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HomeMy WebLinkAbout02-1847McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Washington Mutual Bank, FA 10790 Rancho Bernardo Road San Diego, CA 92127 V. Attorney for Plaintiff Cumberland County Court of Common Pleas Ronald L. Kuhn 15 West Springville Road Boiling Springs, PA 17007 and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Numberoa IPy7 CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE Avxso 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Ctu*LC- Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas an Las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a La corte an forma escrita sus defensas o sus objeciones a Las demandas an contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas Las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Washington Mutual Bank, FA 10790 Rancho Bernardo Road San Diego, CA 92127 V. Ronald L. Kuhn 15 West Springville Road Boiling Springs, PA 17007 and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Attorney for Plaintiff Cumberland County Court of Common Pleas Number oa _lPq7 C'6,C_ CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Washington Mutual Bank, FA, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Ronald L. Kuhn, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 15 West Springville Road, Boiling Springs, PA 17007. 3. The Defendant is Debra A. Kuhn, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 15 West Springville Road, Boiling Springs, PA 17007. 4. On 8/10/00, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Fremont Investment and Loan which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1633, Page 144. 5. The aforesaid mortgage was thereafter assigned by Fremont Investment and Loan to Washington Mutual Bank, FA, Plaintiff herein, by Assignment of Mortgage which will be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 15 West Springville Road, Boiling Springs, PA 17007. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance Interest 11/1/01 through 4/10/02 (Plus $28.51 per diem thereafter) Attorney's Fee Late Charges Corporate Advance NSF Cost of Suit Appraisal Fee Title Search $92,311.63 $ 4,561.60 $ 4,615.58 $ 321.18 $ 200.00 $ 40.00 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $102,599.99 9. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 10. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular and certified mail. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $102,599.99, together with interest at the rate of $28.51 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. TERRENCE J. Mc BE, ESQUIRE Attorney for P aintiff VERIFICATION The undersigned, Maria Severino, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. Maria Sever no Chase Manhattan Mtg 3/20/02 2:40 PAGE 10/57 087-802,003; 08T-89,Q;tIOjV-OQW i.iu? M ROD LO RuNOxr WN ONOW M116 TO' LOW LIM IMIrNf I Tmw a LOAN in N. NIVINVliv om F=d)1 1 4"4119-912 MORTGAGE IId ro?ae cNrwdt r.u,.r1. 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NM i. iR I ti?w it NA11?1m 82"b% A 041" LMOIrb l W 2.i?tlYlrw we-do"" ?WeeRZ ? wcww.rw Chase Manhattan Mtg 3/20/02 2:40 PAGE 16/57 087=602,003: 087 644'OO3YfO3a at.vr Ily vjjV 10 i7CCrOAl1 • „?j4„ L rrwi??A?f fart INr??y, ? 1??C1r?fl1? yam, r ii ¦ >tifwin?eww ow La 1. LwIR a?igr st p MMN ? ?tt?a?ll a 49 ttlM tl! MtrOtl Y ti'WE Xt tete Me -.... i I i i i t i ??NltNtl tApartl It1? Chase Manhattan Mtg 3/20/02 2:40 PAGE 18/57 087=602,003: 087roUdCgM,W4W ;::ur'FAA ?s 11o r?clpN! alit .__ a ? ROOM ? iw.r merit "'? ' Of UPW OF 02 !}yM K O b ¦r wA1Myy w?c"Laskood1?M? moo rpm* rq ¦ /mr/krllsedmob 4 r .o MOe'?rkkvmm gdar ae 4alw IL '06 ;m, I I Chase Manhattan Mtg 3/20/02 2:40 081.602-002: oar®ez,gtp.pOgU ' &iyq V ?- ' aooof to PAGE 20/57 FART 0 @oaa 1111 X on ow cm. Smom d4 b mom w "*WAN ow a! to Nan and d aim AWN4 hIM ??M1N? !?1 nM l Chase Manhattan Mtg 3/20/02 2:40 087=602-003: 087ifi0'XBQ3-9C?,', ;wy? VOy r11 410 PAGE 22/57 "4MONT + ...w WE ?.?rr Olw{ ?OOf 0101/ K 0O1?Oa ?o ae? SEA 1 "'a K OK rw Ian Q01O w ? ? y tldd m " wii? may. ?? -- 00 R §* "m a fain e ?,?ir M W1 ftw?iuO.? 1y?7w? ?I 1431 Chase Manhattan Mtg 3/20/02 2:40 087-602003: 087`6Q'j;QD3MjW::;w"rite rtlitfso PAGE 24/57 PIIiiw 4ow at ow or Ago* dew or pdr laAw?tiarphl""WWII 1idt? MOM ?Mt p1? 7; dY?O MM 0Mj00r11{ r?rw? N.`4.t Mle remit wr ?Ir swift bw om r ws p 34 ?Ma?i16,x."o"pMi s tNwiYe??l?iYltieMOo bwi•0bhire i? rirI M M11 MtrOrw? ff m w a0r ddmmlll1ll ounw 4hi mm" YIt11r ?Mtw¦r 0idy0urn? dl ?Yll?in?wi0! Md r0? id WrI M ft w ai w m v v w irda Vwwiw a it r ?? ?M10rnt ?' ldbmlm 1til?ltl e?MOMLS?Dw'd1?00t?ONf ?1fod?HlrrlwMl 1MwiN?m?llbf VAN" ,00! Chase Manhattan Mtg 3/20/02 2:40 PACE 26/57 087-602-003: 087d8m-ppj-wSW ii ur r" oil lso FAMW • tr Ialo x%Aw, yftml 0 m"" wd wp of *A wo ?k*wwwdkow ?.rl?11oae?w i .? bffi IN_n ** •1rom iiws . g:r , I N.RNV+ im-bri i,°w+aa?ie1ow111 Wbmnyiw lw Qa18161 ww . CO?i10MwRAt.tf{ a l?4gYLr C? cw* ??a '?r+a1r1 ?, uhrt au?d ?ebla./?. K??.hn PNEO _ Irrnmwa arc w lb wmsx w OM WAIF, NMVM d, M ft-own wM Ewa, Cp' A_- l? r f?/MI row ww I" am rdI'`r i w??? Chase Manhattan Mtg 3/20/02 2:40 PAGE 28/57 087-602;003: 087-'652.DM- f9F" "" ^" • . LICAL DESCRIPTION ATTACHMENT TO MORTGAGE ALL TKAT CeRTAfN t W Qf land wW tw kevrowwM. dwnon womd dluab on tlw North ddo of Road In SrA Mlddlelon Town". onow lmd Cow*. Panraylvanb, banded and IM, a draft Of WA SIMY bakq Hid MWWAd hw* byMrebrorms, as hlbMra w, on Jura 12, IIEfIMWNO at s *AM on Me Sautlwm Ikw of Township Road No. 537 kwelly known a ft Songvwa Road IN the Nwftm a n ow0 of land now or f8rmedy of R. Naolay, whldt sWo at ow Plow d Saolrtrart? Is WYS feat want of to aanbdlns of LaplNatlw Raub No. 3101A, No we from add able at 11110 Pk= d d e*m of 2112 ? ON We Of WHI OOW Iran P.l m of land Gmffi d R. 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T vgu rw dw aooaee pN?aeq tba d or li1p+??a apin.t dw dYe ibe C1egp Me NO? i?" ddw wlA drllrer ar MR to m a two ad my Am" 1n nd iae?ea? +au ahryr.'11,a eedw trill lmbtawtlan blibel to mtad.e +w dew wgeleld iow to b.? tae ad do as tl11e led nllp0la aubwota ya n vAo vM amwar o y gaadoaimy bm I "rpSee>tiodra 4"up l nrr?r• r ?Jr ?y sell Chase Manhattan Mtg 3/20/02 2:40 15ACE 36/57 087-602.003: 087-'BUZJQ2,9 3E6? 1ic11 lAL its 410 PUNT • lot? Of TIM PROPI 'P>< OR A i1EGWOSW. IIfIUifi'sP IN Dammam UAMM Onve t 17 dle siaowify boom w 4 mwM bmd i1"mv Tff.nrrdims sralaw wbMnitk111t-Wwm.Wtoor?grpdeE1, ?±4!r ? ?? ii 1010 ? tadla?d_(or !t a .Mo?(I?'?rt lriiws 1e ?e is CIn11Dy Lon* ewi at' no% r---- -- - r•- sr?r lmnedi?ee ?qt k !hl! d ill i_i p1WI11pr V fi eAloa 16111 eit 61 a1eMd ! It 4wieMo lqr w d dIw et iii il?ier Iid don see Isla i am 9 Iy scv er TO on pIaidold by a?,liwhil l .L M owdwp 9L some" in ma a 01id? bad i eOiMrt b 1011 Nam p". laldw do IS ? ? ?? ?ild1lfi ? ? io?il?iM Ii1A0db Od 0? SINEW OII11? 60 OO?M 10 pin do *Wm *NNW MA in *a Nm nd b Ob badgr dokumol. eI 1st l wd Uft ii New Ind wo sN4 r cw= wills 1/ bswYw ?gmI1I i• ?, LIIMte 1111 sita wN soy so of 'ibe s 010 p?p?yli a a0 aae 10w ?b 90 pa isoen it obb 1W 24*1 b ddiv 4 ae a" wi1Mt1 ywdU40 Iq an neelid M dd1 /IOOdI LisiaMw IrwonoNw?i to pq ? itonegr L Y ?re UPdw m "RAN ;= qpwn ?iwlP=W PM? r Chase Manhattan Mtg 3/20/02 2:40 PAGE 38/57 087-602-003, 08778M 41afu iiiu rA& H1It4 lJtglM goo& I BY =00 saWW, Imu.m NNOW eA to as "m Rod cowed 404"lnda4Adioaft 1?llder. =pip& Mau IIIMN L. ?. ? iaww 4k w ,lruwt ??e.rr aow? ?Nlr w.n tiro • • W eel C ?F fi 0 d a - t7 W °rJ to ? I Dt-3 499 Department of the Treasury - Internal Revenue Service Form 668 (Y)(c) (Rev. October 2000) Notice of Federal Tax Lien Area: Serial Number For Optional Use by Recording Office WAGE & INVESTMENT AREA #2 Lien Unit Phone: (800) 829-7650 230289597 1 As provided by section 6321, 6322, and 6323 of the Internal Revenue Code, we are giving a notice that taxes (including interest and penalties) (? G fi have been assessed against the following-named taxpayer. We have made a demand for payment of this liability, but it remains unpaid. Therefore, there is a lien in favor of the United States on all property and rights to property belonging to this taxpayer for the amount of these taxes and f-, , additional penalties, interest, and costs that may accrue. Name of Taxpayer ROBERT T SEEGER r Residence 210 RENO ST NEW CUMP, PA 17070-2047 - v, IMPORTANT RELEASE INFORMATION: For each assessment listed below - l" unless notice of the lien is refiled by the date given in column (e), this notice shall, , on the day following such date, operate as a certificate of release as defined in IRC 6325(a). Kind of Tax Tax Period Ending Identifying Number Date of Assessment Last Day for Refilling Unpaid Balance of Assessment (a) (b) (c) (d) (e) (f) 1040 12/31/1993 209-46-1896 11/10/1997 12/10/2007 4574.75 1040 12/31/1994 209-46-1896 11/10/1997 12/10/2007 19902.51 Place of Filing Prothonotary Cumberland County Carlisle, PA 17013 Total 1 $ 24477.26 This notice was prepared and signed at PITTSBURGH, PA , on this, the 17th day of May 2002 Signatu Title ACS 12-00-0000 for (800) 829-7650 (NOTE: Certificate of officer authorized by law t ke acknowledgment is not essential to the validity of Notice of Federal Tax lien Rev. Rul. 71-466, 1971 - 2 C.B. 409) Part 1 - Kept By Recording Office CAT. 668( (Rev. 10-0 CAT. NO 60025X X SHERIFF'S RETURN - REGULAR CASE NO: 2002-01847 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS KUHN RONALD L ET DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUHN RONALD L the 2002 DEFENDANT , at 2124:00 HOURS, on the 16th day of April , at 15 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007 RONALD L KUHN by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and subscribed to before me this /?? day of A. D. r thonotary So Answers: R. Thomas Kline 04/17/2002 MCCABE WEISBERG CONWAY By. ?oLLM g VSheriff SHERIFF'S RETURN - REGULAR ` CASE NO: 2002-01847 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK FA VS KUHN RONALD L ET AL DAWN KELL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KUHN DEBRA A the DEFENDANT , at 2124:00 HOURS, on the 16th day of April , 2002 at 15 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007 RONALD L KUHN by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 1?6? day of 0,0 a A. D. Prothonotary So Answers: R. Thomas Kline 04/17/2002 MCCABE WEISBERG CONWAY By: I? h2?? Deputy Sheriff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $102,599.99 Interest from 4/11/02-5/24/02 s 1,225.93 TOTAL $103,825.92 TERRENCE J. McC E, ESQUIRE AND NOW, this c v'-\ day of y , 2002, Judgment is entered in favor of Plaintiff, Washington Mutual Bank, FA, and against Defendants, Ronald L. Kuhn and Debra A. Kuhn, and damages are assessed in the amount of $103,825.92, plus interest and costs. BY THE PROTHONOTARY: ??1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Ronald L. Kuhn and Debra A. Kuhn, are over eighteen (18) years of age, and resides at 15 West Springville Road, Boiling Springs, PA 17007. SWORN TO AND SUBSCRIBED BEFORE ME THIS p?[[7OLDAY OF , 2002. it , - / NOTARY PUBLIC TERRENCE J. Mc ABE, ESQUIRE Attorney for Plaintiff MiCHME HoI Holtary Peiblir. ChY PMlad-Phia. Phila. County '?J__2F?res March 28, ?0(3' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA V. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to is to be entered and to the attorn default occurred and at least ten the filing of the Praecipe. A true pursuant to Pennsylvania Rule of attached hereto and marked Exhibit SWORN TO AND SUBSCRIBED BEFORE ME THIS ,?,,DAY OF /)'l N , 2002. (jI the party against whom judgment =y of record, if any, after the (10) days prior to the date of and correct copy of the notice Civil Procedure No. 237.1 is "A„ -4,L (--c YL-cam TERRENCE J. M,&CABE, ESQUIRE Attorney for Plaintiff NOTARY PUBLIC VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. TERRENCE J. Mc ABE, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LAWRENCE E. WELKER Prothonotary May 13, 2002 To: Ronald L. Kuhn 15 West Springville Road Boiling Springs, PA 17007 WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY V. COURT OF COMMON PLEAS RONALD L. KUHN AND DEBRA A. KUHN NUMBER 02-1847 CIVIL TERM NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE 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: Usted se encuentra an estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado por escrito con este Tribunal sus defenses u objeciones a Los reclamos formulados an contra suyo. AL no tomar Is accion debida dentro de diez (10) dias de la fecha de esta notificacion, at Tribunal podra, sin necesidad de comperecer usted en corte u oir preuba alguna, dictar sentencia an su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente pars tat servicio, vaya an persona o Name por telefono a to oficina, nombrada pars averiguar si puede conseguir asistencia Legal. Court Administrator Court Administrator Cumberland County Courthouse Cumberland County Courthouse Carlisle, PA 17013 Carlisle, PA 17013 (717) 240-6200 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/cc EXHIBIT Is OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LAWRENCE E. WELKER Prothonotary May 13, 2002 To: Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY V. COURT OF COMMON PLEAS RONALD L. KUHN AND DEBRA A. KUHN NUMBER 02-1847 CIVIL TERM NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (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: Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NOTIFICACION IMPORTANTE usted se encuentra an estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado por escrito con este Tribunal sus defenses u objeciones a Los reclamos formulados an contra suyo. Al no tomar La accion debida dentro de diez (10) dias de la fecha de esta notificacion, el Tribunal podra, sin necesided de comparecer usted en corte u oir preuba alguna, dictar sentencia an su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente pare tat servicio, vaya an persona o Name por tetefono a la oficina, nombrada pare averiguar si puede conseguir asistencia legal. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire MCCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM,cc EXHIBIT `1,r OFFICE OF THE PROTHONOTARY COURT OF COM14ON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Ronald L. Kuhn 15 West Springville Road Boiling Springs, PA 17007 WASHINGTON MUTUAL BANK, FA V. RONALD L. KUHN AND DEBRA A. KUHN NOTICE CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02 1847 CIVIL TERM Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated elow. 3 `+ ? . Curtis R. Long Prothonotary XX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J McCabe Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 WASHINGTON MUTUAL BANK, FA V. RONALD L. KUHN AND DEBRA A. KUHN NOTICE CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02 1847 CIVIL TERM Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above procee 'ng as indicate below. f) I- Qlifli? ?? - '?? Curtis R. Long Prothonotary XX Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession if you have any questions concerning this Judgment, please call Terrence J McCabe Esquire at (215) 790-1010. X) (Z V 0 cY. ?7 > C- v c? q T ..gin 'T3 c rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Washington Mutual Bank, FA V. Ronald L. Kuhn and Debra A. Kuhn FILE NO.: 02 1847 CIVIL TERM AMOUNT DUE: $103,825.92 INTEREST: from 5/25/02-12/10/03 $9,621.84 at 17.06 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland county, for debt, interest and costs upon the following described property of the defendant(s) 15 West Springville Road, Boiling Springs, PA 17007 (More fully described as attached) PRAECIPE FOR ATTACHMENT 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. June 12, 2003 DATE: Signature: Print Name: TERR C J. McCAB , ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 f V34 -e ? &J JU cc ?c0°??? r? LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: .:t BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA V. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 15 West Springville Road, Boiling Springs, PA 17007, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Washington Mutual Bank, FA Fremont Investment & Loan its Successor and or assigns 10790 Rancho Bernardo Road San Diego, CA 92127 175 North Riverview Drive Anaheim, Ca 92808 Keystone Auto Exchange Sales, Inc 5270 E Trindle Road Mechanicsburg, Pa 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Washington Mutual Bank, FA 10790 Rancho Bernardo Road San Diego, CA 92127 Fremont Investment & Loan its Successor and or assigns 175 North Riverview Drive Anaheim, Ca 92808 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None 6. Name and address Plaintiff has knowledge who may be affected by the sale: Name of every other person of whom the has any interest in the property which Tenant(s) Domestic Relations Commonwealth of Pennsylvania Address 15 West Springville Road, Boiling Springs, PA 17007 Armstrong County Court House Rm 1 500 Market Street Kittaning, PA 16201 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. June 12, 2003 DATE TERR J. McCABE, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: ,l BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8110/2000 and recorded 8117/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 EXHIBIT "A' McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE ,Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Your house (real estate) at 15 West Springville Road, Boiling Springs, PA 17007, is scheduled to be sold at Sheriff's Sale on December 10, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $ 103,825.92 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 Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Washington Mutual Bank, FA, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE AND YOU HAVE EVEN IF THE SHERIFF'S TO SAVE YOUR PROPERTY OTHER RIGHTS SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Ci 1,. - Q r - : ,;. . f. l .• ?? U'? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5125(02-12110/03 $9,621.84 AT 17.06 PER DIEM Atty's Comm % Due Prothy $1.00 Any Paid $119.45 Plaintiff Paid Other Costs Date: JUNE 19, 2003 (Seal) CURTIS R. LONG Prothonotaa ^ Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 06/26/2003 10:40 F.4X 215 790 1274 McCabe Weisberg Conway 1m 002 LAW OFFICES MCCABE, WEISBERG & CONWAY, P.C. SUITE 2080 SUITE 600 123 SOUTH BROAD STREET 216 HADDON AVF,NUE TERRENCE J. K CAGE PHILADELPHIA, PENNSYLVANIA 19109 WESTMONT, NJ 08108 X (6) 858-7080 (215) 790-1010 FAX (215) ) 790 790.1274 FAX (856) 658-7020 SUITE 503 / 53 WEST 36'^ STREET ?/ NEW YORK, NY 10018 (917)351.1188 FAX (917) 35 "363 June 26, 2003 O Sheriff's office CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 p? Re: Washington Mutual Bank, FA p V. b Ronald and Debra Kuhn CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02-1847 PREMISES: 15 West Springville Road, Boiling Springs, PA 17007 111SSS_ Sheriff's Sale Date: December 10. 2003 Dear Sheriff: W As you know, the above-captioned property is currently listed for the December 10, 2003 Sheriff's Sale. I am writing to you at this time to request that you stay the Sale. Defendant filed a ChaFter 13 bk on June 6, 2003 in the Middle District of PA., bk# 03-03371. In addition, please return the writ to the Prothonotary and forward any refun d due my client. L 3 Cj C {T7 N 0 L 04 2 3 4W As acknowledgment of this stay, I would appreciate your signing or time-stamping a copy of this letter and faxing the same to my attention. If you have any questions, please contact me. Thank you for your cooperation. Very truly yours, TERRENCE J. McCABE TJM/3M SENT VIA FACSIMILE TRANSMITTAL--NUMBER (717) 240-6397 SHERIFF'S OFFICE-RECEIVED BY: 5- L-A-, SIGNATURE 6 (zC_ (03 DATE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Arty's Comm % Due Prothy $1.00 Atty Paid $119.45 Other Costs Plaintiff Paid Date: JUNE 19, 2003 CURTIS R. LONG S l Prothonot ?y? n ! n 0 / //CJj/lw ( ea ) . / . ?» - ( DepuTy ? REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANE; FA, Plaintiff (s) From RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 1 7.06 PER DIEM Arty's Comm % Due Prothy $1.00 Arty Paid $119.45 Other Costs Plaintiff Paid Date: JUNE 19, 2003 CURTIS R. LONG l) S Prothonottaa? qa lO 1 l v ? ? ea ( -y,i y: . / . , . T/1 C Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM RECORD ' Tsatknony whereof, I here um set my tow 4#4 tft MW of said at Caro. Pa. 0 da J< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Atty's Comm % Due Prothy $1.00 Arty Paid $119.45 Plaintiff Paid Other Costs Date: JUNE 19, 2003 (Seal) REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 CURTIS R. LONG Prothonotary, ?0, . ?? Deputy TRUE COPY FROM RECORD M TeatWmy whereol, I here unto set my hand ad the seal of said Court at Cal*. Pa. rft-s- .day et ,,ro_ dlKir?y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Any's Comm % Due Prothy $1.00 Arty Paid $119.45 Other Costs Plaintiff Paid Date: JUNE 19, 2003 (Sea]) CURTIS R. LONG Prothonota/r/y ?By: X/i O?f+ i 4t?- Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM RECORD M Taatfmooy wheraW, i here onto set my ha ad arld the Swi of said Court at Caro*. Pa. ?y eft).,,x rt?tr,?,,,aa,y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $119.45 Plaintiff Paid Date: JUNE 19, 2003 (Seal) REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Deputy TRUE COPY FROM RECORD to Tastknwy whera W, 1 two unto set my hared geld tit awl (+i said Gou at Cantab. Pa. ay at .'w - R Mary Other Costs CURTIS R. LONG Prothonota WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (1) You are directed in 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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Arty's Comm % Due Prothy $1.00 Arty Paid $119.45 Plaintiff Paid Date: JUNE 19, 2003 (Seal) Other Costs CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM RECORD M ray vaa`w, , t twe wde ad aw tw4 tM 9bat of wn# k"'% I at Cat". Pa. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02-12/10/03 $9,621.84 AT 17.06 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $119.45 Plaintiff Paid Date: JUNE 19, 2003 (Seal) Other Costs CURTIS R. LONG Prothonot may: zQis. , .??- Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM RECORD to Tasyt?i",fly whereof, 1 herb ;nrata set my haad y4 Ow Seas of said Court at Carlisle, Pa I J6Y .. ?,. onotm MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification. Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 15 West Springville Road, Boiling Springs, PA 17007, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Ronald L. Kuhn and Debra A., Kuhn 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Washington Mutual Bank, FA Fremont Investment & Loan its Successor and or assigns 10790 Rancho Bernardo Road San Diego, CA 92127 175 North Riverview Drive Anaheim, Ca 92808 Keystone Auto Exchange Sales, Inc 5270 E Trindle Road Mechanicsburg, Pa 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Washington Mutual Bank, FA 10790 Rancho Bernardo Road San Diego, CA 92127 Fremont Investment & Loan its Successor and or assigns 175 North Riverview Drive Anaheim, Ca 92808 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name every other person of whom the any interest in the property which Tenant(s) Domestic Relations Commonwealth of Pennsylvania Address 15 West Springville Road, Boiling Springs, PA 17007 Armstrong County Court House Rm 1 500 Market Street Kittaning, PA 16201 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. June 12, 2003 f) DATE TERR J. McCABE, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1465, a draft of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/1712000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 EXHIBIT 49 McCABE, WEISBER.G AND CONWAY, P.C. BY: TERRENCE J'. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Your house (real estate) at 15 West Springville Road, Boiling Springs, PA 17007, is scheduled to be sold at Sheriff's Sale on December 10, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of -q 103,825.92 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 Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Washington Mutual Bank, FA, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND. OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated-herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern comer of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated- herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated-herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated- herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern comer of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Washington Mutual Bank, FA V. Ronald L. Kuhn and Debra A. Kuhn FILE NO.: 02 1847 CIVIL TERM AMOUNT DUE: $103,825.92 INTEREST: from 5/25/02-12/8/04 $15,840.96 at 17.07 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 15 West Springville Road, Boiling Springs, PA 17007 (More fully described as attached) PRAECIPE FOR ATTACHMENT 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: August 16, 2004 Signature ,f?y? (? `n' /X s ?. I I ?1 X? Print Name: TERREE11CE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone; (215) 790 1010 Supreme Court ID No. 16496 4Q xi (AJ v p? p Cf) 0 6 ? ?CCC?CO V N CIO U - F ? G? _Fig LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: ,z BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern comer of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book ' 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN, (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 $103,825.92 L.L. $.50 Interest FROM 5/25/02 -12/8/04 $15,840.96 AT 17/07 PER DIEM Arty's Comm % Due Prothy $1.00 Arty Paid $125.45 Other Costs Plaintiff Paid Date: AUGUST 31, 2004 (Seal) CURTIS R. LONG Prothonot -E$V: Dn, O _ Deputy REQUESTING PARTY: Name TERRANCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 15 West Springville Road, Boiling Springs, PA 17007, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: Name Address Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Washington Mutual Bank, FA Fremont Investment & Loan its Successor and or assigns 10790 Rancho Bernardo Road San Diego, CA 92127 175 North Riverview Drive Anaheim, Ca 92808 Keystone Auto Exchange Sales, Inc 5270 E Trindle Road Mechanicsburg, Pa 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Washington Mutual Bank, FA Fremont Investment & Loan its Successor and or assigns 10790 Rancho Bernardo Road San Diego, CA 92127 175 North Riverview Drive Anaheim, Ca 92808 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name Tenant(s) Domestic Relations every other person of whom the any interest in the property which Commonwealth of Pennsylvania Address 15 West Springville Road, Boiling Springs, PA 17007 Armstrong County Court House Rm 1 500 Market Street Kittaning, PA 16201 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. August 16, 2004 "'n- V1 Va DATE TERRE C J. McCABE, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: ;V BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA V. CUMBERLAND COUNTY COURT OF COMMON PLEAS RONALD L. KUHN AND NUMBER 02 1847 CIVIL TERM DEBRA A. KUHN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Your house (re Springs, PA 17007, December 8, 2004 at located on the 2nd Courthouse Square, court judgment of $ FA against you. a1 estate) at 15 West Springville Road, Boiling is scheduled to be sold at Sheriff's Sale on 10:00 a.m. in the Commissioner's Hearing Room Floor of the Cumberland County Courthouse, 1 Carlisle, Pennsylvania 17013, to enforce the 103,825.92 obtained by Washington Mutual Bank, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Washington Mutual Bank, FA, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR BAR ASSOCIATION 4TH FLOOR, 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 (717) 240-6200 N c? -n Flir- W i ?3 tV :t -= U'r 1? Washington Mutual Bank, FA VS Ronald L. Kuhn and Debra A. Kuhn In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1847 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states t on September 10, 2004 at 8:46 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upo the within named defendants, to wit: Ronald L. Kuhn and Debra A. Kuhn, by makin known unto Debra Kuhn, personally and wife of Ronald Kuhn, at 15 West Springvill Road, Boiling Springs, Cumberland County, Pennsylvania, its contents and at the sam time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states t on October 07, 2004 at 6:39 o'clock P.M., he posted a true copy of the within Real Es Writ, Notice, Poster and Description, in the above entitled action, upon the property o Ronald L. Kuhn and Debra A. Kuhn located at 15 W. Springville Road, Boiling Sprin 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 defendants, to wit: Ronald L. Kuhn and Debra A. Kuhn, by regular mail to their last known address of 15 W. Springville Road, Boiling Springs, PA 17007. This letter was mailed under the date of October 07, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this w is returned STAYED per instructions from Attorney Terrence McCabe. Sheriff's Costs Docketing 30.00 Poundage 5.25 Advertising 15.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Levy 15.00 Mileage 7.40 Surcharge 30.00 Law Journal 118.15 Patriot News Share of Bills 30.42 $267.72 Sworn and subscribed to before me ers: ire This 4w day of X&e4 ? R. Thomas Kline, Sheriff 2004, A.D. dku? , "? r thonotary BY de Real Estate eputy 1. )c Y7 5?Q "Y907 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA CUMBERLAND COUNTY COURT OF COMMON P. V. RONALD L. KUHN AND NUMBER 02 1847 CIVII TERM DEBRA A. KUHN AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff i the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 15 West Springville Road, Boiling Spring , PA 17007, a copy of the description of said property is att ched hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Ronald L. Kuhn and Debra A. Kuhn 15 West Springville oad Boiling Springs, PA 7007 2. Name and address of Defendant(s) in the judgment: Name Address Debra A. Kuhn 15 West Springville R ad Boiling Springs, PA 1 007 3. Name and last known address of every judgment cred for whose judgment is a record lien on the real property to be s d: Name Address Washington Mutual Bank, FA 10790 Rancho Bernardo oad San Diego, CA 92127 Fremont Investment & Loan its Successor and or assigns 175 North Riverview D ive Anaheim, Ca 92808 Keystone Auto Exchange Sales, Inc 5270 E Trindle Road Mechanicsburg, Pa 1705 4. Name and address of the last recorded holder of ev ry mortgage of record: Name Address Washington Mutual Bank, FA 10790 Rancho Bernardo R ad San Diego, CA 92127 Fremont Investment & Loan its Successor and or assigns 175 North Riverview Drive Anaheim, Ca 92808 5. Name and address of every other person who has any reco d interest in or record lien on the property and whose interest m y be affected by the sale: Name Address None 6. Name and address of every other person of who the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenant(s) 15 West Springville oad, Boiling Springs, PA 7007 Domestic Relations Commonwealth of Pennsylvania Armstrong County Court House Rm 1 500 Market Street Kittaning, PA 16201 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or informatio and belief. I understand that false statements herein are made su ject to the penalties of 18 Pa.C.S. Section 4904 relating to uns orn falsification to authorities. August 16, 2004 DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff L LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate o the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounde and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 1 , 1965, a draft of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally own as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, whi h at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence f om said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 d grees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School strict; thence along said line of land of the South Middleton Township School District, South 74 d grees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of R bert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degree 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 14 .20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dw ling house, frame garage and other improvements, known as 15 West Springville Road, Boil' g Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, Hi Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8117/2000 in Reco Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 WASHINGTON MUTUAL BANK, FA V. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON P RONALD L. KUHN AND NUMBER 02 1847 DEBRA A. KUHN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Kuhn and Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 TERM Your house (real estate) at 15 West Springville Road, Boi ing Springs, PA 17007, is scheduled to be sold at Sheriff Is Sal on December 8, 2004 at 10:00 a.m. in the Commissioner's Hearing oom located on the 2nd Floor of the Cumberland County Courthous , 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $ 103,825.92 obtained by Washington Mutual B nk, FA against you. NOTICE OF.OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take 1. The sale will be canceled if you pay to Washington Mut al Bank, FA, the back payments, late charges, costs, nd reasonable attorney's fees due. To find out how much ou must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petit asking the Court to strike or open the judgment, if judgment was improperly entered. You may also ask Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other 1 proceedings. You may need an attorney to assert your rights. The sooner contact one, the more chance you will have of stopping the s (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property w'll be sold to the highest bidder. You may find out the price id by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the s le if the bid price was grossly inadequate compared to the va ue of your property. 3. The sale will go through only if the buyer pays the Sh riff the full amount due on the sale. To find out if thi has happened, you may call Terrence J. McCabe, Esquire at 215) 790-1010. 4. If the amount due from the buyer is not paid to the She iff, you will remain the owner of the property as if the sale ever happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring egal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days fter sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 1,0 days after the filing of the schedule. 7. You may also have other rights and defenses, or way of getting your real estate back, if you act immediately a ter the sale. YOU SHOULD TARE 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. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR BAR ASSOCIATION 4TH FLOOR, 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 (717) 240-6200 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate o; of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounde in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 1 of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally Springville Road at the Northwestern corner of land now or formerly of R. Negley, wh of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence at the place of beginning along line of land now or formerly of R. Negley, South 17 distance of 211.2 feet to an iron pipe in line of land South Middleton Township School along said line of land of the South Middleton Township School District, South 74 distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of thence along line of land now or formerly of the said Robert Trostle, North 17 degr West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 53 the Southern line of Township Road No. 537, North 74 degrees East, a distance of 1 stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame frame garage and other improvements, known as 15 West Springville Road, 1 Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/1712000 in R( 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 the north side and described 1965, a draft mown as the h at the Place nt said stake grees East, a strict; thence grees west a )bent Trostle; s 26 minutes thence along .20 feet to a g house, Springs, Wife by ! Book TAX MAP AND PARCEL NUMBER: 28-2100-292 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA, Plaintiff 1 From RONALD L. KUHN AND DEBRA A. KUHN, (l) 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 fi paying any debt to or for the account of the defendant (s) and from delivering any property of the defen (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 garnishee and is enjoined as above stated. Amount Due $103,825.92 L.L. $30 Interest FROM 5/25/02 -12/8/04 $15.840.96 AT 1 7107 PER DIEM Atty's Comm % Due Prothy $1.00 Arty Paid $125.45 Other Costs Plaintiff Paid Date: AUGUST 31, 2004 CURTIS R. LONG Prothono ary (Seal) Deputy REQUESTING PARTY: Name TERRANCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Real Estate Sale #35 On September 01, 2004 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 15 West Springville Road, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 01, 2004 By: ? Real Esta Deputy C_a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. 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 8, 15, 22, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 35 Writ No. 2002-1847 Civil Washington Mutual Bank, FA vs. Ronald L. Kuhn and Debra A. Kuhn Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erect- ed situate on the north side of Spring- ville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accor- dance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said sur- vey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is Lisa Marie Coyn Editor SW RN TO AND SUBSCRIBED before me this 22 day of OCTOBER 2004 NOTARTAL SEAL LOIS E. SNYDER, Notary Public Ca iisle Boro, Cumberland County My Commission Expires March 5, 2005 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of be- ginning along line of land now or formerly of R. Negley, South 17 de- grees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern corner of land now or formerly of Robert T rostle; thence along line of land now or for- merly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a dis- tance of 140.20 feet to a stake, the place of beginning. CONTEMNING .676 acres and hav- ing thereon erected a two and one- half story frame dwelling house, frame garage and other improve- ments, known as 15 West Springville Road, Bolling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single _t dated 8/10/2000 and recorded 8/ 17/2000 in Record Book 227, Page 503. BEING known as 15 West Spring- ville Road, Boiling Springs, PA 17007. TAX MAP AND PARCEL NUM- BER: 28-2100-292. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION FILE NO.: 02-1847 Civil Term Washington Mutual Bank, FA V. Ronald L. Kuhn Debra A. Kuhn AMOUNT DUE: $103,825.92 INTEREST:$26,697.48 from 5/25/02 - 9/6/06 at $17.07 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 15 West Springville Road Boiling Springs PA 17007 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named gamishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate ofthe defendant(s) described in the attached exhibit. DATE: d Signature: ?r„ M ?l Print Name: TERRENCE J. MCCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 i ? 7L 4 Q CCUt C ?` G r p G ' 4- ^ W _ X- _ UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Ronald Lee Kuhn f/d/b/a Ron! G. Trucking Debra Ann Kuhn /flk/a Debra Sheaffer Debtor(s) CHAPTER 13 CASE NO.: 1-03-bk-03371 ORDER DISMISSING CASE Upon consideration of the Certificate of Default filed by the Trustee, and it having been determined that this case should be dismissed, it is ORDERED that the case of the above-named debtor(s) be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U.S. Bankruptcy Court. Dated: April 10, 2006 By the Court, 71) 14.1- w. Bttft Jptl This electronic order is signed rind flied tin the same date. MDPA.DISM682,WPT REV &8! WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. Interest $26,697.48 FROM 5/25/02 - 9/6/06 AT $17.07 PER DIEM Atty's Comm % Due Prothy $1.00 Arty Paid $414.67 Plaintiff Paid Date: APRIL 28, 2006 Other Costs AIS 5001% Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Washington Mutual Bank, FA V. Ronald L. Kuhn and Debra A. Kuhn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 02-1847 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 15 West Springville Rd., Boiling Springs, PA 17007 (Tax Parcel #28-2100-292), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: 2. Name Ronald L. Kuhn Debra A. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 15 West Springville Road Boiling Springs, PA 17007 Name and address of Defendants in the judgment: Name Ronald L. Kuhn Debra A. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 15 West Springville Road Boiling Springs, PA 17007 3 4. 5. 6. 7 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Keystone Auto Exchange Sales, Inc. Plaintiff herein Address 5270 E. Trindle Road Mechanicsburg, PA 17055 Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Name and address of every other person who has any record lien on the property: Name None Address Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants 15 West Springville Rd., Boiling Springs, PA 17007 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania 1400 Spring Garden Street Inheritance Tax Office Philadelphia, PA 19130 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. April 27, 2006 / DATE TERRENCE J. cCABE, ESQUIRE Attorney for Plaintiff a 4-? n' ^V Cu ?a CJ r,. -T? rn r ?'' i 1 McCABE, WEISBERG AND CONWAY, P.C. BY. TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas VS. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Kuhn Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Your house (real estate) at 15 West Springville Road, Boiling Springs, PA 17007 (Tax Parcel #28-2100-292), is scheduled to be sold at Sheriffs Sale on September 6, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $103,825.92 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 Sheriff's Sale you must take immediate action: The sale will be canceled if you pay to Washington Mutual Bank, FA, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY Y AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern comer of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-,half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. ;. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28-2100-292 IV <l ey C ?' i 1 ._ v Fl . .a r- McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas vs. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 29`h day of June 2006, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) asset forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 29TH DAY OF JUNE, 2006. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Chnssandra Shaye Hamilton, Notary Public City of Philadelphia, Phila. County My Commission Ex ires January 4, 2009 TE NCE J. McCABE, ESQUIRE Attorney for Plaintiff NOTARY PUBLIC McCABE, WEISBERG AND CONWAY. P.C. -' BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Washington Mutual Bank, FA V. Ronald L. Kuhn and Debra A. Kuhn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 02-1847 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was`filed the following information concerning the real property located at: 15 West Springville Rd., Boiling Springs, PA 17007 (Tax Parcel #28-2100-292), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Exhibit "A Name Ronald L. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendants in ejudgment: Name Address Ronald L. Kuhn 15 West Springville Road Boiling Springs, PA 17007 Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 3 4. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Keystone Auto Exchange 5270 E. Trindle Road Sales, Inc. Mechanicsburg, PA 17055 Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Address ;, Plaintiff herein. 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Atl?ress Exhibit A None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants 15 West Springville Rd., Boiling Springs, PA 17007 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 Commonwealth of Pennsylvania ' 1400 Spring Garden Street Inheritance Tax Office , kl hiladelphia, PA 19130 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 I verify that, the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. i June 29, 2006 1?2 DATE TERREi CE J. McCABE, ESQUIRE Attorney for Plaintiff Exhibit "A" McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas V5. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 DATE: June 29, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Ronald L. Kuhn and Debra A. Kuhn PROPERTY: 15 West Springville Road, Boiling Springs, PA 17007 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff s Sale on September 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens op, 2tid/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Exhibit "B" N o ?3 w rva, °J. J ? N 00 ? p@ ?Y ro? am e R .e F 0 m "O 0 'q n m ? i 1 = a v H b`A ?"Hp SO .. n N n MO O^"? r 9 .y Ny P >? 'J G OMO co ? w a b A bQ,^?n ab Mj'4 ?APj.O "O^ 3 r+ »+¢ O` cn 75 cs 101- W 9 , ? tn Ma mO +"U O J ^d m ? N w m. w?O Z A . b n nY and ? 6 . 9yr?? 0 ? ? G m 0 P 7 ? ? OR Q V? ?•omo? N ? z y rn X ? C nvn" o`n ybdC ,, ? y W N W fY O 04 N7'? YNP•? ti'^T?• N y Cl n J N ?oooaa S? H " v . a ^ W cow •c'T?x Y o ? 0 oo pa 'y0 A p Q `ter D. ? ? o nA y A Z iMOLS09VsodbO O 6D l6l BOO d4 ot°io 5OOZ 6Z ry{1f OOVZO "?SOd ?d ?...? ? '(l ?r+ •? C? ?- " _ ' _?? .; ' GI1 ?i' f'l Ci r?? McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas VS. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 SUPPLEMENTAL AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 24`s day of July 2006, a true and correct copy of the Notice of Sheriff s Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 24TH DAY OF JU,1,Y, 2006. n ARY PUBLIC COMMONWEALTH OF PENN8YLVANIA NOTARIAL SEAL FCtmssandra Shaye Hamilton, Notary Public City of Philadelphia, Phila. County 9 My Cornrris6ion Expires January 4, 200 ?--FvtA TERRENCE J. McC E, ESQUIRE Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Washington Mutual Bank, FA Plaintiff Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY V. Ronald L. Kuhn and Debra A. Kuhn Defendants Number 02-1847 Exhibit "A" SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 15 West Springvilia Rd., Boiling Springs, PA 17007, a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Ronald L. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendants in the judgment: Name Address 3 4. 5 Ronald L. Kuhn Debra A. Kuhn 15 West Springville Road Boiling Springs, PA 17007 15 West Springville Road Boiling Springs, PA 17007 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Keystone Auto Exchange 5270 E. Trindle Road Sales, Inc. Mechanicsburg, PA 17055 Plaintiff herein Commonwealth of Department of Revenue Bureau CO Pennsylvania Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None E x hi " ' bit A 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants Address 15 West Springville Rd., Boiling Springs, PA 17007 Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office P.O. Box 320 Carlisle, PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Internal Revenue Service Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. July 24, 2006 DATE YTX? TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Exhibit "A" McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas VS. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 DATE: July 24, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Ronald L. Kuhn and Debra A. Kuhn PROPERTY: 15 West Springville Road, Boiling Springs, PA 17007 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on September 6, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Exhibit "B" C Po J n 8 U 3 F n ?P nF 0 'e n e ? W N ? ? yy Nn? y W J P P So G a'Sp ? a y y ? ?? 0. C ? p ? On0 ? Z W ?• ? y W 9 4 4 L3 ? ? ? ? (1 p9 A? CD C) 0 0 b 0 13 E3 013 r) S O y Cb $ Q H QQQ 7 . H 2 ro N p O? gzg g k. ? ???? b ego W ¢j?ggg???i t 0 ? k ? 8 a $?a?? ? t ? 49A , E b" ? a [ S L e e ?a?y ? ? gg ? E p a3 e 3d d ` ? {i{ E g @g 9 B a ° 3' O o UIWT?O m S i s p y y B $ 8 _ A DC I e - p y i gg v N -p ?'flfr 3 o C z o r 1._ CO N W O iD J? r° ? i ?? =i1 .? (Z' .a ?. {a f 4. .. MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Washington Mutual Bank, FA Cumberland County Court of Common Pleas VS. Ronald L. Kuhn Debra A. Kuhn Number 02-1847 PRAECIPE TO MARK JUDGMENT AND WRIT OF EXECUTION TO USE PLAINTIFF TO THE PROTHONOTARY: Kindly mark Judgment and Writ of Execution to WM Specialty Mortgage, LLC., Use Plaintiff. QA TE NCE J. MCCABE, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which WM Specialty Mtg LLC is the grantee the same having been sold to said grantee on the 6th day of Sept A.D., 2006, under and by virtue of a writ Execution issued on the 28th day of April, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1847, at the suit of Washington Mutual Bank N A against Ronald L Kuhn & Debra A is duly recorded in Deed Book No. 277, Page 696. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of /'9-e? A.D. aQD l? of Deeds Fi`a=* of QnWdKW County. Cafte. PA * ftffft" boa wa FM Monday of Am 2010 Washington Mutual Bank, FA VS Ronald L. Kuhn and Debra A. Kuhn In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1847 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on July 18, 2006 at 5:46 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Ronald L. Kuhn and Debra A. Kuhn, by making known unto Ronald L. Kuhn, personally, husband of Debra A. Kuhn, at 15 West Springsville Road, Boiling Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 23, 2006 at 10:36 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald L. Kuhn and Debra A. Kuhn located at 15 West Springsville Road, Boiling Springs, Pennsylvania, 17007 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 defendants, to wit: Ronald L. Kuhn and Debra A. Kuhn, by regular mail to their last known address of 15 West Springville Road, Boiling Springs, PA 17007. These letters were mailed under the date of July 26, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 6, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Terrence McCabe for WM Specialty Mortgage, LLC. It being the highest bid and best price received for the same, WM Specialty Mortgage, LLC of 2380 Performance Drive, Mail Stop # RGV-C2-48, Richardson, TX 75082, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,034.82. Sheriffs Costs: Docketing $30.00 Poundage 20.29 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Prothonotary 1.00 Mileage 21.12 Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 15.00 30.00 425.00 338.60 19.31 25.00 39.50 $1,034.82 ? /?/d9/b So Answers: R. Thomas Kline, Shenff BY? ' Real Estat ergeant 3? .w McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Washington Mutual Bank, FA V. Ronald L. Kuhn and Debra A. Kuhn Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Number 02-1847 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 15 West Springville Rd., Boiling Springs, PA 17007 (Tax Parcel #28-2100-292), a copy of the description of said property is attached hereto and marked as Exhibit "A." Name and address of Owners or Reputed Owners: Name Ronald L. Kuhn Debra A. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 15 West Springville Road Boiling Springs, PA 17007 2. Name and address of Defendants in the judgment: Name Ronald L. Kuhn Debra A. Kuhn Address 15 West Springville Road Boiling Springs, PA 17007 15 West Springville Road Boiling Springs, PA 17007 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. 2. 3 4 6. 7 If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OR CUMBERLAND COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. April 27, 2006 TERRENCE J. cCABE, ESQUIRE DATE Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT r .w COMMONWEALTH OF PENNSYLVANIA) NO 02-1847 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 RONALD L. KUHN AND DEBRA A. KUHN (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 $103,825.92 L.L. Interest $26,697.48 FROM 5/25/02 - 9/6/06 AT $17.07 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $414.67 Other Costs Plaintiff Paid Date: APRIL 28, 2006 (Seal) URTIS . LONG Prothonotary By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Real Estate Sale # 35 On May 22, 2006 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 15 W. Springville Road, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22, 2006 By: r ? ??vuJlJ?v Real E to Sergeant 11 E :b V S - A vpl 9001 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of July and the 2nd day(s) of August 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION . COPY Sworn to and subscb a ore me this 1 YLVANIA SALE #35 Notarial Seal ' Terry L. Russell, Notary Public REAL ESTATE SALE NO. 35 City Of Harrisburg, Dauphin Court Writ No. 2002-1847 Civil Term M mmis ? Expires June 6, 20101 Washington Mutual Bank, FA / vs Oy Me er, Pen 2nie .?ss?c r.t on caf Notaries Ronald L Kuhn hand Debra A. / Atty: Terrence McCabe N ARY PUBLIC DESCRIPTION ALL THAT M TAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Township, Cumberland County Pennsylvania, bounded and described in accoidance with survey made by Thomas Alvin Neff, Registered Surveyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008; thence from said stake at the place of beginning along line of land now or formerly of R. Negley, South 17 degrees East, a distance of 211.2 feet to an iron pipe in fine of land South Middleton Township School District; thence along said line of land of CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle, thence along line of land now or formerly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a distance of 140.20 feet to a stake, the place of h, ginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improvements, known as 15 West Springville Road, Boiling Springs, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 81101 2000 and recorded 8/17/2000 in Record Book 227, Page 503. Being known as 15 West Springville Road, Boiling Springs, PA 17007 TAX MAP AND PARCEL NUMBER: 28- 2100-292 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: July 21, July 28, and August 4, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 35 Writ No. 2002-1847 Civil Washington Mutual Bank, FA vs. Ronald L. Kuhn and Debra A. Kuhn Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected situate on the north side of Springville in South Middleton Town- ship, Cumberland County, Pennsyl- vania, bounded and described in accordance with survey made by Thomas Alvin Neff, Registered Sur- veyor, on June 12, 1965, a draft of said survey being incorporated herein by reference, as follows: BEGINNING at a stake on the Southern line of Township Road No. 537 locally known as the Springville Road at the Northwestern corner of land now or formerly of R. Negley, which at the Place of beginning is 687.8 feet West of the centerline of Legislative Route No. 21008, thence Ctis'Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 4 day of August, 2006 NOTARIAL SEAL I.OIS E. SNYDER, Notary Public C _to le Boro, Cumberland County x , i-,cfrmission Expires Ka ch a, 2008 from said stake at the place of be- ginning along line of land now or formerly of R. Negley, South 17 de- grees East, a distance of 211.2 feet to an iron pipe in line of land South Middleton Township School District; thence along said line of land of the South Middleton Township School District, South 74 degrees west a distance of 138.60 feet of a stake at the Southeastern comer of land now or formerly of Robert Trostle; thence along line of land now or for- merly of the said Robert Trostle, North 17 degrees 26 minutes West, a distance of 211.20 feet to a stake on the Southern line of Township Road No. 537; thence along the Southern line of Township Road No. 537, North 74 degrees East, a dis- tance of 140.20 feet to a stake, the place of beginning. CONTAINING .676 acres and having thereon erected a two and one-half story frame dwelling house, frame garage and other improve- ments, known as 15 West Springville Road, Boiling Springs, Pennsylva- nia. TITLE TO SAID PREMISES IS VESTED IN Ronald L. Kuhn and Debra A. Kuhn, His Wife by Deed from Geneva B. Politzer, Single dated 8/10/2000 and recorded 8/ 17/2000 in Record Book 227, Page 503. BEING known as 15 West Springville Road, Boiling Springs, PA 17007. TAX MAP AND PARCEL NUM- BER: 28-2100-292. McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Washington Mutual Bank, F.A. VS. Ronald L. Kuhn and Debra A. Kuhn Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-1847 ASSIGNMENT OF BID AT SHERIFF'S SALE Washington Mutual Bank, F.A., was the successful bidder at the Sheriff s Sale conducted by the Sheriff of Cumberland County on the 6"' day of September, 2006. Washington Mutual Bank, F.A., hereby assigns its bid for $1.00 and other valuable consideration to WM Speciality Mortgage, LLC, without recourse for the property known as 15 West Springville Rd., Boiling Springs, PA 17007. McCABE, WEISBERG & CONWAY, P. C. BY.,? 4?? -E' ,lam ' TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff DATE: