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HomeMy WebLinkAbout06-7167 THOMAS I. PULEO, LLC By: Thomas 1. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC 7159 Corklan Drive Jacksonville, Florida 32258 V. MATTHEW A. PRAZENICA 702 Highland Avenue Mt. Holly Springs, PA 17065 : No. 0(wo - 11(ab 7 CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIES QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff, ABN AMRO MORTGAGE GROUP, INC., is a corporation organized and existing under laws of the State of Delaware with offices at 7159 Corklan Drive, Jacksonville, Florida. 2. Defendant, MATTHEW A. PRAZENICA, is the mortgagor and real owner of premises 702 Mount Holly Springs, South Middleton Township, Cumberland County, Pennsylvania, hereinafter described, whose last known address is as stated above. 3. On the 21" day of May, 1999, the above named mortgagor made, executed and delivered a mortgage upon premises hereinafter described to Accubanc Mortgage Corporation, which mortgage is recorded in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 1543 page 769. 4. The premises subject to the said mortgage is described in Exhibit "A" attached hereto and made a part hereof. 5. On the 8`h day of June, 2001, the said mortgage was last assigned to plaintiff, ABN AMRO MORTGAGE GROUP, INC., by written assignment which is recorded in the Office of the Recorder of Deeds for Cumberland County in Mortgage 680 page 1470. 6. The mortgage is in default because the defendant has failed to make the payment of the monthly installment of principal and interest in accordance with the terms of the mortgage for August 1, 2006, and each month thereafter, up to and including the present time. 7. The following amounts are due on the mortgage: -1- Principal $88,286.54 Interest at 8% per annum from 7/1/06 thru 11/30/06 ($19.35 per diem) 2,960.55 Late charges accrued thru 11/30/06 ($37.05/month) 111.15 Escrow deficit (taxes and insurance) ($213.79/month) 855.16 Attorney's fee (5%) 4,414.33 Title information certificate 325.00 Total $96,952.73 8. The said mortgage is not a residential mortgage as defined by Pennsylvania Act No. 6 of 1974, and hence, no notice of intention to foreclose is required by the said Act. 9. The aforesaid mortgage is insured under Title II of the National Housing Act, and therefore, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, plaintiff demands judgment in the sum of $96,952.73 plus interest, late charges, escrow advances and costs to the date of judgment and foreclosure of the said mortgage. OMAS I. PUL O Attorney for P1 intiff -2- ALL THOSE TWO LOTS OR PARCELS OF LAND situate in the Township of South Middleton, County of Cumberland and State of Pennsylvania, being Lots Nos. 33 and 34 in a Plan of Lots known as "Mt. View Addition", the same being of record in the office of the Recorder of Deeds for Cumberland County in Plan Book 3, Page 86, and more particularly described as follows: Tract No. 1 BEGINNING at a point on the East side of Highland Ave., said point being the boundary line of Lots 34 and 35 and approximately 150 feet Northerly along said Highland Ave., from the Northeast point of intersection of Highland Ave. and Mt. View Drive; thence Easterly along the line of Lots 34 and 35, One Hundred Fifty feet to a point; thence Northerly along the line of Lots 34 and 74 to a point on Woodland Ave., a distance of approximately 50 feet; thence Westerly along the South line of Woodland Ave., approximately One Hundred Fifty feet to a point at the intersection of Woodland Ave. and Highland Ave.; thence in a Southerly direction with Highland Ave. approximately 100 feet to the place of BEGINNING. HAVING thereon erected a 6 room brick house with bath and attached garage. Tract No. 2 ALL THAT CERTAIN lot or ground situate in the Township of South Middleton, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point in the Eastern side of Highland Avenue, which point is a corner of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence in an Eastwardly direction along the line of Lot No. 34, a distance of 150 feet to a point in line of Lot No. 74; thence in a Southerly direction along part of Lot No. 74, a distance of 50 feet to a point in line of land of Lot No. 36; thence in a Westwardly direction along the line of Lot No. 36, a distance of 150 feet to a point in the Eastern side of said Highland Avenue; thence in a northwardly direction along the Eastern side of said Highland Avenue, a distance of 50 feet to a point, the place of BEGINNING. BEING all of Lot No. 35 on that certain Plan of Lots laid out and adopted by M.L. Gulden, said Plan being recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book No. 3, page 86, said Plan of Lots being known as "Mountain View Addition". Commonly known as: 702 Highland Avenue, Mount Holly Springs, PA 17065. M ¦ EXHIBIT A VERIFICATION John K. Jonse'ereby states that h St. Vice PresideAABN AMRO Mortgage Group, Inc., the plaintiff, or servicing agent for plaintiff, in this matter; that he is authorized to take this Verification; and that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements made therein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. DATE: 12, " (I - C) VI co T -ij hi < 0 ?I r THOMAS I. PULED, LLC By: Thomas I. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC V. No. 06-7167 Civil Term MATTHEW A. PRAZENICA PRAECIPE FOR JUDGMENT Enter judgment in favor of the Plaintiff and against the Defendant(s) for want of an answer and assess damages as follows: Principal Interest from 7/1/06 to 2/2/07 Late charges accrued thru 2/2/07 Escrow deficit (taxes and insurance) Attorney's fee (5%) Title information certificate $88,286.54 4,198.95 185.25 1,496.53 4,414.33 325.00 Total $98,906.60 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this prae10r, ?A copy of the notice is attached. Pa.R.C.P. 237.1 OMAS I. rJdLEO, ESQUIRE Attorney for Plaintiff AND NOW .h2lL , 2007, Judgment is entered in favor of plaintiff and against defendants and damages assessed as per the above certification. Pro onotary THOMAS I. PULEO, LLC By: Thomas I. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC. V. MATTHEW A. PRAZENICA To: Mr. Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 Date of Notice: January 19, 2007 : No. 06-7167 Civil Term NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237.1 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 AND OTHER IMPORTANT RIGHTS. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 AVISO IMPORTANTE A: Mr. Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 FECHA DEL AVISO: January 19, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATEMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 OMAS I. LEO Attorney for Plaintiff THOMAS I. PULED, LLC By: Thomas I. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC V. : No. 06-7167 Civil Term MATTHEW A. PRAZENICA AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF MONTGOMERY SS. THOMAS I. PULED, being duly sworn according to law deposes and says that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; That Matthew A. Prazenica is over 21 years of age, resides at 702 Highland Avenue, Mt. Holly Springs, Pennsylvania, and is employed by/as unknown. SWORN TO AND SUBSCRIBED BEFORE ME THIS 19" DAY OF January, 2007. l T MAS I. PU Attorney for Plaintiff A, Q-mil NOTARY PUBLIC OTARIAL 9W, LOA R. KANE. Notary P t1N*W Up.. Montgomerytr#QW1t es A ? ? ?- o ?? ? ? r J ? ? ? W s -. (°t'? a`S s C? , `='?? ?<' i ?, .=r ?r,?'; - C.3 ?.? :-- _. _ ?'? ?? i + . ?' ° ` ?..._ iii... Y_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP, INC., Plaintiff, V. MATTHEW A. PRAZENICA, Defendant(s). COURT OF COMMON PLEAS NO. 06-7167 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST FROM 2/3/07 @ $19.35 per diem $98,906.60 COSTS TO BE ADDED $ 111.90 OMAS I. P O, ESQUIRE Attorney for Plaintiff W Fr? pti""s w , !r`t rn o '? e` C o Q C? Q ¦ V ' 7 , ? ?? v w w ? or C 7 ?. SZ f ' THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO. 06-7167 Civil Term V. MATTHEW A. PRAZENICA, Defendant AFFIDAVIT UNDER PA. RCP RULE 3129 THOMAS I. PULED, attorney for Plaintiff in the above captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 702 Highland Avenue, South Middleton Township, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 2. Name and address of each Defendant named in the judgment: Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4 5. 6. 7 Name and address of the last recorded holder of every mortgage of record: ABN AMRO Mortgage Group, Inc., Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 GMAC Mortgage Corporation d/b/a Ditech 3200 Park Center Drive, Suite 150 Costa Mesa, CA 92626 Name and address of every other person or entity which has any record lien on the property: None. Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth of PA Department of Public Welfare P. O. Box 2675 Harrisburg, PA 17105 Stacy Ann Prazenica 702 Highland Avenue Mt. Holly, PA 17065 Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this 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. Section 4904 relating to worn falsification to authorities. Date: January 29, 2007 T MAS I. PUL , ESQUIRE Attorney for Plaintiff r-? - r ;7 `i { ? -a - "t" : - ? t ? v ??': ? ? ?i -.? "" ?..e? ?'"? ; ??-- t r,.? - C ? - ? THOMAS I. PULED, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff V. NO. 06-7167 Civil Term MATTHEW A. PRAZENICA, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 Your house at 702 Highland Avenue, City of South Middleton Township, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $98,906.60 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you. The Sheriffs Sale will be conducted on Wednesday, June 13, 2007, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 06 You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriffs Department at (717) 240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Department at (717) 240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale had never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution sheet is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ALL THOSE TWO LOTS OR PARCELS OF LAND situate in the Township of ` South Middleton, County of Cumberland and State of Pennsylvania, being Lots Nos. 33 and 34 in a Plan of Lots known as "Mt. View Addition", the same being of record in the office of the Recorder of Deeds for Cumberland County in Plan Book 3, Page 86, and more particularly described as follows: Tract No. 1 BEGINNING at a point on the East side of Highland Ave., said point being the boundary line of Lots 34 and 35 and approximately 150 feet Northerly along said Highland Ave., from the Northeast point of intersection of Highland Ave. and Mt. View Drive; thence Easterly along the line of Lots 34 and 35, One Hundred Fifty feet to a point; thence Northerly along the line of Lots 34 and 74 to a point on Woodland Ave., a distance of approximately 50 feet; thence Westerly along the South line of Woodland Ave., approximately One Hundred Fifty feet to a point at the intersection of Woodland Ave. and Highland Ave.; thence in a Southerly direction with Highland Ave. approximately 100 feet to the place.of BEGINNING. HAVING thereon erected a 6 room brick house with bath and attached garage. Tract No. 2 ALL THAT CERTAIN lot or ground situate in the Township of South Middleton, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point in the Eastern side of Highland Avenue, which point is a corner of Lot No. 34 on the hereinafter mentioned Plan of Lots; thence in an Eastwardly direction along the line of Lot No. 34, a distance of 150 feet to a point in line of Lot No. 74; thence in a Southerly direction along part of Lot No. 74, a distance of 50 feet to a point in line of land of Lot No. 36; thence in a Westwardly direction along the line of Lot No. 36, a distance of 150 feet to a point in the Eastern side of said Highland Avenue; thence in a northwardly direction along the Eastern side of said Highland Avenue, a distance of 50 feet to a point, the place of BEGINNING. BEING all of Lot No. 35 on that certain Plan of Lots laid out and adopted by M.L. Gulden, said Plan being recorded in the Office of the Recorder of Deeds in and for the County of Cumberland in Plan Book No. 3, page 86, said Plan of Lots being known as "Mountain View Addition". TAX PARCEL NO. 40-30-2646-037 Commonly known as: 702 Highland Avenue, Mount Holly Springs, PA 17065. EXHIBIT A r.a ?; - ?. ? .--a -n -r m ?"' _ t ?`, , ?? _ ?r ,; ... ^, ,7 ' t.?J ? =-t -- _?_t t`-? -. ??_ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s) From MATTHEW A. PRAZENICA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL NO 06-7167 Civil CIVIL ACTION - LAW 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 $98,906.60 Interest FROM 2/3/07 @ $19.35 PER DIEM L.L. $.50 Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 6, 2007 (Seal) Due Prothy $1.00 Other Costs COSTS TO BE ADDED $111.90 AAe4vw iq&tis R. Lo rotho tary By: Deputy REQUESTING PARTY: Name THOMAS I. PULED, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone : 610-941-3600 Supreme Court ID No. 27615 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 SUITE 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. 7159 Corklan Drive Jacksonville, FL 32058 Plaintiff vs. MATTHEW A. PRAZENICA Mortgagor(s) and Record owner(s) 702 Highland Avenue Mt. Holly Springs, PA 17065 TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Defendant(s) ENTRY OF APPEARANCE CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 06-7167 Civil Term Kindly enter my appearance on behalf of the Plaintiff in the above-captioned matter. GOLDBECK BY: & McKEEVER JR., ESQUIRE JOSEPH As of April 2, 2007, Thomas I. Puleo, Esquire has joined the firm of Goldbeck McCafferty & McKeever in their Philadelphia office. Mr. Puleo's contact information is as follows: Suite 5000, Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Main Phone (215) 627-1322 Direct Phone (215) 825-6309 Direct Fax (215) 825-6409 Email: Tpuleor_t4goldbecklaw.com C3 r.a ? C r4_ ?' ? . ?`?:s=?? ,? ? ?r 'r7 f --. ...-?. ? 4,,,,? f, f :?, ?_ ? ti? SHERIFF'S RETURN - REGULAR CASE NO: 2006-07167 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABN AMRO MORTGAGE GROUP INC VS PRAZENICA MATTHEW A SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE PRAZENICA MATTHEW A was served upon the DEFENDANT , at 1815:00 HOURS, on the 29th day of December-, 2006 at 702 HIGHLAND AVENUE MT HOLLY SPRINGS, PA 17065 -rt mmTTTn T.T TI TI T ?7=-KTT ("A by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing 18.00 Service 4.40 Affidavit .00 Surcharge 10.00 .00 32.40 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/02/2007 THOMAS PULEO By: eputy Sheriff A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. 7159 Corklan Drive Jacksonville, FL 32058 Plaintiff VS. MATTHEW A. PRAZENICA Mortgagor(s) and Record Owner(s) 702 Highland Avenue Mt. Holly Springs, PA 17065 Defendant(s) IN THE COURT OF C MMON PLEAS of Cumberland) County CIVIL ACTION - LAW ACTION OF Term No. 06-7167 Ci CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that si Defendants of the Notice of Sheriff Sale was made by: ( Personal Service by the Sheriffs Office/ (copy of return at ( Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return rec ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defend (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return 2 ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attache ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original recei? Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mail. The undersigned understands that the statements herein are subject to the penalties prQ Section 4904. p1VA. Gol( for Plainti ABNPUL-0079 CF: 12/18/2006 SD: 06/13/2007 $98,906.60 FORECLOSURE Term on the attached). s) of record ) for Certified any) has been attached). by 18 P.S. r. ABN Amro Mortgage Group, Inc. In the Court of Common Pl as of VS Cumberland County, Penns lvani Matthew A. Prazenica Writ No. 2006-7167 Civil T rm Kenneth Gossert, Deputy Sheriff, who being duly sworn according to la` March 27, 2007 at 1634 hours, he served a true copy of the within Real Estate V Description, in the above entitled action, upon the within named defendant to wi Prazenica, by making known unto Matthew Prazenica, personally, at Sheetz, No Street, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, st 12, 2007 at 1440 hours, he posted a true copy of the within Real Estate Writ, No Description, in the above entitled action, upon the property of Matthew A. Praze Highland Ave., Mt. Holly Springs, Cumberland County, Pennsylvania accordinj R. Thomas Kline, Sheriff, who being duly svrorn according to law, state above Real Estate Writ, Notice, Poster and Description in the following manner: mailed a notice of the pendency of the action to the within named defendant, to, Prazenica, by regular mail to his last known address of 702 Highland Ave., Mt. 17065. This letter was mailed under the date of April 4, 2007 and never returne Office. d 'I? A R. Thomas Kline, Sheriff BYJ Real Estate eputy states that on rit, Notice and : Matthew A. th Baltimore he same time rtes that on April :ice, Poster and lica, located at 702 to law. he served the The Sheriff vit: Matthew A. folly Springs, PA . to the Sheriff's I o 00 oo N w ??1 0 Qo No'd p o o ? l ? z a Jy? Fry?9 z . 10 "F $ !S !Ay PA 19'. y c 0 5 n E o? ???? LL J 0 W tip, 0) g he d. CO) A 0 C-4 ti F co o 0,L I? fill r v) x a. a zQ a ???? Lu w ?mf Up ZT Q Q + 4 N ? LLJ aU[LU amIa:i C9rNi F-rr? m U) N ?? a c oc W e E a a ?d ti Q Yd CXL o wo Wa co -J a = (AID z U- Z O 7 0 as ri cf ui cm r? ao a C9mi.d? ,off ?LL 0 r O 0 i?wJ O 1 ?aQU i 5 d N to Q g ??1 0 U- Qc w ?S N O Q 4tINt1 0 0 1• I aA E U) x a? i m CL I c I I , I 8 ? 3 a A W W c N Q ? El ° I Uwe 4 ZZZ W w of U) ? o CL Q ? I vm E? zQ-'p OClD0E Q N D U U) I- i I I I ?C ?-- m W E z CI w uwla 0 Q aNi N $YOW(L N' ?cWO?WW) to co a E z0Fo=? cfl r? ao N co L6 0tnt.-C? 0 m m C m UY Q , 'C a c m a c I O m At 3. ? ? Y m a V O g? N t ? co , a C> C> I? co a N 00 w 0 7 a ? 0 z 7 a c : U N N m Q? W 2 S EC G ? LL U a ? O Q M J W z a p IL d Z Q t- J a Q 2 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ABN AMRO MORTGAGE GROUP, INC. 7159 Corklan Drive Jacksonville, FL 32058 Plaintiff vs. MATTHEW A. PRAZENICA Mortgagor(s) and Record Owner(s) 702 Highland Avenue Mt. Holly Springs, PA 17065 Defendant(s) IN THE COURT OF of Cumberla CIVIL ACTI ACTION OF MORTG? Tei No. 06-7167 VIT ABN AMRO MORTGAGE GROUP, INC., Plaintiff in the above action, by its attorney, Jo Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following inform property located at: 702 Highland Avenue Mt. Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): MATTHEW A. PRAZENICA 702 Highland Avenue Mt. Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: MATTHEW A. PRAZENICA 702 Highland Avenue Mt. Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the I iMMON PLEAS County I - LAW ?FORECLOSURE vil Term A. Goldbeck, Jr., concerning the real to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 • PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support . ' Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: GMAC Mortgage Corporation DBA ditech.com 3200 Park Center Drive, Suite 150 Costa Mesa, CA 92626 5. Name and address of every other person who has any record interest in or record lien on the may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any may be affected by the sale. TENANT/OCCUPANT 702 Highland Avenue Mt. Holly Springs, PA 17065 STACY ANN PRAZENICA 702 HIGHLAND AVENUE MOUNT HOLLY SPRINGS, PA 17065 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my pers? information and belief. I understand that false statements herein are made subject to the penalties of', relating to unworn falsification to authorities. DATED: May 16, 2007 GOL BE K MdCAFFERTY & Mcp BY: Jb_sWh A. Goldbeck, Jr., Esq. Attorney for Plaintiff and whose interest in the property in the property which nal knowledge or .8 Pa. C.S. Section 4904 51 c n M ABN Amro Mortgage Group, Inc. VS Matthew A. Prazenica In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-7167 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March 27, 2007 at 1634 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Matthew A. Prazenica, by making known unto Matthew Prazenica, personally, at Sheetz, North Baltimore Street, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1440 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 Matthew A. Prazenica, located at 702 Highland Ave., Mt. Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Matthew A. Prazenica, by regular mail to his last known address of 702 Highland Ave., Mt. Holly Springs, PA 17065. This letter was mailed under the date of April 4, 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 Thomas I. Puleo. Sheriffs Costs: Docketing 30.00 Poundage 40.00 Posting Handbills 30.00 Advertising 30.00 Law Library .50 Prothonotary 1.00 Mileage 17.28 Levy 30.00 Surcharge 30.00 Law Journal 509.00 Patriot News 445.01 Share of Bills 16.17 Postpone Sale 40.00 $1,218.96 R. Thomas Kline, Sheriff Real f 91 n/6 7 9" BY ? p ? 4o 3 y,?ly 146AW • J Ir ? THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff NO. 06-7167 Civil Term V. MATTHEW A. PRAZENICA, Defendant AFFIDAVIT UNDER PA. RCP RULE 3129 THOMAS. I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 702 Highland Avenue, South Middleton Township, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief. 1. Name and address of each Owner and/or Reputed Owner: Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 2. Name and address of each Defendant named in the judgment: Matthew A. Prazenica 702 Highland Avenue Mt. Holly,. PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None. 4. Name and.address of the last recorded holder of every mortgage of record: ABN AMRO Mortgage Group, Inc., Plaintiff 7159 Corklan Drive Jacksonville, FL 32258 GMAC Mortgage Corporation d/b/a Ditech 3200 Park Center Drive, Suite 150 Costa Mesa, CA 92626 5. Name and address of every other person or entity which has any record lien on the property: None. 6. Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Commonwealth of PA 13 N. Hanover Street Department of Public Welfare Carlisle, PA 17013 P. O. Box 2675 Harrisburg, PA 17105 Stacy Ann Prazenica 702 Highland Avenue Mt. Holly, PA 17065 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this 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. Section 4904 relating to worn falsification to authorities. Date: January 29, 2007 Attorney for Plaintiff 46 rr -? THOMAS I. PULEO, LLC 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ABN AMRO MORTGAGE GROUP, INC., Plaintiff V. NO. 06-7167 Civil Term MATTHEW A. PRAZENICA, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Matthew A. Prazenica 702 Highland Avenue Mt. Holly, PA 17065 Your house at 702 Highland Avenue, City of South Middleton Township, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $98,906.60 obtained by Plaintiff ABN AMRO Mortgage Group, Inc. against you. The Sheriffs Sale will be conducted on Wednesday, June 13, 2007, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: This sale will be canceled if you pay to ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call (610) 941-3600. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to oo the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland County Sheriffs Department at (717) 240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount bid in the sale. To find out if this has happened, you may call the Cumberland County Sheriffs Department at (717) 240-6390. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale had never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution sheet is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-7167 Civil A.. COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s) From MATTHEW A. PRAZENICA (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 $98,906.60 Interest FROM 2/3/07 @ $19.35 PER DIEM Atty's Comm % Atty Paid $114.40 Plaintiff Paid Date: FEBRUARY 6, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs COSTS TO BE ADDED $111.90 s R. Lon on tary By: Deputy REQUESTING PARTY: Name THOMAS I. PULED, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court ID No. 27615 O Real Estate Sale # 65 On March 8, 2007 the Sheriff levied upon the defendant's interest in the real property situated South Middleton Township, Cumberland.County, PA Known and numbered as 702 Highland Avenue, Mt. Holly Springs, more frilly described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 81 2007 By:10 ' ' Real Es ate Sergeant CJ S/ 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 S A L E #65 Sworn to and subscribed before me this 18th day of May 2007 A.D. Notarial Seal Terry L. Russell, Notary Public C4a Harrisburg; Dauphin County ExOres June 6,2D10 M vania Association of Notaries NO ARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27 & May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L-7 P"'Marie Coyne, E?kr SWORN TO AND SUBSCRIBED before me this 1 _,day of Mgy, 2007 2,VITARAL SEAL " LO-10 F. ; !YDER, (Votary PubFic Curoherfand County ?. -,is March 5, 2009 liUUL NOT& = Sam NO. as Writ No. 2006-7167 Civil ABN AMRO Mortgage Group, Inc. VS. Matthew A. Prazenica Atty.: Thomas I. Puleo ALL THOSE TWO LOTS OR PAR- CELS OF LAND situate in the Town- ship of South Middleton, County of Cumberland and State of Pennsyl- vania, being Lots Nos. 33 and 34 in a Plan of Lots known as *Mt. View AEldwm*, the ssroe being of record in the offfee of the Recorder of Deeds for Cumberland County in Pbw back 3, Page 86, and more particularly described as follows: Tract No. 1 BEGINNING at a point on the East side of Highland Ave., said point being-the boundary line of Lots 34 and 35 and approximately 150 feet Northerly along said HW and ' Ave., from the Northeast point of intersection of Highland Ave. and Mt. View Drive; thence Easterly.' along the line of Lots 34 and 35. One Hundred Fifty feet to a point; thence Northerly along the line of Lots 34 and 74 to a point on Wood- land Ave., a distance of approxi- mately 50 feet; thence Westerly L along the South line of Woodland Ave., approximately One Hundred Fifty feet to a point at the intersec- tion of woodland Ave. and Highland Ave.; thence in a Southerly direc- tion with Highland Ave. approxi- mately 100 feet to the place of BE- GINNING. HAVING thereon erected a 6 room brick house with bath and at _tawched garage. Tract No. 2 ALL THAT CERTAIN lot or pwaxl situate in the Township of South Middleton, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point in the Eastern side of Highland Avenue, which point is a corner of Lot No. 34 on the hereinafter mentioned e Plan of Lots; thence in an East- wardly direction along the line of Lot '. No. 34, a distance of 150 feet to a point in line of Lot No. 74; thence in a Southerly direction along part of Lot No. 74, a distance of 50 feet to a point in line of land of Lot No. 36; thence in a VAmetwuOy throe- ` tion ahw tbs me 4(Lst 1M. S a distance of 90 &vt to a palest In the Easte m side of said Highland Avenue; thence in a northwAardly direction along the Eastern side of said Highland Avenue, a distance of 50 feet to a point, the place of BEGINNING. BEING all of Lot No. 35 on that certain Plan of Lots laid out and F adopted by M.L. Gulden, said Plan being recorded in the Ol ice of the Recorder of Deeds in and for the County of Cumberland in Plan Book No. 3, page 86, said Plan of Lots being known as "Mountain View Addition". TAX PARCEL NO. 40-30-2646- 037. Commonly known as: 702 High- land Avenue, Mount Holly Springs, PA 17065.