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HomeMy WebLinkAbout06-7139"0 Leon P. Haller, Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 717.234.4178 ,?fo . 0 ? _ -71 3C1 Ci a; I {7r,,. mtg@pkh.com `? MIDFIRST BANK IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW KARA E. DOHRMAN AND ACTION OF MORTGAGE FORECLOSURE JEFFREY P. DOHRMAN Defendants THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS-LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN AND JEFFREY P. DOHRMAN, Defendants CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE N6. D,6- `7131 THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff No. 0 ? - `)! 3q cl-, 1 MIDFIRST BANK, Vs. KARA E. DOHRMAN AND JEFFREY P. DOHRMAN, Plaintiff Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is MIDFIRST BANK, a corporation whose address is 999 N.W. GRAND BOULEVARD OKLAHOMA CITY, OK 73118. 2. Defendants, KARA E. DOHRMAN and JEFFREY P. DOHRMAN, are adult individuals whose last known address is 298 MOUNT ROCK ROAD NEWVILLE, PA 17241. 3. On or about, October 11, 1996, the said Defendants executed and delivered a Mortgage Note in the sum of $90,000.00 payable to COLUMBIA NATIONAL INCORPORATED, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1346, Page 589 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. and was recorded in the aforesaid County in Mortgage Book 708, Page 4239. The Mortgage was subsequently assigned to MIDFIRST BANK and will be sent for recording. The said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on December 01, 2005 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $10.97 per day From 11/01/2005 To 01/01/2007 ( based on contract rate of 5.1250%) Accumulated Late Charges Late Charges $30.23 From 12/01/2005 to 01/01/2007 Escrow Deficit Attorney's Fee at 5% of Principal Balance TOTAL $78,158.63 $4,673.22 $527.92 $392.99 $2,200.79 $3,907.93 $89,861.48 "Together with interest at the per diem rate noted above after January 01, 2007 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of Intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 12. Prior to the commencement of this foreclosure action, Plaintiff sent to Defendants written notice dated October 25, 2006, notifying them of the fact of default, amount needed to cure the delinquency and that if the account was not timely reinstated, a foreclosure action would be filed. A copy of the October 26, 2006 notice is attached hereto and marked Exhibit "C". WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.1250% ($10.97 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of the property within described. By: v PURC L, KRUG & HALL R Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) 03141405 ADJUSTABLE RATE NOTE P11A Cut No. MI11t1aate 441-5281918 October 11, 1996 Patel 298 Mount Rock Rd. Newville, PA 17241 itpern Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means Columbia National Incorporated and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of Ninety Thousand and 00/100 Dollars (U.S. $ 9o, ooo. oo plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Leader, at a date of Seven and No-Thousandths percent ( 7.000 %) per year until the full amount of principal has been paid. The interest rate may change in accordance with Paragraph 5(C) of this Note. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instnonent that is dated the same date as this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4.14IANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on December 1 , 1996 . Any principal and interest remaining on the fast day of November 1 , 2026 , will be due on that date, which is called the "Maturity Date." (g) Place Payment shall be made at P.O. Box 3050, Columbia, MD 21045-6050 or at such other place as Lender may designate in writing by notice to Borrower. (C) Amount Initially, each monthly payment of principal and interest will be in the amount of U.S. $ 598.78 This amount will be part of a larger monthly payment required by the Security Instrument that shall be applied to principal, interest and other items in the order described in the Security Instrument. This amount may change in accordance with Paragraph 5(E) of this Note. 5. ]LAMEST RATE AND MONTHLY PAYMENT CHANGES (A) Change Date The interest rate may change on the first day of January 1 , 1998 , and on that day of each succeeding year. "Change Date" means each date on which the interest rate could change. (B) The Index Beginning with the first Change Date, the interest rate will be based on an Index. "Index" means the weekly average yield on United States Treasury Securities adjusted to a constant maturity of one year, as made available by the Federal Reserve Board. "Current Index" means the most recent Index figure available 30 days before the Change Date. If the Index (as FHA Multistate Adjustable Rate Note -10/95 4ft-590 (04011 YMP MORTGAGE FOAMS - (4001521-7281 Psp" 1 of 3 INtIW:4 11170943 v590 10/09//96 ` 12:16:51 03141405 defined above) is no longer available, Lender will use as a new index any index prescribed by the Secretary (as defined in Paragraph 7(B)). Leader will give Borrower notice of the new Index. (C) Calculation of Interest Rate Changes Before each Change Date, Fender will calculate anew interest rate by adding a margin of Two and tine-Half percentage point(s) ( 2.500 %) to the Current Index and roundmg the sum to the nearest one-eighth of one percentage point (0.12596). Subject to the limits stated in Paragraph 5(D) of this Note, this rounded amount will be the new interest rate until the next Change Date. (D) Limits on interest Rate Changes The existing interest rate will never increase or decrease by more than one percentage point (1.0%) on any single Change Date. The interest rate will never be more than five percentage points (5.096) higher or lower than the initial interest rate stated in Paragraph 2 of this Note. (E) Calculation of Payment Change If the interest rate changes on a Change Date, Fender will calculate the amount of montbly payment of principal and interest which would be necessary to repay the unpaid principal balance in full at the Maturity Date at the new interest rate through substantially equal payments. In making such calculation, Lender will use the unpaid principal balance which would be owed on the Change Date if there had been no default in payment on the Note, reduced by the amount of any prepayments to principal. The result of this calculation will be the amount of the new monthly payment of principal and interest. (F) Notice of Changes Lender will give notice to Borrower of any change in the interest rate and monthly payment amount. The notice must be given at least 25 days before the new monthly payment amount is due, and must set forth (i) the date of the notice, (ii) the Change Date, (iii) the old interest rate, (iv) the new interest rate, (v) the new monthly payment amount, (vi) the Current Index and the date it was published, (vii) the method of calculating the change in monthly payment amount, and (viii) any other information which may be required by law from time to time. (G) Effective Date of Changes A new interest rate calculated in accordance with Paragraphs 5(C) and 5(D) of this Note will become effective on the Change Date. Borrower shall make a payment in the new monthly amount beginning on the first payment date which occurs at least 25 days after Lender has given Borrower the notice of changes required by Paragraph 5(F) of this Note. Borrower shall have no obligation to pay any increase in the monthly payment amount calculated in accordance with Paragraph 5(E) of this Note for any payment date occurring less than 25 days after Leader has given the required notice. If the monthly payment amount calculated in accordance with Paragraph S(E) of this Note decreased, but Lender failed to give timely notice of the decrease and Borrower made any monthly payment amounts exceeding the payment amount which should have been stated in a timely notice, then Borrower has the option to either (i) demand the return to Borrower of any excess payment, with interest thereon at the Note rate (a rate equal to the interest rate which should have been stated in a timely notice), or (ii) request that any excess payment, with interest thereon at the Note rate, be applied as payment of principal. Leader's obligation to return any excess payment with interest on demand is not assignable even if this Note is otherwise assigned before the demand for return is made. 6. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Fender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 7. BORROWER'S FAILURE TO PAY (A) bate Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, bender may eolloct a late charge in the amount of Four and No-Thousandths percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent`` (W-590 198011 Paps 2 o13 wl-w/C VS90 10/09/96 12:16:51 03141405 default. This Note does not Mize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary„ means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costa and Exposes If Leader has required im>pediate payment in full, a5 described above, Leader may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. s. WAIVERS Borrower and my other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not boxy paid. 9. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to leader at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 10. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to ]Deep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a gaarmtor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Leader may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this NOW BY SIGNING BELOW, Borrower accMts and agrees to the terms and covenants contained in this Note. /J .oln44 (Seat) (Sea,) Je Dohrman -Borrower Ran E. Dohrman (Ses1) (S1) •Bat?ower -Bortowa - - - - (SEA) -Borrower -(Seal) -Hemmer (Sed) (Sell) A-690 meet) rw.i d a V590 10109/96 12:16:52 03141405 NA`tt0?0lt _._...? ??t . ? C i ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a survey by Larry V. Neidlinger, Professional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the center line of L.R. 21003 and at the corner of lands now or formerly of Francis Speck; thence by the center line of said road South 80 degrees 20 minutes 27 seconds East 222.11 feet to-a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the corner of lands now or formerly of Clarence R. Fahnestock; thence along the lands of Fahnestock South 48 degrees 16 minutes 35 seconds west 390.15 feet to a nail in a white oak tree; thence along land now or formerly of Francis Speck North 9 degrees 20 minutes 37 seconds West 328.00 feet to the place of BEGINNING. 6-K - " l 1, - h ( k "S ( ( Midland Mortgage Co. P.O. Box 26648 A Vz O klahom a C ity, O klahom a Phone (800) 552-3000 Fax (405) 426-1739 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO. 6 OF 1974 DATE: 10/25/06 TO: JEFFREY P DOHR.MAN 298 MOUNT ROCK RD NEWVILLE, PA 17241-9575 RE: MMC# 50370487 FHA/VA/PMI# 4415281918703 Dear Mortgagor(s): Midland Mortgage Company is the holder of a Mortgage and a Note on the above premises, or is the mortgage-servicing agent for such holder. As of the date of this notice, THE MORTGAGE IS IN DEFAULT STATUS because of non-payment of the following: Payments, late charges, and advances from 12/01/05 through 10/25/06. The total amount now required to cure the default, or in other words to get caught up on your payments, is $9,946.82. All payments referred to in this notice must be in the form of Cashier's or Certified Check made payable to Midland Mortgage Company and must be received at: Midland Mortgage Company P O Box 268888 Oklahoma City, OK 73126-8888 not later than the dates and times specified herein. In the event payment (as specified in the proceeding paragraph) is not made WITHIN THIRTY (30) DAYS from the date of this letter, it is the intention of the holder of the mortgage, through this company, to accelerate (declare due and payable immediately the entire loan) the mortgage obligation and all other lawful charges and instruct our attorney to institute MORTGAGE FORECLOSURE PROCEEDING. (A) If you wish to CURE THE DEFAULT within thirty (30) days from the date of this letter, you must pay the TOTAL AMOUNT DUE stated above, plus an additional monthly installment if payment is made after the 151 day of the next month, plus an additional late charge if due at time of payment and not included above. A LATE CHARGE is due with each mortgage payment that is paid more than fifteen (15) days after the due date. Your current monthly installment is $755.97. (B) If payment is made AFTER THIRTY (30) DAYS from the date of this letter, but BEFORE FORECLOSURE PROCEEDING has been started, the amount you will have to pay will also ??r include the regular monthly installments and late charges then due, plus, if incurred, any ATTORNEY'S FEE OF NOT MORE THAN $50.00 and any title report costs, which amount can be obtained by contacting Midland Mortgage Company at 1-800-552-3000, extension 1799. AFTER FORECLOSURE PROCEEDING HAS BEEN STARTED, you have the right to STOP the foreclosure action any time up to ONE (1) HOUR BEFORE the commencement of the SHERIFF'S SALE by paying the entire amount due at the time, which shall include all delinquent installments and unpaid late charges, together with REASONABLE LEGAL FEES ACTUALLY INCURRED, cost and other sums related to the foreclosure action, which amount can be obtained by contacting Midland Mortgage Company at 1-800-552-3000. Should you FAIL to reinstate the loan as outlined above, the mortgage premises will be SOLD AT SHERIFF'S SALE, which will take place approximately seven (7) to eleven (11) weeks following SERVICE of the Complaint in Mortgage Foreclosure, at which time your OWNERSHIP interest in mortgaged premises will be TERMINATED, and thereafter, if occupied, proceedings will be taken to OBTAIN POSSESSION of the real estate. You have the right to REFINANCE THE LOAN with another lending institution or TRANSFER THE PROPERTY to another person, under and subject to the existing mortgage. That person will have the SAME RIGHT TO CURE THE DEFAULT as you have, subject to the same limitation and requirements. You may CURE DEFAULTS up to three (3) times in any calendar year. Upon cure of a default you will be in the same position as if there had been NO DEFAULT. A default may be cured by ANYONE on your behalf. Sincerely, Midland Mortgage Company Collection Department 7004 1350 0003 5147 6183 -4 ma m o ?o p1 ? s m 9 0 0 Z mom 10- %ON RL I Midland Mortgage Co. P.O. Box 26648 A Vz O klahom a City, O klahom a Phone (800) 552.3000 Fax (405) 426.1739 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO. 6 OF 1974 DATE: 10/25/06 TO: KARA E DOHRMAN 298 MOUNT ROCK RD NEWVILLE, PA 17241-9575 RE: MMC# 50370487 FHA/VA/PMI# 4415281918703 Dear Mortgagor(s): Midland Mortgage Company is the holder of a Mortgage and a Note on the above premises, or is the mortgage-servicing agent for such holder. As of the date of this notice, THE MORTGAGE IS IN DEFAULT STATUS because of non-payment of the following: Payments, late charges, and advances from 12/01/05 through 10/25/06. The total amount now required to cure the default, or in other words to get caught up on your payments, is $9,946.82. All payments referred to in this notice must be in the form of Cashier's or Certified Check made payable to Midland Mortgage Company and must be received at: Midland Mortgage Company P O Box 268888 Oklahoma City, OK 73126-8888 not later than the dates and times specified herein. In the event payment (as specified in the proceeding paragraph) is not made WITHIN THIRTY (30) DAYS from the date of this letter, it is the intention of the holder of the mortgage, through this company, to accelerate (declare due and payable immediately the entire loan) the mortgage obligation and all other lawful charges and instruct our attorney to institute MORTGAGE FORECLOSURE PROCEEDING. (A) If you wish to CURE THE DEFAULT within thirty (30) days from the date of this letter, you must pay the TOTAL AMOUNT DUE stated above, plus an additional monthly installment if payment is made after the 1" day of the next month, plus an additional late charge if due at time of payment and not included above. A LATE CHARGE is due with each mortgage payment that is paid more than fifteen (15) days after the due date. Your current monthly installment is $755.97. (B) If payment is made AFTER THIRTY (30) DAYS from the date of this letter, but BEFORE FORECLOSURE PROCEEDING has been started, the amount you will have to pay will also include the regular monthly installments and late charges then due, plus, if incurred, any ATTORNEY'S FEE OF NOT MORE THAN $50.00 and any title report costs, which amount can be obtained by contacting Midland Mortgage Company at 1-800-552-3000, extension 1799. AFTER FORECLOSURE PROCEEDING HAS BEEN STARTED, you have the right to STOP the foreclosure action any time up to ONE (1) HOUR BEFORE the commencement of the SHERIFF'S SALE by paying the entire amount due at the time, which shall include all delinquent installments and unpaid late charges, together with REASONABLE LEGAL FEES ACTUALLY INCURRED, cost and other sums related to the foreclosure action, which amount can be obtained by contacting Midland Mortgage Company at 1-800-552-3000. Should you FAIL to reinstate the loan as outlined above, the mortgage premises will be SOLD AT SHERIFF'S SALE, which will take place approximately seven (7) to eleven (11) weeks following SERVICE of the Complaint in Mortgage Foreclosure, at which time your OWNERSHIP interest in mortgaged premises will be TERMINATED, and thereafter, if occupied, proceedings will be taken to OBTAIN POSSESSION of the real estate. You have the right to REFINANCE THE LOAN with another lending institution or TRANSFER THE PROPERTY to another person, under and subject to the existing mortgage. That person will have the SAME RIGHT TO CURE THE DEFAULT as you have, subject to the same limitation and requirements. You may CURE DEFAULTS up to three (3) times in any calendar year. Upon cure of a default you will be in the same position as if there had been NO DEFAULT. A default may be cured by ANYONE on your behalf. Sincerely, Midland Mortgage Company Collection Department 7004 1350 0003 5147 6176 ,.i my 0 m? $ m 0 Nam m 'm ro COMPANY NAME: MIDFIRST BANK VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated 1a? lt?0 Title `/ (4e - F/ 14P S C1?P /? f ?? ' c. ? J[? J K ' ?.w i r;? r?z ?} ? + ? ?' ??;3 ? t ?? L ? ` ? ?^?} h 1 ? V' - _ ? `a? ??.t ? r a 1 ?K MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) CIVIL ACTION LAW NO. 2006-07139 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) KARA E. DOHRMAN and JEFFREY P. DOHRMAN for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid Principal Balance Interest Per diem of $10.97 From 11/01/2005 To 01/01/2007 Accumulated Late Charges Late Charges ($30.23 per month to 01/01/2007) Escrow Deficit 5% Attorney's Commission TOTAL $78,158.63 $4,673.22 $527.92 $392.99 $2,200.79 $3,907.93 $89,861.48 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & Leon er PA I.D. # 15700 171 orth Front Street Harrisburg, PA 17102 (717) 234-4178 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN AND JEFFREY P. DOHRMAN Defendants DATE OF THIS NOTICE: February 13, 2007 TO: KARA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 NO. 2006-07139 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & LEON P. R, Attorney for Plaintiff I.D. 0 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 4 ;n -. tv i C) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2006-07139 MIDFIRST BANK, VS. PLAINTIFF KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) Total Judgment Amount $89,861.48 Interest $1,755.20 Per diem of $10.97 to sale date 6/13/2007 Late Charges $151.15 $30.23 per month to sale date 6/13/2007 Escrow Deficit $2,000.00 TOTAL WRIT $93,767.83 *Plus additional interest, late charges and other costs to date of sheriff's sale. SALE DATE: Wednesday, June 13, 2007 (PROTHONOTARY'S USE) Pltf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned Date: February 20, 2007 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 E n P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a survey by Larry V. Neidlinger, Professional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the center line of L. R. 21003 and at the corner of lands now or formerly of Francis Speck; thence by the center line of said road South 80 degrees 20 minutes 27 seconds East 222.11 feet to a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the corner of lands now or formerly of Clarence R. Fahnestock; thence along the lands of Fahnestock South 48 degrees 16 minutes 35 seconds West 390.15 feet to a nail in a white oak tree; thence along land now or formerly of Francis Speck North 9 degrees 20 minutes 37 seconds West 328.00 feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 BEING THE SAME PREMISES WHICH Mark M. Curtis and Jacquelyn S. Curtis, husband and wife by deed dated 10/11/96 and recorded 10/16/96 in Cumberland County 147, Page 630, granted and conveyed unto Kara E. Dohrman and Jeffrey P. Dohrman. TO BE SOLD AS THE PROPERTY OF KARA E. DOHRMAN AND JEFFREY P. DOHRMAN ON JUDGMENT NO. 2006-07139 ASSESSMENT NO. 46-09-0519-018 t^ ? 'T3 C`? } s't {? C r C C C C ?, 4 ?° J 4,7 0 00 d 1 1 1 ^ ? ? iPn MIDFIRST BANK, I IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me hi day of 20 f 7 : OF PENNSYLVANIA LALLER, ESQUIRE I -NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Aug. 8, 2010 rtr ? ? -v N P: Iq MIDFIRST BANK, VS. PLAINTIFF KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 298 MOUNT ROCK ROAD NEWVILLE, PA 17241: 1. Name and address of the Owner(s) or Reputed Owner(s): KARA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN f 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 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 subiect to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authoritie PA I.D. #15700 ell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 20, 2007 t? ? O -?ri :?,: ?t ? "? ^'' r.,y ? r? s ;-` '... -7 ?? t: , `-=_ ?=? ? ? y ?? ? ?-? L .??' ?? Ive r MIDFIRST BANK, VS. PLAINTIFF KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 13, 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2006-07139 JUDGMENT AMOUNT $89,861.48 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: KARA E. DOHRMAN and JEFFREY P. DOHRMAN r n A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. I* YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a survey by Larry V. Neidlinger, Professional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the center line of L. R. 21003 and at the corner of lands now or formerly of Francis Speck; thence by the center line of said road South 80 degrees 20 minutes 27 seconds East 222.11 feet to a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the corner of lands now or formerly of Clarence R. Fahnestock; thence along the lands of Fahnestock South 48 degrees 16 minutes 35 seconds West 390.15 feet to a nail in a white oak tree; thence along land now or formerly of Francis Speck North 9 degrees 20 minutes 37 seconds West 328.00 feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 BEING THE SAME PREMISES WHICH Mark M. Curtis and Jacquelyn S. Curtis, husband and wife by deed dated 10/11/96 and recorded 10/16/96 in Cumberland County 147, Page 630, granted and conveyed unto Kara E. Dohrman and Jeffrey P. Dohrman. TO BE SOLD AS THE PROPERTY OF KARA E. DOHRMAN AND JEFFREY P. DOHRMAN ON JUDGMENT NO. 2006-07139 ASSESSMENT NO. 46-09-0519-018 ;q m -rt SHERIFF: I am submitting documentation necessary to schedule a Sheriffs sale of real estate. If you require anything further or have any questions as to content or format, please contact the undersigned. Thank you. Maryland Ferretti Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 PHONE: (717) 234-4178 Inquiries relating to service should be directed to Mindy Horley. Inquiries relating to the actual sale should be directed to Sharon Dunn. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7139 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s) From KARA E. DOHRMAN AND JEFFREY P. DOHRMAN (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 $89,861.48 L.L. $.50 Interest PER DIEM OF $10.97 TO SALE DATE 6/13/07 - $1,755.20 Atty's Comm % Due Prothy $1.00 Atty Paid $157.56 Other Costs LATE CHARGES - $30.23 PER MONTH TO SALE DATE 6/13/07 - $151.15 -- ESCROW DEFICIT - $2,000.00 Plaintiff Paid Date: FEBRUARY 21, 2007 (Seal) Curt' R. Long, P thonot ry 46 By: Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-07139 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MIDFIRST BANK VS DOHRMAN KARA 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 TENANT/OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT , TENANT/OCCUPANT 298 MOUNT ROCK ROAD NOT FOUND , as to NEWVILLE, PA 17241 THERE ARE NO TENANTS AT GIVEN ADDRESS. Sheriff's Costs: So answer Docketing 6.00 Service 10.56 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 31.56 PURCELL KRUG HALLER ,Jay?G? 12/26/2006 Sworn and Subscribed to before me this day of A. D. .r.i. ?t? SHERIFF'S RETURN - REGULAR , CASE NO: 2006-07139 P «.« COMMONWEALTH OF PENNSYLVANIA: -° COUNTY OF CUMBERLAND MIDFIRST BANK VS DOHRMAN KARA E ET AL SGT BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DOHRMAN KARA E the DEFENDANT , at 1433:00 HOURS, on the 21st day of December-, 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to KARA DOHRMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service .00 Affidavit .00 Surcharge 10.00 1/2q(o? .00 28.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 12/26/2006 PURCELL KRUG HALLER By: De ty Sh"eri f f A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-07139 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS DOHRMAN KARA E ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DOHRMAN JEFFREY P the DEFENDANT at 1455:00 HOURS, on the 20th day of December 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to JEFFREY DOHRMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing Service Affidavit Surcharge 12 4/0 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/26/2006 PURCELL By of A. D. .r ..i» .irlM MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on _31 (a I a0 M , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: KA.RA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANVOCCUPANT 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 By ;,TUG & HALLER for Plaintiff IgI9 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN KARA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANT/OCCUPANT 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 HERSHEY (717)533-3836 JOSEPH NISSLEY (1910-1982) JOHN W.PURCELL VALERIE A. GUNNOF COUNSEL NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate ll be divested by the sale and that you have an opportunity to protect your interest, if any, by bei ied of said Sheriffs Sale. By: Le Haller PA I.D.15700 Atfornev for Plaintiff MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) TAKE NOTICE: CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 13, 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2006-07139 JUDGMENT AMOUNT $89,861.48 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: KARA E. DOHRMAN and JEFFREY P. DOHRMAN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a survey by Larry V. Neidlinger, Professional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the center line of L. R. 21003 and at the corner of lands now or formerly of Francis Speck; thence by the center line of said road South 80 degrees 20 minutes 27 seconds East 222.11 feet to a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the corner of lands now or formerly of Clarence R. Fahnestock; thence along the lands of Fahnestock South 48 degrees 16 minutes 35 seconds West 390.15 feet to a nail in a white oak tree; thence along land now or formerly of Francis Speck North 9 degrees 20 minutes 37 seconds West 328.00 feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 BEING THE SAME PREMISES WHICH Mark M. Curtis and Jacquelyn S. Curtis, husband and wife by deed dated 10/11/96 and recorded 10/16/96 in Cumberland County 147, Page 630, granted and conveyed unto Kara E. Dohrman and Jeffrey P. Dohrman. TO BE SOLD AS THE PROPERTY OF KARA E. DOHRMAN AND JEFFREY P. DOHRMAN ON JUDGMENT NO. 2006-07139 ASSESSMENT NO. 46-09-0519-018 7160 3901 O MI 0762 W% TO: JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 SENDER: NOS 06/13/07 REFERENCE: MIDLAND/ DOHRMAN ?1W 3901 %49 0%2 BM TO: KARA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 SENDER: NOS 06/13/07 REFERENCE: MIDLAND/ DOHRMAN RETURN Postage RETURN Postage RECEIPT SERVICE Certified Fee RECEIPT ? 40 Certified Fee 240 Return Receipt Fee SERVICE I Rs Return Receipt Fee Restricted Delivery 370 Restricted Delivery Total Postage & Fees Total Postage & Fees US Postal Service POSTMARK OR DATE US Postal Service POSTMARK OWDATE Receipt for ° Receipt for Certified Mail Certified Mail No Insurance Coverage Provided No Insurance Coverage Provided Do Not Use for International Mail Do Not Use for Internat oral Mail MIDLAND MORTGAGE COMPANY v. KARA E. DOHRMAN JEFFREY P. DOHRMAN Cumberland County Sale 6/13/2007 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: KARA E. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 02 1A $. • 0004353811 N} OO 950 2007 MAILED FROM ZIPCODE 1 1 1 02 ?? ^-> ??? ? -r? ` +w . ; ,-. ? ' ? ? c ? . f-' _, . ? .., Midfirst Bank In The Court of Common Pleas of VS Cumberland County, Pennsylvania Kara E. Dohrman and Jeffrey P. Dohrman Writ No. 2006-7139 Civil Term William Cline, Deputy Sheriff, vwwl o being duly sworn according to law, states that on March 22, 2007 at 1035 hours, he served a true capy of the within Real Estate Writ, Notice and Description, in the above entitled action, within n=W ndant to wit: Kara E. Dohrman, by making known unto Kara E.1" sli. pwomAy, at 798 Mount Rock Road, Carlisle, Cumberland County, Pennsylvania its psalm& to 1e same time handing to her personally the said true and correct copy of the same. Sgt. Jody Smith, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2007 at 0840 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Jeffrey Dohrman, by making known unto Jeffrey Dohrman, personally, at The Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on April 12, 2007 at 1450 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kara E. Dohrman and Jeffrey P. Dohrman, at 298 Mount Rock Road, Newville, 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: Kara E. Dohrman and Jeffrey P. Dohrman by regular mail to their last known addresses of 798 Mount Road Road, Carlisle, PA 17013 and 298 Mount Rock Road, Newville, PA 17241, respectively. These letters were 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 Leon Haller. Sheriffs Costs: Docketing 30.00 Poundage 440.00 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 32.64 Levy 15.00 Surcharge 30.00 Patriot News 329.42 Law Journal 355.00 Share of Bills 16.17 Postpone Sale 40.00 $1,319.73 R. Thomas Kline, Sheriff 'YVL BY 'j; Real Estate Se eant ,/ 4, p/.23/0?. ,-? 7,2 s MIDFIRST BANK, VS. PLAINTIFF KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNS A CIVIL ACTION LAW !/ I f NO. 2006-07139 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 298 MOUNT ROCK ROAD NEWVILLE, PA 17241: Name and address of the Owner(s) or Reputed Owner(s): KARA E. DOHRIVIAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 JEFFREY P. DOHRMAN 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN r 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: DOMESTIC RELATIONS Cumberland County Courthouse 13 North Hanover Street Carlisle, PA 17013 TENANVOCCUPANT 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) 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 7:?'..- penalties of 18 PA C.S. Section 4904 relating to unworn falsification to authoritie PA ect to the I.D. 415700 PH-de'll, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 20, 2007 MIDFIRST BANK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. KARA E. DOHRMAN JEFFREY P. DOHRMAN, DEFENDANT(S) TAKE NOTICE: CIVIL ACTION LAW NO. 2006-07139 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, June 13, 2007 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 2006-07139 JUDGMENT AMOUNT $89,861.48 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: KARA E. DOHRMAN and JEFFREY P. DOHRMAN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BEHELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a survey by Larry V. Neidlinger, Professional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the center line of L. R. 21003 and at the comer of lands now or formerly of Francis Speck; thence by the center line of said road South 80 degrees 20 minutes 27 seconds East 222.11 feet to a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the comer of lands now or formerly of Clarence R. Fahnestock; thence along the lands of Fahnestock South 48 degrees 16 minutes 35 seconds West 390.15 feet to a nail in a white oak tree; thence along land now or formerly of Francis Speck North 9 degrees 20 minutes 37 seconds West 328.00 feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 298 MOUNT ROCK ROAD NEWVILLE, PA 17241 BEING THE SAME PREMISES WHICH Mark M. Curtis and Jacquelyn S. Curtis, husband and wife by deed dated 10/11/96 and recorded 10/16/96 in Cumberland County 147, Page 630, granted and conveyed unto Kara E. Dohrman and Jeffrey P. Dohrman. TO BE SOLD AS THE PROPERTY OF KAR.A E. DOBRMAN AND JEFFREY P. DOBRMAN ON JUDGMENT NO. 2006-07139 ASSESSMENT NO. 46-09-0519-018 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7139 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDFIRST BANK, Plaintiff (s) From KARA E. DOHRMAN AND JEFFREY P. DOHRMAN (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 $89,861.48 L.L. $.50 Interest PER DIEM OF $10.97 TO SALE DATE 6/13/07 - $1,755.20 Atty's Comm % Due Prothy $1.00 Atty Paid $157.56 Other Costs LATE CHARGES - $30.23 PER MONTH TO SALE DATE 6/13/07 - $151.15 -- ESCROW DEFICIT - $2,000.00 Plaintiff Paid Date: FEBRUARY 21, 2007 (Seal) Cu s R. Long, Prot ry By: Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone : 717-234-4178 Supreme Court ID No. 15700 Real Estate Sale # 74 On March 14, 2007 the Sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA Known and numbered as 298 Mount Rock Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2007 By: CL4 Real Estate ergeant Z? :? C; a- UV!?j LODl _-i?_ GO 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 2U, 2"1, 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. REAL ESTATE SALE NO. 74 Writ No. 2006-7139 Civil (,/G7 Midfirst Bank VS. Kara E. Dohrman and Jeffrey P. Dohrman Atty.: Leon Haller ALL THAT CERTAIN tract of land situate in West Pennsboro Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described pursuant to a sur- vey by Larry V. Neidlinger, Profes- sional Engineer, dated January 27, 1975, as follows: BEGINNING at a nail in the cen- ter line of L. R. 21003 and at the corner of lands now or formerly of Francis Speck; thence by the cen- ter line of said road South 80 de- grees 20 minutes 27 seconds East 222.11 feet to a nail in the center line of said road; thence continuing in said road South 77 degrees 58 minutes 47 seconds East 128.30 feet to a nail in the center line of said public road and at the corner of lands now or formerly of Clarence sa Marie Cowil Editor S TO AND SUBSCRIBED before me this 4 day of May, 2007 NOTARIAL SEAL V LO!S E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2009 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#74 .... ..... ... ............. ......? .............. .......... Sworn to and subscribed before me this 18th day of May 2007 A.D. COMMONWEALTH OF PENNSYLV NIA Notarial Seal Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County Cor ion Expires June 6, 2010 M Aber, Pgfir. flvpnia Association of Notaries Y PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Ihaller .Dkh.com MIDFIRST BANK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006 -07139 Civil IN MORTGAGE FORECLOSURE VS. KARA E. DOHRMAN AND JEFFREY P. DOHRMAN, Defendants PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered in the above captioned matter satisfied of record. PURCELL, KRUG & HALLER By Leon P.i riD #15700 Attorney for Plaintiff Date: September 19, 2007 r-a co 0 ri Arn