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HomeMy WebLinkAbout06-7123IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. I hereby certify that the address of Plaintiff is: 4600 Regent Blvd., Suite 200 Irving, TX 75063 the last known address of Defendants is: 22 South 4`h Street Halifax, PA 17032 GRENEN & BIRSIC, P.C. CIVIL DIVISION NO.: 06-7123 CIVIL TERM TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Deanna E. Hoffinan and John T. Hoffman, in the amount of $23,565.71, which is itemized as follows: Principal $15,972.57 Interest to 3/1/07 $ 2,638.36 Late Charges to 3/1/07 $ 133.28 Corporate Advances $ 1,071.50 Attorney's fees $ 15250.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $235565.71 with interest on the principal sum at the rate of $5.80 per from March 1, 2007, and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. GRENQk& BIRSIC, P.C. BY3?A os? A. Fi er, squ ? fornevs for Plaintiff • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Joseph A. Fidler, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendants were not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Sworn to and subscribed before me this I ? day of ?J? 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Ptd ffC City Of Pittsburgh, Allegheny Cour?jl My Commission E)ires June 2,2W7 Member, Pennsylvania Association Of N OWIes IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TO: Deanna E. Hoffman 22 South 4' Street Halifax, PA 17032 DATE OF NOTICE: February 16, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street, Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAEL, POSTAGE PREPAID GRENEN,& BIRSIC, P.C. Attor eys for Plaintiff O101 Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 0 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TO: John T. Hoffman 22 South 4' Street Halifax, PA 17032 DATE OF NOTICE: February 16, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association .32 S. Bedford Street, Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. ( ?W Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 ? g w 3 r, s r _TJ s-v r? r ?i co CD ro co T- -T yt r3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Deanna E. Hoffinan 22 South 4`h Street Halifax, PA 17032 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ate? ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $23,565.71 with interest on the principal sum at the rate of $5.80 per diem from March 1, 2007 and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: John T. Hoffman 22 South 4cn Street Halifax, PA 17032 ( ) Plaintiff (XX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $23,565.71 with interest on the principal sum at the rate of $5.80 per diem from March 1, 2007 and additional late charges, additional reasonable and actually incurred attorneys' fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the mortgaged premises. &471?; '`' A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Mortgage Electronic Registration Systems, INc., as Nominee for American Rome Mortgage d/b/a American Home Mortgage Servicing, Inc. VS. Deanna E. Hoffman and John T. Hoffman TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment (xx ) Other File No. 06-7123 Civil Term Amount Due $23,565.71 Interest $ 640.06 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) See Attached Description County, . PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of 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). 17 (indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name: Joseph A. Fidler Address: Attorney for: Telephone: Supreme Court ID No.: One Gateway Center, 9th Floor Pittsburgh, PA 15222 Plaintiff (412) 281-7650 87325 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). e1 If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. 0 •? U) w arJ QS 1 C) C'z1! CO -+4 ' A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five-tenths (198.5) feet to a point marked by an iron pin; thence South eighty- two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five-tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401- 403 Front Street, West Fairview, Pennsylvania. i, BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffinan, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffinan and Deanna E. Hoffinan, husband and wife. GRENEN &/BIRSIC, P.C. A. Fidler, Esquire ;vs for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7123 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN HOME MORTGAGE D/B/A AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff (s) From DEANNA E. HOFFMAN AND JOHN T. HOFFMAN (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 $23,565.71 Interest $640.06 Atty's Comm % Atty Paid $254.21 Plaintiff Paid Date: MARCH 8, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curtis . Long, Pr notary By: Deputy REQUESTING PARTY: Name JOSEPH A. FIDLER, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone : 412-281-7650 Supreme Court ID No. 87325 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. CIVIL DIVISION NO.: 06-7123 CIVIL TERM AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Joseph A. Fidler, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 401-403 Front Street, West Fairview, Pennsylvania 17025 are, Defendants, Deanna E. Hoffman and John T. Hoffman, who reside at 22 South 4`h Street, Halifax, Pennsylvania 17032, to the best of his information, knowledge and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS ` DAY OF \AOn C- , 2007. ALOCOMMONWEH P&Wtt LVANIA Notarial Seat Patricia A. Townsend, Notary Pubic City of Pittsburgh, Altegheny County My Cortxnission EMm June Z, 2W7 Member. Pennsylvania Asscxiarnn Of NoWies C ice, ---Y 4 - - ..y-• . ? } NI ?''? ,?yo •w - ? -33 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S.101, ET. SEQ. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Joseph A. Fidler, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that on October 27, 2006, Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 by certified mail, return receipt requested, and first class U.S. Mail. Plaintiff was not required to send Defendants separate Notices of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. §101, et seq., as a result of sending the Act 91 SWORN TO AND SUBSCRIBED BEFORE ME THIS _ DAY OF , 20 De- NotaPublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Pattma A. Townsend, Notary Public City Of Pittsburgh, Alleg WN County My Commission Expires June 2, 2007 Member, Pennsylvania Association Of Notaries wr ,_l.. ari r _ 1 S `'"ro IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffinan and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffinan and John T. Hoffinan 22 South 4`h Street Halifax, PA 17032 2. The name and address of the defendants in the judgment: Deanna E. Hoffinan and John T. Hoffinan 22 South 4t' Street Halifax, PA 17032 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 401 Front Street West Fairview, PA 17025 Tenants 403 Front Street West Fairview, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. ose A. Fidler, Esquire ' A rney for Plaintiff SWORN to and subscribed before me this ? day of r Y ?A y \\ 52007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary PubIC City of Pittsburgh, Allegheny County L My Commission Expires June 2.2007 Member, Pennsylvania Associatjon Of Notaries 71: -TI C l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Deanna E. Hoffinan 22 South 4 h Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 13, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffman are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, VS. Deanna E. Hoffman and John T. Hoffman, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $24,205.77. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENE)'& BIRSIC, P.C. B Jo h A. Fidler', Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five-tenths (198.5) feet to a point marked by an iron pin; thence South eighty- two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five-tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401- 403 Front Street, West Fairview, Pennsylvania. a BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffinan, husband and wife. GRENEN "IRSIC, P.C. B A. Fidler, Esquire ;vs for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 C-0 CX) A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John T. Hoffinan 22 South 4th Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 13, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. -0 -A The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, vs. Deanna E. Hoffman and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $24,205.77. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIRSIC, P.C. sep Fidler, Esquire Att ey for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five-tenths (198.5) feet to a point marked by an iron pin; thence South eighty- two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by aniron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five-tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401- 403 Front Street, West Fairview, Pennsylvania. .4 BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN &AIRSIC, P.C. dose A. Fidler, Esquire AfTorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 ?» ?? ?_ ?., .tee l _ ?"'? ?,? `d -%? : i ? j ?ryJ ?, i _ l f ..,?.i `?,. _, k ? ?;,? .?:? r<? "-< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: MORTGAGE SERVICING INC. ILC, Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TO DEFENDANTS You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM 2(RVICE HEREOF / /?. TYPE OF PLEADING CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 4600 Regent Blvd., Suite 200 Irving, TX 75063 AND THE DEFENDANTS IS 401-403 Front Street West F ' ' 7025 F PLAI F RTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 401-403 Front St., Boro of West Fairview (CITY, BORO, TOWNSHIP) (WARD) 0 RP T F Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME NO. MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO. L Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendant. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., which has its principal place of business at 4600 Regent Blvd., Suite 200, Irving, Texas 75063 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Deanna E. Hoffman and John T. Hoffman, are individuals whose last known address is 401-403 Front Street, West Fairview, Pennsylvania 17025. 3. On or about September 29, 2005, Defendant, Deanna E. Hoffinan, executed a Note in favor of American Home Mortgage, in the original principal amount of $16,000.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about September 29, 2005, as security for payment of the Note, Defendants made, executed and delivered to, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, a Mortgage in the original principal amount of $16,000.00 on the premises hereinafter described, the Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Mortgage Book Volume 1925, Page 1512. A true and correct copy of the Mortgage, containing a description of the premises subject to the Mortgage ("Mortgaged Premises"), is marked Exhibit "B", attached hereto and made a part hereof. 5. Mortgage Electronic Registration Systems, Inc. is the owner of legal title to the Mortgage and the nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., which is the owner of the entire beneficial interest in the Mortgage. 6. Defendants are the record and real owners of the aforesaid Mortgaged Premises. 7. Defendants are in default under the terms of the Mortgage for, inter alia, failure of Defendant, Deanna Hoffinan, to pay the monthly installments of principal and interest when due under the terms of the Note. Defendants are due for the January 1, 2006 payment. 8. On or about October 27, 2006, Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 (Act 91 Notices) in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983, as amended. 9. Plaintiff was not required to send Defendants separate Notices of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P. S. §101, et seq., as a result of sending the Act 91 Notices. 10. The amount due and owing Plaintiff by Defendants is as follows: Principal $15,972.57 Interest to 12/4/06 $ 2,139.56 Late Charges to 12/4/06 $ 104.72 Attorney's fees $ 1,250.00 Title Search, Foreclosure and Execution Costs $ 2,500.00 TOTAL $21,966.85 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $21,966.85 with interest thereon at the rate of $5.80 per diem from December 4, 2006, and additional late charges, additional reasonable and actually incurred attorney's fees, plus costs (including increases in escrow deficiency) and for foreclosure and sale of the Mortgaged Premises. GRENEN & BIRSIC, P.C. Ag6 ieys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" ,r Secondary Mortgage Loan This agreement is subject to the provisions of the Secondary Mortgage Loan Act. . NOTE September 29, 2005 CAMP HILL Pennsylvania Date city Stara 401-403 FRONT STREET, West Fairview, PA 17025 t Properly Address 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 16, 000.00 (this amount will be called principal''), plus interest,.to the order of the Leader. The Lender is American Home Mortgage . I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note will be called the" Note Holder." 2. INTEREST 1 will pay interest at a yearly rate of 13.250%. Interest will be charged on unpaid principal until the full amount of principal has been paid. 3. PAYMENTS 1 will pay principal and interest by making payments each month of U.S. $ 190.31 I will make my payments on the lot day of each mouth beginning oa November let , 2005 A will will make these payments every month until I have paid all of the principal and interest and any other charges, described below, that I may owe under this Note. If, on October 1, 2025 , I still owe amounts under this Note, l will pay all those amounts, In full, on that date. I will make my monthly payments at PO Box 660029, Dallas, TX 75266-0029 or at a different place if required by the Note Holder. 4. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any of my monthly payments by the end of Fifteen calendar days after the date It is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000% of my overdue payment, but not less than U.S. $ 1.00 and not more than U.S. $ 9.52 I will pay this late charge.only once on any late payment. (B) Default If I do not pay the full amount of each monthly payment by the date stated in Section 3 above, I will be in default. Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described below, the Note Holder will still have the right to do so If I am in default at a later time. (C) Notice from Note. Holder If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice Is mailed to me or, if it is not mailed, 30 days after the date on which it is delivered to me. (D) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back for its costs and expenses to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. DOC #:314151 APPL #:0000967156 PENNSYLVANIA - SECOND MORTOAOE - 1/80 - FNMA/M AC UNIFORM INSTRUMENT Form 3939 tw 1 at 2 75A(PA) (Me wai nc6 VMr MOR7GA02 PORAt4•(BP$21.7291 4iW4: ?I THIS NOTE SECURED BY A MORTGAGE In addition to the protections given to the Note Holder wider this Note, a Mortgage, dated September 29, 2005 protects the Note Holder from possible losses which might result if 1 do not keep the promises which I make in this Note. That Mortgage describes how and under what conditions I may be required to make immediate payment in full of all amounts that I owe under this Note. 6. BORROWER'S PAYMENTS BEFORE THEY ARE DUE I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a prepayment." When I make a prepayment, I will tell the Note Holder in a letter that I am doing so. A prepayment of all of the unpaid principal is known as a " full prepayment." A prepayment of only part of the unpaid principal is known as a " partial prepayment." I may make a full prepayment or a partial prepayment without paying any penalty. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no delays in the due dates or changes in the amounts of my monthly payments unless the Note Holder agrees in writing to those delays or changes. I may make a full prepayment at any time. If I choose to make a partial prepayment, the Note Holder may require me to make the prepayment on the same day that one of my monthly payments is due. The Note Holder may also require that the amount of my partial prepayment be equal to the amount of principal that would have been part of my next one or more monthly payments. 7. BORROWER'S WAIVERS I waive my rights to require the Note Holder to do certain thiags.'Those things are: (A) to demand payment of amounts due (known as ' ` presentment"); (B) to give notice that amounts due have not been paid (known as " notice of dishonor"); (C) to obtain an official certification of nonpayment (known as a " protest").Anyone else who agrees to keep the promises made io this Note, or who agrees to make payments to the Note Holder if I fail to keep my promises under this Note, or who signs this Note to transfer it to someone else also waives these rights. These persons are known as " guarantors, sureties and endorsers." 8. GIVING OF NOTICES Any notice that must be given to me under this Note will be given by deliveriog it or by mailing it by certified mail addressed to me at the Property Address above. A notice will be delivered or mailed to me at a different address if 1 give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by mailing it by Certified mail to the Note Holder at the address stated in Section 3 above. A notice will be mailed to the Note Holder at a different address if I am given a notice of that different address. 9. RESPONSIBILITY OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each of us is fully and personally obligated to pay the full amount owed and to keep all of the promises made in this Note. Any guarantor, surety, or endorser of this Note (as described in Section 7 above) is also obligated to do these things. The Note Holder may enforce its rights under this Note against each of us individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. Any person who takes over my rights or obligations under this Note will have all of my rights and must keep all of my promises made in this Note. Any person who takes over the rights or obligations of a guarantor, surety, or endorser of this Note (as described in Section 7 above) is also obligated to keep all of the promises made in this Note. DEANNA E. HOFFMAN -Borrower _ (Seal) -Borrower .....(Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) .Borrower -Borrower (Sign Original Only) (073A(PA) mo DOC 0:319152 nv2d2 APPL #:0000967256 Form 3939 EXHIBIT "B" Prepared By: Cortney Worth 3047 Columbia Avenue Lancaster, PA 17603 (717) 239-7691 Return To: CERTIFU TRUE American Home Mortgage 520 Broadhollow Road Melville, NY 11747 (516)949-3900 Parcel NW&b&7-1044-100 Premises: [Space Above Ttdl LAM For Recording Drkl MORTGAGE MIN 100024200009671567 THIS MORTGAGE is made this 29th day of September, 2005 , between the Mortgagor, DEANNA E. HOFFMAN, JOHN T. HOFFMAN (herein "Borrower"), and the Mortgagee, Mortgage Electronic Registration Systems, Inc. ("MERS"), (solely as nominee for Leader, as hereinafter defined, and Leader's successors and assigns). MFRS is organized -and existing under the laws of Delaware, and has an address and telephone gumber of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. American Home mortgage ("Loodor") is organized and existing under the laws of State of New York and bas an address of 520 BROADHOLLOW ROAD, MELVILLE, NY 11747 WHEREAS, Borrower is indebted to Lender in the principal sum of U.S. $ 16, 000.00 , which indebtedness is evidenced by Borrower's note dated September 29, 2005 and extensions and renewals thereof' (herein "Note"), providing for monthly installments of principal and interest, with the balance of the indebtedness, if not sooner paid, due and payable on October 1, 2025 PENNSYLVANIA SECOND MORTGAGE -1/80 • FNMA/FHLMC UNIFORM INSTRUMENT WITH MFRS ® Form 3839 DOC 4:32ab01 4e-76N(PA) (MO tended 6/02 APPL 1:0000967156 ' f'11jt1 II ??tg11 "ids UM VMP M01pp 804402' b a (&qn1--=1 11r (?//`1 I I?I?11f ?I ?I ? IIIIN [[atI IIII I II lF UI tltl t81 I EXHIBIT "A" ALL THAT CERTAIN tract of land, situate in the Borough of West Fairview, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North 82 degrees 45 minutes East, 54 feet to an iron pin at the shore of the Susquehanna River; thence North 07 degrees 15 minutes West, 198.5 feet to a point marked by an iron pin; thence South 82 degrees 45 minutes West, 54 feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South 07 degrees 15 minutes East, 198.5 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a double -frame dwelling house known and numbereii as 401-403 Front Street, West Fairview, Pennsylvania. nn n John T. Hoffman 6beanna E. Hoffman r TO SECURE to Leader the repayment of the indebtedness evidenced by the Note, with interest thereon; the payment of all other sums, with interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and the performance of the covenants and agreements of Borrower herein contained, Borrower does hereby mortgage, grant and convey to MFRS (solely as nominee for Leader and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in the County of CUMBERLAND State of Pennsylvania: SEE ATTACHED LEGAL DESCRIPTION which has the address of 401-403 FRONT STREET Isu-l West Fairview [City]. Pennsylvania 17025 (ZIP Code] (herein "Property Address"); TOGETHER with all the improvements now or hereafter erected on the property, and all easements, rights, appurtenances and routs, all of which shall be deemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasebold estate If this Mortgage is on a leasehold) are hereinafter referred to as the "Property." Borrower understands and agrees that MFRS holds only legal tide to the interests granted by Borrower in this Mortgage; but, if necessary to comply with law,or custom, MBRS, (as nominee for Lender and Lender's successors and assigns), has the right: to exercise say or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Mortgage. Borrower covenants that Borrower Is lawfully seised of the estax hereby conveyed and has the right to mortgage, grant and convey the Property, and that the Property is unencumbered, except for encumbrances of record. Borrower covenants that Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to encumbrances of record. UNIFORM COVENANTS. Borrower and Leader covenant and agree as follows: 1. Payment of Principal and Interest. Borrower shall promptly pay when due the principal and interest indebtedness evidenced by the Note and late charges as provided in the Note. 2. Funds for Taxes and Insurance. Subject to applicable law or a written waiver by Lender, Borrower shall pay to Lender on the day monthly payments of principal and interest are payable under the Note, until the Note is paid in full, a sum (herein "Funds") equal to one-twelfth of the yearly taxes and assessments DOC /:328602 APPL }:0000967136 1k Ct-76N(PA) OR cep r d a Fo 3839 (Iaoludiag ooadomialum and planned unit development assessments, if any) which may attain priority over this Mortgage aad ground rents on the Property, if say, plus one-twelfth of yearly premium installments for hazard insuraact, plus one-twelfth of yearly premium installments for mortgage insurance, if any, all as reasonably estimated ioldally and from time to time by Leader on the basis of assessments and bills and reasonable estimates thereof. Borrower shall not be obligated to make such payments of Funds to Lender to the extent that Borrower makes such payments to the. holder of a prior mortgage or deed of trust if such holder is so institutional lender. If Borrower pays Funds to Lender, the Funds shall be held in as institution the deposits or accounts of which are insured or guaranteed by a federal or state agency (including Lender if Leader is such an institution). Leader shall apply the Funds to pay said taxes, assessments, insurance premiums and ground rents. Leader may not charge for so holding and applying the Faads, analyzing said account or verifying and compiling said assessments and bills, unless Leader pays Borrower interest on the Funds and applicable law permits Leader to make such a charge. Borrower and Leader may agree in writing at the time of execution of this Mortgage that interest on the Funds shall be paid to Borrower, and unless' such agreement is made or applicable law requires such interest to be paid, Leader shall not be required to pay Borrower any interest or earaia&s on the Funds. Leader shall give to Borrower, without charge, ao annual accounting of the Funds showing credits and debits to We Fantle and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for the sums secured by Wis Mortgage. 1f the amount of the Funds held by Leader, together with the future monthly, installments of Funds payable prior to the due dates of taxes, assessments, insurance premiums anti ground rents, shall exceed the amount required to pay said taxes, assessments, insurance premiums and ground rents as they fall due, such excess shall be, at Borrower's option, either promptly repaid to Borrower or credited to Borrower on monthly installments of Funds. If the amount of the Funds held by Lendcr shall not be sufficient to pay taxes, assessments, insurance premiums and ground rents as they fall due, Borrower shall pay to Leader may amount accessary to make up the deficiency in one or more payments as Leader may require. Upon payment in full of all sums secured by this Mortgage, Loader shall promptly refund to Borrower any Funds held by Leader. If under paragraph 17 hereof the Property is sold or the Property is otherwise acquired by Lender, Lender shall apply, no later than immediately prior to the sale of the Property or its acquisition by Loader, any Funds held by Lander at the time of application as a credit against the sums secured by this Mortgage. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under the Note and paragraphs 1 and 2 hereof shall be applied by Lander first in payment of amounts payable to Lender by Borrower under paragraph 2 hereof, then to interest payable on the Note, and then to the principal of the Note: 4. Prior Mortgages and Deeds of Trust; Charges; Liens. Borrower shall perform all of Borrower's obligations under say mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage, Including Borrower's covenants to make payments when due. Borrower shall pay or cause to be paid all taxes, assessmeats and other charges, fines and impositions attributable to the Property which may attain a priority over this Mortgage, and leasehold payments or ground rents, if say. 5. Hazard Insurance. Borrower•sball keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "extended. coverage," and such other hazards as Lender may require and in such amounts and for such periods as Lander may require. The insurance carrier providing the lasumace shall be chosen by Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably withheld. All insurance policies and renewals thereof shall be in a form acceptable to Lander and shall include a standard mortgage clause in favor of and in a form acceptable to Lander. Leader shall have the right'to hold the polities and renewals thereof, subject to 1:328603 APPL 1:0000967156 W:.W; 9-- % •76N(PA) pm »p 3 at s Form 3839 the terms of any mortgage, deed of trust or other security agreement with alien which has priority over this Mortgage. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. If the Property is abandoned by Borrower, or if Borrower falls to respond to Leader within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at leader's option either to restoration or repair of the Property or to the sums secured by this Mortgage. 6. Preservation and Maintenance of Property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shall not commit waste or permit impairment or deterioration of the Property and sball comply with the provisions of any lease if this Mortgage Is on a leasehold. If this Mortgage is on a unit In a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the declaration or covenants creating or governing the condominium or planned unit development, the by-laws and regulations of the condominium or planned unit development, and constituent documents. 7. Protection of Lender's Security. If Borrower fails to perform -the covenants and agreements contained in this Mortgage, or if any action or proceeding is commenced which materially affects Leader's interest in the Property, then Lender, at Lender's option, upon notice to Borrower, may make such appearances, disburse such sums, including reasonable attorneys' fees, and take such action as is necessary to protect Lender's interest. If Lender required mortgage insurance as a condition of making the loan secured by this Mortgage, Borrower shall pay the premiums required to maintain such insurance in effect until such time as the requirement for such insurance terminates in accordance with Borrower's and Leader's written agreement or applicable law. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the Note rate; shall become additional indebtedness of Borrower secured by this Mortgage. Unless Borrower and Lender agree to other terms of payment, such amounts shall be payable upon notice from Leader to Borrower requesting payment thereof. Nothing contained is this paragraph 7 shall require Lender to incur any expense or take any action hereunder. 8. Inspection. Lender may make or cause to be made reasonable entries upon and inspections of the Property, provided that Lender shall give. Borrower notice prior to any such inspection specifying reasonable cause therefor related to Leader's interest in the Property. 9. Condemnation. The proceeds of any award or claim for damages, direct or Consequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall be paid to Leader, subject to the terms of any mortgage, deed of trust or other security agreement with a lien which has priority over this Mortgage. 10. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Mortgage granted . by Lender to any successor in interest of Borrower sball not operate to release, in say manner, the liability of the original Borrower and Borrower's successors in interest. Loader shall not be required to commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reason of any demand made by the original Borrower and Borrower's successors in interest. Any forbearance by Leader in exercising any right or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any such right or remedy. DOC #:328604 APPL #:0000967156 WWI: CI-76N(PA) PQ ? 3839 by 4 d a Form 3839 T 11. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements berein contained shall bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Borrower who co-signs this Mortgage, but does not execute the Note, (a) is co-signing this Mortgage only to mortgage, grant and convey that Borrower's interest in the Property to Leader under the terms of this Mortgage, (b) is not personally liable on the Note or under this Mortgage, and (c) agrees that Leader and any other Borrower hereunder may agree to extend, modify, forbear, or make any other accommodations with. regard to the terms of this Mortgage or the Note without that Borrower's consent and without releasing that Borrower or -modifying this Mortgage as to that Borrower's interest in the Property. 12. ]Notice. Except for any notice required under applicable law to be given in another manner, (a) any ootice to Borrower provided for in this Mortgage shall be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Borrower may designate by notice to Leader as provided herein, and (b) any notice to Tender shall be given by certified trail to Leader's address stated bereia or to such other address as Lender may designate by notice to Borrower as provided herein.'Aay notice provided for in this Mortgage shall be deemed to have been given to Borrower or Leader when given in the manner designated herein. 13. Governing Law; Severability. The state and local laws applicable to this Mortgage shall be the laws of the -jurisdiction in which the Property is located; The foregoing sentence shall not limit the applicability of federal law to this Mortgage. In the event that any provision or clause of this Mortgage or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this end the provisions of this Mortgage and the Note are declared to be severable. As used horcia, "costs," "expenses" and "attorneys' fees" include all sums to the extent not prohibited by applicable law or limited herein. 14. Borrower's Copy. Borrower shall be furnished a conformed copy of the Note and of this Mortgage at the time of execution or after recordation hereof. 15. Rehabilitation Loan Agreement. Borrower shall fulfill all of Borrower's obligations under soy home rehabilitation, improvement, repair, or other loan agreement which Borrower eaters into with Lender. Leader, at Lender's option, may require Borrower to execute and deliver to Lender, is a form acceptable to Leader, an assignment of any rights, claims or defenses which Borrower may have against parties who supply labor, materials or services in connection with improvements made to the Property. 16. Transfer of the Property or a Beneficial Interest in Borrower. If all or say part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Leader's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Mortgage. However, this option shall not be exercised by Leader if exercise is prohibited by federal law as of the date of this Mortgage. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less then 30 days from the date the notice Is delivered or mailed within which Borrower must pay all sums secured by this Mortgage. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Mortgage without further notice or demand on Borrower. DOC ;:320605 APPL 4:0000967156 Ct-76N(PA) pan h6" s d a w ww 1]?? ? ? ?JL- NON-UNIFORM COVENANTS. Borrower snd Leader further covenant and agree as follows: 17. Acceleration; Remedies. Upon Borrower's breach of any covenant or agreement of Borrower in this Mortgage, including the covenants to pay when due any sums secured by this Mortgage, Lender prior to acceleration shall give notice to Borrower as provided by applicable law specifying, among other things: (1) the breach; (2) the adion required to cure such breach; (3) a date, not less than 30 days from the date the notice Is mailed to Borrower, by which such breach must be cured; and (4) that failure to cure such breach on or before the date specified In the notice may result In acceleration of the sums secured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property. The notice shall further Inform Borrower of the right to reinstate alter acceleration and the right to assert in the foreclosure proceeding the nonexistence of it default or any other defense of Borrower to acceleration and foreclosure, If the breach is not cured on or before the date specifted in the notice, Lender, at Lender's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. Lender shall be entitled to coiled In such proceeding all expenses of foreclosure, Including, but not limited to, reasonable attorneys' fees, and costs of documentary evidence, abstmets and title reports. 18. Borrower's Right to Reinstate. Notwithstanding Lender's acceleration of the sums secured by this mortgage due to Borrower's breach, Borrower shall have the right to have any proceedings begun by Lender to enforce this Mortgage discontinued at any time prior to at least one hour before the commencement of bidding at a sheriff's We or other sale pursuant to this Mortgage if: (a) Borrower pays Leader all sums which would be thea due under this. Mortgage and the Note had no acceleration occurred; (b) Borrower cures all breaches of any other covenants or agreements of Borrower contained in this Mortgage; (c) Borrower pays all reasonable expenses incurred by Lender in enforcing the covenants sad agreements of Borrower contained in this Mortgage and in enforcing Leader's remedies as provided in paragraph 17 hereof, including, but not limited to, reasonable attorneys' fees; and (d) Borrower takes such action as Leader may reasonably require to assure that the lien of this Mortgage, Leader's interest in the Property and Borrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired, Upon such payment and cure by Borrower, this Mortgage and the obligations scoured hereby shall remain in full force and effect as if no acceleration bad occurred. 19. Assignment of Rents; Appointment of Receiver; Lender in Possession. As additional security hereunder, Borrower hereby assigns to Lender the teats of the Property, provided that Borrower shall, prior to acceleration under paragraph 17 hereof or abandonment of the Property, have the right to collect and retain such rents as they become due and payable. Upon acceleration under paragraph 17 hereof or abandonment of the Property, Leader, in person, by agent or by judicially appointed receiver shall be entitled to enter upon, .take possession of and manage the Property and to collect the mats of the Property including those past due. All rents collected by Leader or the receiver shall be applied first to payment of the costs of management of the Property and collection of rents, including, but act limited to, receiver's fees, premiums on receiver's bond and reasonable attorneys' fees, and then to the sutras secured by this Mortgage. Leader and the receiver shall be liable to account only for those rents actually received. 20. Release. Upon payment of all stuns securcd by this Mortgage, Lender shall discharge this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 21, Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgmeat is entered on the Note or in an action of mortgage foreclosure shall be the rate stated in the Note. DOC 1:326606 APPL 1:0000967156 4%•76N(PA) Oran r y a a s Form 3839 .t REQUEST FOR NOTICE OF DEFAULT AND FORECLOSURE UNDER SUPERIOR MORTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, deed of treat or other encumbrance with a lien which has priority over this Mortgage to give Notice to Leader, at Leader's address set forth on page out of this Mortgage, of any default under the superior encumbrance and of any sale or other foreclosure action. IN WITNESS WHEREOF, Borrower has executed this Mortgage. Witnesses; D n a ?r -Borrower EANNA E. HOFFMAN •Borrowar 4 (Seat) JOHN T. HOFFMAN Borrower (Seal) -Borrower - (Seal) -Borrower _ (Seal) -Borrower (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower (Sign Original Only) DOC #:328607 APPL 4:0000967156. Ck-76N(PA) osm rsp 7 d B Form 3839 ;I h• COMMONWEALTH OF PENNSYLVANEA,(:,County ss: On this, the 29th day of September 2005 , before me, the undersigned officer, personally appeared DEANNA E. HOFFMAN, JOHN T. HOFFMAN known to me (or satisfactorily proven) to be the Person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that be/sbe/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: al Seal %k NotaryPW*e cmember, RPenn ALTH OF p VANIA CtmbetWW CW* MvkW Aup. 5, 2008 le Aeaegetlon Ot Noteclee CertlHcate of Residence r /? I, e? fY 2?` p? , do hereby certify that the correct address of the within-na Mo is P.O. Box int, MI 48502-2026. Witness my hand this 29th day of Sept r 2005 Agent of Moapjgee DOC #:328608 APPL 1:0000967156 tt-76N(PA) MM e ye a of a .,erg ' X14 Porm 9 VERIFICATION Deborah Cutchshaw, Foreclosure Specialist and duly authorized representative of American Home Mortgage Servicing, Inc., deposes and says subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities that the facts set forth in the foregoing Complaint are true and correct to her information and belief. American Home Mortgage Servicing, Inc. 1lGUVizui %.ULUMIUdW Foreclosure Specialist i , t ZZ) t`,. e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TYPE OF PLEADING Praecipe to Reinstate Civil Action - Complaint in Mortgage Foreclosure FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY:7Ameys Fidler, Esqu for Plaintiff E:y ._..t C ..-- 1 J ' N '- N t r'y 1 '? t??? .Y ....m ..?l " . fi `?? Y ? ~ `? ? ~ e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., vs. Plaintiff, DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. CIVIL DIVISION NO.: 06-7123 CIVIL TERM TYPE OF PLEADING MOTION TO STRIKE ASSIGNMENT OF MORTGAGE FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. MOTION TO STRIKE ASSIGNMENT OF MORTGAGE AND NOW, comes the Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., by and through its attorneys, GRENEN & BIRSIC, P.C., and files the within Motion to Strike Assignment of Mortgage as follows: 1. On or about December 14, 2006, Plaintiff filed a Complaint in Mortgage Foreclosure against the Defendants, Deanna E. Hoffman and John T. Hoffman. 2. Plaintiff is the holder of a first and second mortgage against Defendants' real property as follows: (a) Mortgage dated September 29, 2005 in the original principal amount of $64,000.00 executed by Defendants in favor of Plaintiff and recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania l on October 3, 2005 at Mortgage Book Volume 1925, Page 1495 ("First Mortgage"); and (b) Mortgage dated September 29, 2005 in the original principal amount of $16,000.00 executed by Defendants in favor of Plaintiff and recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania on October 3, 2005 at Mortgage Book Volume 1925, Page 1512 ("Second Mortgage"); 3. The instant foreclosure action is to foreclose the Second Mortgage. 4. Mortgage Electronic Registration Systems, Inc. as Nominee for American Home Mortgage assigned the aforesaid Second Mortgage to American Home Mortgage Servicing, Inc. 5. However, on or about February 16, 2007, Plaintiff erroneously filed an Assignment of Mortgage conveying the First Mortgage to American Home Mortgage rather than the Second Mortgage. A true and correct copy of the erroneous Assignment of Mortgage is marked as Exhibit "A", attached hereto and made a part hereof. 6. Plaintiff wishes to strike the Assignment of Mortgage that was recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania on February 16, 2007 at Mortgage Book Volume 0734, Page 2238 in order to clarify the chain of title for this property. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an order directing the Office of the Recorder of Deeds of Cumberland County, Pennsylvania to strike the Assignment of Mortgage recorded on February 16, 2007 at Mortgage Book Volume 0734, Page 2238, and authorizing Plaintiff to file said Order with the Recorder's Office of Cumberland County, Pennsylvania. GRENEN & BIRSIC, P.C. BY:t? J sep A. Fidler, Esquire P .D.#87325 Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 EXHIBIT "A" iR• 5?2z 0 Prepared By: Grenen & Birsic, P.C. One Gateway Center, 9 h Floor Pittsburgh, PA 15222 Return To: Grenen & Birsic, P.C. One Gateway Center, 9 h Floor Pittsburgh, PA 15222 Parcel #: 45-17-1044-100 11ROSEIRT P. ZIEGLER RCORDO OF DEEDS G!;M-8ERLAND -COUNTY- F 10 FEB 16: H(l 10 27 ASSIGNMENT OF MORTGAGE From Deanna E. Hoffman and ) John T. Hoffman ) Mortgagors ) To Mortgage Electronic Registration ) Systems, Inc., as Nominee for ) Mortgage Dated: September 29, 2005 Mortgage Recorded: October 3, 2005 Mortgage Book Volume 1925, Page 1495 in the Recorder's Office of Cumberland Amencan Home Mortgage, ) County, Pennsylvania. ?= ... Mortgagee ) Amount: $64,000.00 For value received and intending to be legally bound hereby, Mortgage Electronic Re ' tmi tion S , Inc., as Nominee for American Home Mortgage, ("Assignor') does hereby this ?Y of 2007, grant, sell, assign, transfer, set over and deliver unto American Home Mortgage Servic' , Inc., ("Assignee"), its successors and assigns, all right, title and interest of Assignor in and to the above-referenced Mortgage together with all of Assignor's rights, remedies, incidents and appurtenances as stated in the Mortgage and all of the right, title and interest of Assignor in the premises described in the Mortgage; and Assignor specifically assigns by this Assignment the debt instrument intended to be secured by the Mortgage. In Witness Whereof, Assignor has caused this Assignment to be executed by its hand and seal, with authority therefore, the day and year first above written. ATTEST: By: MORTGAGE ELECTRONIC EGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN HOME MORTGAGE---" -p-w, ;:!? Name: Robert Hardman Title: Vice President Property Address: 401403 Front Street, West Fairview, PA 17025 734228 t 4 STATE OF TEXAS ) ss: COUNTY OF DALLLAS ) On this, the day of 2007, before me, the undersigned officer, personally appeared Robert Hardman, who ackno ged himself to be the Vice President of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage and that he, being authorized to do so, executed the foregoing Assignment of Mortgage for the purposes therein contained by signing the name of the corporation by himself. It Witness Whereof, I hereunto set my hand and official seal. MATTHEW G STONER a•' *s NOTARY PUBLIC 's,.?•. , e:' State of Texas Notary Public .' a.•*'•? Comm. Exp. 08-30-2008 Certificate of Residence I, Joseph A. Fidler, Esquire, do certify that the Assignee's precise residence is 4600 Regent Blvd., Suite 200, Irving, Texas 75063. 101 Commonwealth of Pennsylvania ) County of Cumberland ) Recorded on this day of ss: A.D. 2007, in the Recorder's Office of the said County, at Mortgage Book Volume Page Give under my hand and the seal of the said office the day and year aforesaid. Recorder WITNESS: By: W-1--10.'73VPG 229 I Certify this to be recorded In Cumberland County PA ?i.` Yr'IFtr O Recorder of Deeds CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Motion to 0?. r Strike Assignment of Mortgage was mailed to the following on this day of March, 2007, by first class, U.S. Mail, postage pre-paid: Cumberland County Recorder of Deeds One Courthouse Square Carlisle, PA 17013-3387 HSBC Bank USA, National Association c/o Francis S. Hallinan, Esquire Phelan, Hallinan & Schmieg, LLP 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 GRENEN & BIRSIC, P.C. Atneys for Plaintiff O fie Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 CAA C -5 1 '' r{ N 4::.. f SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-07123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HOFFMAN DEANNA E ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HOFFMAN DEANNA E but was unable to locate Her deputized the sheriff of DAUPHIN serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On January 31st , 2007 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: o answer Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kli Dep Dauphin County 49.00 Sheriff of Cumberland County Postage 1.74 87.74 ? ??i ?G 9 C?,.,. 01/31/2007 GRENEN & BIRSIC Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-07123 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HOFFMAN DEANNA E ET AL R. Thomas Kline County, Pennsylvania, to duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT HOFFMAN JOHN T but was unable to locate Him deputized the sheriff of DAUPHIN serve the within COMPLAINT - MORT FORE Sheriff or Deputy Sheriff who being On January 31st , 2007 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge So answers•? 6.00 .00 10.00 R. Thomas Kline .00 Sheriff of Cumberland (Ounty .00 16.00 211_31b 7 L 01/31/2007 GRENEN & BIRSIC Sworn and subscribe to before me this day of to wit: in his bailiwick. He therefore A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania, Mortgage Electronic Registration Systems Inc vs. Deanna E. Hoffman et al SERVE: Deanna E. Hoffman No. 06-7123 civil Now, Janus 23, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit ofService Now, , 2C L_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sworn and subscribed before me this day of , 20 Sheriff of . County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT In The Court of Common Fleas of Cumberland County, Penasylvanlx Mortgage Electronic Registration Systems Inc vs. Deanna E. Hoffman et al SERVE: John T. Hoffman So answers, Now, January 23, 2007 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of _ Dauphin No. 06-7123 civil County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of -Service Now, , 20 , at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA 11 CPffice of t4tc*4Priff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania : MORTGAGE ELECTRONIC REGISTRATION SYSTE vs County of Dauphin HOFFMAN DEANNA Sheriff's Return COMPLAINT IN MORTGAGE FORECLOSURE AND NOW:January 26, 2007 at 8:40AMserved the within HOFFMAN DEANNA to DEFENDANT No. 0112-T - - -2007 OTHER COUNTY NO. 06-7123 upon by personally handing 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 22 SOUTH 4TH STREET HALIFAX, PA 17032-0000 Sworn and subscribed to before me this 26TH day of JANUARY, 2007 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2010 So Answers, ?k e;l* Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$49.00 PD 01/24/2007 RCPT NO 225807 WONG (i?ffice of f4e o$heriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania MORTGAGE ELECTRONIC REGISTRATION SYSTE vs County of Dauphin HOFFMAN DEANNA Sheriff's Return No. 0112-T - - -2007 OTHER COUNTY NO. 06-7123 AND NOW:January 26, 2007 at 8:40AMserved the within COMPLAINT IN MORTGAGE FORECLOSURE upon HOFFMAN JOHN T by personally handing to DEFENDANT 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 22 SOUTH 4TH STREET HALIFAX, PA 17032-0000 Sworn and subscribed to before me this 26TH day of JANUARY, 2007 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2010 So Answers, ? 1?*7 ell)ee Sheriff f Dauph County, Pa. *;low By Deputy Sheriff Sheriff's Costs:$49.00 PD 01/24/2007 RCPT NO 225807 WONG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, TYPE OF PLEADING AMENDMENT TO PLAINTIFF'S MOTION TO STRIKE ASSIGNMENT OF MORTGAGE Defendants. FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AMENDMENT TO PLAINTIFF'S MOTION TO STRIKE ASSIGNMENT OF MORTGAGE AND NOW, comes the Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., by and through its attorneys, GRENEN & BIRSIC, P.C., and files the within Amendment to Plaintiff's Motion to Strike Assignment of Mortgage as follows: This matter has not come before a Judge in Cumberland County, Pennsylvania nor has a Judge in Cumberland County, Pennsylvania ruled upon this case. 2. Plaintiff has received no objections to the Motion upon consultation with the office of the Recorder of Deeds of Cumberland County, Pennsylvania and counsel on behalf of HSBC Bank USA, National Association. GRENEl & BIRSIC, P.C. J .? ¢ eph Fidler, E s q u re ?A. .#87325 Att meys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 ..> - - ?7 __ ` ?:7 _._,? . --t .. i ??., "? ? .. ,. C r. :"?- • • ?. MAR 2 7 2007?fy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. ORDER OF COURT AND NOW, this day of '44"1 , 2007, upon consideration of the foregoing Motion to Strike Assignment of Mortgage filed by Plaintiff, it is hereby ORDERED, ADJUDGED and DECREED that the Recorder of Deeds of Cumberland County shall strike the Assignment of Mortgage conveying the mortgaged premises to American Home Mortgage Servicing, Inc., which was recorded on February 16, 2007 at Mortgage Book Volume 0734, Page 2238. Plaintiff shall record a copy of this Order of Court with the Recorder of Deeds of Cumberland County, Pennsylvania within twenty (20) days of the date of this Order. J. BY THE COURT: J d j iJ f " f t 1 ?? Ci J t/Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff, Vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. CIVIL DIVISION NO.: 06-7123 CIVIL TERM TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 6/13/07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. P_a RCP RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS Joseph A. Fidler, Esquire, Attorney for Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on June 13, 2007 as follows: 1. Deanna E. Hoffinan and John T. Hoffman are the owners of the real property and have not entered an appearance of record. 2. By letter dated March 12, 2007, the undersigned counsel served Defendants, Deanna E. Hoffinan and John T. Hoffinan, with true and correct copies of Plaintiffs notice of the sale of real property by certified mail, restricted delivery, return receipt requested, addressed to 22 South 4t' Street, Halifax, Pennsylvania 17032. On or about March 15, 2007, the signed certified mail receipts were returned to Plaintiff, indicating the Defendants were served with the i Notice of Sheriff s Sale. True and correct copies of the returned certified mail receipts, are marked Exhibit "A", attached hereto and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. GRENEN & BIRSIC, P.C. BY: Fidler, Esquire for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF ?. , 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A Townsend, Notary Pubk City OF Pittsburgh, Allegheny County My Commissim E)ires June Z 2007 Member, Penrnylvania Association of Notaries w EXHIBIT "A" 4h ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this cans to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 22 ` ,-?V1 (-frn A. Signature &?` C+ ? Agent CU Addressee X C• r . co-Aft-4E3 B. Received by (Printed C. Date of Delivery DeaLl, QPwh D. Is delivery address different from itern 17 ? Yes If YES, enter delivra-bel ? N o ?1oN l X 3, Type \7? ?j CvtlHed' Mail 1 ? Registered R for Merchandise ?' Insured Mail C.O.D. 4. Restricted Delivery? (Exile Fee) Yes 2. Article Numibef' (transfer from service labeo 7006 2760 0004 7013 9929 PS Form 381:1, February 2004 Domestic Return Receipt 102595.02-WI540 ¦ Complete Items 1, 2, and 3. Also complete A item 4 N Restricted Delivery is desired.' ¦ P int ur p Agent r yo name and address on the reverse D Addressee so that we`can return the card to you. N Attach this card to the back of the mailpieoe, by ( fVame of Delivery / ?' or on the front if space permits. ` O 11 le Addressed to: D. Is delivery address a from 1? If YES, enter delivery t ? ' ' '2SZ Saj-1 f t `'P ?b1 nc) ? lX r' ' t fc/l 3. Service Type 7rCertifled Mall ?'Express Mail ? Registered eZ Return Receipt for Merchandise ? insured Mali ? C.O.D. 4. Resorted DeNveryt {Extra Fee) Yes 2. Adds Number 7 D :27L 0 0-13 0 4: 7 0 1 3 9 912 (rransferfh"service ) Ps For-rn 3$11 February 2004 Domestic Retum Receipt 102595-0244-1540 V 1 A , r ? ? rte! Oll t = ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, Vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. SALE DATE: 6/13/07 TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Joseph A. Fidler, Esquire, Attorney for Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129. 1, as well as all persons named in Plaintiff's Supplemental Affidavit pursuant to Rule 3129.1 as follows: By letters dated March 12, 2007, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. 2. By letters dated March 29, 2007, undersigned counsel served the persons named in Plaintiffs Supplemental Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective address set forth in the Supplemental Affidavit Pursuant to Rule 3129.1. A true and correct copy of said Supplemental Affidavit Pursuant to Rule 3129.1 and Certificate of Mailing are marked Exhibit "B", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BY: Atfdrnevs for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS p? DAY OF C)?n, 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Public City OF Pittsburgh, Allegheny County My Commissim Expires June 2,2W7 Member, Pennsylvania Association Of Notaries EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffinan and John T. Hoffman 22 South 46' Street Halifax, PA 17032 2. The name and address of the defendants in the judgment: Deanna E. Hoffman and John T. Hoffman 22 South 4 h Street Halifax, PA 17032 3. The name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Horne Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 0 9 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Tenants 401 Front Street West Fairview, PA 17025 Tenants 403 Front Street West Fairview, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. 4 ose A. Fidler, Esquire A omey for Plaintiff SWORN to and subscribed before me this day of U?Xc_1 e y? , 2007. 0 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patrlds A. Townsend, Notary Pubic COU* City Ot Pittsburgh, Fjores ANegny heJ U My Commisston Member. PennsYNarna,assodafion Of Notaries N -n w? ?w 'D -4 -? 4 (DD Q 2 d 0 0 IV I m W 0 m 0 w co r c CL W N W O d n K n N CD 3 co 7 •o O A W H CD 90 9)1 CA CD v N m w rt -n n O z? 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EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., Plaintiff in the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Deanna E. Hoffman and John T. Hoffrnan located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: HSBC Bank USA National Association 3476 Stateview Blvd. Fort Mill, SC 29715 HSBC Bank USA National Association c/o Francis S. Hallinan, Esquire Phelan, Hallinan & Schmieg, LLP 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. GRENEN & BIRSIC, P.C. BY: Atto,X6€ys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2007. 2 ? Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Pubic City Of PitLburgh, Allegheny Comfy My Commission Expires June 2,2W7 Member. Pennsylvania Association Of Notaries U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTER MAIL DQES ITT PROVIDE FOR INSURANCE-POSTMASTER Received From: J Grenen & Birsic P.C. ' 0 2 1 P 137 One Gateway Center, 9? Floor. 22g1?D F W . U One piece of ordinary mail addressed to: i t3 d HSBC Bank USA National Asso ciation 3476 Stateview Blvd. Fort Mill, SC 29715 Affix fee here in stamps or meter postage and Qost mark. Inquire of p t PITNEY BOWES 00•W MAR 29 2007 CODE15222 r ??q . I J 3 PS Form 3817, January 2001- fifdflt.BMq" of OMESTIC AND INTER r ANCE-POSTMASTER T!!VR7 ICE C I , d 0002421379 WAR 29 2007 MAILED FRO ZIPCODE15222 ic P.C. F inary mail addressed to: USA Nat ional Association Hallinan Esquireinan & Sc" e>LLP vd. Suite 00 PA 19103 t PS Form 3817, January 2001 -- C? "tt -Y 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, TYPE OF PLEADING SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 FILED ON BEHALF OF PLAINTIFF: Defendants. Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 6/13/07 r IN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., Plaintiff in the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Deanna E. Hoffinan and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF r_ %, CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: HSBC Bank USA National Association 3476 Stateview Blvd. Fort Mill, SC 29715 HSBC Bank USA National Association c/o Francis S. Hallinan, Esquire Phelan, Hallinan & Schmieg, LLP 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. GRENEN & BIRSIC, P.C. BY: for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 1 , 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Patricia A. Townsend, Notary Pudic City OF Pittsburgh, Allegheny County My Commission Expires June 2,2W7 Member, Pennsylvania Association Of Notaries , C7 C= p t_ ? n ." t?- Fr ?.%??? G31 rZ? + ' Y`?, r 1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-07123 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HOFFMAN DEANNA E ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOFFMAN DEANNA E but was unable to locate Her in his bailiwick. COMPLAINT - MORT FORE , He therefore returns the NOT FOUND , as to the within named DEFENDANT , HOFFMAN DEANNA E 401-403 FRONT STREET WEST FAIRVIEW, PA 17025 DEANNA HOFFMAN DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: So answers• Docketing 18.00 Service 14.08 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Postage 39 47.47 GRENEN & BIRSIC i/AKr iq 4, 01/05/2007 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-07123 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS HOFFMAN DEANNA E ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT HOFFMAN JOHN T but was unable to locate Him in his bailiwick. He therefore returns the f-nMnT TTTTM _ MnUM VnDV the within named DEFENDANT , HOFFMAN JOHN T 401-403 FRONT STREET WEST FAIRVIEW, PA 17025 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. NOT FOUND , as to Sheriff's Costs: So answers- Docketing 6.00 Service .00 Not Found 5.00 R. Thomas Surcharge 10.00 Sheriff of Cumberland County .00 4, ,/ 21.00 GRENEN & B I RS I C 01/05/2007 Sworn and Subscribed to before me this day of , A. D. Mortgage Electronic Registration Systems, In The Court of Common Pleas of Inc., as Nominee for American Home Cumberland County, Pennsylvania Mortgage d/b/a American Home Mortgage Writ No. 2006-7123 Civil Term Servicing, Inc. VS Deanna E. Hoffman and John T. Hoffman R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Deanna E. Hoffinan and John T. Hoffman, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description according to law. Dauphin County Return: And now, March 28, 2007 at 0955 hours served the within Real Estate Writ, Notice and Description upon John T. Hoffinan and Deanna E. Hoffman by personally handing to John Hoffman, personally and adult in charge for Deanna E. Hoffinan, two true attested copies of the original Real Estate Writ, Notice and Description and making known to him the contents thereof at 22 South 4th Street, Halifax, PA 17032. So answers: J. R. Lotwick, Sheriff of Dauphin County, PA. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1029 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of John T. Hoffman and Deanna E. Hoffman located at 401-403 Front Street, West Fairview, 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 defendants, to wit: John T. Hoffinan and Deanna E. Hoffman, by regular mail to their last known address of 22 South 4th Street, Halifax, PA 17032. These letters were mailed under the date of April 05, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Joseph Fidler. Sheriff s Costs: Docketing 30.00 Poundage 18.30 Advertising 15.00 Posting Handbills 15.00 Mileage 14.40 Levy 15.00 Law Library .50 Prothonotary 1.00 Surcharge 30.00 Out of County 9.00 Dauphin County 49.00 Law Journal 359.00 Patriot News 360.95 Share Bills 16.17 * lb If 4 $ 933.32 , 1,613 So Answers: R. Thomas Kline, Sheriff BY Real Estate ergeant I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffman and John T. Hoffinan 22 South 4 h Street Halifax, PA 17032 2. The name and address of the defendants in the judgment: Deanna E. Hoffman and John T. Hoffinan 22 South 4`h Street Halifax, PA 17032 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 401 Front Street West Fairview, PA 17025 Tenants 403 Front Street West Fairview, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. ose A. Fidler, Esquire A mey for Plaintiff SWORN to and subscribed before me this 1.4 day of ?? S) C' V- , 2007. Notary Public COMMONWEALTH OF PENNSYLVANIA EgPa:bidcla otarial Seal awnse W. Notary Pubic urgh, Allegheny Cony w Expires June 2, 207 Member, Pennsylvania ASS(;; ron of Notaries I' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Deanna E. Hoffinan 22 South 4t' Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 13, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. i The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, VS. Deanna E. Hoffinan and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $24,205.77. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. & BIRSIC, P.C. B Jo h A. Fidler, 5squire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John T. Hoffman 22 South 4th Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on June 13, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffman and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, VS. Deanna E. Hoffman and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $24,205.77. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN §i BIRSIC, P.C. Fidler, Esquire for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five-tenths (198.5) feet to a point marked by an iron pin; thence South eighty- two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five-tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401- 403 Front Street, West Fairview, Pennsylvania. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN ]R SIC, P.C. ZB. os A. Fidler, Esquire omeys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7123 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN HOME MORTGAGE D/B/A AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff (s) From DEANNA E. HOFFMAN AND JOHN T. HOFFMAN (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 $23,565.71 Interest $640.06 Atty's Comm % Arty Paid $254.21 Plaintiff Paid Date: MARCH 8, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs C R. Long, P nota By: REQUESTING PARTY: Name JOSEPH A. FIDLER, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Deputy Telephone: 412-281-7650 Supreme Court ID No. 87325 Real Estate Sale # 90 On March 15, 2007 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 401-403 Front Street, West Fairview, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: Marcil j 5:, 2007. By: Real Estate Sergeant t d i? r`?d LOiZ io PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27, May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Ci Mane Coyne, ditor SWORN TO AND SUBSCRIBED before me this 4 day of May, 2007 t2rg R OTW"'! ",t.. SEAL LO!lz E. C :?Y(tF ,Notary Riblic C-` G'i'ma erhnd Couri?ty „_ G; h"arcta 5,209.9 REAL ESTATE SALE NO. 90 Writ No. 2006-7123 Civil Mortgage Electronic Registration Systems, Inc. as Nominee for American Home Mortgage d/b/a American Home Mortgage Servicing, Inc. vs. Deanna E. Hoffman and John T. Hoffman Atty.: Joseph Fidler LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty- five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety- eight and five-tenths (198.5) feet to a point marked by an iron pin; thence South eighty-two (82) degrees forty-five (45) minutes West, fifty- four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety- eight and five-tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401-403 Front Street, West Fairview, Pennsylva- nia. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Page 1190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. Parcel# 45-17-1044-100. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#90 Sworn to and subscribe?ke 18th day of May 2007 A.D. ....,,.. fore me this. - _? _ Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County My Cam ion Expires June 6, 2010 emb vlvania;;ssociation otNotaries TARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 MW THE COURT OF GMMON PLEAS OF CUMBERLAND CQWTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Mortgage Electronic Registration Systems, : INc., as Nominee for American Home Mortgage d/b/a American Home. Mortgage Servicing, Inc. VS. Deanna E. Hoffman and John T. Hoffman TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment (xX ) Other File No. 06-7123 Civil Term Amount Due _23,565.71 Interest $ 4,343.16 : Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, See Attached Description PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of • County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis 4dens a' st real estate of the defendant(s) described in the attached exhibit. Date 0 7 Signature: Print Name: A. Fidler A ddress: Attorney for: Telephone: Supreme Court ID No.: One Gateway Center, 9th Floor Pittsburgh, PA 15222 Plaintiff (412) 281-7650 87325 (over) h o w C ? Q Y C .c c '? G GD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five- tenths (198.5) feet to a point marked by an iron pin; thence South eighty-two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five- tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401-403 Front Street, West Fairview, Pennsylvania. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN & BIRSIC, P.C. By: orneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7123 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN HOME MORTGAGE DB/A AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff (s) From DEANNA E. HOFFMAN AND JOHN T. HOFFMAN (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 $23,565.71 Interest $4,343.16 Atty's Comm % Atty Paid $309.03 Plaintiff Paid Date: JULY 19, 2007 (Seal) REQUESTING PARTY: Name JOSEPH A. FIDLER, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF L.L. Due Prothy $2.00 Other Costs iieputy Telephone: 412-281-7650 Supreme Court ID No. 87325 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT OF LAST KNOWN ADDRESS COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Joseph A. Fidler, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that the owners of the property located at 401-403 Front Street, West Fairview, Pennsylvania 17025 are, Defendants, Deanna E. Hoffman and John T. Hoffman, who reside at 22 South 4 h Street, Halifax, Pennsylvania 17032, to the best COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commilmlon Expires Jan. 6, 2008 Member, Pennsylvania Association Of Notaries r? co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S.101,,_ET. SEQ. AND ACT 91 OF 1983 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) Before me, the undersigned authority, a Notary Public in and for the said County and Commonwealth, personally appeared Joseph A. Fidler, Esquire, attorney for the Plaintiff, who being duly sworn according to law deposes and says that on October 27, 2006, Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 by certified mail, return receipt requested, and first class U.S. Mail. Plaintiff was not required to send Defendants separate Notices of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. §101, et seq., as a result of sending the Act 91 Notices. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY F , 2007. Votary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Pa0m, Notary Public City OF Piftburgh, Allegheny Coul* My Commission Expires Jan. 6,20M Member, Pennsylvania Association Of Notaries _ ?4 :t cri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA } SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffinan and John T. Hoffinan located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffinan and 22 South 4' Street John T. Hoffinan Halifax, PA 17032 2. The name and address of the defendants in the judgment: Deanna E. Hoffman and John T. Hoffman 22 South 4"` Street Halifax, PA 17032 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. HSBC Bank USA National Association 3476 Stateview Blvd. Fort Mill, SC 29715 HSBC Bank USA National Association c/o Francis S. Hallinan, Esquire Phelan, Hallinan & Schmieg, LLP 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None he plaint!" has knowledge who has any every other person whom Sale:P 7 , The name lanoa?y $`,5,lii h may be affected by the, interest in the prop 401 Front StreepA 1025 West Fairv1ew, e vit are true and correct to the best ma are e in the Affida statements herein statements mad l understand that false f that the and belief. to uns?,,o falsification to authorities. l very y information 9p4 relating personal knowledge, C.S.A. §`4 subject to the penalties of 18 Pa. SWORN to and subscribed before -'`t 11 day of me this My Cprntrifs? ?^r ` t Notaries tvania AssoC'ation Member, Pe""sY 'r-` hJ -1 ?? 'r. ';: -"' Ca ? .: - ..,, ?? t ` - ?7 C. ? ,'? - r •? ? T ? `v ? - .: _)?? 4 !? ?'r`j ~c A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Deanna E. Hoffman 22 South 40' Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 5, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffman and John T. Hoffman are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. .,a The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, vs. Deanna E. Hoffinan and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $27,908.87. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN ? BIRSIC, P.C. J sfi r, .squire Atrney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 iIe t IN T11 COURT OF COMMON PLEAS 01- CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN IJOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN 1'. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five- tenths (198.5) feet to a point marked by an iron pin; thence South eighty-two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five- tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401-403 Front Street, West Fairview, Pennsylvania. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN & BIRSIC, P.C. By: orneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 r t M co w l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John T. Hoffinan 22 South 4 h Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 5, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. a The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, VS. Deanna E. Hoffinan and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $27,908.87. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN &_ BIRSIC, P.C. Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 4% IN '1 HE COUIZT Ol- COMMON PLEAS OF CUMB BLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and 301-IN 1'. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River; thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five- tenths (198.5) feet to a point marked by an iron pin; thence South eighty-two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five- tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401403 Front Street, West Fairview, Pennsylvania. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Page 1190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN & BIRSIC, P.C. By: ` set? A. Fidler, Esquire Azfomeys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 c"? ? C? _.... -,` << c_ ?-- ?? Y ,, } ?.: -;-, , _ ?:, ._ _... - _? .. ?-, ?: C3 H ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c)(2) PURSUANT TO RULE 3129.1 LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 12/5/07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE I, Joseph A. Fidler, Esquire, Attorney for Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129. 1, as well as all persons named in Plaintiff's Supplemental Affidavit pursuant to Rule 3129.1 as follows: 1. By letters dated July 24, 2007, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. 2. By letter dated August 15, 2007, undersigned counsel served the persons named in Plaintiffs Supplemental Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective address set forth in the Supplemental Affidavit Pursuant to Rule 3129.1. A true and correct copy of said Supplemental Affidavit Pursuant to Rule 3129.1 and Certificate of Mailing are marked Exhibit "B", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. BY: PV?1V?/ { 1. L {Y{V{,. LuYY{{V A rneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS' DAY OF , 2007. Notary Public COQ MO"EALTH OF PENNSYLVANIA WNW Seel ubBc oyAwend, Notary P M My CaTwdssl E JAM w xvopk W ?] Member, Pennsylvania Association O Noterles EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Horne Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffman and 22 South 4" Street John T. Hoffman Halifax, PA 17032 • • 2. The name and address of the defendants in the judgment: Deanna E. Hoffman and John T. Hoffman 22 South 4'' Street Halifax, PA 17032 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. HSBC Bank USA National Association 3476 Stateview Blvd. Fort Mill, SC 29715 HSBC Bank USA National Association Phelan, Hallinan & Schmie& LLP c/o Francis S. Hallinan, Esquire 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 401 Front Street West Fairview, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworD falsification to authorities. for Plaintiff SWORN to and subscribed before me this day of '2007. No ary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seel Ekzabettt M. Pataw Notary Pudic CRY Of Pftbxgh, Akgt" County My Comrraission Ele kw Jan. s, 2008 Member. Pennsylvania Association Of Notaries o 3 1 0- m I l y A O A O O W d 7 C71 a 5 N ?0 ?D n CD 25 0 (a rr oX D? y c c n -'' CD z z N n m m g - - -1 S bj N°-4??, ?-4 ooaoa a to" •? -n vi W g 2 a 7 a m N 3 O N E A N N ?? A ?A to - o, .. -o?°n moo- < 3 a CO) u Dc?n°, ?atv? ? yam = M -L D D N a -4 C W q6 3. 000? r A O 91 1 a E i s? ?l? _ v O ?,,fqs N - q. •9.? o % N ` g ? v Y o?Cy9 S? O m.V?? 71 UI N 8? N Orryy?? I N OM. N -•+ b EXIFIIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., Plaintiff in the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 982 Enola Drive Enola, PA 17025 I verify that the statements made in the Supplemental Affidavit are but and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. GRENEN & BIRSIC, P.C. BY:,-? iFEsquire Att ys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS ?yl DAY OF , 2007. Notary Public COMMONWEALTH OF PENNSYLVAN{A Nofaital seal Pattie A. Tow wrrn0, Noloy PtM Cky Or PWdx#gK AkiptoW Courty W Cornxnt don E>q n June $ 2011 Member, Pennsylvania Association of Notaries T U.S. POSTAL SERVICE CERTIFICATE OF MIRILH+N3 ?? hw h or mabr poets p and MAY BE USED FOR DOMESTIC AND NTERNATIONAL MAIL, DOES NOT of PROVIDE FOR IGURANCE-P05TMASTER ourrrlnt Roo" From ?p a G Gregen & Sirsic. P.C. One Gelmm Center, 9* Flw, Piltstw P Y t W Orb piece of orfnery maa addressed b: East POnn$bDrO Township ' , cc) i C) 982 Enda $ ., End-. PA 17025 En o d N? b PS Form 3817, Januarl! 2001 352.231 Hoffman PT . : ' ; ? rTl • .% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE DEFENDANTS/OWNERS FILED ON BEHALF OF PLAINTIFF: Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 12/5/07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. Pa. R.C.P. RULE 3129.2(c) AFFIDAVIT OF SERVICE Joseph A. Fidler, Esquire, Attorney for Plaintiff, Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., being duly sworn according to law deposes and makes the following Affidavit regarding service of Plaintiffs notice of the sale of real property in this matter on June 13, 2007 as follows: 1. Deanna E. Hoffman and John T. Hoffman are the owners of the real property and have not entered an appearance of record. 2. By letter dated July 24, 2007, the undersigned counsel served Defendants, Deanna E. Hoffman and John T. Hoffman, with true and correct copies of Plaintiffs notice of the sale of real property by certified mail, restricted delivery, return receipt requested, addressed to 22 South 0 Street, Halifax, Pennsylvania 17032. On or about July 27, 2007, the signed certified mail receipts were returned to Plaintiff, indicating the Defendants were served with the Notice of Sheriff's Sale. True and correct copies of the returned certified mail receipts, are marked Exhibit "A", attached hereto and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information, and belief. SWORN TO AND SUBSCRIBED BEFORE ME Jos . Fidler, Esquire orneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 THIS S DAY OF , 2007. C? 1 ?? ? m> ? ??nao? Notary Public COMMONWEALTH OF PENNSYLVANIA Nota W Seal Palle A. TowttsaW, Notary Public City Of Piltsbugl% ANe"V Courttyy My CwYnWs1 n E*m June $ 2011 Member, Pennsylvania Association of Notaries GRENEN & BIRSIC, P.C. f EXHIBIT "A" 4 ¦ #, 2, 4ery y Edo ootnplks fterrl A ? ? Delhr Is dashed. A. s i?eit?a ¦ Pr#r r?arr? and address on the reverse so:that we can return the card to you. B. ReosNed by (PM W fir * C. Dde of Delivery ¦ Attach this card to the back of the mal"m, j or on the front " space permits. Vale D. Is dsiwry address 1 Addnseed to: ff YE3 enter delivery. ` ? ly e 3 ? ?? D . Urplobl"I Reoelpt for Msrdrarrdfes ? ReyietBfed' i O Insured Md o C.O.D. f 4. Restricted D~ ttcxba Fso 2. ArdoleF?ktmbor :t; 7001r f ? eer1?? ? S ; ' , 440. ;OdOl 2506;; %! : i' F [ 1111 Domestic Reti m RsoW 10 MO424& 446 F ¦ Cornpleis two 1, 2, and 3. Also oonvl to A. I Item 4 If Restricted Delivery Is desired- X Agent 1 ¦ Pdnt your name and address on the reverse 0 ?rddrsaee 1 aro OW w o can return the card to you. by ( Delp of DWkwy ¦ Attach this CaFd'to the back of the rnanpfece, or on the frant if space permits. D is dsrery addres 'I 1, ArtieN Addressed to: i 1j ??,Jr ' r ? .ll l ? 1 ^ N <- rz yin 2 ?. service Type , X- Pw ils and ? EANNO Mal ? RooWersd Ret un Receipt for MeroWWWD 0 bmired &W ? C.OA. 4. PMUk bd Dslwry4 4BOU Fes) 11Ys 2. Artlder4,r* f 7906 3450 01101 2506 9680 1 (rnmw ft m servos mW PS form 3811, febnmy 2W.4 Dcxnes@c ReWm Pox)O C tames aa+rr taw z Q J K4 71 r? Jin ?E r: N -G 411 1 ,or , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, TYPE OF PLEADING SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 FILED ON BEHALF OF PLAINTIFF: Defendants. Mortgage Electronic Registration Systems, Inc., as Nominee for American Horne Mortgage, d/b/a American Home Mortgage Servicing, Inc., COUNSEL OF RECORD FOR THIS PARTY: Joseph A. Fidler, Esquire Pa. I.D. #87325 GRENEN &. BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 12/5/07 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., Plaintiff in the above-captioned action files the instant Supplemental Affidavit Pursuant to Rule 3129.1. The information identified below is in addition to the information previously identified in the Affidavit Pursuant to Rule 3129.1. As of the date that the Praecipe for Writ of Execution was filed, the information set forth below was of record concerning the real property of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF I CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 982 Enola Drive Enola, PA 17025 I verify that the statements made in the Supplemental Affidavit are true and correct to the best of my personal knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities GRENEN & BIRSIC, P.C. BY: Iis er, Esquire Att Heys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF , 2007. -Q? Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seel Pabida A. Townsend. Notary Public City Of Piltsbio, Aftheny Courtly My Commission Etq*es Jute 2, 2011 Member, Pennsylvania Association of Notaries C'? P?7 C:a • ' ' r G'? rc t rr, Mortgage Electronic Registration Systems In the Court of Common Pleas of Inc., as Nominee for American Home Cumberland County, Pennsylvania Mortgage, d/b/a American Home Mortgage Writ No. 2006-7123 Civil Term Servicing, Inc. VS Deanna E. Hoffinan and John T. Hoffman R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Deanna E. Hoffman and John T. Hoffman, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice of Sale and Description, in the above entitled action, according to law. Dauphin County Return: And Now, September 06, 2007 at 0920 hours served the within Real Estate Writ, Notice of Sheriffs Sale and Description upon the within named defendants, Deanna E. Hoffman and John T. Hoffinan by personally handing to Deanna Hoffman, for herself and for her husband, John T. Hoffman, at 22 South 4th Street, Halifax, Pennsylvania, and made known unto her the contents thereof. So answers: J.R. Lotwick, Sheriff of Dauphin County, Pennsylvania. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 1409 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Deanna E. Hoffman and John T. Hoffman located at 401-403 Front Street, West Fairview, 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 defendants, to wit: Deanna E. Hoffinan and John T. Hoffinan by regular mail to their last known address of 22 South 4th Street, Halifax, PA 17032. These letters were mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Fidler. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Levy Surcharge Out of County Dauphin County Law Journal Patriot News Share of Bills 30.00 17.80 15.00 15.00 2.00 15.36 15.00 30.00 9.00 49.00 359.00 335.72 14.92 $ 907.80 ? /,? f /% ? So Answers: R. Thomas Kline, Sheriff BY ?JU Real Estate ' rgeant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC., CIVIL DIVISION NO.: 06-7123 CIVIL TERM Plaintiff, VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc., 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 of Deanna E. Hoffinan and John T. Hoffinan located at 401-403 Front Street, West Fairview, Pennsylvania 17025 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. 1. The name and address of the owners or reputed owners: Deanna E. Hoffman and 22 South 4 h Street John T. Hoffman Halifax, PA 17032 2. The name and address of the defendants in the judgment: Deanna E. Hoffman and John T. Hoffinan 22 South 4`h Street Halifax, PA 17032 3. The name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. 4. The name and address of the last record holder of every mortgage of record: Mortgage Electronic Registration PLAINTIFF Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. HSBC Bank USA National Association 3476 Stateview Blvd. Fort Mill, SC 29715 HSBC Bank USA National Association c/o Francis S. Hallinan, Esquire Phelan, Hallinan & Schmieg, LLP 1617 JFK Blvd., Suite 1400 Philadelphia, PA 19103 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants 401 Front Street West Fairview, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswor4 falsification to authorities. SWORN to and subscribed before AU6mev for Plaintiff me this day of '2007. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Elizabeth M. Paiano, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Jan. 6, 2008 Member, Pennsylvania Association Of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Deanna E. Hoffinan 22 South 4`h Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 5, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, vs. Deanna E. Hoffman and John T. Hoffman, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $27,908.87. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN 4 BIRSIC, P.C. Bv: A brney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN T. HOFFMAN, Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: John T. Hoffinan 22 South 4`h Street Halifax, PA 17032 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 5, 2007 at 10:00 A.M., the following described real estate, of which Deanna E. Hoffinan and John T. Hoffinan are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF DEANNA E. HOFFMAN AND JOHN T. HOFFMAN OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN THE BOROUGH OF WEST FAIRVIEW A/K/A EAST PENNSBORO TOWNSHIP, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 401-403 FRONT STREET, WEST FAIRVIEW, PA 17025. DEED BOOK VOLUME 271, PAGE 1190, AND PARCEL NUMBER 45-17-1044-100. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action of Mortgage Electronic Registration Systems, Inc., as Nominee for American Home Mortgage, d/b/a American Home Mortgage Servicing, Inc. Plaintiff, vs. Deanna E. Hoffman and John T. Hoffinan, Defendants, at Execution Number 06-7123 CIVIL TERM in the amount of $27,908.87. A Schedule of Distribution will be filed by the Office of the Sheriff no later than thirty (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution unless exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the date when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN, BIRSIC, P.C. By;, loso A. Fidler, Esquire A orney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MORTGAGE ELECTRONIC: CIVIL DIVISION REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME NO.: 06-7123 CIVIL TERM MORTGAGE SERVICING, INC., Plaintiff, vs. DEANNA E. HOFFMAN and JOHN']'. HOFFMAN, Defendants. LONG FORM DESCRIPTION ALL that certain tract of land, situate in the Borough of West Fairview also known as East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence North eighty-two (82) degrees forty-five (45) minutes East, fifty-four (54) feet to an iron pin at the shore of the Susquehanna River, thence North seven (07) degrees fifteen (15) minutes West, one hundred ninety-eight and five- tenths (198.5) feet to a point marked by an iron pin; thence South eighty-two (82) degrees forty-five (45) minutes West, fifty-four (54) feet to a point marked by an iron pin to the East side of Front Street; thence along Front Street, South seven (07) degrees fifteen (15) minutes East, one hundred ninety-eight and five- tenths (198.5) feet to a point, the place of BEGINNING. HAVING thereon erected a double frame dwelling house known and numbered as 401-403 Front Street, West Fairview, Pennsylvania. BEING the same premises which Richard Frey, Michael Frey, Barry Frey, Tracey Frey, now by married Tracey Frey Hoffman, Joseph Frey, Ruth Frey-Lupfer, individually and Ruth Frey-Lupfer, as Administrator, by Deed dated September 29, 2005 and recorded in the Office of the Recorder of Deeds of Cumberland County on October 3, 2005 in Deed Book Volume 271, Pagel 190, granted and conveyed unto John T. Hoffman and Deanna E. Hoffman, husband and wife. GRENEN & BIRSIC, P.C. By: A. Fidler, Esquire O??'se orneys for Plaintiff e Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 Parcel# 45-17-1044-100 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7123 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN HOME MORTGAGE DB/A AMERICAN HOME MORTGAGE SERVICING, INC., Plaintiff (s) From DEANNA E. HOFFMAN AND JOHN T. HOFFMAN (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 $23,565.71 Interest $4,343.16 Atty's Comm % Atty Paid $309.03 Plaintiff Paid Date: JULY 19, 2007 (Seal) L.L. Due Prothy $2.00 Other Costs Deputy REQUESTING PARTY: Name JOSEPH A. FIDLER, ESQUIRE Address: ONE GATEWAY CENTER, 9TH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. 87325 AAA cim-l Real Estate Sale # 45 On August 17, 2007 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 401-403 Front Street, West Fairview, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 17, 2007 By J Real Estate Sergeant S I - ( C - Z 1'if E??l PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 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. 45 Writ No. 06-7123 Civil MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for AMERICAN HOME MORTGAGE, d/b/a AMERICAN HOME MORTGAGE SERVICING, INC. VS. DEANNA E. HOFFMAN and JOHN T. HOFFMAN Atty.: Joseph Fidler DESCRIPTION ALL that certain tract of land, sit- uate in the Borough of West Fairview also known as East Pennsboro Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: BEGINNING at an iron pin, on the East side of Front Street; thence Lis arie Coyne, Edit /r SWORN TO AND SUBSCRIBED before me this 9 day of November, 2007 r Notary NOTARIALSEAL _ DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Explres Apr 28, 2010 .. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ?latriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below: 10/24/07 11111W io 45 10/31/07 7 QAft MIC., +kallElMOM 11/07/07 P.O. 1 MIG. . D 11NIi11&mand Sworn to dscribed befo a this 30 day of November, 2007 A.D. No ry Public M: dw mt* tax of INK AMW is Ilk 4 WW ftiv do "WAt• Fat . lMafivaw k COMMONWEALTH OF PENNSYLVANIA d?efe?aivs air ' Nota" Seal G t m iio? pia, e? Ilk Eet aide of James L. Clark. "rY Public RW Skw &me no" MZ City OF Hartis M. Dauphin County hg41 P, fo ear ? > My Commission E)ires June 2, 2008 0?oft of do Nam spa Member, Pennsylvania Association of Notaries ?s?A ¢? tsltt?? eat?t