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HomeMy WebLinkAbout01-5457FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHiLADELPHIA, PA 19103-1814 (215) 563-7000 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, 1NC. 1111 NORTHPO1NT DRIVE COPPELL, TX 75019 Plaintiff DONNA LEE MCDERMOTT LURILLA L. PENSINGER WILLIAM E. DONICKER 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1F YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 033753860312 ! 10 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 1111 NORTHPOINT DRiVE COPPELL, TX 75019 The name(s) and last known address(es) of the Defendant(s) are: DONNA LEE MCDERMOTT LUR1LLA L. PENSINGER WILLIAM E. DONICKER 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 11/19/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1585, Page 467. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." The following amounts are due on the mortgage: Principal Balance Interest 11/1/00 through 8/1/01 (Per Diem $47.45) Attorney's Fees Cumulative Late Charges 11/19/99 to 8/1/0I Cost of Suit and Title Search Subtotal $155,956.53 13,001.30 4,000.00 0.00 550.00 $173,507.83 Escrow Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $173,507.83 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sherifl~s Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. §1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $173,507.83, together with interest from 8/1/01 at the rate of $47.45 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE TO: Donna Lee McDermott 1330 Williams Grove Road Mechanicsburg, PA 17055 Lurilla L. Pensinger 1330 Williams Grove Road Mechanicsburg, PA 17055 William E. Donicker 1330 Williams Grove Road Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the mortgage on your home is in default and the lender intends to foreclosure. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with you when you meet the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Nonce. Il'you have any quesnons, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN AD JUNTO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSiNG FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PAiL& UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. EXHIBIT "A" STATEtMENTS OF POLICY HOMEOWNER'S NAME(S): Donna Lee McDermott, Lurilla L. Pensinger, and William E. Donicker PROPERTY ADDRESS: 1330 Williams Grove Road, Meehanicsburg, PA 17055 LOAN ACCT. NO.: 033753860312110 ORIGINAL LENDER: Associates Home Equity Consumer Discount Company CURRENT LENDER:SERVICER: Citifinancial Mortgage Company, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. · IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, · IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND · IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty three (33) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed ai the end of this Notice THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice the lender may NOT take action a~ainst you Ibr thirty three(33) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counselin~ agencies for the county in which the properW is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender irrmaediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default lbr the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must ill[ out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty three (33) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, EORECLOSURE MA~ PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTiON-Available fi.~nds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Fmance Agency has sixty (60) days to make a decision after it receives your application. During that time. EXHIBIT "A" no lbreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY. THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply I~r Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brino. it up to date), X ~FURE OF THE DEE ',ULT-The MORTGAGE debt held by the above lender on your property located at: 1330 Williams Grove Road. Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS fur the lbllowing months and the following amounts are now past due: Start/End: 12/1/00 thru 8/1/01 at $1,490.16 per month. Monthly Payments Plus Late Charges Accrued $13,411.44 NSF: $0.00 hl~pccoou~. $0.00 Other: $0.00 (Suspense): $0.00 Total amount to cure default $13,411.44 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT-You may cure the default within THIRTY THREE {33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $13,411.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY THREE (33) DAY PERIOD. As of the date of this letter, you owe the amount specified above. Because of interest, late charges, and other charges that may vary from day to day, the amount due on the day that you pay may be greater. Hence, if you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned or call (215) 563-7000 and ask for the Reinstatement Department. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Federman & Phelan, LLP, One Penn Center at Suburban Station. Suite 1400. Philadelphia, PA .19103-1914. Attention: Reinstatment Department. You can cure any other delhuh by taking the following action ~ithin THIRTY THREE {33) DAYS of the date of this letter. {Do not use if not applicable.) N/A. IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default e, ithin THIRTY THREE(33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. The means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is nm made xx ithm THIRTY THREE (33) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure upon your morro;age property. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's l~cs that were actually recurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount to the lender~ which may also include other reasonable costs. If you cure the default within the THIRTY THREE (33) DAY period, you will not be required to pay attorney's fees. EXHIB!T OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by pavint~ the total amount then past due, plus any late or other char~es then due. reasonable attorne,~ 's tbes and costs connected with tile foreclosure sale and an,, other costs connected with the Sheriff's Sale as specified in writing by the lender and bi performing an,/other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Attorney Representing Lender: FEDERMAN & PHELAN, LLP One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Contact Person: Janette Mahoney EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. · TO HAVE THIS DEFAULT CURED BY ANY TH1RD PARTY ACTING ON YOUR BEHALF. · TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED LFNDER THE MORTGAGE DOCUMENTS · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER · TO SEEK PROTECTION UNDER THE FEDEILAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COL ~%'TY IS ATTACHED EXHIBIT "A" If this is the first notice that you have received from this office, be advised that: You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty three (33) days from the date of this letter, this firm will obtain and provide you with written verification thereof; otherwise the debt will be assumed to be valid. Likewise if requested within thirty three (33) days from the date of this letter, the firm will send you the name and address of the original creditor if difl~rent from above. Very truly yours, FEDEILMAN AND PHELAN, LLP Cc: Citifinancial Mortgage Company, Inc. Arm: Account No.: 0337538603121 I0 Mailed by 1~ Class mail and by certified Mail No: 7106 4575 1294 4772 1381 7106 4575 1294 4772 1374 EXHIBIT "A" PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY A~SISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) Lycomthg-Clthmn Count:es Commision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1323 Williamsport, PA [7703 (570) 326-0537 FAX (570) 322-2197 CGC$ of Northeastern PA 20l Basin Stree[ Williamspor[ PA 17703 (570) 323-6627 FAX (570) 323-6626 31 W Market Stree~ POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 CLINTON COUNTY COLUMBIA COUNTY Commission on Economics Opportunity of Luz~me County 163 Amber Lane Wilkes-Bame, PA 18702 (570) 8264)510 or (800) 8224)359 FAX (570) 829-1665--(Cali Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-563 b--(Call Before Faxing) (570) 8364090 Tunldlarmock Booker T. W~hington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (8[4) 5749 CRAWFORD COL ~'NTY lohn F Kennedy Center, [nc, 2021 East 20u' Street Erie, PA 16510 ($14) 898-0400 FAX (814) 8984243 CCCS of Weztem Pennsylvania, Inc. 2000 Lingle~town Road Harrisburg, PA 17102 (717) 541-1757 CUMBERLAND CO L ~%q'Y Urban League of Metropolitan Hanisburg N. 6u~ Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Corem of the Capital Region 1514 Derq' Street Hamsburg, PA [ 7104 (717) 232-9757 F.~X (717) 234-2227 CCCS of Northeastern PA 1631 South Atherton SL, Suite I00 State College, PA 1680t (814) 238-3668 FAX (8 [4) Z38-3669 1400 Abin~on Executive Park Suite 1 Clarks SummiL PA 1841 [ (570) 58%9163 or (800) 922-9537 F.-LX (570) 587-9134-9135 Grealer Erie Community Action Comminee 18 West 9~ Stceet Erie, PA 16501 (814)459-$581 F~X (814) 456416I Shenango Valley Urban Lea~e, Inc. 601 Indiana .&venue Far'tell, PA 16121 (412) 981-5310 Financial Counseling Services of Franklin 31 West 34 Street Waynesboro, ?A 17268 (717) 762-3285 YWCA of Carlisle 301 "G" Street Ca~lisle, PA 17013 . (717) 243-3818 F:LX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gem/sburg, PA 17325 (717) 334-1518 F,~LX 3344326 PENNSYLYANIA BULLETIN, VOL. 29, NO. ~, J~NE 5, 1999 EXHIBIT"A" ALL TI]AT CERTAIN piece or parcel of ground, situate ix: the Township of Monroe, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western right-of-way line of the Williams Grove Road, at corner of Green Lane, as shoval on the Plan of Lots hereinafter mentioned; thence by the right-or-way line of the Williams Grove Road, Soutl~ 00 degrees I 1 minutes 11 seconds West, two hundred twenty-five and twenty-four hundredths (225.24) feet to a point; thence by the dividing line between Lots Nos. 1 and 2 on said Plan, South 87 degrees 32 minutes 12 seconds West, nine hundred eighty and fifty-one hundredths (980.51) feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two hundred twenty-five ands twenty-nine hundredths (225.29) feet to a point on the southern line of Green Lane; theuce by the southern line of Green Lane, North 87 degrees 32 minutes 12 seconds East, nme hundred seventy-nine and for~y hundredths (979.40) feet to a point, tile place of BEGINNING. BEING Lot No. 1 in tile Plan of Lots of Frank E. Stoner, as recorded in plan Book Q36, at Page 106, Cumberfand County Recorder of Deed's Office. SUBJECT to setback lines as shown on said Plan. HAVING thereon erected a single dwelling house known and numbered as 1330 Williams Grove Road, Mechanicsburg, PA. BEING the same premises which Rosemary Marie Stoner, by her deed dated the 24t~' day of September, 1998, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book ff~O , Page ~_.~4_, Vol. ~ granted and conveyed unto William E. Donicker, LuRilla L. Pensinger, and Douna Lee McDermott, Grantors herein. VERIFICATION MICHAEL GRAHAM hereby states that he is ASSISTANT VICE PRESIDENT of CITIFINANCIAL MORTGAGE COMPANY, INC. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned tmderstands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: SHERIFF'S RETURN - C~SE NO: 2001-05457 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES HOME EQUITY CONSUME VS MCKERMOTT DONNA LEE ET AL REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MCDERMOTT DONNA LEE the DEFENDANT , at 1745:00 HOURS, on the 19th day of September, 2001 at 1330 WILLIAMS GROVE RD MECHANICSBURG, PA 17055 DONNA MCDERMOTT by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.85 Affidavit .00 Surcharge 10.00 .00 33.85 Sworn and Subscribed to before me this ~ ~- day of ~ ~rothonotary J ' So Answers: R. Thomas Kline 09/20/2001 FEDERMAN & SHERIFF'S RETURN - CASE NO: 2001-05457 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES HOME EQUITY CONSUME VS MCKERMOTT DONNA LEE ET AL REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PENSINGER LURILLA L the DEFENDANT at 9 WALNUT LANE at 1908:00 HOURS, on the 19th day of September, 2001 MECFL~NICSBURG, PA 17055 WILLIAM DONICKER by handing to BOYFRIEND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 6.50 Affidavit .00 Surcharge 10.00 .00 22.50 Sworn and Subscribed to before me this 2~~ day of A.D. I Prothonotary So Answers: R. Thomas Kline 09/20/2001 FEDERMAN &~h~e By: ri~f SHERIFF'S RETURN - ~ASE NO: 2001-05457 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES HOME EQUITY CONSUME VS MCKERMOTT DONNA LEE ET AL REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DONICKER WILLIAM E the DEFENDANT at 9 WALNUT LANE at 1908:00 HOURS, on the 19th day of September, 2001 MECHANICSBURG, PA 17055 by handing to WILLIAM DONICKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~l~~-- day of 'P~othonotary So Answers: R. Thomas Kline 09/20/2001 FEDERMAN & PHELANA By: ~~ ~h~riff FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 1111 NORTHI'OINT DRIVE COPPELL, TX 75019 Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : NO. 01-5457 CIVIL TERM Defendant(s). : PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DONNA LEE MCDERMOTT and LURILLA L.. PENSINGER AND WILLIAM E. DONICKER, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 8/1/01 to 10/25/01 TOTAL $173,507.83 $4,033.25 $177,541.08 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy att.ached. FRA~ FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ROeR Y (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 1111 NORTHPOINT DRIVE Plaintiff, Vo DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-5457 CIVIL TERM Notice is given that a Judgment in the above-captioned matter has been entered against you on 2001. DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE 1N BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** FEDERMAN AND PHELAN, L.L.P. 'Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY vs. : NO. 01-5457 CIVIL DONNA LEE MCDERMOTT LURILLA L. PENSINGER WILLIAM E. DONICKER Defendant (s) TO: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG,PA 17055 DATE OF NOTICE: OCTOBER 10,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERL~ COLrNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN 'Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff vs. DONNA LEE MCDERMOTT LURILLA L. PENSINGER WILLIAM E. DONICKER : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : N0.01-5457 CIVIL Defendant TO: WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: OCTOBER 10.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ZMPO You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMANAND PHELAN -Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff VS. DONNA LEE MCDERMOTT LURILLA L. PENSINGER WILLIAM E. DONICKER : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO.01-5457 CIVIL Defendant TO: LURILLA L. PENSIN~ER 9 WALNUT LANE MECHANICSBURG, PA 17055 DATE OF NOTICE: TOBER 10 2 01 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. i T N You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3 ! 66 F~ank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN ' By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 1111 NORTHPOINT DRIVE Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-5457 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DONNA LEE MCDERMOTT is over 18 years of age and resides at , 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055. (c) that defendants LURILLA L. PENSINGER AND WILLIAM E. DONICKER are over 18 years of age, and reside at, 9 WALNUT LANE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER No. 01-5457 CIVIL TERM Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest fi.om 10/25/01 to 3/6/02 (per diem -29.18) TOTAL $177,541.08 ~/ $3,851.76and Costs $181,392.84 FRANK FEDERMAlq, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. ALL THAT CI~TAIN piece or parcel of ground, situate in the Township of Monroe, County of Cumberland and Sure Of Pennsylvania, more particularly bounded and descn'bed aa follows, w wit: BEGINNING at a point on the Westa'a fight-of-way line of tho Williams Grove Road, at corner of Green Lane, as shown on the Plan of Lots her¢inaf~r mentioned; thence by rim right-of-way line of ~ Williams Grove Read, South 00 degrees 11 minutes 11 seconds West, two lnmdred ~went~-five and ~wenty-four hundredths (225.24) feet Io a point; thence by the dividing line bctween Lots Nos. 1 ..a 2 on said Plan, South 8'/degrees 32 minutes 12 seconds West, nine hundred ~igluy and fifty- ;ne hundredths (980.51) -feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two hu~lred twenty-five and twenty-nine hundredths (225.29) feet to a point on the Southern line of Green Lane; thence by the Southern line of Green Lane, North 8'/degr~s 32 minutes 12 seconds East, nine hundred seventy-nine and forty hundredrhs (979.40) feet to a point, thc place of BEGINNING. BEING Lot No. I in the Plan of Lots of Fra~ E. Stoner, as record~I in Pla. Book Q36, at Page 106, Cumberland County Recorder of D~d's Office. SUBJECT to sctback lin~s as shown on said Plan. HAVING thereon ~recled a dwelling known as 1330 Wllli9r°s Grove Road. TAX PARCEL NUMBER.: 2,2.11-0278-~18 Ti'YLE TO SAID PREMISES IS VESTED IN Luriilia L. PenSinger and Donna Lee McDen'mou, as joint tep_~ts with dght of survivorship by rc~tson of ~1~ following,: BEING the same pramises which Rosemary Marie Stoner, a sintle person by Deed dat~l 9/24/98 and recorded 12/2/99 in the County of Cumberland in R~ord Book 212 Page 490 conveyed unw William E. Donicker and Lurilla L. p~nsinger, both single persons as joint tenants and Donna Lee McDermott. AND ALSO BEING the same premises which William E. Donicker and Luri!la L. pensinger ina Domm Lee McDermott by Deed dated 10J25/00 and recorded 10/25/00 in the County of Cumberl!.d in Record Book 232 Page 2'/8 conveyed unto Lurillia L. pensinger and Donoa Lee NicDermou, as joint tenants with right of survivorship. ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 01-5457 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name DONNA LEE MCDERMOTT LURILLA L. PENS/NGER WILLIAM E. DONICKER Last Known Address (if address cannot be reasonably ascertained, please indicate) 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 9 WALNUT LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: 9 WALNUT LANE MECH.a2~CSBURG, PA 17055 DONNA LEE MCDERMOTT LURILLA L. PENSINGER WILLIAM E. DONICKER 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 9 WALNUT LANE MECHANICSBURG, PA 17055 9 WALNUT LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) CITIFINANCIAL, INC. 6520 CARLISLE PIKE, STE. 155 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 October 25, 2001 DATE I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-5457 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: 0 an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ASSOCIATES HOME.FQUITY CONSUMER DISCOUNT COMPANY, INC. ' Plaintiff, CUMBERLAND COUNTY No~. 01-5457 CIVIL TERM DONNA LEE MCDERMOTT : LURILLA L. PENSINGER AND WILLIAM E. : DONICKER : Defendant(s). October 25, 2001 TO: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER AND WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERT]( ** Your house (real estate) at ~ 1330 WMS GROVE ROAD~ MECFIANICSBURG, PA 17055~ is scheduled to be sold at the Sheriff's Sale on MARCH 6~ 2002 at 10:00 a.m. in the Cumberland County .." Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by ~ (the mortgagee) against you " ASSOCIATES ItOME EQUITY CONSUMER DISCOUNT COMPANY~ INC - If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. -' NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215} 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STII,I, BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE S~4F, RIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full mount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the mount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN piece or parcel of ~round, situate in the Township of Monroe, County of Cumberland and State of pmmsylvania, more particularly bounded and dascr~ed as follows, w wit: BEGINNING at a point on the Western ri~hI-of-way ~ of ~ Wil!~,~, C-~ov¢ Road, at c~rner of Green T~e, Si shown on rile Plan of Lots hc-rcinaftcr mentioned; thence by the right-of-way line of the Williams Grove Road, South 00 d~grees 11 m!",,v~ 11 seco~d~ Wast, two hundred twerp-five and twenty-four hundredth~ (225.24) fe~'t m a point; thence by the dividinl line between Lots Nos. 1 and 2 on said Plan, South 87 d~-~rees 32 minut~ 12 so;onds West, nine hundred ~igl~'y and o~z lmn~edths (980.51) feet to a point; thence North 00 de/r~s ~28 mlmltes 00 seconds ~a.st, two hundred ~wsnty-five and ~w~y-~ine hu~kedt~ (22~.29) feet to a point oa rl~ Southern line of Gree~ ! ~e; thence by the Southern line of C.~,een Lane, North 87 de/r~s 32 mlnlRes 12 second$ Ea~, ~ hundred seven~y-vin~ and forv] hundredths (979.40) feet ~o a point, the place of BEGINNIN(}. BEINO Lot No. 1 in the Plan of Lo~s of Frank E. Smn~r, as r~orded in Plan Book Q36, at 10/i, O_~herland Counv] Record~ of D~'~l's Office. SUBIECT to setback ~ as shown on said Plan. HAVING thereou erected a dw'411ng known as 1330 Williams ~rove Road. TAX PARCEL NUMBER: 22-11-02/8-078 TITLE TO SAID pREMISES IS VESTED IN Lmillia L. peter ired Do~-~ Lee McDermott, as jo~t ~ ~ d~t of ~o~hip by ~n of ~ fo~ow~: ~a ~ 121~99 ~ ~ Co~ of ~ ~ ~ ~k 212 ~e 4~ conv~ ~ W~ E. Do~ ~ L~ L. P~, ~ ~ile ~ ~ jo~ ~ ~ ~ ~ M~e~o~. ~ ~O B~G ~ s~e p~ w~ W~ E. Do~ ~ L~ L. Pe~r Do~ ~ McD~ by D~ ~ 10~/~ ~ ~ 10~/~ ~ $e ~ of ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, l~lC. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER Defendant(s). CUMBERLAND COUNTY No. 01-5457 CIVIL TERM October 25, 2001 TO: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER AND WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 **THIS FIRM IS`4 DEBT COLLECTOR `4TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBT`4INED YeTLL BE USED FOR TH`4 T PURPOSE. IF YOU H`4 VE PREVIOUSLY RECEIVED ,4 DISCH,4RGE IN B,4NKRUPTCY AND THIS DEBT I, K4S NOT RE,4FFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ,4N ,4TTEMPT TO COLLECT/1 DEBT, BUT ONLY ENFORCEMENT OF ,4 LIEN ,4G,4INST PROPERTY. ** Your house (real estate) at, 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055~ is scheduled to be sold at the Sheriffs Sale on MARCH 6 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC. (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STH,L BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTItER RIGHTS EVEN IF THE ~qI~ERIF/PS SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling ~. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full mount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (8O0) 990-9108 ALL THAT C]/RTAIN piece or parcel of/wu~, siame ia the Township of Monroe, County of Cumber[and and $~ate of p~unsylvania, more particularly bounded and described as follows, m BEGINNING at a poin~ on ~c Western fil~n-of-way liae of the W~!~ms C.~ovc Roatl, at comer of Green Lane, as shown on d~e Plan of Lots hereinafter mentioned; thence by file r~_aht-of-way line of de~rees 11 minnr_~ 11 seconds West, two Imn/ked hyena-five the Williams Grove Read, South 00 - ,~- ~,~ the dividin/line bct-ween Lo~ Nos. 1 one hunctrcdths (980.51) fce~ to a point; thence North 00 degr=es 2S mlr, u~cs 00 seconds Fast, two a~i twen~-ni'~e hundredths (22~.29) feet to a point on the Southern linc of hundred ~wenU-five Southern line of Green Lane, North 87 degrees $2 ~ 1~ seconds Green ! ~e; thence hy the F~, ninc hundred seven~y-dne and for~ hundredths I~.~O) feet to a point, thc placc of BEIN~ Lot No. 1 in r~ Plan of Lots of Frank £. Stoner. as recorded ia Plan Book (~t, at Page I0/~, O~''~herland Coun~ Recorder of Dced'$ Office. SURFECT to setbaclc lines as shoWU on sa/d Pl~u. HAVING thereon erected a dwclliag known a~ 1330 Will/a~ C.-wve Road. TAX PARCBL ~: 22.11-0278-078 ~ IN Lurillia L. pcn,~iager and Do,ua Lee McDcrmou, as TITLE TO SAID p~S~ IS of ~ fo~ow~i: jo~ ~ ~ d~t of ~vo~ by B~G ~ ~e pr~s~ wM~ ~ ~ Sw~, a ,ingle ~ by ~ ~ 9~98 ~ ~o~ 1~99 ~ ~ C~ of C~ ~ ~ ~k 212 P~e 4~ conv~ ~ W~ E. Do~ ~ ~ L. P~, W~ ~le ~m ~ jo~ ~ ~ ~ TM ~ ~ 10~/~ ~ ~ ~ of D~ ~ McD~O~ by D~ ~ 10t~1~ p~ ~ ~ ~ C~ ~ ~ ~k ~2 ~c ~78 ~nv~ ~ ~h L. McD~, ~ jo~ ~ wi~ d~t of ~v~h¥. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 56~-7000 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. VS. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DMSION CUMBERLAND COUNTY No.: 01-5457 CWIL TERM AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE Pl IR RI IANT TO P g C.P. 404(9)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriffs Sale was made by sending a true and correct copy by certified mall to Defendant, DONNA LEE MCDERMOTT at 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055, which notice of Sheriffs Sale was received by Defendant, DONNA LEE MCDERMOTT on 11/01/01 as evidenced by the attached return receipt. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unswom falsification to authorities. FRANI~ FEDERMAN, ES/QUIRE Date: November 27. 2001 AlqqDA%'~IT OF SERVICE PLAINTIFF ASSOCIATF~ HOME EQUt't'Y CONSUMER DISCOUNT COMPANY, INC. DEFENDANT(S) DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER SERVE LURILLA L. PENSINGER AT 9 WALNUT LANE MECH~aNICSBURG, PA 17055 CUMBERLAND COUNTY No, 01-54b'7 ClXqL TERM ACCT. ~k~0337538603'12110 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 6, 2002 SERVED Served and mada known to ~O~.;l[a I~. f~M$;~-~-. , Defendant, on the of Pe~ylv~a, ~ ~e ~er described ~low: day of ~J~ V. ,200~ , Commonwealth Defendant personally served. ' --n~5~-Adult family member with whom Defendant(s) reside(s). Relationship is Cc, - ~ ~o; ~ ~ ~. '~'-, Adult in charge of Defendam(s)'s residence who refused to give name or relationship. __.Manager/Clerk of place of lodging in which Defendant(s) reside(s). __ Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age I/O,6) )~5 Height ~'8 '~ Weight /~-6) Race ~ Sex /34 Other I, d~ e loc e. ~,, C*~.~( t '-~'-e.. , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of me Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at e address indicated abov1. NOTA~? Se&L ~wom to aha sunscribed I ChamNgl~r~ Bar0, Franklin ~ I ,~, ~ befor, e, methi,s /~'~'-daYl [~/C~mmi~Y. K0i~[~l~ll~ I ~.a/ ffff~ \ of/q/~get'n~n.,200J. ~.~ I b'lA.,,~aa ~ri,. i ?~.9~ 9~ No y: By: V NOT SERVED On the day of ,200__, at __ Moved __ Unknown__ No Answer o'clock __.rn., Defendant NOT FOUND because: __ Vacant Other: Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorne for Plaintiff Frank Federman, Esquire - IA). No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 PLAIN:I'IFF DEFENDANT(S) AFFIDAVIT OF SERVICE ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER SERVE WILLIAM E. DONICKER AT 9 WALNUT LANE MECHANICSBURG, PA 17055 CUMBERLAND 6OUNTY No. 01~5457 CIVIL TERM Type of Action ~ Notice of Sheriff's Sale Sale Date: MARCH 6, 2002 SERVED Served and made known to [,~u~2: ~, 0O~,/;C_IQ~(~ .Defendant, onthe of Peansylvania, in the manner described below: Defendant personally served. ' Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. day of /~1/. ,200Z , Commonwealth Description: Age ~O gA~ , ,! Height ~ Weight /~0 Race {,0 Sex ~ O~er I, ~e ~ c~ ~, ~ / ~, a coherent adul~ berg d~y sworn accord~g ~o law, depose ~d s~te ~t I perso~lIy h~ded a ~e and co~ect copy of~e No~ce of Shefi~s Sale in ~e ~er as set fo~ h~re~ issued ~ the captioned case on ~e date ~d at · e ad.ess ~dicated abov&' ~, 1 NOT~ .; ' I / ANNE G. 80a, , ,'y Pu~c Swomto andsubsc~bed / ~m~mBo;~ ~rafi~,,-~-.,~. · a ~ . ~ beforeme~s /~v[ ~v~'l.z.~'~ ] ........... NOT SERVED On the day of __ Moved __ Unknown__ ,200._., at . No Answer o'clock __.m., Defendant NOT FOUND because: __ Vacant Other: Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (~lS) s~'~-TOnn ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. VS. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-5457 CIVIL TERM AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE Pl ~R~qI IANT TO P.R (~ P. 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attomey for Plaintiff, hereby certifies that service of the Notice of Sheriffs Sale was made by sending a true and correct copy by certified mail to Defendant, DONNA LEE MCDERMOTT at 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055, which notice of Sheriffs Sale was received by Defendant, DONNA LEE MCDERMOTT on 11/01/01 as evidenced by the attached remm receipt. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unswom falsification to authorities. Date: Nnvemher 20. 200] SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. No.: 01-5457 CIVIL TERM VS. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiffin 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: 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. February 26, 2002 FRAN~ FED~EqRM~, ES'~UIRE Attorney for Plaintiff ASSOCIATES HOME, EQUITY CONSUMER DISCOUNT COMPANY, INC. ~ Plaintiff, ¥. DONNA LEE MCDERMOTT : LURILLA L. PENSINGER AND YVILLIAM E. : DONICKER : Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit' No. 1) CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION NO. 01-5457 CIVIL TERM ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for thc Writ of Execution was filed the following information concerning the real property located at ~1330 WMS GROVE ROAD~ MECHANICSBURG~ PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER 9 WALNUT LANE MECHANICSBURG, PA 17055 WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER 9 WALNUT LANE MECHANICSBURG, PA 17055 WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Hal'ne Last Known Address (if address cannot be reasonably ascertained, please indicate) NoBe. 4. Name and address of last. recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CITIFINANCIAL, INC. 6520 CARLISLE PIKE, STE. 155 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Nanle Las{ Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: maine Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 1330 W'MS GROVE ROAD MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Weffare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. October 25 2001 ~A&~L ~ ~x~_l DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DATE: TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND V~LLIAM E. DONICKER PROPERTY: 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 6~ 2002, at 10:00 a.m. in Cumberland County Courthouse~ South Hanover Streeh Carlisle~ PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriffon a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, 1NC. No.: 01-5457 CIVIL TERM VS. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE 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: 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached February 26, 2002 FRANk FED-~RMAX~, ESQUIRE Attorney for Plaintiff STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert: P Ziegler ............................................................................. Recorder of Deeds in amd for said County amd State do'hen:by certify that the SherlWs Deed in which ................ Citifinanc£al Mtg Co .................................................................................... is the grantee 6th the same having been sold to said grantee on the ............................................... day of March ' 2002 ........................................ A. D., ~ ..... , under and by virtue of a writ .............. Execution 29th ................................................ issued on the ..................................... October 2001 dayof .......................... A.D., ..... ~ out of the Court of Commam Pleas o~sald County~as of Civil .................................................................................. Term, ' . ..... ' 5457 Associates Home Equity C D C Inc Number .............. , at the suit of ............................................................... Donna Lee ~CD~mott ~ur$1~a L Pensinger ................................... ~inst .................................................... is 252 273 duly reoorded in Sheriff's Deed Book No ............. , Page ............. 2001 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ........... day o, ........ ............ A. Associates Home Equity Consumer Discount Company, Inc. VS Donna Lee McDermott, Lurilla L. Pensinger and William E. Donicker In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5457 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 06, 2001 at 11:28 o'clock A.M., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Donna Lee McDermott, by making known unto Donna Lee McDermott personally, at 1501 Williams Grove Rd., Lot g4, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said hue and correct copy of the same. Michael Bardck, Deputy Sheriff, who being duly sworn according to law, states that on November 06, 2001 at 11:44 o'clock A.M., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Lurilla L. Pensinger, by making known unto Lurilla L. Pensinger personally, at 9 Walnut Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said hue and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 06, 2001 at 11:44 o'clock A.M., EST, he served a hue copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: William E. Donicker, by making known unto Lurilla L. Pensinger, adult in charge, at 9 Walnut Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said hue and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2002 at 4:55 o'clock P.M., E.S.T., he posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna Lee McDermott, Lurilla L. Pensinger and William E. Donicker located at 1330 Williams Grove Road, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Donna Lee McDermott, by regular mail to her last known address of 1501 Williams Grove Rd., Lot g4, Mechanicsburg, PA 17055. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Lurilla L. Pensinger, by regular mail to her last known address of 9 Walnut Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: William E. Donicker, by regalar mail to his last known address of 9 Walnut Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. r. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Frank Federman for Citifinancial Mortgage Company. It being the highest bid and best price received for the same, Citifinancial Mortgage Company of 1111Northpoint Drive, Coppell, TX 75019, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $1,000.00, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 3.93 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 18.85 Certified Mail 2.32 Levy 15.00 Surcharge 40.00 Law Journal 395.60 Patriot News 347.10 Share of Bills 24.20 Distribution of Proceeds Sheriff's Deed 25.00 26.50 $1,000.00 paidby attorney 5/29/02 Sworn and subscribed to before me This/,2 ~ day of ~ 2002, A.D. (~_ ~. )Jt~t.~ P'ro{honotary R. Thomas Kline, Sheriff Real Es'late Deputy ~SSOCIATES HOME EQUITY CONSUMER .. 'DISCOUNT COMPANY, INC. Plaintiff, DONNA LEE MCDERMOTT LURILLA L. PENSLNGER AND WILLIAM E. DONICKER Defendant(s)· CUMBERLAND COUNTY COURT OF coMMoN PLEAS CIVIL DMSION NO. 01-5457 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavii No. 1) ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~1330 WMS GROVE ROAD~ MECHANICSBURG~ PA 17055 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER 9 WALNUT LANE MECHANICSBURG, PA 17055 WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD M~CHANICSBURG, PA 17055 LURILLA L. PENSINGER 9 WALNUT LANE MECHANICSBURG, PA 17055 WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Nolle. 4. Name and address of last recorded holder of every mortgage of record: Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) CITIFINANCIAL, INC. 6520 CARLISLE PIKE, STE. 155 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Narne Last' Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 1330 WMS GROVE ROAD M~CllANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are mae and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. October 25, 2001 ~3~L 4 ~L~ -J DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, ¥. DONNA LEE MCDERMOTT LURILLA L. PENSINGER AND WILLIAM E. DONICKER CUMBERLAND COUNTY No. 01-5457 CIVIL TERM Defendant(s). October 25, 2001 TO: DONNA LEE MCDERMOTT 1330 WMS GROVE ROAD MECHANICSBURG, PA 17055 LURILLA L. PENSINGER AND WILLIAM E. DONICKER 9 WALNUT LANE MECHANICSBURG, PA 17055 **THIS FIP. M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 1330 WMS GROVE ROAD~ MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on MARCH 6 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by "' ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC. (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHER.[FF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STII,L.BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SAI,~, DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be ~ntitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 parcel of g~oun~, simam in ~ Tow,,~h~ of Monroe, Com~ of A~ ~T C~T~ pi~ o~ ~ p~cu~ly ~,~d~ ~ ~ ~ ~, m ~: C~b~l~d ~ S~ of p~lv~a, BEGgiNG at a ~ on ~ We~ fi~f-~Y ~ of ~ WHI~*~' ~ovc ~, ~ ~ of O~ ~e. ~ shown on ~e P~ of ~ts ~e~ ~on~; ~ by ~ gibber'waY ~ of ~e W~i~ms Grove ~, Sou~ ~ ~ees 11 ~ 11 seco~s We~, ~o ~ ~-five ~ ~-fo~ h~ (~.24) f~ w a po~; ~nce by ~ ~ ~e bc~een ~ N~. l o~ ~cd~ (980.51) .f~t to a point; ~ce No~ ~ ~ ~ ~{~t~ ~ s~ ~, ~o h~ ~-five ~ ~-~ ~ (~.29) f~t w a po~ on ~ ~u~ ~ of Gr~ ~; ~e by ~ Sou~ ~ of ~ ~, No~ 87 ~ 32 ~in~ 12 s~ ~, ~ ~ud seven~-~ ~d ~ h~ (~9.~) feet w a po~;, ~ P~ of BEG~O. B~O Lot No. 1 ~ ~e V~ of ~ of F~,k E. Sm~, ~ ~o~ ~ ~ ~k ~6, a ~ge 105, O,m~rl~ Cou~ ~ of ~'s Office. SUBJECT to setback lines as shown on said Plan. HAVING thereon erected a dwelling known as 1330 Williams Grove Road. TAX PARC]~ NUMBER: 22.11-02'78..0'78 TiT-LiE TO SAID PREMISES I,S VEqTED IN Lurillia L. Pensi~e'r and Douaa Lee McD~:mou, as joins u~u~,n~s with d/.ht of survivor~,{l', by t-~,,.~.,u of the followin$: BF_ING th~ same premises which Roscma~ Made Stoner, a dna. ie person by Deed dated 9/24./98 aud. ~,o~ed 12/2Y99 in tt~ Coumy of Cumberla~ in Reco~d ]Book 212 Pa~e 4g0 conveyed unto William I/. Donicker and Lurilla L. pcnsin/er, boll~ single pe~ons as joint t~nts and Dom~a L~ McDennou. AND ALSO BI~ING th~ same premises wh/ch William E. Donir, J~r and Luff!la L. Donna Lee McDermott by Deed dated 10/25/00 and ~.corded 10/25/00 in the C, oumy of Cumberland in l~cord Book 232 Page 278 conve~ed unto Lurillia L. pe~sin/e~ ~d Donna Lee McDe~ou, as joint ~_~n~s with ~i/ht of sur~ivo~hL°. WRIT OF EXECUTION and/or A'I-I'ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy the debt. interest and costs due C~.= =_ny, !Nc_ lrom NO. 01-5457 CIVIL Ii~X %"ER'4 CIVIL ACTION - LAW COUNTY: A~nc~R~-~m Hcrn~ ~c~]~t~. Const~aer Discot.Ln-t PLAINTIFF(S) Donna Lee McDermott, 1330 Willi~ns Grove Road, Mechanicsburg, PA 17055 Lurilla L. Pensinger and Willian E. Donicker, 9 Walnut Lane, Me®hanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Lec~al 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 gamishee(s) is/are enjoined from paying any debt to or for the account of lhe defendant(s) and from delivering any property of the defendant(s) or othe~vise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possessionof anyoneolher than a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and Is enjoined as above stated. Amount Due $177,541.08 Interest frcm 10/25/01 to 3/6/02 (per deim - Atty's C0m~9'18) $3,851.76%and Costs Arty Paid $144_ 35 Plaintiff Paid t.t. $.50 Due Prothy $1.00 Other Costs ~s R. Lopg Date: October 29, 2001 REQUESTING PARTY: Name Prothonotary, Civil Division Frank FedeIman, Esq. One Penn Center at Suburban Station Address: ............... -~-- =~,~-~-,',~ Suite 1400 Philadelphia, PA 19103-1814 A~orney for~ Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 REAL ESTATE SALE No. 1~ On November 01, 2001, the sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, known and numbered as 1330 Williams Grove Road, Meehanicsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 01, 2001 Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by thc local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, be~n 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 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are tree. Writ No. 2001-5457 Civil Associates Home Equity Consumer Discount Company, Inc. VS. Donna Lee McDermott Lurala L. Pensinger and William E. Dordcker Atty.: Frank Federman ALL THAT CERTAIN piece or par- cel of ground, situate in the Town- ship of Monroe. County of Cumber- land and State of Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at a point on the ~stern right-of-way line of the Wil- liams Grove Road, at corner of Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBR ARY 2002 LOIS E. SNYDER, Notary Public Cadi~ Boro, Cumberland County THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The 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 Da '~Miscellaneous Book "M", Volume 14, Page 317. ~~f/p~ PUBLICATION CO P Y Sworn to and s~bscribed befor ruary 2002 A.D. I No~flal ,Seal Ha~l~u~g. Oaup~n Co~nW - - ~- - My C_~ E~mS Juae 6, 2002, N(~TA RY PUBLIC · Menfoer, Pennsylvania Assoclati~ol N~aries My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Totat $ 345.60 $ 1.50 $ 347.10 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of ~and Th n P tri t-N , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.