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Home My WebLink About06-4367 .. . SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., ATTORNEY !.D. NO. 86727 LAUREN R. TABAS, ESQ., ATTORNEY !.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY !.D. NO. 87137 MEGAN D.H. SMITH, ESQ., ATTORNEY I.D. NO. 84047 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY C!.j(J~L J~ NO: O/P - '-I!,t:. 7 VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 131 W. North Street Carlisle, PA 17013 and Chante T. Walker (real owner) 131 W. North Street Carlisle, PA 1701 DEFENDANT(S) COMPLAINT - CML ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFfER TlOS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITIEN APPEARANCE PERSONALLY OR BY A TIORNEY 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 IMPORT ANT TO YOU. YOU SHOULD TAKE TIDS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. Cwnberland County Lawyer Referral Service Cwnberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 . < PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TIDS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUlERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUlENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN PERSONA 0 PORABOGADO Y ARCHlY AREN LA CORTE EN FORMA ESCRITA SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEAA VlSADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVlO A VlSO 0 NOTIFICACIONY PORCUALQUlERQUEJA 0 ALMO QUE ES PEDIDO ENLA PETICION DE DEMANDA. USTED PUEDE PERDERDINERO 0 SUS PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTADEMANDAA UN ABOGADOINMEDIATAMENTE. SINO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFlCIENTE DE PAGAR TAL SERVlCIO, VA YA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 .. SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., ATTORNEY I.D. NO. 86727 LAUREN R. TABAS, ESQ., ATTORNEY !.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY !.D. NO. 87137 MEGAN D.H. SMITH, ESQ., ATTORNEY !.D. NO. 84047 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY {!/(.~l 'T ~"'- NO: 01.:.- /"(61.,.1 VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 131 W. North Street Carlisle, P A 17013 and Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 1701 DEFENDANT(S) COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America, the address of which is, 1270 Northland Drive, Suite 200, Mendota Heights, MN 55120, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortl!:al!:e: Mortl!:al!:ee: PNC Mortgage Corp. of America Mortl!:al!:ons): Ralston Walker (b) Date ofMortl!:al!:e: October 7,1999 (c) Place and Date of Record ofMortl!:al!:e: Recorder of Deeds Cumberland COlUlty Mortgage Book 1576 Page 459 Date: October 14, 1999 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 93 B Street, Carlisle, Pa 17013 and is more specifically described as attached as part of Exhibit "A." 4. The name and mailing address of each Defendant is: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, 131 W. North Street, Carlisle, P A 17013; Chante T. Walker (real owner), 131 W. North Street, Carlisle, PA 17013. 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both, AND the said Ralston Walker (mortgagor) departed this life on or about August 13,2005, thereby vesting title in Chante T. Walker, his wife, by right of survivorship. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of March 1, 2006 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of July 31,2006: Principal of Mortgage debt due and unpaid Interest currently due and owing at 5.625% per annum calculated from February 1, 2006 at $6.09 each day Late Charge of$15.66 per month assessed on the 16th of each month from March 16,2006 to July 16, 2006, (5 Months) Escrow Balance (Credit to Defendant) Mortgage Insurance Premiums Title Search/Report Fees Attorneys' Fees and Costs $39,485.23 $1,102.29 $78.30 ($288.06) $37.84 $250.00 $1,500.00 TOTAl, $42,165.60 8. Interest accrues at a per diem rate of6.09 each day after July 31,2006, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. . 10. This interest rate is subject to adjustment as more fully set forth in the Mortgage. 11. The original principal balance of the Mortgage exceeds Fifty Thousand Dollars ($50,000.00). Accordingly, Notice of Intention to Foreclose pursuant to 41 P.S. ~ 403 is not required. 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 D.S.C. ~ 1707-1715z-18). Accordingly, the Homeowners' Emergency Assistance Act of 1983,35 P.S. ~ 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & KREISMAN, LLC Date:~ BY: S & K File No. 06-27084 ~jbl+ \IA'\ ~I' .,7r~ .~ ...tIlT I. ZIIli,P .~_El Of .IEI' alIUOU"" C~-IA '18 DCIl~ HunS ............. tIC -..... _. e&......... -- ".... ~..... ..... "".. 111 ""' ,.. ......NJU"~ .....~.._IW......~ I;::u .LIIllIIrt:,..I"'" ... ,.",........ MORTGAGE ~~ ..-..1 .... .. 1IlU ,..JrICI1'CWtIr...-~",.,.. ..--". un _.........~ ..a-. -....... .......... ~'IIII"""--"--. ...,.....-...,................ ::....~ ft'=r=='*=-~..... aJ1II. 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CUSf.... ............................,.,..... .~"........ ..................... ___........._.........-eI ......... ............ ............................. ........ ....... -_....--...........~............ ........ ..................._......_.,~..If_......"~_.... ..... ....".......fI.,............... ,.....,.. ...... ........--...................... ...-..- a.-.. ..............,.......__............... 'nt .............-.........---......-........-....... ..4........ CIt II .............__-........ --..... ....III' ................M.._..__..a_~""......it........ ......11__..... .......(\11I)................ ............. 1M. ...- ..-....,,~ It. _.... _............ ..............:a ....."...... wII...... ..... ..0-............ .................... ............... ............... -..............:;s..... ............. .............."'..................... .......--......... ~.................-........ .................... ...... _s.- tilt............... ...................... II --..,.............................-..............."....... ................~~... -...............-.......-- ......*"It/................................ _II _fl.. ~......_.......tI.__._.....~...ellIII.......... .... ~............. .-.......... ..........--... ..........,......... -........-...-................." lIt......-....... ........................... .......... ~ ...."... -ftL ._15'Ill... .. r" ..--.--..........-...--.... ......... ~ - .::, - ... - .- - - ~ ::::. ... .. - - ~ ~oatKlO ... .....- VERIFICATION lIana Zion, Esquire hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiffs verification could not be obtained within the time necessary to file this pleading, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa,C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: ~~~ II ion, Esquire Attorney for Plaintiff Dated: 7 13 I 10<0 --... " :--:1 ( ;,,' .(,-';- \ -l4 ((j ;d lr\ ~ ....' t VI V'l - C> - ~ '"<:> C> t .- '", - -- C> - ."-~ " l.rt , of'" ~4 .....c.. - J \.. ."' ~ , SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: 87137 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Shapiro & Kreisman, LLC, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, upon the above-captioned Defendant(s), Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) by publication and by posting of the subject premises located at 93 B Street, Carlisle, PA 17013 and, in support thereof avers the following: 1. Plaintiff believes, and therefore avers, that Ralston Walker died on or about August 13, 2005. Plaintiff, by and through its agents, has reviewed the appropriate public records to determine if an estate has been created and, if so, whether a personal representative has been appointed. The review of these public records indicates that no estate exists for Ralston Walker. An Affidavit of Investigation setting forth the inquiries made and the results there from is attached hereto and marked as Exhibit "A". .-' .. . 2. Any attempts at personal service of the Complaint in Mortgage Foreclosure would not be successful. 3, Service of process by publication is permitted by Pennsylvania Rule of Civil Procedure 430(b). 4. Pennsylvania Rule of Civil Procedure 430 (b) (2) provides: "When service is made by publication upon the heirs and assigns of a named former owner or party in interest, the court may permit publication against the heirs or assigns generally if it is set forth in the Complaint or an affidavit that they are unknown." 5. In the case at bar, the Complaint in Mortgage Foreclosure as filed indicates that the heirs of Ralston Walker, deceased Real Owner and Mortgagor, are unknown to Plaintiff, despite a good faith investigation of the probate records as set forth in the Affidavit attached hereto and incorporated herein as Exhibit "A" WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, upon the unknown heirs of Ralston Walker, by publication in a legal publication designated by the Court for the publication of legal notices and in one newspaper of general circulation within Cumberland County, and by posting the subject premises located at 93 B Street, Carlisle, PA 17013. SHAPIRO & KREISMAN, LLC BY: ~ Ilana Zion, Esquire Attorney for Plainti ... - -- - fait Eqras Smica, INC . .' 13000 RT. 73 Greentree etr Suite 107 Marlton, NJ 08053 P - 856-985-3340 fax - 856-985-3342 Joe.Sarocy@defaultexpress.com WWHl. defaultexpress.com 7/31/2006 PROBATE SEARCH Re: Walker, Ralston - SS# 264-91-9374 - DOD- 08/13/05 Our office contacted the Register of Wills office in Cumberland. Per Register of Wills office there is no estate raised for the above individual(s), CREDIT INFORMATION *WALKER,RALSTON SINCE 09/05/92 FAD 06/05/06 131,W NORTH,ST,CARLISLE, PA, 17013,TAPE RPTD 11/05 93,B,ST,CARLISLE, PA, 17013,TAPE RPTD 11/99 TELEPHONE NUMBER (717) 249-6957 SPEC 08/05 159,N HANOVER,ST,CARLISLE,PA,17013,TAPE RPTD 08/92 BDS-04116/1944,SSS-264-91-9374 FN-333 DECEDENT INFORAMTION Viewing 1-1 ofl !Name-~~hl~~~t~~::~~:=-- :~~~I~;---I~~::;;::o~~iR~;::;?! ...... r~""-^"^"" r---'-^"~. r~-"---~--"" ,--~--- r-~-" r.-~~~~- - - - " : ! 116 113 Aug ,1701~ I 1264- i I iRALSTON Apr 12005 i(C'fltsle, i(non~ 91- iFlorida : ~:L~R~~(V) J~mbCJlan~peclfied) ,9374 ' __J Viewing 1-1 ofl (V)=(Verified) Report verified with a family member or someone acting on behalf of a family member. (P)=(Proof) Death Certificate Observed, exHIBIT "A" . ." .. POSSIBLE HEIRS FOR THIS SUBJECT Nothing Found .. This is to certify that this is a true and accurate copy of the death record on file with the Division of Vital Records, and that I, Frank Yeropoli, am and was at the time of the issuance of this copy Director, Division of Vital Records of the Department of Health for the Commonwealth of Pennsylvania, duly appointed and commissioned as directed by Act 66 of the General Assembly, approved 29 June 1953, P,L, 304, ,-' . . SEP 12 2006 Date Issued ~~~ P--. ( . ~- H'~.~..;.3R4N. 2117 COMMONWEALTH OF PENNSYLVANIA. DEPARTMENT OF HEALTH' VITAL RECORDS CERTIFICATE OF DEATH 084317 TYPEII'*NT IN I'EAIII.OHENT BUCk .... NAME OF DECEDENT fF.". Middle. I._ .. AGf!(l.oot_Yl !oW'l fU ltUW8!R socw.. SECUIUTY NUMlUR 91 ~ ... ... ) ?-. . ~ .... 5- 61 v,.. COUNTY OF DEArH J..I .. Cumberland DECEDENT"S USUAL OCCUPtVKlH ~..:=:&:oc::~..,. .~ Laborer .~ lIEOElJeHf'SMALlNG_S$_~,"""Z",,,- 131 West North Street ... o w .. ::> ~ .. "". DId - ...... Cumberland -' 17.J!J ::..."'::'.:'.'::'.. IotOTttEA'S MMlIE ff'U1t Midde. hI8Iden Sut,..".. N.tIWW. SWlJS -....... --- -~ 't. Harried 11c.O .....~....... _. ... Carlisle PA 17013 FRHER'S NAME (Fir.... MiOcIe. Lase) Carlisle _. ... ~S_(T_ Johnn Walker Chante Walker __....0 MAT.. OItw~COftdIIiON.........IO......bUt ItCII """'in."~c::auM9'*'lnPNffI. { : OUIE 10 (OR AS A CONSEQUENCe OF): OF DERH? - 1( o o ewe Of INJURY .""'._1 11NE OF INJURY INJURY "'..-. DESCRIBE HOW INJURY OCCUAAIED. WERE Al1JOPSY FINDINGS --.E""""'1O OF CAUSE MANNER Of DEATH -... - -- o o o PlACE. OF 1NJ\JA't . lilt home. ....::... ractorr. otftce M. -....- .... .... 0 NoD -MEDICAl. EXAMINE.RICORONER On.... ba.'. 01 ....'''lin.clon and/Of invesllg~'ion. in my opicUon. death occurred" the lime. dete, and place, .net d,,- to lhe cause(.)_ 11IM....,.. stated.................................................................................................. 3'.. REGISTRAR'S StGNA1UAE AND NUW8E.R 1;2../ ~I/I ... ...00 s..lddo Coutd noI bfJ deIMrltnctd 20. l- Z ... o w [;:1 o .. o w 2 .. z .PftONOUttC1NG AND CERTIFYING PHYSICIAN (PhvsIc;!lIn boltl plonoutlClng 0Ulh.nd~ IOcause of dea1l) Tolhe bntofmYkna~. de-'hoccwrttd., __lime. ca.... ..ndpl8c:e. MddWto...cauMf.J.ncfman".,....I.ted.......................... "I' . ~ Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America vs. Unknown Heirs, Successors, Assigns, And All Persons, Firms, Or Associations Claiming Right, Title Or Interest From Or Under Ralston Walker (Mortgagor), Deceased And Chante T. Walker (Real Owner) VERIFICATION Ilana Zion, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief, The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. See, 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: DATE: q J /0 101.0 .,. t t SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY J.D. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CNIL TERM vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: If service cannot be made under the applicable rule, the Plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. In real property actions, such as the instant action in mortgage foreclosure, Pennsylvania Rule of Civil Procedure, 410 (c), sets forth the manner in which service shall be made pursuant to an Order of Court under Pa RC.P. 430 (a): The court shall direct one or more of the following methods of service: (1) publication as provided by Rule 430 (b ),(2) posting a copy of the original process on the most public part of the property, (3) registered mail to the defendant's last known address, and (4) such other methods, if any, as the court deems appropriate to serve notice to the defendant. A good faith effort to discover the whereabouts of the Defendant(s) has been made in accordance with Pennsylvania Rule of Civil Procedure 430(a), as evidenced by the attached Affidavit of Investigation, marked as Exhibit "A". .. t . Pennsylvania Rule of Civil Procedure 430 (b) (2) provides: "When service is made by publication upon the heirs and assigns of a named former owner or party in interest, the court may permit publication against the heirs or assigns generally if it is set forth in the Complaint or an affidavit that they are unknown." As both the Complaint in Mortgage Foreclosure as filed and the Affidavit of Investigation, attached hereto and incorporated herein by reference as Exhibit "A," make clear the heirs of Ralston Walker are unknown to Plaintiff. In order to complete service on the Defendant( s) so as to move this action forward to ultimate disposition, the Plaintiff respectfully requests that this Honorable Court, pursuant to Pennsylvania Rule of Civil Procedure 430, grant a special Order directing service of the Complaint in Mortgage Foreclosure, Notice of Sale and all subsequent pleadings that require personal service only, on the Defendant(s), by publication in a legal publication designated by the Court for the publication of legal notices and in one newspaper of general circulation within Cumberland County, and by posting the subject premises located at 93 B Street, Carlisle, P A 17013 by the Sheriff, competent adult, or other party allowed by law, Respectfully Submitted, SHAPIRO & KREISMAN, LLC BY: of . . SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY LD. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS CERTIFICATION I hereby certify that I have served a true and correct copy of this Motion For Service Pursuant to Special Order Of Court and the papers attached thereto on all parties named herein at their last known address or upon their attorney of record by regular mail, postage prepaid to the Defendants listed below at the address provided on q \ /q 2006. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 131 W. North Street Carlisle, PA 17013 Chante T, Walker (real owner) 131 W. North Street Carlisle, P A 17013 SHAPIRO & KREISMAN, LLC ( BY: Ilana Zion, Esquire Attorney for Plainti ~ ~ a '6- ~. ~ ~ ~~.... iV. :..0 W~).:\... ~ ~~.. ..'.. ~<:.:..., 0 -. .,"p.,.^~ ... .). ~. , ~c..~. ~ ..:.. _"li'() ~ ~ ~~ ~ ?l r " SHERIFF'S RETURN - REGULAR CASE NO: 2006-04367 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WALKER RALSTON UNKNOWN HEIRS WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WALKER CHANTE T the DEFENDANT , at 2051:00 HOURS, on the 14th day of August , 2006 at 131 W NORTH STREET CARLISLE, PA 17013 by handing to CHANTE WALKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. 18.00 4.40 .00 10.00 .00 32.40/ q/~~olt ~ Sworn and Subscibed to Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~~~ R. Thomas Kline 08/15/2006 SHAPIRO & KREISMAN day By: d V-~- ~ Deputy Sheriff before me this of A.D. (' ... SHERIFF'S RETURN - REGULAR CASE NO: 2006-04367 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WALKER RALSTON UNKNOWN HEIRS WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TENANT/OCCUPANT the DEFENDANT , at 2055:00 HOURS, on the 14th day of August , 2006 at 93 B STREET CARLISLE, PA 17013 by handing to MICHAEL MESSINA a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: ~ 6.00 4.40 .00 10.00 .00 20.40 ;/ ct/:J.'i/ol, to ~~~~<~, R. Thomas Kline 06/15/2006 SHAPIRO & KREISMAN day By: d~ yJ~ Deputy Sheriff Sworn and Subscibed before me this of A.D. .. SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY LD. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America W08 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 PLAINTIFF VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker I (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO:06-4367 CIVIL TERM PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to the Complaint in the above-captioned civil action. BY: Respectfully Submitted, SHAPIRO & KREISMAN Ilana Zion, Esqui Attorneys for PIal ..... , Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America v. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) VERIFICATION The undersigned is Assistant Vice President of Washington Mutual Bank on behalf of Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Washington Mutual Bank, on behalf of Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America Date: A4j' I ~J ( JG 1.)' ,- "'j W~: Title: ASsist nt Vice President Company: t.J.i.:,h;"j1<", MI., 1 1,., 1 ~f\ ~ Loan: 5100383271 06-27084 .~. .~.~: ~'~1 f!"~ .I':~, ~: ., ,.4~, , t..~ ,e-* ; ,,,::,~;;,,(\ () ~: ,....., = = 0" (/) r: -v !'.) co ::: ~ o ..,., --I :en; :D I r m o (~.~ ... :r.~ :J (") ~,,")nl ~\ ?is :< <2 N \.0 .. . . . .. SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY J.D. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS ,... AND NOW, this 1. ~ day of 1-:-.::--.,---- 17 i "'..,'., --~, -:-::--7-~.'::--)--L- ! JL ;'-...., .i,""~~,,.l_.. SEP 2 1 2006 ; - '----- --- COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM ORDER ~ t,,~ \'L tf\ ~ t. f ,2006, upon consideration of Plaintiffs Motion For Service Pursuant To Special Order Of Court and the Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require personal service only, on Defendant Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, shall be complete when Plaintiff or its counselor agent has published a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent pleadings in the legal publication designated by the Court for the publication of legal notices and in one newspaper of general circulation within Cumberland County and the Sheriff has posted a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale and or any subsequent pleadings on the most public part of the mortgaged premises located at 93 B Street, BY THE COURT: 'l J. 'tt'iN\/I\lAS:\!j{3d i 1/\ 'lir-.,-. ,"," "'1 .~'-.'/Jnl"\ f'I..L.l\i: :,.':". I. :.""' :".-f:',! .J I 2 :8 Hd SZ d3S 900l ^b'V10l~()H.LObd '3Hl ;jO 3~)!:!!O-"(]:nH SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY J.D. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANT(S) PRAECIPE FOR REINSTATEMENT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & KREISMAN, LLC BY: ~ &~ Ilana Zion, Esquire Attorney for Plaintiff C:Y (., -"; I (). c..) 0.1 0', SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF VS. Unknown heirs, successors, assigns, and all persons, firms, or'associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM AFFIDAVIT OF SERVICE I, Angela D' Antonio, the undersigned, being duly sworn according to law, hereby depose and say that on the /3D day of f'0tD\;fL , 2006, pursuant to the Order of Court, attached as Exhibit "A," I served a true and correct copy of the Complaint in Mortgage Foreclosure in the above-captioned matter to the Defendant(s) listed below at the address provided by publication in a legal publication designated by the court for the publication of legal notices and in one newspaper of general circulation within Cumberland County, Proof of said publications are attached as Exhibit "B." Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 131 W. North Street Carlisle, P A 17013 SHAPIRO & KREISMAN, LLC BY: AngiM"to1J!f~ Legal Assistant to Attorney for Plaintiff I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this Affidavit of Service is made subj ect to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. - "'...."-_-r;' .,_... ':/ ,>_A.L.J SEP 2 1 2006 SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY LD. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF J3Y: \. .-' . 1("') , \....:.::...../U.__.' COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NO: 06-4367 CIVIL TERM ORDER AND NOW, this ~-HI dayo~e_pte.r1e& ,2006, upon consideration of Plaintiffs Motion For Service Pursuant To Special Order Of Court and the Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require personal service only, on Defendant Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, shall be complete when Plaintiff or its counselor agent has published a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent pleadings in the legal publication designated by the Court for the publication of legal notices and in one newspaper of general circulation within Cumberland County and the Sheriffhas posted a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale and or any subsequent pleadings on the most public part of the mortgaged premises located at 93 B Street, Carlisle, Pa 17013. .,..~ '-'" ,.,rrORD ocr: -"$ , s::t my hand _Jr lis! I Pa. BY THE COURT: -e<"'~ ,,- 'A " PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) October 16, 2006 COpy OF NOTICE OF PUBLICATION -;Jr~\; s~\ .. -fi 1 .. .-' ':'~'.;' ' , ~' I """"""\' ~. "" -' .........u................"._.'J...,..~.... '.........~ .lr; -. t:!QIlg ..ljF~UJ~iR\~~~TC?:u~~~~~~~k~t~ ANtA . t'...;\,f.. CIVIL ACTION-LAW V., ,NO..O~-4367CIVIL TERM " . . 'OF:ACTlCm IN MORTGAGEFOFlg,QL()~UI\\'L. ~~ftr. ,".','" ....... .....,. ..,. ~Nf( SUCCESSOR IN INTl:Ri:ST TO PNC MPRTGAGE . ,J:;FVs. UNKNOWN HEIRS, SUCCESSORS, . ONS, FIRMS, OR AS$()CIATIONS CLAIMING RIGHT, OMOR UNDER RALSTONWALKEf\ (mortgagor), Ii T. WALKER (rea/owner), DEFENDANTS Jllliewh Heirs, Successors, Assigns, All Pef'$ons, Firms, or .. .to title or Interest frqm or under Ralston Walker ljnd Chante T. Walker(reaf owner): TAKE NOTICE THAT. on Mutual Bank succ.ssor In Int.rest to PNC Mortgage IIldan action in Mortgage Foreclosure as captipned - .!:iQI.!g NO. YOU MUST ENTER A WRITTEN APPEARANCE n-ORNEYANDFILE YOUR DEFENSES OR ~COURT.YO!J ARE WARNED THAT IFYOU FAIL TO PROCEED WITH OUT AND A JUDGMENT MAY BE "IiJWITHOUT FURTHER NOTICE FOR THE Rl:LIEF LAINTIFF.YOU MAY LOSE MONEY OR PROPERTY OF TANTTO YOU, NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT OR TELEPHONE THE OFFICE SET FORTH BELOW. \lIDE YOU WITH INFORMATION ABOUT HIRING A T AFFORD TO HIRE A LAWYER, THIS OFFICE JPE YOU WITH INFORMATION ABOUT AGENCIES ^L SERVICES TO ELIGIBLE PERSONS AT A REpUCED '~,iA--; . " :" ,l.,AWYERS REFERRAL SERVICE 0',;' .."'";~gm.berland County Bar Association ;;".j ~<'W 32 S. Bedford.SI. Carlisle. PA 17013-3302 717,249,3166 :-j/ 1 i,{l~~ 'h,.:~ .~.~)~ -- r~ Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of :1::~~~{:Q~ Sworn to and subscribed before me this 18th. day of October 2006. C~ljlJf;{Ao.., rfi ~Q Notary Pu . My commission expires: q /I/D? COMMONWEALTH OF PENNSYLVANIA I Notarial Seal '\' cnnstina L Wdfe, Notary Public Carilsle Boro, Cumbef'land County l_~ Commission ExpireS ~~l1. 2008 . Memher, p"!nnsylvania ASSOCiation Of Notaries "BH\(6\\ ,\~l' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz October 20, 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, SWORN TO AND SUBSCRIBED before me this 20 day of October, 2006 ~~~.~. ...~ . ".,.NQtary-.",...,.,..,,,, ' ..'0' r,~ (} .'1 ,~-'- ;::, ':;\L,:~; E ;:~':, ~.. CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 06-4367 Civil Term WASHINGTON MUTUAL BANK SUCCESSOR IN INTEREST TO PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER RALSTON WALKER (mortgagor), DECEASED & CHANTE T. WALKER (real owner), DEFENDANTS NOTICE OF ACTION IN MORTGAGE FORECLOSURE To the Defendants, Unknown Heirs, Successors, Assigns, All Persons, Firms, or Associations claiming right, title or interest from or under Ralston Walker (mort- gagor), deceased and Chante T. Walker (real owner): TAKE NOTICE THAT the Plain- tiff, Washington Mutual Bank suc- cessor in interest to PNC Mortgage Corp. of America has fIled an action in Mortgage Foreclosure as cap- tioned above. NOTICE IF YOU WISH TO DEFEND, YOU MUST ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE YOUR DE- FENSES OR OBJECTIONS WITH THE COURT. YOU ARE WARNED TliAT IF YOU FAIL TO DO SO TIlE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU WITH- our FURTHER NOTICE FOR THE RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE TIllS NO- TICE TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AF- FORD TO HIRE A lAWYER, THIS OFFICE MAY BE ABLE TO PRO- VIDE YOU WITH INFORMATION ABour AGENCIES TliAT MAY OF- FER LEGAL SERVICES TO ELI- GIBLE PERSONS AT A REDUCED FEE OR NO FEE. lAWYERS REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013-3302 (717) 249-3166 ILANA ZION, ESQUIRE SHAPIRO & KREISMAN, LLC Attomeys for Plaintiff 3600 Horizon Dr. Suite 150 King of Prussia, PA 19406 (610) 278-6800 Oct. 20 11 ('} ~~ ~ c:::> cr o ~ c.:> - ~ :1'"f1 rn,';;=; 4"J~ ~:J ,~~" ,:~,:~(< ~(:'S~" ~~: rn (:) ::~ ;.0 :.<. -,., ..,.....- ......,.,.-;j#' ~*' -- -- -- - SHAPIRO & KREISMAN, LLC BY: LAUREN R. T ABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all NO:06-4367 CIVIL TERM persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $44,636.05 in favor of the Plaintiff and against the defendants, jointly and severally, for failure to file an answer to Plaintiff's Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid Interest at 5.625% from February 1, 2006 to November 21,2006 (294 days @ $6.09 per diem) Late charges (for certain months prior to default and every month after at a rate of $15.66 per month) Escrow Advance Property Inspections Mortgage Insurance Premium Title Search Report Fees Attorneys Fees (As stated in Complaint) TOTAL AMOUNT DUE $39,485.23 $1,790.46 Lauren. . a as, quire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant nd damages are assessed as above in the sum of $44,636.05. $140.94 $922.38 $35.60 $37.18 $250.00 $1,974.26 $4 36.05 06-27084 SHAPIRO & KREISMAN, LLC BY: KEVIN DISKIN, ESQ., LAURENR. TABAS,ESQ., AND ILANA ZION, ESQ. ATTORNEY J.D. NOS. 86727,93337 & 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 131 W. North Street Carlisle, P A 17013 and Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 DEFENDANT(S) STATE OF: ('YlN COUNTY OF: 01z..cAli, AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Washington Mutual Bank on behalf of Washington Mutual Bank successor in interest to PNC Mort age Corp. of America By: NAME: f)r,j l;)~. > TITLE: Assls ant Vice President ->. Sworn to and subscribed before me this ~ day of , 2006. , Notary Public SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D, NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORT ANT NOTICE TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased DA TE OF NOTICE: November 10, 2006 You are in default because you have failed to enter a written appearance personally or by attorney and me in writing with the court your defenses or objections tc! 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 fmd out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TillS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE U sted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted incorte 0 escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes, Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PAl 70 13 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TmS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Chante T. Walker (real owner) 131 W, North Street Carlisle, P A 17013 Ilana Zion,Esq ir Shapiro & Kreis an, LLC Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY tD, NO: PA Bar # 87137 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CNIL TERM VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Chante T. Walker (real owner) DATE OF NOTICE: November 10, 2006 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights . You should take this notice to a lawyer at once, If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TInS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE U sted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte 0 escuchar preuba alguna, dictar sentencia en su contra, Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 Hame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT TIDS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased . 93 B Street Carlisle, PA 17013 Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 Ilana Zion, Esq r Shapiro & Krei an, LLC Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY J.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM VS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, November 10, 2006 to the following Defendants: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 d~~sswmnt to IIana Zion, Esquire for Shapiro & Kreisman, LLC SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) DEFENDANTS NO:06-4367 CIVIL TERM CERTIFICATE OF SERVICE I, Lauren R. Tabas, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies ofthe attached papers upon the following persons or their attorney of record: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 Chante T. Walker (real owner) 131 W. North Street Carlisle, PA 17013 Date mailed:~ BY: aur n R. Tabas, Esquire Attorney for Plaintiff 06-27084 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURTOFCO~ONPLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NO:06-4367 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 and that the last known addresses of the judgment debtor (Defendants) are: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 BY: Lauren . Tabas, Esquire Attorney for Plaintiff 06-27084 t (:) -c,g.. N 7CJ ...0 g g Q ~ '1 . s- d"' \) -oIJ) a ~~ mft C> --;:::. ".1:.; ....r:: - -71- N r tr~_\:~.:', 'O~ --.. ..0 (") - ",,"""f""'" 2C.\:> ~ ....:) ~U ~"--~ :P" :c ::t~ p'''' ~,.*~ C)~ ~ " p:: :;;;~ (-."J ~ ~.,. ~ }:P'C:: 9 0 ~ ::::.t Z ~ -4 N ~ <.J'\ ~ ~ -=1. ~ 0 .... ~ ~ . . .. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 Curtis R. Long Prothonotary TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Washington Mutual Bank: successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) DEFENDANTS NO:06-4367 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below, Curtis R. Long Prothonotary .... [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY LAUREN R. TABAS, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Caption: PRAECIPE FOR WRIT OF EXECUTION Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America PLAINTIFF vs, Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment (x ) Other File No, 06-4367 Civil Term Amount Due $44.636.05 Interest November 22. 2006 to March 7. 2007 is $729.28 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Leaal Description PRAECIPE FOR ATTACHEMENT EXECUTION _ Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as f the defendant(s) described in the attached exhib~. ~ ~ ~ Date:J.l.:aD -O~ Signa ur . ~ Print Name: Lauren R. Tabas. Esquire Address: 3600 Horizon Drive, Ste.150 King of Prussia, P A 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 93337 ~ ~ i ~ ~ ~ ~ 8 t ~~~ ~ ~ (f) ~ .~ ~ ~ i ~ ~ u ~ ~ o 2'-Sz ft~. -'-I-:: ~2 ~o.. o:~ ~ CJ Lf) o - x: ..c:; s 1= t ., -; .~ .... - ~ ~"' .~ ~ )0< U i'C ~ ~ ~~ a"g i' ~e ~~ "iU at'.> ~! ii .S ~ -a~ ~ ~ '" (.'!oJ ::;.0 ~ ~ ~ ?:. -/ ?~ ~~~.~ -::; ,~;}~ ~~l~ -r~ --P ...'- L- uJuJ cD n.. ~ a t/1 > ~t ;;~~ 'd.t~ Q ~~ ~ ~ ~ = ~ "'. Q'd fA ... = ~. .= ~ .... .!! G\ "t f"l fAU~"'" ~ ~fA ~ Q =~....r+oOr- "'~_.....~~ t.~"9.~~~ ~~""'~~~ ~ .~ ::s ~ t/1 ~ ~-)o<U " U~~~~~ ~ i! a 'dO' ~ :a fA)o<~'i:' )0< t ~"' J: ~ ~ .~tlA1~ .c:I~)o<! =u::.$~ t $.e! .a=~ =e~ ';;) 8. ~ . ~~ , a.~ ... ~~~.. (l=-~ ~ () c o ::r '":1 CJi c-i 0 ~("C\\l ~ ~ ~ "t ~ "'+00 'i:'~f"l ~~~ =~Q J:t/1~ ~~.( ..t~ ~ ~ ... .:.. z ~ t~:a ~ ~ ;;~n ~~~ ~ .$ ~ e .... .... ~ , Q ::r ~ ~ o "Z' ~ ~ ~~~ """"'~ ~~ ~ ~ ';Ju ~ ~ ~~~ ~ ~ bI) U Q ~ ~ "'" ... "" .. " ... .. ... \ a g ~ . . ~~c'i .~ ~ "a i:1't' ~e J;! ~< ~'" ~\ !:l'a ~~ ~ ~ ~ ., ... - ~1 \) \) C lIJ I <) ('/ . ~ t'"- -- ~ ~ . ~...,. t-- ~ ~ -- 1 f1 -+ .~ ~ ~4: ~~ ~\: - ~'& WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4367 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK SUCCESSOR IN INTEREST TO PNC MORTGAGE CORP. OF AMERICA, Plaintiff(s) From UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER RALSTON WALKER (MORTGAGOR), DECEASED AND CHANTE T. WALKER (REAL OWNER) (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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $44,636.05 Interest 11/22/06 TO 3/7/07 IS $729.28 Arty's Comm % Arty Paid $173.20 Plaintiff Paid Date: NOVEMBER 29, 2006 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) em/J~.~~ By: Deputy REQUESTING PARTY: Name LAUREN R. TABAS, ESQillRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 . .- SHAPIRO & KREISMAN, LLC BY: LAURENR. TABAS,ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NO: 06-4367 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 93 B Street, Carlisle, P A 17013. 1. Name and address of Owners or Reputed Owners Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 Chante T. Walker (real owner) 131 W, North Street Carlisle, PA 17013 2, Name and address of Defendants in the judgment: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Chante T, Walker (real owner) 131 W. North Street Carlisle, PA 17013 .. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 4, Name and address ofthe last recorded holder of every mortgage of record: Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America, Plaintiff 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 93 B Street Carlisle, PA 17013 Internal Revenue Service Federal Estate Tax Chief Examination Division Group 1820 p, O. Box 12040 Philadelphia, P A 19105 Commonwealth of Pennsylvania Department of Revenue Inheritance Tax Division Bureau of Compliance Dept 280946 Harrisburg, PA 17128-0946 . . -.-., Michael Messina 93 B Street Carlisle, P A 17013 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. 06-27084 8 <" ~~ (j) ., <" r-' ~ ".;;:"~ . 'i'; '-..) - c- z =<! '" <::::> c--:;> C3"' Z o ...:::: N \.0 :=0- :Jt '2 (11 o ~ ~:rJ -oFTi e59 ~9 c".) -H :>-0 om ~ (.<. SHAPIRO & KREISMAN, LLC BY: LAURENR. TABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America PLAINTIFF vs. NO: 06-4367 CNIL TERM Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 Your house (real estate) at: 93 B Street, Carlisle, P A 17013 06-20-1798-051 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00am, to enforce the court judgment of $44,636.05 obtained by Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1, The sale will be cancelled if you pay back to Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800, 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings, ..... .. You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two of how to obtain an attorney, ) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling (610) 278-6800. 5 . You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390, 7, If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 9. You may be entitled to a share of the money, which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale, This schedule will state who will be receiving the money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 06-27084 . ALL THAT CERTAIN tract ofland situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, having thereon erected a single family dwelling house with mailing address of 93 B Street, the same being bounded and described as follows: ON THE South by B Street, on the East by lot now or formerly of George McKillit, on the North by a 13 foot alley, and on the West by property now or formerly of C, W, Whit's Trustees. CONTAINING 20 feet in front on said B Street and extending back at an even width 85 feet in depth to the aforesaid alley, having thereon erected a two story frame dwelling house and other improvements. BEING the same premises which Ralston Walker, married man, by Deed dated April 18, 2005 and recorded in the Cumberland County Recorder of Deeds Office on April 18, 2005 in Deed Book 269, page 2272, granted and conveyed unto Ralston Walker and Chante T. Walker, husband and wife. (") c ~ "1Ji.i mr'. -.....,-- zC ~;~~- <-~, ...." ~(" ~C2 .... c. z: =< r--.) = = C7"" Z c::> -c: ~ \D ~ :i!:o mFM a9 ~S 0- ~~ :"-I ~ ::7:JIo 3 9 Ul o ,~ " SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF vs. NO: 06-4367 CIVIL TERM Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Chante T. Walker (real owner) 131 W. North Street Carlisle, PA 17013 Your house (real estate) at: 93 B Street, Carlisle, P A 17013 06-20-1798-051 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00am, to enforce the court judgment of $44,636.05 obtained by Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America the amount ofthe judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney. ) -""' 1 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800, 5 . You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 9, You may be entitled to a share of the money, which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 1 O. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 06-27084 ..-. \ ALL THAT CERTAIN tract of land situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, having thereon erected a single family dwelling house with mailing address of 93 B Street, the same being bounded and described as follows: ON THE South by B Street, on the East by lot now or formerly of George McKillit, on the North by a 13 foot alley, and on the West by property now or formerly of C, W, Whit's Trustees. CONTAINING 20 feet in front on said B Street and extending back at an even width 85 feet in depth to the aforesaid alley, having thereon erected a two story frame dwelling house and other improvements. BEING the same premises which Ralston Walker, married man, by Deed dated April 18, 2005 and recorded in the Cumberland County Recorder of Deeds Office on April 18, 2005 in Deed Book 269, page 2272, granted and conveyed unto Ralston Walker and Chante T. Walker, husband and wife. g s: '-\ ~T !'T.. , "-:,7,.. "'"-. 7' (h3: ;::;. <:: ~t~~ - ~ ,....:) c::::> ~ Z o < N \D !:fi ~::n -o~ :P ~ ~~ ~ J:>o ~ ~ ~ s .. Ul o SHERIFF'S RETURN - REGULAR CASE NO: 2006-04367 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WALKER RALSTON UNKNOWN HEIRS HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE TENANT/OCCUPANT was served upon the DEFENDANT , at 0838:00 HOURS, on the 9th day of October ,2006 at 93 B STREET CARLISLE, PA 17013 by handing to POSTED PROPERTY AT 93 B STREET CARLISLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff1s Costs: Docketing Service Posting Surcharge 18.00 4.40 6.00 10.00 R. Thomas Kline .00_/ 38,407 10/11/2006 II/0I,Jot." SHAPIRO & KREISMAN So Answers: r~~ ~ Sworn and Subscibed to By: ~~;:~~ before me this day of A.D. ... SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. NO: 06-4367 CIVIL TERM Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANT(S) CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO P A R.C.P 3129.2 (C) (2) I, Heather Whitman, Legal Assistant for Shapiro & Kreisman, LLC, attorneys for the Plaintiff, Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on January 16, 2007, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C,P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S, Section 4904. Respectfully submitted, SHAPIRO & KREISMAN, LLC BY: ~\1L::-- Heather Whitman Legal Assistant 06-27084 .., ... 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CD '" '" Q. en (1) :J C. ~ ~~t~\~.! ~~\V.~ =~ :J5 it "''' ~~"E '" ~""~.5R~ to. ~ .~ ~~ g Z' -E-~ .~ ~1~1~! .-~.i ~~ l~ \ i~.$1.81 r~ ~~l~.~ =\~l~ ~~ ~ t8~~~ 1 ~l~~~ h\~Ul l=.~l~~~ ._~c:~€>!1 -giil~~.~ .\l~T~~"'9l. l~~ ..~$ e ~'S~~i8~ 6l!ll!.!I!~~"O ,min. .!I!~E $~!~J!l S lE \~ .1"! ~ ~ .t! ~ j~ ~ ~ :6 'i.~ e~l~l1~~ l~Hit\~ ~l'E$i-", -- ~ 0 c::> --n --J ...., :-1 rl1 .1- 11 w fl'p f11 I 0 I t-i >/; ~ ::.:::, ~ l.,~' C5tS ~;~ ~:\ W ::ij I""':> .< ,~, .1'" ~ ~ , , c SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF YS. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 06-4367 CIVIL TERM AFFIDAVIT OF SERVICE \, Heather Whitman, the undersigned, being duly sworn according to law, hereby depose and say that on the _29th_ day of _December, 2006, pursuant to the Order of Court, attached as Exhibit "A," I served a true and correct copy of the Notice of Sale in the above-captioned matter to the Defendant, Unknown Heir..:, listed below at the address provided by publication in a legal publication designated by the court fur the publication of legal notices and in one newspaper of general circulation within Cumberland County, Proof of said publications are attached as Exhibit "B." Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 SHAPIRO & KREISMAN, LLC BY: ~ \1J;~c__ Heather Whitman, Legal Assistant to Attorney for Plaintiff I he~eby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this Affidavit of Service is made subject to the penalties of 18 Pa. C,S, Sec. 4904 relating to unsworn falsification to authorities. - "'_,,-_...d '"'^-_ _'_.__-<,_".~'_ ";__~d' 2.......-"" SEP 2 1 2006 SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY J.D. NO: 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF BY; i , '-"_.J ./)...'. ~_../ ~_\ __ f. -'.) , -.....,~,' --_/' COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NO: 06-4367 CNIL TERM ORDER AND NOW, this $~ day o~e_pl:.e.~ , 2006, upon consideration of Plaintiffs Motion For Service Pursuant To Special Order Of Court and the Affidavit of Good Faith Investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure, Notice of Sale, and all subsequent pleadings that require personal service only, on Defendant Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, shall be complete when Plaintiff or its counselor agent has published a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale, or any subsequent pleadings in the legal publication designated by the Court for the publication of legal notices and in one newspaper of general circulation within Cumberland County and the Sheriff has posted a true and correct copy of the Complaint in Mortgage Foreclosure, Notice of Sale and or any subsequent pleadings on the most public part of the mortgaged premises located at 93 B Street, Carlisle, Pa 17013. TR,'!:~ ,..-~ _.~.. ~... ,~ ',! "ECORD . S2t my hand _Jr\isl , Pa. BY THE COURT: - ~L6.t \\At- PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tanuny Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being du1y sworn, deposes and says that THE SENTINEL, a newspaper of general circu1ation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) December 21, 2006 COpy OF NOTICE OF PUBLICATION OF Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are e. I Sworn to and subscribed before me this 27th. day of December 2006. C~;{?~ Notary Pu c My commission expires: q I t I C!8' COMMONWEALTH OF PENNSYLVANIA Notarial Seal amstlna L. WC'Afe. Nolary Public carlisle 80m, CUI11berland Camly MI CommIsSiOO ExpIreS Sepl1. 2008 . Member, Pennsylvania Association Of Notanes [Kkl~V t l~\GY' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz December 29,2006 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, , SWO 0 AND SUBSCRIBED before me this 29 day of December, 2006 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 . ,.. . CUMBERlAND LAW JOURNAL NOTICE In the Court of Conunon Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 06-4367 CML TERM Washington Mutual Bank. successor in interest to PNC Mortgage Corp. of America, PLAINTIFF vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor). deceased and Chante T, Walker (real owner). DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERlY TO: Unknown heirs. successors, assigns, and all persons. finns, or associations claim- ing right. title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle. PA 17013 Your house (real estate) at: 93 B Street, Carlisle. PA 17013, 06-20- 1798-051. is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County, Sheriffs Office. 1 Courthouse Square. Car- lisle, PA 17013 at 10:00 a.m., to enforce the court judgment of $44.636.05 obtained by Washing- ton Mutual Bank. successor in in- terest to PNC Mortgage Corp, of America against you. NanCE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TIllS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank. successor in interest to PNC Mortgage Corp. of America the amount of the judgment plus costs or the back payments, late charges. costs. and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278- 6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judg- ment. if the judgment was improp- erly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceed- ings. You may need an attorney to as- sert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an Attorney.) YOU MAY STILL BE j\BLE TO SAVE YOUR PROPERlY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4. If the Sheriffs Sale is not stopped. your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your prop- erty. 6. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out 7 . . . . CUMBERlAND LAW JOURNAL if this has happened you may call (717) 240-6390. 7, If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the prop- erty as if the sale never happened. 8. You have a light to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer may bring legal proceedings to evict you. 9. You may be entitled to a share of the money, which was paid for your house. A schedule of distribu- tion of the money bid for your house will be IDed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distri- bution is wrong) are IDed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of get- ting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATIEMPTING TO COILECT A DEBT. ANY INFOR- MATION OBTAINED WILL BE USED FOR THAT PURPOSE. LAUREN R. TABAS. ESQUIRE SHAPIRO & KREISMAN. LLC ATIORNEYS FOR PLAINTIFF 3600 Horizon Dr. Suite 150 King of Prussia. PA 19406 (610) 278-6800 Dec. 29 8 ~ c:::::> ::3 ...,., f"\ cP \ - ~ ..-\ :::t:--n "'e:. ~)~ ;:l.~,~) c r: ~~'\~. :..'() ,:::'rn :,~~ J-i) :..::: - C? c,,) - COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Washington Mutual Bank is the grantee the same having been sold to said grantee on the 7th day of March A,D., 2007, under and by virtue of a writ Execution issued on the 29th day of No v, A.D" 2006, out of the Court of Common Pleas of said County as of Civil Term, 2006 Number 4367, at the suit of Washington Mutual Bank against Chante T Walker is duly recorded in Deed Book No. 279, Page 1236, IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ;;u day of ~ J--O" 7 ,A.D. L. ~ ~ Xd-c ..-..4...~=~ Recorder ofDeeds Washington Mutual Bank, successor in Interest to PNC Mortgage Corp, of America VS Unknown heirs, successors, assigns, and all Persons, firms or associations claiming right, Title or interest from or under Ralston Walker (Mortgagor), deceased and Chante T. Walker (Real Owner) In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2006-4367 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 13,2006 at 1949 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Unknown heirs, successors, assigns, and all persons, firms or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, by posting the premises pursuant to order of court, located at 93 B Street, Carlisle, Cumberland County, Pennsylvania with the said true and correct copy of the same, according to law, Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on December 26,2006 at 1057 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Chante T, Walker (real owner), by making known unto Tyrone Williams, fiancee ofChante T. Walker and adult in charge, at 131 West North Street, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 17,2007 at 1609 hrs, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ralston Walker (mortgagor), deceased, located at 93 B Street, Carlisle, Cumberland County, Pennsylvania according to law, R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased, by regular mail to their last known address of93 B Street, Carlisle, PA 17013. This letter was mailed under the date of January 16,2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Chante T. Walker by regular mail to her last known address of 131 W, North Street, Carlisle, PA 17013. This letter was mailed under the date of January 16, 2007 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 March 07, 2007 at 10:00 o'clock A.M. He sold the same for the sum of $1,00 to Attorney Lauren R. Tabas, on behalf of Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America. It being the highest bid and best price received for the same, Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America, of 11200 West Parkland Ave., Milwaukee, WI 53224, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$926.96. . ' Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Posting Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30,00 18.18 15,00 15,00 30.00 10,00 .50 1.00 13.20 1.22 15,00 20.00 6.00 355,00 315.53 16.83 25,00 39.50 $ 926.96 1/ ~J21J(j? ~ so~ _ ~ . ~......~..tlC' '.1~~ R. Thomas Kline, Sheriff BY do~S~ Real Estate ergeant ~e1>>A 3D' (}O 1.8t> {!Je S 7 9..u f2u-. it; Ot;.tf;L, ,', 1 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY LD. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, P A 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANTS NO: 06-4367 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 93 B Street, Carlisle, P A 17013. 1, Name and address of Owners or Reputed Owners Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, PA 17013 Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 2. Name and address of Defendants in the judgment: Unknown heirs, successors, assigns, and all persons, firms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Chante T. Walker (real owner) 131 W, North Street Carlisle, PA 17013 , ' , , , 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Washington Mutual Bank: successor in interest to PNC Mortgage Corp, of America 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 4. Name and address ofthe last recorded holder of every mortgage of record: Washington Mutual Bank: successor in interest to PNC Mortgage Corp. of America, Plaintiff 1270 Northland Drive, Suite 200 Mendota Heights, MN 55120 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, P A 17013 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 93 B Street Carlisle, P A 17013 Internal Revenue Service Federal Estate Tax Chief Examination Division Group 1820 P. O. Box 12040 Philadelphia, P A 19105 Commonwealth of Pennsylvania Department of Revenue Inheritance Tax Division Bureau of Compliance Dept 280946 Harrisburg, PAl 7128-0946 Michael Messina 93 B Street Carlisle, P A 17013 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, BY. KREISMAN, LLC /' / 06-27084 . ' SHAPIRO & KREISMAN, LLC BY: LAUREN R. T ABAS, ESQUIRE ATTORNEY I.D, NO: PA Bar # 93337 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO, 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp, of America PLAINTIFF vs. NO: 06-4367 CNIL TERM Unknown heirs, successors, assigns, and all persons, finns, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T. Walker (real owner) DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Unlmown heirs, successors, assigns, and all persons, finns, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased 93 B Street Carlisle, P A 17013 Your house (real estate) at: 93 B Street, Carlisle, P A 17013 06-20-1798-051 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, P A 17013 at 1O:00am, to enforce the court judgment of $44,636.05 obtained by Washington Mutual Bank: successor in interest to PNC Mortgage Corp. of America against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1, The sale will be cancelled if you pay back to Washington Mutual Bank: successor in interest to PNC Mortgage Corp. of America the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due, To find out how much you must pay, you may call: (610) 278-6800, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause, 3. You may be able to stop the sale through other legal proceedings. . , ' You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney, ) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HA VB OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE, 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling (610) 278-6800, 5 , You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 6, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened you may call 717-240-6390, 7, If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you, 9 . You may be entitled to a share of the money, which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10, You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 06-27084 ALL THAT CERTAIN tract ofland situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, having thereon erected a single family dwelling house with mailing address of 93 B Street, the same being bounded and described as follows: ON THE South by B Street, on the East by lot now or formerly of George McKillit, on the North by a 13 foot alley, and on the West by property now or formerly of C. W. Whit's Trustees. CaNT AINING 20 feet in front on said B Street and extending back at an even width 85 feet in depth to the aforesaid alley, having thereon erected a two story frame dwelling house and other improvements. BEING the same premises which Ralston Walker, married man, by Deed dated April 18, 2005 and recorded in the Cumberland County Recorder of Deeds Office on April 18, 2005 in Deed Book 269, page 2272, granted and conveyed unto Ralston Walker and Chante T, Walker, husband and wife. . , . SHAPIRO & KREISMAN, LLC BY: LAURENR. TABAS,ESQUIRE ATTORNEY J.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO, 06-27084 Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America PLAINTIFF vs. NO: 06-4367 CIVIL TERM Unknown heirs, successors, assigns, and all persons, fIrms, or associations claiming right, title or interest from or under Ralston Walker (mortgagor), deceased and Chante T, Walker (real owner) DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Chante T. Walker (real owner) 131 W. North Street Carlisle, P A 17013 Your house (real estate) at: 93 B Street, Carlisle, P A 17013 06-20-1798-051 is scheduled to be sold at Sheriffs Sale on March 7, 2007 at: Cumberland County Sheriffs OffIce 1 Courthouse Square Carlisle, P A 17013 at 10:00am, to enforce the court judgment of $44,636.05 obtained by Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Washington Mutual Bank successor in interest to PNC Mortgage Corp. of America the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due, To fInd out how much you must pay, you may call: (610) 278-6800, 2, You may be able to stop the sale by f1ling a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two of how to obtain an attorney, ) . ~ .. YOU MAY STILL BE ABLE TO SA VB YOUR PROPERTY AND YOU HA VB OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 4, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800, 5 , You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 6. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened you may call 717-240-6390, 7. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 8. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you, 9 , You may be entitled to a share of the money, which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty (30) days from the date of the sale, This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 06-27084 ," ALL THAT CERTAIN tract ofland situate in the 5th Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, having thereon erected a single family dwelling house with mailing address of 93 B Street, the same being bounded and described as follows: ON THE South by B Street, on the East by lot now or formerly of George McKillit, on the North by a 13 foot alley, and on the West by property now or formerly of C. W, Whit's Trustees, CONTAINING 20 feet in front on said B Street and extending back at an even width 85 feet in depth to the aforesaid alley, having thereon erected a two story frame dwelling house and other improvements. BEING the same premises which Ralston Walker, married man, by Deed dated April 18, 2005 and recorded in the Cumberland County Recorder of Deeds Office on April 18, 2005 in Deed Book 269, page 2272, granted and conveyed unto Ralston Walker and Chante T, Walker, husband and wife, . . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4367 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due W ASIDNGTON MUTUAL BANK SUCCESSOR IN INTEREST TO PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s) From UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER RALSTON WALKER (MORTGAGOR), DECEASED AND CHANTE T. WALKER (REAL OWNER) (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 $44,636.05 Interest 11/22/06 TO 3/7/07 IS $729.28 L.L. $.50 Atty's Comm % Arty Paid $173.20 Plaintiff Paid Date: NOVEMBER 29, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, P A 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 Real Estate Sale # 67 On December 4, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 93 B Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 4, 2006 By: \jt~S~ Real E~ate Sergeant ~ ~ ~ ~ << , 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 smce; 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 24th and 31st day(s) of January and the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #67 M CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: January 26, February 2 and February 9,2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 67 Writ No. 2006-4367 Civil Washington Mutual Bank. successor in interest to PNC Mortgage Corp. of America vs. Unknown heirs. successors. assigns, and all persons. firms. or associations claiming right. title or interest from or under Ralston Walker (mortgagor). deceased and Chante T. Walker (Real Owner) Atty.: Lauren Tabas ALL THAT CERTAIN tract of land situate in the 5th Ward of the Bor- ough of Carlisle. Cumberland County. Pennsylvania. having there- on erected a single family dwelling house with mailing address of 93 B Street. the same being bounded and SWORN TO AND SUBSCRffiED before me this 9 dayof FebruarvL7 0:~:~~~A/ Lr'~;~ '~, '(" ;::rv l'")~,_lhl~C ~ fJ ~.:our.-:y ~ ~-: r ",dJC" r r ,] . .__,.,~""'~'-'-_"~' >.J " ~ -'.____~'l... __1 __ -C'_,,__