invoke any remedies permitted by this Security Instrunent without further notice or demand on
Borrower.
MULTISTATE FIXED RATE HOTE-SIa21e Family-Fuale Mae'Freddk Mee UNIFORM INSTRUMENT Form 32001roi
auvwes (page l of 4 pager) Modified for VA
a.vn ovunow
6 ? )q;?,j?70
420002]0
WITNESS THE HANDS S) OF THE UNDMIIGNED
BORROWER - EBNHBTR E. O REN - DATH -
PAY TO THE ORDER OF:
WANNGfON MUTUAL BANK. FA
WITHOUT RECOURSE /
TRANS NC LSE /ICES, INC. /
BY: G
INGkUQ 7. FER IN
SENION VICE PR 'IDENT
(Sign Original Only)
MULTISTATE FIXED RATE NOTE-Single FUVdy-F...WM.Nllddi. M.v UNIFORM INSTRUMENT Farm 31001N1
CCCVVPV, (page 4 of 4 pages) Modifiad for VA
ppyvnp,.y} oa/if/lool
Washington Mutual
Mailstop JAXB2004
P.O. Box 44090
Jacksonville, FL 32231-4090
December 15, 2005
#BWNCLNN#
#0906459106987392#
KENNETH GREEN
209 112 S SECOND ST
WORMLEYSBORG PA 17043
000662 /PA
0645106873
WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED
NOTICE OF COLLECTION ACTIVITY
RE: ACCOUNT # 0645106873
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This an pi ici al ti that the your home i s in defau lt. and h lender intends to foreclose ¢p= if f t n bQU11he
nature
The H of t
OM he d
EOW efault '
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MOR d d in
TGAG the attach
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ANCE PROG
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EMAP
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lp to save your holua.
This N
To
see otic
if H e p
EM la' s h
" can ow th
U112 y e progra
ou mu m works
st MEET
WITH A CO
NSUMER
tRE1
21T COUNSELING
AGENCY WITHIN
30 DA YS OF T HE DA TE O F THIS NOTICE lake this Notice ' thy hen yQu meet wit hlhe Co liinq Agen cy.
T 'd a an d phon e - be of Con 5iurltr Credi t Counsel ing Ag encies serving ,your County a_ tited at th e end of this Notice. I
you h ave n t nig 'o a.you m ca ll the Pe nsyl an' Ho using Fi m A gency toll free at 1 -800-342-2997 (Person
'mimed
s with
be-m g ca n cal l (717) 7R[)-18 69)-
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you
find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU
CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE
LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDES SER ELEGIELE PARA UN PRESTAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMSR SU HiPOTECA.
PA ACT 91
HOMEOWNER'S NAME(S): Kenneth Green
PROPERTY ADDRESS: 209 1/2 S. Second St.
Wormleysburg PA 17043
LOAN ACCT. NUMBER: 0645106873
ORIGINAL LENDER: Flo
CURRENT LENDER/SERVICER: Washington Mutual Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF
1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty
(30) days from the date of this Notice. During that time you must arrange and attend a "face-lo-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (301 DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MGRTG A "° A °"QT NC YO MUST BRING YOUR MGRT A UP TO DATE THE PART
OF THIS NOTICE CA . - D "HOW TO CS7?UR MORTGAGH DEFAI7 T" XPI. iNS HOW TO BRING YOUR MORTGAGE
UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of
this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The addresses, and
telephone numbers of designated consumer credit counseling. agencies for the county in which the property' located a t f th at the
end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following
pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must
fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or
postmarked within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME
PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives
your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set
forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
000663/coe25
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it uo to date)- The MORTGAGE debt held by the above lender on your property located at
209 I2 S. Second St.
Wormleysburg PA 17043
IS SERIOUSLY IN DEFAULT BECAUSE:
Non-payment
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
Monthly Installments: 10!012005 $476.08
11/012005 $476.08
121012005 $494.90
Other charges (explain/immize):
Uncollected Late Charges $44.97
Uncollected Fees: $8.90
Less Credits $0.00
TOTAL AMOUNT PAST DUE: $1500.93
B. YOU HAVE FAILED TO TAKE. THE FOLLOWING ACTION (Not applicable):
HOW TO CURE THE D FA T - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE
TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1500.93, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD, Payments must be made either by cash cashier's check- certified
check, moo y rde d payable and sent In,
Washington Mutual Bank
Cash Processing
P.O. Box 3200
Milwaukee, WI 53224
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable):
IF YOU DO NOT CURE THE DEFAULJ - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the tender
intends t exercisets rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered
due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past
due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your
mortgaged oronerly.
*IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. H the
lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you,
you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be
added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY tam
DAY period yo ill n t he 7esatived t pa attorney's fees.
OTHELENDER REM nl c - The lender may also sue you personally for the upaid principal balance and all other sums due under the
mortgage.
PA ACT 91
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE - If you have not cured the default within the THIRTY (30) DAY period
and foreclosure proceedings have begun, yo may till have the rjght to a the default and nr t the le mime to to one hour
b fn the Sheriff's al Y may do by pgydng the t t_ al a mi.t t?_ t d DS 1 Y late o th.4r charges then n due. ?---? .-, reasonable
o
att v' fees and costs t d with the foreclolirc 1 and any other 1s ciInn t d with the Sh 'ff al specified 'lin b
the lender and by performing an other rea + t under th mortgage -, Curing your default in the manner set forth in this notice will
restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBI F SHERIFF'S SAT DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property
could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be
sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER,
Name of Lender: Washington Mutual Bank
Address: 7255 Baymeadows Way
Jacksonville, FL 32256
Phone Number: 866-926.8937
Fax Number: 904-281-3914
Contact Person: Collection Department
Email Address: www.wamuhomeloans.com
EFFECTS OF SHERIFF'S SAL F: - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your
right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You _ may or ]L may not sell or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that
the other requirements of the mortgage are satisfied.
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE
THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED
We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your
account may be reflected in your credit report.
PA ACC 91
Washington Mutual 0645106873
Mailstop JAXB2004
P.O. Box 44090
Jacksonville, FL 32231-4090
7100 4047 5100 2142 0550
December 15, 2005
KENNETH GREEN
209 1/2 S SECOND ST
WORMLEYSBURG PA 17043
000663 /PA
WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
PLEASE REVIEW THE DEBT VALIDATION NOTICE ENCLOSED
NOTICE OF COLLECTION ACTIVITY
RE: ACCOUNT# 0645106873
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an Official notice that the ortgagcyyour ho is' default and the 1 d 'nt d t12 f cl $;Le-£ f atio h ut th
nature of the default's pro-tided ithe attached gy
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HFMAP)_may be able to he to save your h me-
Th' Notice explains ho the program works-
lo e if HEMAP can help- w t MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN
30 DAYS OF THE DATE OF THIS NOTICE Take this Notice 'thy h you + with h CQunseling Agency-
Ilic n e address and oh e j2umbcr of Consumer Credit Counseling Ag nc' serving y-Qur County are fisted at the end of this N fc If
you have any Questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-742-2397 iPersons with 'mpailid
li wring can call (717) 780-18691
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency
may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may he able to help you
find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU
CASA. SI NO COMPRENDE EL CONTENIDO DE FSTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE
LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
PA ACT 91
HOMEOWNER'S NAME(S): Kenneth Green
PROPERTY ADDRESS: 209 1/2 S. Second St.
Wormleysburg PA 17043
LOAN ACCT. NUMBER: 0645106873
ORIGINAL LENDER: Flo
CURRENT LENDER/SERVICER: Washington Mutual Bank
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN AVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENT
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF
1983 (THE "ACr"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty
(30) days from the date of this Notice. During that time you most arrange and attend a "face-to-face" meeting with one of the consumer
credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT !.? DAYC IF YOU DO
NOT APPLY FOR M R NCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORT AC P TO DATE THE PART
OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGEDEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGF
UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIFS - If you meet with one of the consumer credit counseling agencies listed at the end of
this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and
telephone numbers of designated consumer credit counseling agencies for the county which the _property' located a et forth at the
end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following
pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender,
you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must
fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or
postmarked within thirty (30) days of your face-m-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME
PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the
eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives
your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set
forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
000663/co816
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date)
- The MORTGAGE debt held by the above lender on your property located at
209 12 S. Second St.
Wormleysburg PA 17043
IS SERIOUSLY IN DEFAULT BECAUSE:
Non-payment
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
Monthly Installments: 10/01/2005 $476,08
11/01/2005 $476.08
121OV2005 $494.90
Other charges (exptain/iterrize):
Uncollected Late Charges $44.97
Uncollected Fees: $8,90
Less Credits $0,00
TOTAL AMOUNT PAST DUE: $1500.93
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable):
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE
TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1500.93, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Parents must be d either by ash cashier's check, certified
check. or mnneyyrder made payable and sent to-
Washington Mutual Bank
Cash Processing
P.O. Boa 3200
Milwaukee, WI 53224
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable):
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender
intends to exereice its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered
due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past
due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon jour
mortyagedyronerty.
*IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the
lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be
required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you,
you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be
added to the amount you owe the lender, which may also include other reasonable costs. If you cure the defa,dt within the THIRTY tin)
DAY period. you will not be required to pay attorney's fees.
mortgage.
The lender may also sue you personally for the upafd principal balance and all other sums due under the
PA AGT 91
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S
and foreclosure proceedings have begun, you may still have
restore your mortgage to the same position as if you had never
If you have not cured the default within the THIRTY (30) DAY
Curing your default in the manner set forth in this notice will
EARLIEST POSSIBLE SHERIFF'S SALE DATE - it is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property
could be held would he approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be
sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: Washington Mutual Bank
Address: 7255 Baymeadows Way
Jacksonville, FL 32256
Phone Number: 866-926.8937
Fax Number: 904-281-3914
Contact Person: Collection Department
Email Address: www.Eamubomeloans.com
EFFECTS OF SHERIFF'S SALF• - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your
right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could he started by the lender at any time.
ASSUMPTION OFMORTGAGE - You _ may or $ may not sell or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that
the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE. RIGHT-
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE
THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES
IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED
We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your
account may be reflected in your credit report.
PA ACT 91
VERIFICATION
Ilana Zion, Esquire hereby states that she is the Attorney for the Plaintiff in this
action, that she is authorized to make this Verification as the Plaintiff is outside the
jurisdiction of the Court and Plaintiff's verification could not be obtained within the time
necessary to file this pleading, and that the statements made in the foregoing Complaint in
Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the penalties
of 18 Pa.C.S. Sec. 4904 relating to unworn falsification to authorities.
S14APIRO & KREISMAN
i
IY: lfli
Ilana Zion, quire
Attorney for Plaintiff
Dated:
J? (?J?U?
r C '
t
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I.D. NO: 87137
2520 RENAISSANCE BLVD., SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
W08
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO:06-1434
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification to the Complaint in the above-captioned civil
action.
Respectfully Submitted,
SHAPIRO & KREISMAN
BY: \(?-
ana Zion, Esquir
Attorneys for Plaintiff
1
Washington Mutual Bank, FA v. Kenneth Green a/k/a Kenneth E. Green
VERIFICATION
The undersigned, an officer of the Corporation which is the Plaintiff in the
foregoing Complaint or an officer of the Corporation which is the servicing agent of
Plaintiff, and being authorized to make this verification on behalf of Plaintiff, hereby
verifies that the facts set forth in the foregoing Complaint are taken from records
maintained by persons supervised by the undersigned who maintain the business records
of the Mortgage held by Plaintiff in the ordinary course of business and that those facts
are true and correct to the best of the knowledge, information and belief of the
undersigned.
I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
n
Date: - - ? cc?
T
Loan:0645106873
06-26302
Name: 'tLck' Iq t(o i v
Title:
GYP
Company: ?q/as? • Jan /?v?
?:s Cti/<,
511APIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I.D. NO: 87137
2520 RENAISSANCE BLVD., SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA ;
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
SHAPIRO & KREISMAN, LLC
BY: , ?\
Ilana Zion, EsquireAttorney for Plamti
14.
c
?y
d
cn :> 1
Y4
? dam
W
.c
t
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2006-01434 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
R. Thomas Kline
, Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT , to wit:
GREEN KENNETH AKA KENNETH E GREEN but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT SERVED , as to
the within named DEFENDANT GREEN KENNETH AKA KENNETH E
GREEN
209 1/2 SOUTH SECOND
WORMLEYSBURG, PA 17043
PER NEIGHBOR, DEFENDANT IS AVOIDING SERVICE.
Sheriff's Costs: So answers:
Docketing 18.00
Service 28.16
Affidavit .00 R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
56.16 SHAPIRO & KREISMAN
04/17/2006
Sworn and subscribed to before me
this jrl?- day of -1
,Xft? A. D.
Prothonotary
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2006-01434 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
R. Thomas Kline
, Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
OCCUPANT but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOT SERVED , as to
the within named DEFENDANT OCCUPANT
209 1/2 SOUTH SECOND STREET
WORMLEYSBURG, PA 17043
PER NEIGHBOR, DEFENDANT IS AVOIDING SERVICE.
Sheriff's Costs: So answers:
Docketing 6.00
Service .00
Affidavit .00 `R. Thomas Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
16.00 SHAPIRO & KREISMAN
04/17/2006
Sworn and subscribed to before me
this /,8 eO day of 2
kppl, A. D.
Prothonotary
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01434 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
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
GREEN KENNETH AKA KENNETH E GREEN but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT
GREEN
6 ADAMS STREET
NOT FOUND , as to
GREEN KENNETH AKA KENNETH E
ENOLA, PA 17025
DEFT'S SISTER LIVES AT 6 ADAMS ST. SHE SAYS THAT HE LIVES AT
209 1/2 S 2ND ST. SOMEONE THERE BUT WOULD NOT ANSWER THE DOOR.
Sheriff's Costs: So answ -?
Docketing 18.00
Service 14.08
Not Found 5.00 R. Tho as Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
47.087 SHAPIRO & KREISMAN
9- 1/v3i0 (, 06/06/2006
Sworn and Subscribed to before
me this day of
A. D.
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
NO: 06-1434
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
SHAPIRO & KREISMAN, LLC
a
BY: ?.?
Ilana Zion
Attorney for Plaintiff
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
MOTION FOR SERVICE PURSUANT
TO SPECIAL ORDER OF COURT
Plaintiff, by its counsel, SHAPIRO & KREISMAN, LLC, moves this Honorable Court
for an Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all
subsequent pleadings that require personal service only, upon the above-captioned Defendant, by
regular mail and certified mail to the last known addresses of Kenneth Green a/k/a Kenneth E.
Green, only which are 209 1/2 South Second Street, Wormleysburg, PA 17043 and 6 Adams
Street, Enola, PA 17025, and by posting of the subject premises located at 209 1/2 South Second
Street, Wormleysburg, PA 17043, and in support thereof avers the following:
1. The Sheriff has been unable to serve the Complaint in Mortgage Foreclosure.
Further attempts at personal service would not be successful. A true and correct copy of the
Sheriffs Return of Service is attached hereto and marked as Exhibit "A".
2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good
faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the
specific inquiries made and the results there from is attached hereto and marked as Exhibit "B".
3. The last known addresses of the Defendant is as set forth in Exhibits "A" and "B".
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in
Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service
only, upon the above named Defendant, Kenneth Green a/k/a Kenneth E. Green, by regular mail
and certified mail to the last known addresses of the Defendant, Kenneth Green a/k/a Kenneth E.
Green, only which are 209 1/2 South Second Street, Wormleysburg, PA 17043 and 6 Adams
Street, Enola, PA 17025, and by posting of the subject property located at 209 1/2 South Second
Street, Wormleysburg, PA 17043.
SHAPIRO & KREISMAN, LLC
i
BY:
Ilana Zion
Attorney for Pla tiff
SHERIFF'S RETURN - NOT FOUND b-b- Z (9
CASE NO: 2006-01434 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
R. Thomas Kline
duly sworn according to law,
inquiry for the within named
GREEN KENNETH AKA KENNETH E
unable to locate Him in his
COMPLAINT - MORT FORE
-,Sheriff or Deputy Sheriff, who being
says, that he made a diligent search and
DEFENDANT
GREEN but was
bailiwick. He therefore returns the
the within named DEFENDANT
GREEN
209 1/2 SOUTH SECOND STREET
WORMLEYSBURG, PA 17043
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE
WE WERE UNABLE TO SERVE DEFENDANT.
Sheriff's Costs: So answers:
Docketing 18.00 _ f
Service 42.24
Not Found 5.00 R. Thomas"Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
75.24 SHAPIRO & KREISMAN
12/04/2006
Sworn and Subscribed to before
me this day of ,
A. D.
NOT FOUND as to
. GREEN KENNETH AKA KENNETH E
p(Nkl& IT
'A°
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01434
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
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
GREEN KENNETH AKA KENNETH E GREEN but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
the within named DEFENDANT
GREEN
6 ADAMS STREET
NOT FOUND , as to
GREEN KENNETH AKA KENNETH E
ENOLA, PA 17025
DEFT'S SISTER LIVES AT 6 ADAMS ST. SHE SAYS THAT HE LIVES AT
209 1/2 S 2ND ST. SOMEONE THERE BUT WOULD NOT ANSWER THE DOOR.
Sheriff's Costs: So answ
Docketing 18.00
Service 14.08
Not Found 5.00 R. Tho as Kline
Surcharge 10.00 Sheriff of Cu erland County
.00
47.08 SHAPIRO & KREISMAN
06/06/2006
Sworn and Subscribed to before
me this day of ,
A.D.
hQ I Marlton, M.1 0$053
Fax: 856-985-332
File #
Firm
Subject:
Current Address
Property Address
Mailing Address:
IPPPP* Defzrult Express Services, Inc.
13000 Route 73 Suite 707
Four Gr+?entre?: 'Center
Phone: 85685-340
i nfo4a?d of au Ite x ?a ress. cv m;
2155
Shapiro & Kreisman
Kenneth Green
209 1/2 S. 2nd St. Wormleysburg, PA 17043
209 1/2 S. 2nd St. Wormleysburg, PA 17043
209 1/2 S. 2nd St. Wormleysburg, PA 17043
I Steven M. Ruffo,being duly sworn according to law, do hereby depose and state
as follows, I have conducted an investigation into the whereabouts of the above
noted individual(s) 5/2/06 and have discovered the following
I. CREDIT INFORMATION
A. SOCIAL SECURITY NUMBER
Our search verified the following to be true and correct
Kenneth Green - 167-40-4414
B. EMPLOYMENT SEARCH
Kenneth Green - Our Office was unable to verify the employment information on
the credit report.
C. INQUIRY OF CREDITORS
On 5/2/06 our inquiry with the creditors indicate that Kenneth Green reside(s)
at 209 1/2 S. 2nd St. Wormleysburg, PA 17043
II. INQUIRY OF TELEPHONE COMPANY
A.DIRECTORY ASSISTANCE SEARCH
On 5/2/06 our inquiry with the Directory Assistance indicated that Kenneth
Green reside(s) at 209 1/2 S. 2nd St. Wormleysburg, PA 17043 717-774-0158.
Our office made a telephone call to the mortgagor number and got the voicemail
III. INQUIRY OF NEIGHBORS
Using our Whitepages database on 5/2/06 we were unable to verify the current
address with any of the Neighbors within ten houses of the above referenced
subject.
IV. INQUIRY OF POSTOFFICE
A. NATIONAL ADDRESS UPDATE
Our inquiry with National Address database on 5/2/06 indicates the following is
correct Kenneth Green - 209 1/2 S. 2nd St. Wormleysburg, PA 17043
B. ADDITIONAL ACTIVE MAILING ADDRESS
Per our inquiry with creditors on 5/2/06 the following is an active mailing
address : 6 Adams St. Enola, PA 17025
V. MOTOR VEHICLE REGISTRATION 1a4A%9o(T
A. MOTOR VEHICLE & DMV OFFI CE
Per the Pennsylvania Department of motor vehicle Kenneth Green has a valid 1• h
identification registered with the state.
VI. OTHER INQUIRIES
A. DEATH RECORDS
As of 5/2/06 Vital records has no death records on file for Kenneth Green
B. PUBLIC LISCENSES (PILOT, REAL ESTATE ETC.)
Our investigation could not find Public licenses/ records for the mortgagor
C. COUNTY VOTER REGISTRATION
The Cumberland Cnty voter registration would only indicate a registration for
Kenneth Green
D. INTERNET
All accessible public databases have been checked and cross-referenced for the
above named individual(s).
E. TAX ASSESSMENT OFFICE
On 5/2/06 our office conducted a search of the following tax records which
showed the following : See Attached
VII. ADDITIONAL INFORMATION OF SUBJECT
A. DATE OF BIRTH
Kenneth Green - 5/4/62
B. A.K.A
Kenneth Green - Kenneth E. Green
The undersigned understands that this statement herein is made subject to the penalties
of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities
I hereby verify that the statemants made herein are true and correct to the best of my
knowledge, information and belief and that this affidavit of investigation is made subject to
the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities.
Ote'- fu 1?t __
AF ANT Steven M. uffo
Default Express Services, INC. President
Sworn to and subscribed before me this 2th day of May 2005
NOTARIAL SEAL
Joseph J. Sarocy
Notary Public of New Jersey
Commission Expires 10/20/2009
OT RY P LIC
Default Express Services, Inc.
1 3000 'Route 73 Sulte- 107
Forir Greentree Center
Marlton, NJ 08053
Phone: 856 385-3340
Fax: 056-985-3.342
i nfo(&_)d efau Itex p ress:corn
*GREEN,KENNETH,L SINCE 11/02/86 FAD 09/28/05 FN-319
209 1/2,S 2ND,ST,WORMLEYSBURG,PA,17043,TAPE RPTD 06/02
6,ADAMS,ST,ENOLA,PA,17025,TAPE RPTD 04/02
22,N FRONT,ST APT 1,WORMLEYSBURG,PA,17043,TAPE RPTD 05/97
FN-GREEN,KENNETH,E
BDS-05/04/1962,SSS-167-40-4414
* * * * WARNING BANKRUPTCY ON FILE, FULL CREDIT REPORT IS
ADVISED.....
PAGE 1
PENNSY" `NIA DEPARTMENT OF TRANSPO' 1TION
AUREAU OF DRIVER LICENSING
BASIC DRIVER INFORMATION
APR 28 2006
DRIVER: KENNETH EDWARD GREEN DRIVER LICENSE NO : 19745647
209 1/2 S 2ND STREET DATE OF BIRTH : MAY 04 1962
WORMLEYSBURG, PA 17043 SEX : MALE
RECORD TYPE : REG LICENSE
DRIVER LICENSE (DL)
LICENSE CLASS : C
LICENSE ISSUE DATE: APR 08 2003
LICENSE EXPIRES : MAY 05 2007
ORIG ISSUE DATE : MAR 25 2000
MED RESTRICTIONS : 1
LEARNER PERMITS
LICENSE STATUS
COMMERCIAL DRIVER LICENSE (CDL )
CDL LICENSE CLASS :
CDL LICENSE ISSUED :
CDL LICENSE EXPIRES:
CDL ENDORSEMENTS : NONE
CDL RESTRICTIONS : NONE
CDL LEARNER PERMITS:
CDL LICENSE STATUS :
SB ENDORSEMENT :
PROBATIONARY LICENSE (PL)
PL LICENSE CLASS
PL LICENSE ORIG ISS:
PL LICENSE ISSUED :
PL LICENSE EXPIRES :
PL LICENSE STATUS :
OCCUPATIONAL LIMITED LICENSE (OLL)
OLL LICENSE CLASS
OLL LICENSE ISSUED :
OLL LICENSE EXPIRES:
OLL LICENSE STATUS :
*** END OF RECORD ***
Input Parameters
Refortnce Number
Permissible Purpose = ;SI;;
Primary Subject = ;;;;;;;;;;;;;;XXXXX4414;;;
TRANSUNION SSN REPORT
FOR
SBJ Y NJ0200302
RPT ON
GREEN, KENNETH E.
MKT/SUB INFILE
17 HB 9/87
SSN
167-40-4414
DATE TIME
05/03/06 11:30CT
DOB
5/62
CURR/ADD
209 S. 2ND ST., #2ND. WORMLEYSBURG PA. 17043
FRMR ADD
6 ADAMS ST., ENOLA PA. 17025
22 N. FRONT ST., #1ST. WORMLEYSBURG PA. 17043
CURR EMP & ADD PSTN INCM
DUKES BAR & GRILL E
FRMR EMP & ADD
WITER CONCORDIA CO INC
*** INQUIRY ANALYSIS ***
DATE SUBCODE SUBNAME
04/13/2006 B1252004 WAMU
GREEN,KENNETH
209 1/2 S SECOND ST WORMLEYSBURG,PA 17043
TEL#
RPTD 774-0158
05/2002
04/2002
EMPDATE RPTD
6/05R
7/04R
END OF TRANSUNION REPORT
****************************************************************************
Washington Mutual Bank, FA
vs.
Kenneth Green a/k/a Kenneth E. Green
VERIFICATION
Ilana Zion, hereby states that she is the Attorney for the Plaintiff in this action, that she is
authorized to take this Verification, and that the statements made in the foregoing MOTION
FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best
of her knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the penalties of
18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
SHAPIRO & KREISMAN, LLC
BY: JAW duJ?
Ilana Zion
Attorney for Plai ff
S & K FILE NO. 06-26302
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
If service cannot be made under the applicable rule the plaintiff may move the court for a
special order directing the method of service. The motion shall be accompanied by an
affidavit stating the nature and extent of the investigation, which has been made to
determine the whereabouts of the defendant and the reasons why service cannot be made.
The comment to Pa.R.C.P. 430(a) illustrates what would be a good faith effort to locate
the Defendant:
NOTE: [A]n illustration of a good faith effort to locate the defendant includes (1)
inquiries of postal authorities including inquiries pursuant to the Freedom of Information
Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the
defendant, and (3) examinations of local telephone directories, voter registration records,
local tax records, and motor vehicle records. Comment to Pa.R.C.P. 430 (a).
In real property actions, such as actions in mortgage foreclosure, the Pennsylvania Rules
of Civil Procedure, Rule 410 (c), provides how service shall be made pursuant to an Order of
Court under Pa R.C.P. 430 (a):
The court shall direct one or more of the following methods of service: (1) publication as
provided by Rule 430 (b), (2) posting a copy of the original process on the most public
part of the property, (3) registered mail to the defendant's last known addresses, and (4)
such other methods, if any, as the court deems appropriate to serve notice to the
defendant.
As set forth in the Sheriffs Return of Service, attached to the Plaintiffs motion as Exhibit
"A", the Sheriff has been unable to serve the Complaint in Mortgage Foreclosure. A good faith
effort to discover the whereabouts of the Defendant has been made in accordance with
Pennsylvania Rule of Civil Procedure 430(a), as evidenced by the attached Affidavit of Good
Faith Investigation, attached to the Plaintiffs motion as Exhibit "B".
In order to complete service on the Defendant, Kenneth Green a/k/a Kenneth E. Green, so
as to move this action forward to ultimate disposition, the Plaintiff respectfully requests that this
Honorable Court, pursuant to Pennsylvania Rule of Civil Procedure 430, grant a special Order
directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent
pleadings that require personal service only, on the Defendant, Kenneth Green a/k/a Kenneth E.
Green, by regular mail and certified mail to the last known addresses of the Defendant, Kenneth
Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street, Wormleysburg, PA
17043 and 6 Adams Street, Enola, PA 17025; and by posting of the subject property located at
209 1/2 South Second Street, Wormleysburg, PA 17043 by the Sheriff, competent adult, or other
party allowed by law.
Respectfully Submitted,
SHAPIRO & KREISMAN, LLC
Date: ?2 6lo BY: \
Ilana Zion
Attorney for Plain
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
CERTIFICATION
I hereby certify that I have served a true and correct copy of this Motion for Service
Pursuant to Special Order of Court and the papers attached thereto on all parties named herein at
his last known address or upon his attorney of record by regular mail, postage prepaid to the
parties listed below on 2006.
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
SHAPIRO & KREISMAN, LLC
BY:?- tl?,
Ilana Zion
Attorney for Plaintif
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
CERTIFICATION OF ADDRESS
I, Angela D'Antonio, the undersigned, being duly sworn according to law, hereby depose
and say that the address of the above Defendant are as follows:
Kenneth Green a/k/a Kenneth E. Green
209 1 /2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
SHAPIRO & KREISMAN, LLC
BY:
Angela 'An oni
Legal Assistant to Attorney for Plaintiff
r-a
". -in
f elI
DEC i c 2ooe pq'
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
ORDER
0%
AND NOW, this 18 , day of lbeua?u, 2006 upon consideration of Plaintiffs
Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith
Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage
Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on
the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and
correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent
pleadings by certified mail and regular mail to the last known addresses of the Defendant,
Kenneth Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street,
Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025, and the Sheriff, Marshal or
other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of
Sale or said subsequent pleading on the most public part of the property located at 209 1/2 South
Second Street, Wormleysburg, PA 17043, which is the subject of this action in mortgage
foreclosure.
BY THE COURT:
J.
I :8 t'lJ 8 13 -38 graz
3141 Jtj
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
SHAPIRO & KREISMAN, LLC
BY: L
a Zion, Esquire
Attorney for Plaintiff
"'
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
NO: 06-1434
AFFIDAVIT OF SERVICE
I, Angela D'Antonio, the undersigned, being duly sworn according to law, hereby depose
and say that on the day of 200tZ pursuant to the attached
Order of Court, attached as Exhibit "A", I served a true and correct copy of the Complaint in
Mortgage Foreclosure in the above captioned matter to the Defendant by certified and regular
mail, to their last known address of:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
SWORN AND SUBSCRIBED
Before me this day ofl(lU4120 A. _ n T//
N
Notadal Seal
Denise L SW*d, Notary PUAC
Lj%w VwWY my Car "w E?iM J* 2 Ca0i?
SHAPIR & rREISM
BY:
Ange a D' An onio
Legal Assistant to Attorney for Plaintiff
Memoer. Pennsylvania Association of
DEC 16 ly(
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
C?Op?f
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
ORDER
AND NOW, this _L?_, day of?Decyi4h&d, 2006 upon consideration of Plaintiffs
Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith
Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage
Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on
the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and
correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent
pleadings by certified mail and regular mail to the last known addresses of the Defendant,
Kenneth Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street,
Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025, and the Sheriff, Marshal or
other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of
Sale or said subsequent pleading on the most public part of the property located at 209 1/2 South
Second Street, Wormleysburg, PA 17043, which is the subject of this action in mortgage
foreclosure.
T" (ANVY F Recom
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-01434 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
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
(+DVVNT VV1VTTVrrW nun V TMTWTW T+ CIRP.P.N but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
NOT FOUND , as to
the within named DEFENDANT GREEN KENNETH AKA KENNETH E
GREEN
209 1/2 SOUTH SECOND STREET
WORMLEYSBURG, PA 17043
ALTHOUGH NUMEROUS ATTEMPTS WERE MADE
WE WERE UNABLE TO SERVE DEFENDANT.
Sheriff's Costs: So answers:
Docketing 18.0 0
Service 42.24
Not Found 5.00 R. Thomas .,Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
75.24 ? SHAPIRO & KREISMAN
12/04/2006
Sworn and Subscribed to before
me this day of
A. D.
I
SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT NO:06-1434
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $75,661.48 in favor of the Plaintiff and against
the defendant for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure
within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as
stated in the Complaint:
Principal of mortgage debt due and unpaid $66,127.70
Interest at 5.375% from October 1, 2005 to
February 6, 2007 (494 days @ $9.75 per diem) $4,816.50
Late charges $14.99
Escrow Advance $795.90
Appraisal Fees `?, $350.00
Title Search Report Fees $250.00
Attorneys Fees $3,306.39
TOTAL AMOUNT DUE -5%66l .48
`Lain & W. Tabassquire
Attorney for Plaintiff
AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant and
damages are assessed as above in the sum of $75,661.48.
06-26302
ro. Prothy.
SHAPIRO & KREISMAN, LLC
BY: KEVIN DISKIN, ESQ.,
JOSEPH REJENT, ESQ.,
AND ILANA ZION, ESQ.
ATTORNEY I.D. NOS. 86727, 59621 & 87137
2520 RENAISSANCE BLVD., SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
DEFENDANT(S)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO:
STATE OF: M/\?
COUNTY OF: L k.o ? (^
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she is over the age of
eighteen years and competent to make this affidavit and the following averments are
based upon investigations made and records maintained either as Plaintiff or servicing
agent of the Plaintiff and that the above-captioned Defendants' last known address is as
set forth in the caption and they are not in the Military or Naval Service of the United
States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended. I /"
Washington Myfual Bank, F.
By:
NAME: (, , wee G /o p
TITLE:
Sworn to and subscribed before me this
of
Notary Public
06-26302
JAME•:R C. MORRIS
NOTARY PUBLIC-MINNESOTA
MY' COMMISSION
"? E.X01RFSJAN 31,
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
NO: 06-1434
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Kenneth Green a/k/a Kenneth E. Green
DATE OF NOTICE: January 26, 2007
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
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTIFICACION IWORTANTE
Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte
en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha
de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar
preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos
importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene
abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a
la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir
assitencia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
cN-?
Ilana Zion, Esquire
Shapiro & Kreisman,
Attorney for Plaintiff
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Kenneth Green a/k/a Kenneth E. Green
DATE OF NOTICE: January 26, 2007
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
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTMCACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte
en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha
de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar
preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos
importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene
abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a
la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir
assitencia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Kenneth Green a/k/a Kenneth E. Green
-209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
. '
Ilana Zion, Esquire /
Shapiro & Kreisman,
Attorney for Plaintiff
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS ;
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe
for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their
attorney of record, if any, after the default occurred and at least (10) days prior to the date of
the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice
attached hereto, January 26, 2007 to the following Defendants:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
Angela D'Antonio, Legal Assistant
to Ilana Zion, Esquire for
Shapiro & Kreisman, LLC
SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
CERTIFICATE OF SERVICE
I, Lauren R. Tabas, Esquire, Attorney for the Plaintiff, hereby certify that I have served
by first class mail, postage prepaid, true and correct copies of the attached papers upon the
following person or their attorney of record:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Date mailed: -
06-26302
Attorney for Plaintiff
SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
and that the last known addresses of the judgment debtor (Defendant) is:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Bpi:
& KREISMAN, rLLC
L/aurdn R. Tabas, Esquire
Attorney for Plaintiff
06-26302
QS
i
"rl
W
?.f
O
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Curtis R. Long
Prothonotary
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Washington Mutual Bank, FA
PLAINTIFF
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
0
urtis R. Lo
Prothonot ry
[XX] Judgment by Default
[ ] Judgment for Possession
[ ] Judgment on Award of Arbitration
[ ] Judgment on Verdict
[ ] Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LAUREN R. TABAS, ESQUIRE AT (610) 278-6800.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Curtis R. Long
Prothonotary
TO: Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
Curtis R. Lo
Prothonotary
[XX] Judgment by Default
[ ] Judgment for Possession
[ ] Judgment on Award of Arbitration
] Judgment on Verdict
[ ] Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LAUREN R. TABAS, ESQUIRE AT (610) 278-6800.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Washington Mutual Bank, FA
PLAINTIFF
vs
() Confessed Judgment
() Other
File No. Q(. - 14W
Amount Due $75,661.48
Interest February 7, 2007 to June 13, 2007
is $1,414.78
Atty's Comm
Costs
Kenneth Green aWa Kenneth E. Green
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s)
defendant(s) described in the attached exhibit. .
Date:
Sign?tu
Print
Address
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 93337
3600 Horizon Drive, Ste. 150
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ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1434 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From KENNETH GREEN A/K/A KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $75,661.48
Interest 2/7/07 TO 6/13/07 IS $1,414.78
Atty's Comm %
Atty Paid $324.56
Plaintiff Paid
Date: FEBRUARY 6, 2007
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curt' R. Long, Pr notaryBy:
REQUESTING PARTY:
Name LAUREN R. TABAS, ESQUIRE
Address: 3600 HORIZON DRIVE, STE. 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Deputy
Supreme Court ID No. 93337
SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
NO: 06-1434
AFFIDAVIT PURSUANT TO RULE 3129.1
Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1/2 South Second Street, Wormleysburg, PA 17043.
Name and addresses of Owner or Reputed Owner
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
2. Name and addresses of Defendant in the judgment:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
4. Name and address of the last recorded holder of every mortgage of record:
Washington Mutual Bank, FA, Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
NONE
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wormleysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
KREISMAN,
R. Tab-as, Esquire
06-26302
?
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SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Your house (real estate) at:
209 1/2 South Second Street, Wormleysburg, PA 17043
47-20-1858-165
is scheduled to be sold at Sheriffs Sale on June 13, 2007 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at I0:00am, to enforce the court judgment of $75,661.48 obtained by Washington Mutual Bank,
FA against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be cancelled if you pay back to Washington Mutual Bank, FA the amount
of the judgment plus costs or the back payments, late charges, costs, and reasonable
attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610) 278-6800.
5. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer.
At that time, the buyer may bring legal proceedings to evict you.
9. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty (30) days from the date of the sale. This schedule will state who will be receiving
the money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the date of filing of said schedule.
10. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
06-26302
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1l2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
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SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
DEFENDANTS
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that she is a legal assistant for Plaintiff in the above case
and that pursuant to the attached Court Order she has mailed a true and correct copy of the
Notice of Sale in the above-captioned case to Defendant by certified and regular mail, to the last
known addresses as follows: 209 1/2 South Second Street, Wormleysburg, PA 17043 and 6
Adams Street, Enola, PA 17025 on March 20, 2007 as evidenced by the receipts of mailing
attached hereto and made a part hereof.
I verify that the statements made herein are true and correct and I understand that false
statements made herein are subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating
to unsworn falsification to authorities.
DATED:
SHAPIRO & KREISMAN, LLC
BY: add
Heather Whitman
Legal Assistant
06-26302
DEC 16 2wy?
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
C?OP17
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
ORDER
AND NOW, this -L?-, day of _, 2006 upon consideration of Plaintiff's
Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith
Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage
Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on
the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and
correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent
pleadings by certified mail and regular mail to the last known addresses of the Defendant,
Kenneth Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street,
Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025, and the Sheriff, Marshal or
other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of
Sale or said subsequent pleading on the most public part of the property located at 209 1/2 South
Second Street, Wormleysburg, PA 17043, which is the subject of this action in mortgage
foreclosure.
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
Sha iro and Kreisman LLC ' ~ `u7
3600 Horizon Drive Ste. 150
King Of Prussia, PA 19406
One piece of ordinary mall addressed to:
Kennet, Green a/k/a Kenneth E Green
6 Adams Street
Enola, PA 17025
PS Form 3817, January 2001
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Shapiro and Kreisman LLC
3600 Horizon Drive Ste. 150M
King Of Prussia, PA 19406
One piece of ordinary mail addressed to:
Kenneth Green a/k/a Kenneth E green
209 1/2 South Second Street
Wormle r PA 17043
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SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
Kenneth Green aWa Kenneth E. Green
DEFENDANT(S)
CERTIFICATION OF NOTICE TO LIENHOLDERS
PURSUANT TO PA R.C.P 3129.2 (C) (2)
I, Heather Whitman, Legal Assistant for Shapiro & Kreisman, LLC, attorneys for the
Plaintiff, Washington Mutual Bank, FA, hereby certify that Notice of Sale was served on all
persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage
prepaid, with Certificates of Mailing on March 20, 2007, the originals of which are attached and
that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1.
The undersigned understands that the statements herein are subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
SHAPIRO & KREISMAN, LLC
BY: ?at? 1 Jt
Heather Whitman
Legal Assistant
06-26302
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01434 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WASHINGTON MUTUAL BANK FA
VS
GREEN KENNETH AKA KENNETH E GR
SHAWN HARRISON
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
GREEN KENNETH AKA KENNETH E GREEN the
DEFENDANT , at 1723:00 HOURS, on the 28th day of December-, 2006
at 209 1/2 SOUTH SECOND STREET
WORMLEYSBURG, PA 17043
PROPERTY POSTED AT 209 1/2
by handing to
S SECOND STREET WORMLEYSBURG
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 18.00
Service 14.08
Posting 6.00
Surcharge 10.00
.00
j/lF (c -7 ? 4 8 . 0 8
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
01/02/2007
SHAPIRO & KRE C,
By.
eput Sheriff
A.D.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WASHINGTON MUTUAL BANK, FA,
Plaintiff,
V.
KENNETH E. GREEN
Defendant.
CIVIL ACTION - LAW
No. 2006-1434
MORTGAGE FORECLOSURE
SUGGESTION OF BANKRUPTCY
COMES NOW the Defendant, Kenneth E. Green through his undersigned
attorneys, Gates, Halbruner & Hatch, and would show the Court:
1. Dale and Amber Wolfgang have filed a petition for relief under Title 11, United
States Code, in the United States Bankruptcy Court for the Middle District of Pennsylvania,
which bears the case number 1:07-bk-01796.
2. Relief was ordered on June 12, 2007.
3. This action is founded on a claim from which a discharge would be a release or
that seeks to impose a charge on the property of the estate.
4. This is for informational purposes only, and does not constitute a notice of
appearance by the undersigned.
WHEREFORE, the defendants suggests that this action has been stayed by the operation
of 11 U.S.C. § 362.
Respectfully Submitted,
GATES, HALBRUNER & HATCH, PC
Sarah E. McCarroll, Esquire
Attorney ID No. 91102
Gates, Halbruner & Hatch, PC
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
(717) 731-9600
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SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
NO: 06-1434
SUGGESTION OF BANKRUPTCY
TO THE PROTHONOTARY:
It is hereby suggested of record that Kenneth Green a/k/a Kenneth E. Green Defendant(s)
in the above captioned case has filed a Chapter 13 bankruptcy under case number 07-01796 on
June 12, 2007, in the Middle District of Pennsylvania and the above captioned Action in
Mortgage Foreclosure is accordingly stayed
pendency of the Bankruptcy.
BY:
Lauren R. Tabas, Esquire
Attorney for Plaintiff
C°7 ~'
Washington Mutual Bank, FA In The Court of Common Pleas of
VS Cumberland County, Pennsylvania
Kenneth Green a/k/a Writ No. 2006-1434 Civil Term
Kenneth E. Green
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on
March 19, 2007 at 1609 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant to wit: Kenneth Green
a/k/a Kenneth E. Green, by posting the premises located at 209 1/2 South Second Street,
Wormleysburg, Cumberland County, Pennsylvania, pursuant to order of court, with the said true
and correct copy of the same.
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April
12, 2007 at 0956 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and
Description, in the above entitled action, upon the property of Kenneth Green a/k/a Kenneth E.
Green, at 209 1/2 South Second Street, Wormleysburg, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Kenneth Green
a/k/a Kenneth E. Green, by regular mail to his last known address of 209 1/2 South Second Street,
Wormleysburg, PA 17043. This letter was mailed under the date of April 03, 2007 and never
returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of request from Attorney Lauren Tabas.
Sheriff's Costs:
Docketing $30.00
Poundage 16.85
Posting Handbills 15.00
Advertising 15.00
Law Library .50
Prothonotary 1.00
Mileage 30.72
Levy 15.00
Surcharge 20.00
Posting 6.00
Law Journal 355.00
Patriot News 297.89
Share of bills 16.17
Postpone Sale 40.00
$ 859.13
So Answers:
R. Thomas Kline, eriff 1.60 A
0 LOO too
Byj tv , I CA
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Real Estate ergeant
. HAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
AFFIDAVIT PURSUANT TO RULE 3129.1
Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1/2 South Second Street, Wormleysburg, PA 17043.
1. Name and addresses of Owner or Reputed Owner
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
2. Name and addresses of Defendant in the judgment:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
4. Name and address of the last recorded holder of every mortgage of record:
Washington Mutual Bank, FA, Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
NONE
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wormleysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
KREISMAN,
B
R. Tali-as, Esquire
06-26302
4'
A
SHAPIRO & KREISMAN, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
VS.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Your house (real estate) at:
209 1/2 South Second Street, Wormleysburg, PA 17043
47-20-1858-165
is scheduled to be sold at Sheriffs Sale on June 13, 2007 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at I0:00am, to enforce the court judgment of $75,661.48 obtained by Washington Mutual Bank,
FA against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to Washington Mutual Bank, FA the amount
of the judgment plus costs or the back payments, late charges, costs, and reasonable
attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
16
V
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610) 278-6800.
5. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
8. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer.
At that time, the buyer may bring legal proceedings to evict you.
9. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty (30) days from the date of the sale. This schedule will state who will be receiving
the money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the date of filing of said schedule.
10. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
06-26302
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast comer of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-1434 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From KENNETH GREEN A/K/A KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $75,661.48
Interest 2/7/07 TO 6/13/07 IS $1,414.78
Atty's Comm %
Atty Paid $324.56
Plaintiff Paid
Date: FEBRUARY 6, 2007
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curti R. Long, Pr otary
By:
Deputy
REQUESTING PARTY:
Name LAUREN R. TABAS, ESQUIRE
Address: 3600 HORIZON DRIVE, STE. 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 93337
06 "1
Real Estate Sale # 59
On March 7, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
Wormleysburg Borough, Cumberland County, PA
Known and numbered as 209 '/2 South Second Street,
Wormleysburg, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: March 7, 2007 By:
d
Real Es a Sergeant
ZZ c? S) 93.E Lou
I
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Shannon D. Billhime, being duly sworn according to law, deposes and says:
That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the
2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE#59
;j2i6e00 ........... .......
Sworn to and subscribed before me this 18th day of May 2007 A.D.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Terry L Russell, Notary Public
City Of Harrisburg, Dauphin County
Co i sion Expires June 6, 2010
mber, a svlvania Association of Notaries
A
NOT AY P BLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 20, 27 & May 4, 2007
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
r
is arie Coyne, E for
SWORN TO AND SUBSCRIBED before me this
__.4day of May, 2007
1'...
WAAL XWTAXZ W A& 100. SY
Writ No. 2006-1434 Civil
Washington Mutual Bank, FA
vs.
Kenneth Green a/k/a
Kenneth E. Green
Atty.: Lauren Tabas
ALL THAT CERTAIN tract or Par-
cel of land and premises, situate,
lying and being in the Borough of
Wormleysburg in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly de-
scribed as follows:
BEGINNING at a point on Sec-
ond Street, said point being Eighty-
Two (82) feet from the Northeast
comer of South Second Street and
Third Avenue; THENCE along the
line of South Second Street, North
43 degrees West Seventeen and
Nine Tenths (17.9) feet to the cen-
ter of a party wall; THENCE along
said party wall, North 47 degrees
East One Hundred Five (105) feet
to a point; THENCE South 43 de-
grees East Seventeen and Nine
Tenths (17.9) feet to a point;
THENCE along the said line of land,
South 47 degrees West One Hun-
dred Five (105) feet to the Point and
Place of Beginning.
HAVING THEREON ERECTED a
two story frame dwelling house
known and numbered as 209 1 /2
Second Street, Wormieysburg, Penn-
sylvania.
BEING THE SAME PREMISES
which Clinton Archer and Evelyn
Archer, husband and wife, by Deed
dated April 30, 2002, and recorded
in the Cumberland County Recorder
of Deeds Office on May 03, 2002,
in Deed Book 251, Page 2854,
granted and conveyed unto Kenneth
E. Green, single.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption
Washington Mutual Bank, FA
PLAINTIFF
VS
() Confessed Judgment
() Other
File No. 0(0- 1 134
Amount Due $75,661.48
Interest February 7, 2007 to March 4, 2009
is $8,432.98
Atty's Comm
Costs
Kenneth Green a/k1a Kenneth E. Green
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment agai,ist the above-named garnishee(s) for the following property (if real
estate, supply six copies, of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this wr'41 against the garnishee(s) as a lis pendens again Teal estate of the
: ? J
defendant(s) described in the attached exhibit. ?? s '
Date: a 68 _ Signature
Print Name: Michael J. lark, Esquire
Address: 3600 Horizon Drive, Ste. 150
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 202929
p IM? p ?„$
:, s
17
DEC If an yi
SHAPIRO & KREISMAN, LLC
BY: ILANA ZION
ATTORNEY I. D. NO: PA Bar # 87137
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
Kenneth Green alk/a Kenneth E. Green
DEFENDANT
GOO P?(
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
ORDER
AND NOW, this _L?__, day of 2006 upon consideration of Plaintiffs
Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith
Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage
Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on
the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and
correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent
pleadings by certified mail and regular mail to the last known addresses of the Defendant,
Kenneth Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street,
Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025, and the Sheriff, Marshal or
other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of
Sale or said subsequent pleading on the most public part of the property located at 209 1/2 South
Second Street, Wormleysburg, PA 17043, which is the subject of this action in mortgage
foreclosure.
?CAVY ?+M
to . -" a+" Pt I .w BY THE COURT:
r OM ' i two "(ft let nw ho°
C of said
J.
l
?--O630Z
UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
In re: Kenneth Edward Green,
Debtor.
Wells Fargo Bank, N.A.,
Movant,
V.
Kenneth Edward Green,
Debtor,
and
Charles J. DeHart III, Trustee,
Additional Respondent.
CHAPTER 13
BANKRUPTCY CASE NUMBER
1-07-bk-01796 RNO
ORDER
AND NOW, after notice to all required parties and certification of default under the
terms of this Court's Order of March 13, 2008 it is
ORDERED AND DECREED that the Automatic Stay of all proceedings, as provided
under section 362 of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005
(The Code) 11, U.S.C. 362, is lifted to allow Movant to proceed with, or to resume proceedings
in Mortgage Foreclosure, including, but not limited to Sheriffs or Marshal's Sale of 209 1/2
South Second Street, Wormleysburg, PA 17043 (the "Mortgaged Premises"); and to take action,
by suit or otherwise as permitted by law, in its own name or the names of its assignee, to obtain
possession of the Mortgaged Premises.
Dated: August 29, 2008
6" U. gitpV
Robert N. t 19 Abp ky 3odgc
This document is e(ectromcatty signed and filed on the same date. (on
Case 1:07-bk-01796-RNO Doc 71 Filed 08/29/08 Entered 09102/0807:33:13 Desc
Main Document Page 1 of 1
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I hereby certify that I am the Attorney of record for the Plaintiff in this Action against
Real Property and further certify this Property is:
FHA - Tenant Occupied or Vacant
Commercial
As a result of a Complaint in Assumpsit
That the Plaintiff has complied in all respects with Section 403 of the
X Mortgage Assistance Act including but not limited to:
(a, Service of notice on Defendant(s)
(b) Expiration of 30 days since the service of notice
(c) Defendant(s) failure to request or appear at meeting with Mortgagee or
Consumer Credit Counseling Agency
(d) Defendant(s) failure to file application with Homeowners Emergency
Assistance Program.
I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any
false statement given herein.
SHAPIRO & DENARDO, LLC
BY: A?L ? (' 4
MI HAEL J. CL , Esquire
PA Bar # 202929
C?
t? c
°
?
:
r N
??;
-?: ? at ``
" ?3 ,t
_ C";.
.?^ ?- r... ? rr
.. ?.?„
G "?
.?-, to
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT
AFFIDAVIT PURSUANT TO RULE 3129.1
Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1 /2 South Second Street, Wormleysburg, PA 17043.
Name and addresses of Owner or Reputed Owner
Kenneth Green a/k/a Kenneth E. Green
209 1/2 S:,uth Second Street
WormleN sburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
r•.,iola, PA 17025
2. Name and addresses of Defendant in the judgment:
Kenneth Green aik/a Kenneth E. Green
209 1 /2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
,.-., •
4. Name and address of the last recorded holder of every mortgage of record:
Washington Mutual Bank, FA, Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
Name and address of every other person who has any record lien on the property:
NONE
6. ' Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1 /2 South Second Street
Wormleysburg, PA 17043
t verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO & DENARDO, LLC
1 r
BY:
MICHAEL J. CLA , squire
06-26302
n C5 0
C-) crt
. 1
;..
, Q tZtr'
_
N) CJ
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Your house (real estate) at:
209 1/2 South Second Street, Wormleysburg, PA 17043
47-20-1858-165
is scheduled to be sold at Sheriffs Sale on March 4, 2009 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at i 0:00am, to enforce the court judgment of $75,661.48 obtained by Washington Mutual Bank,
FA against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
i . The sale will be cancelled if you pay back to Washington Mutual Bank, FA the amount
of the judgment plus costs or the back payments, late charges, costs, and reasonable
attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Courtto
postpone the sale for good cause.
You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610) 278-6800.
You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buffer.
At that time, the buyer may bring legal proceedings to evict you.
9. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty (30) days from the date of the sale. This schedule will state who will be receiving
the money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the date of filing of said schedule.
10. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
06-26302
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1434 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From KENNETH GREEN a/k/a KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $75,661.48 L.L.
Interest from 2/07/07 to 3/04/09 is -- $8,432.98
Atty's Comm % Due Prothy $2.00
Atty Paid $1,205.19 Other Costs
Plaintiff Paid
Date: 9/29/08
rothono
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL J. CLARK, ESQUIRE
Address: SHAPIRO & KREISMAN, LLC
3600 HORIZON DRIVE, STE.150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 202929
Deputy
J ~
e
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs. ;
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1/2 South Second Street, Wormleysburg, PA 17043.
Name and addresses of Owner or Reputed Owner
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
2. Name and addresses of Defendant in the judgment:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
4. Name and address of the last recorded holder of every mortgage of record:
Washington Mutual Bank, FA, Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wormleysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO & DENARDO, LLC
BY:
MICHAEL 7Esquire
06-26302
r-3? 0
i
SHAPIRO & DeNARDO, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & D FILE NO. 06-26302
Washington Mutual Bank, FA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
NO: 06-1434
DEFENDANTS
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that she is a legal assistant for Plaintiff in the above case
and that pursuant to the attached Court Order she has mailed a true and correct copy of the
Notice of Sale in the above-captioned case to Defendant(s) by certified and regular mail, to the
last known address of said Defendant(s) as follows: Kenneth Green a/k/a Kenneth E. Green, 209
1/2 South Second Street, Wormleysburg, PA 17043 on October 20, 2008 as evidenced by the
receipts of mailing attached hereto and made a part hereof.
I verify that the statements made herein are true and correct and I understand that false
statements made herein are subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating
to unsworn falsif/i}cation to authorities.
DATED: gl
SHAPIRO & DENARDO, LLC
BY:
Lisa Kosik
Legal Assistant
06-26302
m (Domestic Only; ? Insurance Coverage Prowdej
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3600 Horizon Drive Ste. 150
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SHAPIRO & DeNARDO, LLC
BY: LAUREN R. TABAS, ESQUIRE
ATTORNEY I.D. NO: PA Bar #93337
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & D FILE NO. 06-26302
Washington Mutual Bank, FA
PLAINTIFF
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
NO: 06-1434
CERTIFICATION OF NOTICE TO LIENHOLDERS
PURSUANT TO PA R.C.P 3129.2 (C) (2)
I, Lisa Kosik, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff,
Washington Mutual Bank, FA, hereby certify that Notice of Sale was served on all persons
appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid,
with Certificates of Mailing on January 23, 2008, the originals of which are attached and that
each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1.
The undersigned understands that the statements herein are subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
SHAPIRO & DENARDO, LLC
BY: '4 el&l
Lisa Kosik
Legal Assistant
06-26302
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SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # Attorney I.D. No
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
S & D FILE NO. 06-26302
Washington Mutual Bank, N.A
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
202929
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
PRAECIPE TO MARK THE JUDGMENT TO THE USE OF WELLS FARGO BANK. NA
TO THE PROTHONOTARY:
Kindly mark the judgment in the above-captioned matter to the use of "Wells Fargo
Bank, NA" as the real party/Plaintiff in interest in this action and the holder of the Note and
Mortgage.
SHAPIRO & DENARDO, LLC
BY:
Michael J. Clark, Esquire
DATED: March 3, 2009
J(
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # Attorney I.D. No
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
S & D FILE NO. 06-26302
Washington Mutual Bank, N.A
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
202929
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
CERTIFICATION
I hereby certify that I have served a true and correct copy of this Praecipe to Mark
Judgme t o the Use of WELLS FARGO BANK, NA and the papers attached thereto on
to all parties named herein at their last known address or upon their attorney of
record as below listed by regular mail, postage prepaid:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Dated: 4r
SHAPIRO & DENARDO, LLC
BY: V-" V ?-
Michael J. lark, Esquire
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Washington Mutual Bank, FA
VS
Kenneth Green a/k/a Kenneth E. Green
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2006-1434 Civil Term
Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on
November 20, 2008 at 1840 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Kenneth Green
a/k/a Kenneth E. Green, by posting the premises located at 209 1/2 South Second Street,
Wormleysburg, Cumberland County, Pennsylvania with the said true and correct copy of the same,
according to law.
Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January
06, 2009 at 1600 hrs, he served a true copy of the within Real Estate Writ, Notice of Sale and
Description, in the above entitled action, upon the within named defendant, wit: Kenneth Green
a/k/a Kenneth E. Green, by making known unto Kenneth Green personally at 209 1/2 South Second
Street, Wormleysburg, Cumberland County, Pennsylvania, its contents and at the same time
handing to him personally the said true and correct copy of the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on
January 12, 2009 at 1612 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Kenneth Green a/k/a Kenneth E.
Green located at 209 1/2 South Second Street, Wormleysburg, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Kenneth Green
a/k/a Kenneth E. Green, by regular mail to his last known address of 209 1/2 South Second Street,
Wormleysburg, PA 17043. This letter was mailed under the date of January 9, 2009 and never
returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED.
Sheriff s Costs:
Docketing 30.00
Poundage 18.12
Posting Bills 15.00
Advertising 15.00
Law Library .50
Prothonotary 2.00
Mileage 57.60
Levy 15.00
Surcharge 20.00
Posting 6.00
Postpone sale 40.00
Law Journal
patriot News
Share of bills
So Answers:
R. Thomas Kline, 5henff
Y?Y
Real Estate coordinator
355.00
334.58
15.52
924.32
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SHAPIRO & DENARDO, LLC
BY: MICHAEL, J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HOI IZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANT ;
AFFIDAVIT PURSUANT TO RULE 3129.1
Washington Mutual Bank, FA, Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1 /2 South Second Street, Wormleysburg, PA 17043.
Name and addresses of Owner or Reputed Owner
Kenneth Green a/k/a Kenneth E. Green
209 1/2 S,uth Second Street
WormleN sburg, PA 17043
Kenneth Green aik/a Kenneth E. Green
6 Adams St.
r nola, PA 17025
2. Name and addresses of Defendant in the judgment:
Kenneth Green aik/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Washington Mutual Bank, FA
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
4. Name and address of the last recorded holder of every mortgage of record:
Washington Mutual Bank, FA, Plaintiff
1210 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
NONE
6. ' Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wornileysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO & DENARDO, LLC
i
1 ?s
BY:
MICHAEL J. CLA squire
06-26302
SHAPIRO & DENARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs. ;
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANTS ;
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
6 Adams St.
Enola, PA 17025
Your house (real estate) at:
209 1 /2 South Second Street, Wormleysburg, PA 17043
47-20-1858-165
is scheduled to be sold at Sheriffs Sale on March 4, 2009 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00am, to enforce the court judgment of $75,661.48 obtained by Washington Mutual Bank,
FA against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to Washington Mutual Bank, FA the amount
of the judgment plus costs or the back payments, late charges, costs, and reasonable
attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800.
You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find,out the price bid by calling (610) 278-6800.
You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390 .
7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
8. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer.
At that time, the buyer may bring legal proceedings to evict you.
9. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty (30) days from the date of the sale. This schedule will state who will be receiving
the money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten () 0) days after the date of filing of said schedule.
10. You ma} also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOIJ SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
06-26302
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
4
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002,. in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-1434 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To latisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff (s)
From KENNETH GREEN a/k/a KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $75,661.48 L.L.
Interest from 2/07/07 to 3/04/09 is -- $8,432.98
Atty's Comm % Due Prothy $2.00
Atty Paid $1,205.19 Other Costs
Plaintiff Paid
Date: 9/29/08
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name: MICHAEL J. CLARK, ESQUIRE
Address: SHAPIRO & KREISMAN, LLC
3600 HORIZON DRIVE, STE. 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 202929
Real Estate Sale #45
On November 14, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Wormleysburg Borough, Cumberland County, PA
Known and numbered as 209 1/2 South Second St., Wormleysburg
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated. herein.
Date: November 14, 2008 By:
b
Real Este er er
g
L0:E d 0Ed3Sow
ltd `,kjNjjGJ i dla:i
-44143149 3HI j0 30uj0
L
TIP Patriot-News Co.
812 Market St.
Harrisburg, PQ 17101
Inquiries - 717-255-8213
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
ZhePatriot-News
Now you know
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Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
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newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid. that
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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
REAL ESTATE SALE NO. 45
Writ No. 2006-1434 Civil Term
Washington Mutual Bank, FA
VS
Kenneth Green a/k/a Kenneth E.
Green
Attorney Michael Clark
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land
and premises, situate, lying and being in the
Borough of Womtleysburg in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly described as
follows:
BEGINNING at a point on Second Street, said
point being Eighty-Two (82) feet from the
Northeast comer of South Second Street and
Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen
and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall.
North 47 degrees East One Hundred Five (105)
feet to a point; THENCE South 43 degrees East
Seventeen and Nine Tenths (17.9) feet to a point:
THENCE along the said line of land, South 47
degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story
frame dwelling house known and numbered as
209 1/2 Second Street, Wormleysburg.
Pennsylvania.
BEING THE SAME PREMISES which Clinton
Archer and Evelyn Archer, husband and wife. by
Deed dated April 30, 2002, and recorded in the
Cumberland County Recorder of Deeds Office
on May 03, 2002, in Deed Book 251, Page 2854.
granted and conveyed unto Kenneth E. Green.
single.
This ad ran on the date(s) shown below:
01/21/09
01128/09
02/04/09
........... ..........
Sworn to and &bscribed before me this 25 day of February, 2009 A.D.
Notary Public
vl?
SheR101 . f':i;:,, ,;tiyPUUIC {
Cky Of Harn ...
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"-_! moo"^• issi „i t, ;'r.:,hin County
9 1'10V.26,20111
Member, Pennsy-, i-rtun of Notules
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
. ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 30, February 6, and February 13, 2009
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.
y
?sa Marie Coyn V Editor
SWORN TO AND SUBSCRIBED before me this
13 day of Febru 13 2009
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My CommisSion Expires Apr 28, 2010
RX&L 99T&i 8" 90. 45
Writ No. 2006-1434 Civil
Washington Mutual Bank, FA
VS.
Kenneth Green a/k/a
Kenneth E. Green
Atty.: Michael Clark
ALL THAT CERTAIN tract or
Parcel of land and premises, situ-
ate, lying acid being in the Borough
of Wwva in the County of
Cumberland and Ca wealth
of PeansytVania, more particularly
described as .
Bgt3II! NIM at a paint on Second
Street, said point being Mighty-Two
(82) feet from the Northeast corner
of South Second Street and Third
Avenue; THENCE along the line
of South Second Street, North 43
degrees West Seventeen and Nine
Tenths (17.9) feet to the center of a
party wall; THENCE along said party
wall, North 47 degrees East One
Hundred Five (105) feet to a point;
THENCE South 43 degrees East Sev-
enteen and Nine Tenths (17.9) feet to
a point; THENCE along the said line
of land, South 47 degrees West One
Hundred Five (105) feet to the Point
and Place of Beginning.
HAVING THEREON ERECTED
a two story frame dwelling house
known and numbered as 209 1/2
Second Street, Wormleysburg, Penn-
sylvania.
BEING THE SAME PREMISES
which Clinton Archer and Evelyn
Archer, husband and wife, by Deed
dated April 30, 2002, and recorded
in the Cumberland County Recorder
of Deeds Office on May 03, 2002, in
Deed Book 251, pap 2854, granted
and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-1434 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. Plaintiff (s)
From KENNETH GREEN A/K/A KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the 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 $75,661.48
L.L.
Interest February 7, 2007 to December 9, 2009 is $11,552.18
Atty's Comm % Due Prothy $2.00
Atty Paid $2161.51
Plaintiff Paid
Date: 7/8/09
(Seal)
Other Costs
urtis R. Long, Protho otar
By:
REQUESTING PARTY:
Name: MICHAEL J. CLARK, ESQ.
Address: 3600 HORIZON DRIVE, STE. 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone:
Deputy
Supreme Court ID No. 202929
aj
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Caption:
Wells Fargo Bank, N.A.
PLAINTIFF
vs.
() Confessed Judgment
() Other
File No. (-o ly 3Lf
Amount Due $75,661.48
Interest February 7, 2007 to December 9,
2009 is $11,552.18
Atty's Comm
Costs
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) 'described in the attached exhibit.
Date: lD ! 2,y I U7 Signature:
Print Name: Michael . Clark Esquire
Address: 3600 Horizon Drive, Ste. 150
King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 202929
THE
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SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A.
PLAINTIFF
vs.
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT(S)
NO:06-1434
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
Wells Fargo Bank, N.A.W08
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
and that the last known address(es) of the judgment debtor (Defendant(s)) is:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Kenneth Green a/k/a Kenneth E. Green
6 Adams Street
Enola, PA 17025
SHAPIRO & DENARDO, LLC
BY:
Michael J. lark, Esquire
Attorney r Plaintiff
06-26302
TILE
OF TFr
2CO9 JUL -8 Phi 3: k 7
ti
SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A.
PLAINTIFF
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1/2 South Second Street, Wormleysburg, PA 17043.
Name and address of Owner(s) or Reputed Owner(s)
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
2. Name and address of Defendant(s) in the judgment:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Wells Fargo Bank, N.A.W08
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043
d
4. Name and address of the last recorded holder of every mortgage of record:
Wells Fargo Bank, N.A., Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wormleysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO & DENARDO, LLC
BY:
Michael J. Park, Esquire
06-26302
FILEC
01 TF;r c A
2OG9 ,'1" -8 Ph 3: 147
SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A. COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Your house (real estate) at: 209 1/2 South Second Street, Wormleysburg, PA 17043 is scheduled
to be sold at Sheriffs Sale on December 9, 2009 at I0:00am, in Cumberland County Sheriffs
Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $75,661.48
obtained by Wells Fargo Bank, N.A. (the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be cancelled if you pay back to the mortgagee the back payments, late charges,
costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:
(610) 278-6800.
You may be able to stop the sale by filing a petition asking the Court to strike or
open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
2. You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two of how
to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
If the Sheriffs Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling (610) 278-6800.
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 recorded only if the purchaser pays the Sheriff the full amount of
the bid. To find out if this has happened yet, you may call the Sheriff's Office at:
717-240-6390.
4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be
rescheduled.
5. You have a right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings, if necessary, to evict you.
6. You may be entitled to a share of the proceeds, which were paid for your house.
A proposed schedule of distribution of the money bid for your house will be
prepared by the Sheriff within thirty (30) days from the date of the sale. This
schedule will state who will be receiving the money. The money will be paid out
in accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the
posting of said schedule of distribution.
7. You may also have other rights and defenses or ways of getting your house back,
if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A
DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
06-26302
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
'ter ?•F{L riA7Y
2009 !U _3 P ? 3.4
cued,
SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A.
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
CERTIFICATION OF NOTICE TO LIENHOLDERS
PURSUANT TO PA R.C.P 3129.2 (C) (2)
I, Lisa Kosik, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff,
Wells Fargo Bank, N.A., hereby certify that Notice of Sale was served on all persons appearing
on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with
Certificates of Mailing on October 21, 2009, the originals of which are attached and that each of
said persons appears on Plaintiff s Affidavit pursuant to Pa. R.C.P. 3129.1.
The undersigned understands that the statements herein are subject to the penalties
provided by 18 P.S. Section 4904.
Respectfully submitted,
SHAPIRO & DeNARDO, LLC
BY: Y" "l M/''
Lisa Kosik
Legal Assistant
06-26302
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SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A.
PLAINTIFF
VS.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:06-1434
VERIFICATION OF SERVICE BY CERTIFIED MAIL AND
REGULAR MAIL PURSUANT TO COURT ORDER
The undersigned hereby verifies that she is a legal assistant for Plaintiff in the above case
and that pursuant to the attached Court Order she has mailed a true and correct copy of the
Notice of Sale in the above-captioned case to Defendant by certified and regular mail, to the last
known address of said Defendant as follows: Kenneth Green a/k/a Kenneth E. Green, 209 1/2
South Second Street, Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025 on July
20, 2009 as evidenced by the receipts of mailing attached hereto and made a part hereof.
I verify that the statements made herein are true and correct and I understand that false
statements made herein are subject to the penalties set forth in 18 Pa. C.S. Section 4904, relating
to unsworn falsification to authorities.
DATED: t 64
SHAPIRO & DeNARDO, LLC
BY: j i'?1Grd?
Lisa Kosik
Legal Assistant
06-26302
arc is Y(
SHAPIRO & KREISMAN, LLC
BY: ILANAZION ?
-y
Qo
ATTORNEY I.D. NO: PA Bar # 87137 u
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & K FILE NO. 06-26302
Washington Mutual Bank, FA COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
VS.
NO: 06-1434
Kenneth Green a/k/a Kenneth E. Green
DEFENDANT
ORDER
AND NOW, this _L?_, day of , 2006 upon consideration of Plaintiffs
Motion For Service Pursuant To Special Order of Court and the Affidavit of Good Faith
Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage
Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on
the Defendant, shall be complete when Plaintiff or its counsel or agent has mailed true and
correct copies of the, Complaint in Mortgage Foreclosure, Notice of Sale and all said subsequent
pleadings by certified mail and regular mail to the last known addresses of the Defendant,
Kenneth Green a/k/a Kenneth E. Green, only which are 209 1/2 South Second Street,
Wormleysburg, PA 17043 and 6 Adams Street, Enola, PA 17025, and the Sheriff, Marshal or
other appropriate party has posted a copy of the Complaint in Mortgage Foreclosure, Notice of
Sale or said subsequent pleading on the most public part of the property located at 209 1/2 South
Second Street, Wormleysburg, PA 17043, which is the subject of this action in mortgage
foreclosure.
T" LMY FROM
the ?. ! h A unto set WN ham,
s+" of saw C ' ;arlisle P
BY THE COURT:
pry , L _ 1 r
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING 1 Affix fee here in stamps
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From; 1 (3 i"i
Shapiro and Kreisman LLC
3600 Horizon Drive Ste 150
.
` 0202009"1
N
King Of Prussia, PA 19406
One piece of ordinary mail addressed to; D ID r\) UNIrFa
Kenneth Green a/k/a Kenneth
E reen S
6 Adams Street '
C) a
- nola, PA 17025
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PS Form 3817, January 2001 'Q
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U.S. POSTAL SERVICE CERTIFICATE OF MAILI
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D07°
PROVIDE FOR INSURANCE-POSTMASTER
Received From: x JUL Shapiro and Kreisman LLC Wo 2009
3600 Horizon Drive Ste. 150
King Of Prussia, PA 19406
One piece of ordinary mail addressed to:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
PS Form 3817, January 2001
(Domestic Mail C
' For delivery inform
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a?a?tt?nK ion SZ7??aQ ?uav?d 3g0 k2d
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
}?", p{ :"_?ilns,r 1FI
Jody S Smith '
Chief Deputy Zu i t"
Edward L Schorplp
Solicitor
Wells Fargo Bank
Case Number
vs.
Kenneth Green 2006-1434
SHERIFF'S RETURN OF SERVICE
09/24/2009 08:56 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09/24/09
at 2055 hours, he posted a I'rue copy of the within Real Estate Writ, Notice, Poster and Description, in the
above entitled action, upon the property of Kenneth Green, located at, 209 & 1/2 South Second Street,
Wormleysburg, Cumberland County, Pennsylvania according to law.
10/19/2009 06:25 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10/19/09 at
1825 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above
entitled action, upon the within named defendant, to wit: Kenneth Green, by posting the premises pusuant
to Court Order at: 209 & 1/2 South Second Street, Wormleysburg, Cumberland County, Pennsylvania, its
contents.
12/08/2009 Property sale postponed to 3/3/2010.
03/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Michael Clark on 3/2/10
SHERIFF COST: $741.44
March 05, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
i
SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A.
PLAINTIFF
vs.
Kenneth Green a/k/a Kenneth E. Green
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 06-1434
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth, as of the date the
praecipe for the writ of execution was filed, the following information concerning the real
property located at 209 1/2 South Second Street, Wormleysburg, PA 17043.
1. Name and address of Owner(s) or Reputed Owner(s)
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 1,7043
2. Name and address of Defendant(s) in the judgment:
Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Wells Fargo Bank, N.A.W08
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
Borough of Wormleysburg
20 Market Street
Wormleysburg, PA 17043
4. Name and address of the last recorded holder of every mortgage of record:
Wells Fargo Bank, N.A., Plaintiff
1270 Northland Drive, Suite 200
Mendota Heights, MN 55120
5. Name and address of every other person who has any record lien on the property:
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
209 1/2 South Second Street
Wormleysburg, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO & DENARDO, LLC
BY: V, ?
Michael J. lark, Esquire
06-26302
a
SHAPfRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-26302
Wells Fargo Bank, N.A. COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
vs.
Kenneth Green a/k/a Kenneth E. Green NO: 06-1434
DEFENDANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Kenneth Green a/k/a Kenneth E. Green
209 1/2 South Second Street
Wormleysburg, PA 17043
Your house (real estate) at: 209 1/2 South Second Street, Wormleysburg, PA 17043 is scheduled
to be sold at Sheriffs Sale on December 9, 2009 at 10:00am, in Cumberland County Sheriffs
Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $75,661.48
obtained by Wells Fargo Bank, N.A. (the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be cancelled if you pay back to the mortgagee the back payments, late charges,
costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:
(610) 278-6800.
You may be able to stop the sale by filing a petition asking the Court to strike or
open the judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
2. You may be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the
more chance you will have of stopping the sale. (See notice on page two of how
to obtain an attorney.)
YOU MAY STILI. BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
If the Sheriffs Sale is not stopped, your property will be sold to the highest
bidder. You may find out the price bid by calling (610) 278-6800.
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.
The sale will recorded only if the purchaser pays the Sheriff the full amount of
the bid. To find out if this has happened yet, you may call the Sheriff's Office at:
717-240-6390.
4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be
rescheduled.
You have a right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings, if necessary, to evict you.
6. You may be entitled to a share of the proceeds, which were paid for your house.
A proposed schedule of distribution of the money bid for your house will be
prepared by the Sheriff within thirty (30) days from the date of the sale. This
schedule will state who will be receiving the money. The money will be paid out
in accordance with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the
posting of said schedule of distribution.
7. You may also have other rights and defenses or ways of getting your house back,
if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A ]LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE, OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A
DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
06-26302
ALL TliAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described ,as follows:
BEGINNING at a point on Second Street, said point being Eighty-Two (82) feet from the
Northeast corner of South Second Street and Third Avenue; THENCE along the line of South
Second Street, North 43 degrees West Seventeen and Nine Tenths (17.9) feet to the center of a
party wall; THENCE along said party wall, North 47 degrees East One Hundred Five (105) feet
to a point; THENCE South 43 degrees East Seventeen and Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, South 47 degrees West One Hundred Five (105) feet to the
Point and Place of Beginning.
HAVING THEREON ERECTED a two story frame dwelling house known and numbered as 209
1/2 Second Street, Wormleysburg, Pennsylvania.
BEING THE SAME PREMISES which Clinton Archer and Evelyn Archer, husband and wife,
by Deed dated April 30, 2002, and recorded in the Cumberland County Recorder of Deeds
Office on May 03, 2002, in Deed Book 251, Page 2854, granted and conveyed unto Kenneth E.
Green, single.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) N006-1434 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. Plaintiff (s)
From KENNETH GREEN A/K/A KENNETH E. GREEN
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $75,661.48 L.L.
Interest February 7, 2007 to December 9, 2009 is $11,552.18
Atty's Comm % Due Prothy $2.00
Atty Paid $2161.51
Plaintiff Paid
Date: 7/8/09
(Seal)
Other Costs
Curtis R. Lo , ro honota
By:
Deputy
REQUESTING PARTY:
Name: MICHAEL J. CLARK, ESQ.
Address: 3600 HORIZON DRIVE, STE. 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone:
Supreme Court ID No. 202929
Real Estate Sale #
On August 19, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Borough of Wormleysburg, Cumberland County, PA
Known and numbered as, 209 & 1/2 South Second Street,
Wormleysburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: August 19, 2009
?Q???oo ??? JOY)
R Est't?"Crdinator
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 23, October 30 and November 6, 2009
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Marie Coyne, E itor
SW6YM TO AND SUBSCRIBED before me this
6 day of November, 2009
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
Writ No. 2006-1434 Civil
Wells Fargo Bank, N.A.
vs.
Kenneth Green,a/k/a
Kenneth E. Green
Atty: Michael J. Clark
ALL THAT CERTAIN tract or
Parcel of land and premises, situ-
ate, lying and being in the Borough
of Wormleysburg in the County of
Cumberland and Commonwealth
of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on Second
Street, said point being Eighty-Two
(82) feet from the Northeast corner
of South Second Street and Third
Avenue; THENCE along the line
of South Second Street, North 43
degrees West Seventeen and Nine
Tenths (17.9) feet to the center of a
party wall; THENCE along said party
wall. North 47 degrees East One
Hundred Five (105) feet to a point;
THENCE South 43 degrees East Sev-
enteen and Nine Tenths (17.9) feet to
a point; THENCE along the said line
of land, South 47 degrees West One
Hundred Five (105) feet to the Point
and Place of Beginning.
HAVING THEREON ERECTED
a two story frame dwelling house
known and numbered as 209 1/2
Second Street, Wormleysburg, Penn-
sylvania.
BEING THE SAME PREMISES
which Clinton Archer and Evelyn
Archer, husband and wife, by Deed
dated April 30, 2002, and recorded
in the Cumberland County Recorder
of Deeds Office on May 03, 2002, in
Deed Book 251, Page 2854, granted
and conveyed unto Kenneth E.
Green, single.
The Patriot-News Co.
8112 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
ZhePatriot News
Now you know
CUMBERLAND CO. SHERIFF=S OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
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
Leslie Kramer, being duly sworn according to law, deposes and says:
That she is a Staff Accountant 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 date(s) indicated below. That neither she 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 she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
10/23/09
10/30/09
sworn to and subscribed before me this 16 ay November, 2009 A.D.
\ (:
Notary Pubic
COMMONWEALTH Or PENNSYLVANIA
Notarial Seal
Sherrie L. Kisner, Notary Public
City Of Warrisiaurg. Dauphin County
d My Connmtsstori wirer Nov. 26, 2011
11/06/09
Member, Pennsylvania Association of Votaries
4M No. 2006.1484 CWN Term
W*ft POW 20t, N.A.
Va
KIM118 h Green, AAtt Kenneth E.
Given
Atty- Michael J. Clark
AIL THAT CERTAN tract or Parcel of land
aW ptednises, situate, lying and being in the
Bomuglr of Wormleysburg in the County of
Cumberland and Commonwealth of
l oosylvanw, more pudcularly described as
follows:.,
BEGONNO; 9 a point on Second. feet, said
paint being Eighty-Two (82) feet from the
Northeast corner of South Second Street- and
Third Ayenue; THENCE along the line of South
Second Sheet, Mod 43 degrees West Seventeen
and Nine. Tenths (17.9) feet to the antra of a
patty,waq; THENCE along said patty wall,
North 47 degrees East One A ndre8 Five (105)
feet to a point; THENCE South 43 degrees East
Seventeen aid Nine Tenths (17.9) feet to a point;
THENCE along the said line of land, south 47
degrees West One Hundred Five (105) feet to the
Point ad Place of Beginning..
HAVU40 THEtP.ON ERECTED a two story
frame dwelling house known and numbered as
209 1/2 Second Street, Wonnleysburg,
Pennsylvania.
Axbw of Bwfp Archer, hasisal it y
Dead iced Aim waif ?sMiatt in the
C rNa lagDeedswee
on May 03, 2002, in Deed Book 251, Page 2654,
granted and conveyed unto Kenneth E. Green,
single.