Loading...
HomeMy WebLinkAbout02-3271McCABE, WEISBERG AND CONWAY, P.C. BY= TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A., as Trustee 10790 Rancho Bernardo Road San Diego, CA 92127 Christopher R. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 and Aimee J. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 Attorney for Plaintiff Cumberland County Court of Common Pleas CIVIL ACTION/MORTGAGE FORECLOSU~_~ NOTICE AVISO You have been sued in court. [f 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 meney claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. cumber[and County gar Association 2 Liberty Avenue Car[is[e, PA 17013 (717) 249-3166 Le hah demandado a usted en la corte. Si usted qufere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomare medidas y puede continuar la demanda en contra suya sin previo avfso o notificacion. Ademas, la corte puede decidir a favor de[ demandante y requiere que usted cump[a con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DLRECCION SE ENCUENTR.A ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue CarLisLe, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A., as Trustee : 10790 Rancho Bernardo Road : San Diego, CA 92127 : Christopher R. Leader : 899 Old Silver Springs Road : Mechanicsburg, PA 17055 : and : Aimee J. Leader : 899 Old Silver Springs Road : Mechanicsburg, PA 17055 : Attorney for Plaintiff Cumberland County Court of Common Pleas CIVIL ACTION/MORTGAGE FORECLOSU~ 1. Plaintiff is Citibank, N.A., as Trustee, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Christopher R. Leader, who is one of the owners of the mortgaged property hereinafter last-known address is 899 Old Silver Springs mortgagors and real described, and his Road, Mechanicsburg, PA 17055. 3. The Defendant is Aimee J. Leader, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 899 Old Silver Springs Road, Mechanicsburg, PA 17055. 4. On 9/10/99, mortgagors made, executed and delivered a mortgage upon the premises hereinafter described to Fieldstone Mortgage Company which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1570, Page 652. 5. On 11/13/00, the aforesaid mortgage was thereafter assigned by Fieldstone Mortgage Company to Citibank, N.A., as Trustee, Plaintiff herein, by Assignment of Mortgage recorded in the Office of the Mortgage Book 659, 6. mortgage attached as Exhibit "A" and Springs Road, Mechanicsburg, PA 17055. Recorder of Cumberland County in Assignment of page 1022. The premises subject to said mortgage is described in the is known as 899 01d Silver principal 7. The mortgage is in default because monthly payments of and interest upon said mortgage due 11/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance Interest 10/1/01 through 7/3/02 (Plus $11.51 per diem thereafter) Attorney's Fee $ 2,169.98 Late Charges $ 194.80 Miscellaneous $ 185.00 Cost of Suit $ 225.00 Appraisal Fee $ 125.00 Title Search $ 200.00 $43,399.67 $ 3,165.25 GRAND TOTAL $49,664.70 9. 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 1974 (41 P.S. §403) fees will be charged based on work actually performed. 10. Notice of Intention to Foreclose as required by Act 6 of and notice required by the Emergency Mortgage mortgage property. Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular and certified mail. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $49,664.70, together with interest at the rate of $11.51 per diem and other costs and charges collectible under the and for the foreclosure and sale of the mortgaged TERRENCE J. McC~ Attorney for P1. ESQUIRE ntiff VERIFICATION The undersigned, Jennifer Mendoza, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within act ion, ~~ ~]~. ~~~ and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. ~4904 relating to unsworn falsification to authorities. Chase Manhattan Mtg 216102 5:11 081-015-'002: 081-015-002-000F PAGE 8/17 I hereby certify that t~m Is a true and con'ec~ ~opy. plslmm~vm~,. 8tn~ P,md~ · PNWM:HLIIO Chase Manhattan Mtg 2/6/02 5:11 PAGE 9/17 081-01'5-002:081-01 §-002-001F C~nee~ga ~ I~t~,zncl 8¢HEDULI~ 0 PEOfq~l"t IDF.~CRIFTIO# PE~VNaA, MOIRE PN~IGtJ/.M~,Y DESG~gED M FoU.Oti~: Chase Manhattan Mtg 2/6/02 5:11 PAGE 10/17 081-01'5-002:081-01 §-002-002F Chase Manhattan Mtg 2/6/02 5:11 PAGE 11/17 081 ~)1 §-002:081-01 Chase Manhattan Mtg 2/6/02 5:11 PAGE 12/17 081-01.5-002; 081-015-002-004{: Ch&so Hanh&ttan Mtg 216102 §:11 PAGE 13117 081 ~01B-002:081-01 §-002-005F ~_,_,~..~ ................. ~m~m~~. ~ - -- -- q~'~IIpA}ImMI 'qtidl ~ Chase ~anhattan Mtg 2/6/02 5:11 PAGE 14/17 0~1-015-002~ 0~1-015-002-006F Chase Manhattan Mtg 2/6/02 5:11 PAGE 15/17 081-01 ~-002:081-01 §-002-007F CONDOMINIUM RIDER U U/'~OTAT]~ ~INDOUH4JUU RIDEH,4blgM ~ml~f-F~m~ M m,T*reddle M~ U~FQ~W INSTIt~UENT Ch~se Nanh&tt&n Ntg 2/6/02 5:11 PAGE 16/17 081-01 ~-002: 081-0'i 5-002-008F _ Imdld I0 TJ'b'. Sm:h I%'Omds draft be Chase Manhattan Mtg 2/6/02 5:11 PAGE 17/17 o81-.Ol 6-002:o81-Ol SHERIFF'S RETURN - CASE NO: 2002-03271 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK NA VS LEADER CHRISTOPHER R ET AL REGULAR RONALD HOOVER , Sheriff or Deputy Sheriff of Cu~oerland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LEADER CHRISTOPHER R the DEFENDANT at 1440:00 HOURS, at 899 OLD SILVER SPRINGS ROAD MECHANICSBURG, PA 17055 CHRISTOPHER LEADER on the llth day of July , 2002 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 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this ~ day of D.~sJ~ ~3AD J~ A. D. t ~rothonotary ' So Answers: R. Thomas Kline 07/12/2002 MCCABE WEISBERG CONWAY Deputy Sheriff SHERIFF'S RETURN CASE NO: 2002-03271 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK NA VS LEADER CHRISTOPHER R ET AL - REGULAR RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LEADER AIMEE J the DEFENDANT , at 1440:00 HOURS, at 899 OLD SILVER SPRINGS ROAD MECHANICSBURG, PA 17055 CHRISTOPHER LEADER, HUSBAND on the llth day of July , 2002 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 02~ day of ~,~- ~L~ A.D. ! ~r6th~notaf~- '~ So Answers: R. Thomas Kline 07/12/2002 MCCABE WEISBERG CONWAY Deputy Sheriff Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 To: Christopher R. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Cumberland County Court of Common Pleas Number 02-3271 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT hasbee~ntered in the above proceeding as indicated below. ~.~ ~x,. ~'~ Curt Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Esquire at (215)790-1010. Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 To~ Aimee J. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Cumberland County Court of Common Pleas Number 02-3271 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has be~t~entered in the Curt Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Esquire at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MeCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Cumberland County Court of Common Pleas Number 02-3271 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 49,664.70 Interest from 07/04/2002 - 08/21/2002 $ 552.48 TOTAL AND NOW, this °~3tWd~'aay °f ~ $ 50,217.18 ~E~NCE J. IV~cCABE, ESQUIRE ,2002, Judgment is entered in favor of Plaintiff, Citibank, N.A., as Trustee, and against Defendants, Christopher R. Leader, and Aimee J. Leader, and damages are assessed in the amount of $50,217.18, plus interest and costs. BY THE PROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-3271 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA : The undersigned, being duly sworn according to law, deposes and says that the Defendants 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; and that the Defendant, Christopher R. Leader, is over eighteen (18) years of age and resides at 899 Old Silver Springs Road, Mechanicsburg, PA 17055; and that the Defendant, Aimee J. Leader, is over eighteen (18) years of age and resides at 899 Old Silver Springs Road, Mechanicsburg, PA 17055. SWORN TO AND SUBSCRIBED BEFORE ME THIS~17} DAY OF _ . _ , 2002. Notary Public ' TERRENCE J. IV~CABE, ESQUIRE Attorney for Plaintiff MeCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Christopher R. Leader and Aimee J. Leader Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-3271 Civil Term CERTIFICATION Terrence J. McCabe, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS~/~AY NOTARY PUBLIC ,2002. TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are tree and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unswom falsification to authorities. TERRENCE J. McC~ABE, ESQUIRE Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 August 5, 2002 To~ Christopher R. Leader $99 Old Silver Springs Road Mechanicsburg, PA 17055 Citibank, N.A., as Trustee VS. Christopher R. Leader and Aimee J. Leader Cumberland County Court of Common Pleas Number 02-3271 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE 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 (l 0) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personaimente o pot abogado y por no haber radlcado por escrito con este Tribunal sus defensas u objeciones a los reclamos formulados en contra suyo. Al no tomar la accion debida dentro de diez (10) dias de la fecha de esta notification, el Tribunal podra, sin necesidad de comparecer usted en torte u oir preuba alguna, dictar sentencia en an contra y usted podria perder bienes u otxos derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no fiene dinero suficiente para tal servicio, vaya en persona o llame pot telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/cc OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary August 5, 2002 To~ Aimee J. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 Citibank, N.A., as Trustee VS. Christopher R. Leader and Aimee J. Leader Cumberland County Court of Common Pleas Number 02-3271 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE You are in default because you have failed to enter a written appearance personally or by atlomey and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado pot escrito con este Tribunal sus defensas u objealones a los reclamos formulados en contra suyo. Al no tomar la accion debida dentro de diez (10) dias de la fecha de esta notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta nofificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o game por telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 TJM/cc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Citibank, N.A., as Trustee V. Christopher R. Leader and Aimee J. Leader 899 Old Silver Springs Road, Mechanicsburg, PA 17055 FILE NO.: 02-3271 Civil Term AMOUNT DUE: INTEREST: from 8/22/02-3/5/02 at 8.25% ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR RX~CUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 899 Old Silver Springs Road, Mechanicsburg, PA 17055 (More fully described as attached) PRAECIPE FOR ATTACHMENT ~Y~CUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. November 26, 2002 DATE: Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 LEGAL DESCRIPTION Parcel ID #18-22-0519-001 Being Known As: 899 Old Silver Springs Road, Mechanicsburg, PA 17055. ~cCABE, WEISBERG A_ND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee Christopher R. Leader and Aimee d. Leader Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02-3271 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 899 Old Silver Springs Road, Mechanicsburg, PA 17055, a copy of the description of said property is attached hereto and marked Exhibit "A." Name and address of Owner(s) or Reputed Owner(s) Name Addre s s Christopher R. Aimee J. Leader Leader and 899 Old Silver Springs Road, Mechanicsburg, PA 17055 2 o Name and address of Defendant(s) in the judgment: Name Address Christopher R. Aimee J. Leader Leader and 899 Old Silver Springs Road, Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. Walnut Villas Condominium Association 921 Old Silver Spring Road Mechanicsburg, PA 17050 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name every other person of whom the any interest in the property which Address Tenant (s) /Occupant (s) 899 Old Silver Springs Road, Mechanicsburg, PA 17055 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 Commonwealth of Pennsylvania, Department of Welfare, P.O. Box 2675, Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 26, 2002T~E'R~/]} k/( ~ /k~-''~ ~ ~/ ~. ~, DATE ~CE ~. ~cCABE, ESQUIRE Attorney for Plaintiff LEGAL DESCRIPTION Parcel ID #18-22-0519-001 Being Known As: 899 Old Silver Springs Road, Mechanicsburg, PA 17055. McCABE, WEISBERG AND CON-WAY, P.C. 5Y: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Citibank, N.A., as Trustee : Christopher R. Leader and : Aimee J. Leader CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02-3271 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Christopher R. Leader and Aimee J. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 Your house (real estate) at 899 Old Silver Springs Road, Mechanicsburg, PA 17055, (more fully described as attached) is scheduled to be sold at Sheriff's Sale on March 5, 2003, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $50,217.18 obtained by Citibank, N.A., as Trustee, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI.R TO prevent this Sheriff's Sale you must take immediate action: The sale will be canceled if you pay to Citibank, N.A., as Trustee the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 o 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 the following notice on how to obtain an attorney.) YOU HAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHT~ EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. You may also have other rzghts and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COI/NTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUlqTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3271 Civil COUNTY OF CUMBERLAND) CIVIL ACTION LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK, N.A., AS TRUSTEE Plaintiff (s) From CHRISTOPHER R. LEADER AND AIMEE J. LEADER, 899 OLD SILVER SPRINGS ROAD, MECHANICSBURG, 17055 (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 fi'om 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 $50,217.18 Interest FROM 8/22/02 - 3/5/02 AT 8.25% Atty's Comm % Atty Paid $127.90 Plaintiff Paid Date: DECEMBER 4, 2002 (Seal) REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonot,~ Deputy McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Christopher R. Leader and Aimee J. Leader Attorney for Plaintiff CUHBERLAND COUNTY COU'RT OF COMMON PLEAS : : : NUMBER 02-3271 Civil Term AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 16TM DAY OF JANUARY, 2003, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129' which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." TERRENd~ J~'~CABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 16TM DAY OF JANUARY, 2003. NOTARY PUBLIC NOTAFiiA "SEA'L . ~ 'Y ~.~mae~pnia' Phila. County " McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS : : : NUMBER 02-3271 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 899 Old Silver Springs Road, Mechanicsburg, PA 17055, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s : Name Address Christopher R. Leader and Aimee J. Leader 899 Old Silver Sprmngs Road, Mechanicsburg, PA 17055 o Name and address of Defendant(s) in the judgment: Name Address Christopher R. Leader and Aimee J. Leader 899 Old Silver Springs Road, Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. Walnut Villas Condominium Association 921 Old Silver Spring Road Mechanicsburg, PA 17050 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. and~~s~~e~v ~A~'person who has any record 5. Name interest in or reco~~~7~--~-~"~ ~'~r~ ~rop~r~'m and whose interest may be affected by the sale: Name Addre s s 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenant (s) /Occupant (s) 899 Old Silver Springs Road, Mechanicsburg, PA 17055 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 Commonwealth of Pennsylvania, Department of Welfare, P.C. Box 2675, Harrisburg, PA 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. January 16, 2003 . DATE TERRE~Ck J. McCABE, ESQUIRE Attorney for Plaintiff EXHIBIT McCABE, WEISBERG AND CON-WAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A., as Trustee Christopher R. Leader and Aimee J. Leader Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS : : : NUMBER. 02-3271 Civil Term DATE: TO: January 16, 2003 ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) : Christopher R. Leader and Aimee J. Leader PROPERTY: 899 Old Silver Springs Road, Mechanicsburg, PA 17055 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on MARCH 5, 2003, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT "B" 0 0 EXHIBIT "B" McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE V. CHRISTOPHER R. LEADER and AIMEE J. LEADER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMB5iR 02-3271 CIVIL TERM PETITION TO ALLOW SERVICE ON T}{E DEFENDANT BY REGULAR MAIL, CERTIFIED MAIL AND POSTINC PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to serve a true and correct copy of the Notice of Sale upon the Defendant, Aimee J. Leader at the mortgaged premises known as 899 Old Silver Springs Road, Mechanicsburg, PA 17055. The Sheriff adv~[sed that after several attempts he was unable to serve the Defendant with the Notice of Sale. A true and correct copy of the Sheriff,s Return of Service form indicating the same is attached hereto and marked as Exhibit 2. Plaintiff searched for a forwarding address for Defendant, Aimee J. Leader, the Post Master advised that the Defendant, Aimee J. Leader has no change of address from 899 Old Silver Springs Road, Mechanicsburg, PA 1705.5. A copy of the Affidavit of Good Faith Investigation indicating the same, is attached hereto and marked Exhibit "B." 3. Plaintiff has checked the Local Telephone Directory and 411 Assistance for an address for the Defendant, Aimee J. Leader. However, there are no listings in or around the Mechanicsburg area. A copy of the Good Faith Investigation, indicating the same, is attached hereto and marked Exhibit "B.~ 4. Plaintiff attempted to make inquiry with neighbors of the Defendant, Aimee J. Leader. Andrew Doughty of 897 Old Silver Springs Road, Mechanicsburg, PA 17055 with a telephone number of 717-791-6292. However, Plaintiff left messages but received no response. JM Stofanak, of 895 Old Sliver Springs Road, Mechanicsburg, PA 17055 with a telephone number of 717-766-5711. Plaintiff attempted to contact said neighbor. However, there was no answer after several attempts. David Reinert, of 901 Old Silver Springs Road, Mechanicsburg, PA 17055 with a telephone number of 717-691-1832 was contacted. However, Plaintiff left messages but received no response. A copy of the Affidavit of Good Faith Investigation is attached hereto and marked Exhibit 5. Plaintiff has made inquiry with the local tax bureau for an address for the Defendant, Aimee J. Leader. The Tax office has a mailing address of 899 Old Silver Springs Road, Mechanicsburg, PA 17055. A copy of the Affidavit of Good Faith Investigation is attached hereto and marked Exhibit "B." 6. Plaintiff has made inquiry with the Social Security and was advised that there are no death records for the Defendant, Aimee J. Leader, under her social security number. A copy of the Affidavit of Good Faith Investigation indicating the same, is attached hereto and marked Exhibit 7. Plaintiff has investigated the Defendant's Voter Registration Records for and address for the Defendant, Aimee J. Leader. The Defendant is registered at the property of 899 Old Silver Spring Road, Mechaniscburg, PA 17055. A copy of the Affidavit of Good Faith Investigation indicating the same is attached hereto and marked Exhibit "B." 8. If service cannot be made on the Defendant, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Aimee J. Leader, by regular mail, certified mail, return receipt requested and further by posting the same by Sheriff of Cumberland County at the mortgaged premises known as 899 Old Sliver Springs Road, Mechanicsburg, PA 17055. TE~[I~NCE J. McCABE, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE V. CHRISTOPHER R. LEADER and AIMEE J. LEADER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMBER 02-3271 CIVIL TERM MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service ~_n such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. ~ER~:~CE J. McCABE, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE V. CHRISTOPHER R. LEADER and AIMEE J. LEADER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02-3271 CIVIL TERM CERTIFICATION OF SERVICR I, Terrence J. McCabe, Esquire, attorney for the Plaintiff, hereby certify that I served a true and correct copy of the foregoing Motion for Alternative Service Pursuant to Pa.R.C.P. 430, by United States Mail, first class, postage prepaid, on the 10tn day of February, 2003, upon the following: Aimee J. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 TERRENCE J. McCABE, ESQUIRE VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRENCE J. McCABE, ESQUIRE Citibank, N.A., as Trustee VS Christopher R. Leader and Aimee J. Leader In The Cotmt of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3271 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Christopher R. Leader and Aimee J. Leader, but was unable to locate tihem in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale, and Description as NOT FOUND as to the defendants, Christopher R. Leader and Aimee J. Leader. Several attempts of service were made on defendants at 899 Old Silver Springs Road, Mechanicsburg, Cumberland County, Pennsylvania, but contact could not be made with anyone. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 8, 2003 at 5:56 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Christopher R. Leader and Aimee J. Leader located at 899 Old Silver Springs Road, Mechanicsburg, Pennsylvania, according to law. Sworn and subscribed to before me This 2003, A.D. day of Prothonotary So Answej-s: R. Thomas Kline, Sheriff Real Estate Dep--~y Citibank, N.A., as Trustee VS. CHRISTOPHER R. LEADER AIMEE J. LEADER LARRY DEL VECCHIO PROCESS SERVER FOR MCCABE, WEISBERG & CONWAY, P.e. P.o. BOX 3221 WARMINISTER, PA 19874 (215) 442-5668 (215) 442-9727 FAX COUI~ OF COMMON PLEAS CU~E~ COUNTY NO. 02-3271 CIVIL TERM LAST KNOWN ADDRESS: 899 Old Silver Spring Road, Mechanicsbuxg, PA 17055 LOAN NUMBEPc 59-0884PA AFFIDAVIT OF GOOD FAITH EFFORT TO LOCATE DEFENDANT S I hereby certify that on January 28, 2003, a good faith effort was made to discover the correct address of said defendant (s), by.' 1. Inquiry of Postal authority; Postal authority states Aimee has no change of address; Christopher has filed a chan~e of address to 18 Bellrnore Rd., Camp Hill, PA 17011. 2. Examination of loeal telephone directories and 411 assistance; There are no listings for the defendant s in or around thc Mcchanicsburg area. 3. Neighbor Contacts: Andrew Doughty, 897 Old Silver Spring Rd., (717) 791-6292, left n~ssages with no response JM Stofanak, 895 Old Silver Spring Rd., (717) 766-571.1, no answer, several attempts David Reinert, 901 Old Silver Spring Rd., (717) 6 ' 91-1[,32, left messages with no response 4. Tax Information: - Tax office has mailing address same as property, 899 Old Silver Spring Rd. 5. Death Records: Social Security has no death records for the defendants ~mder their names and/or SSN. 6. Voter Registration: The defendants are registered at property, 899 Old Silw.'r Spring Rd. I certify that this information is tree and correct to the best of my knowledge, information and belief. BY: '~'~ NOTARY PUBLIC: Larry Del Vecchio, Process Server ~ef°W°r~e~'de~..~~ day ._..EXHIBi "8" P.O. BOX 3221 WARMINSTER, PA. 18974 Postmaster Mechaniesburg, PA 17055 LARRY DEL VECCHIO PROCESS. SERVER FOR MCCABE, WEISBERG & CON-WAy, P.C. : January 28, 2003 (215) 442-5668 FAX (215) 442-9727 REQUEST FOR CHANGE OF ADDRESS OR BOXItOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (ifa boxholdcr) for the following: Name: Christopher R. Leader Address: 899 Old Silver Spring Rd Mechanicsburg, PA 17055 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). Thtxe is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for MeCabe, Weisberg & P.C. 3. The names of all known parties to this litigation: Conway, Citibank, NA, as Trustee v. Christopher R. Leader & Aimee J. Leader 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas 5. The docket or other identifying number if one has been assigned: 02-3271 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR TO PROSEPCTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP $10,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMRATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITIt ACTUAL OR PROSPECTIVE LITIGATI~ _ LARRY DEL VECCHIO P.O. Box 3221 For MeCabc, W¢isberg & Conway, P.C. Warminster, PA. 18974 FOR THE POST OFFICE USE ONLY - NO CHANGE OF ADDRESS ORDER ON FILE NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS_: POST MARK LARRY DEL VECCHIO PROCESS SERVER FOR MCCABE, WEISBERG & CONWAY, P.C. P.O. BOX 3221 WARMINSTER, PA. 18974 Postmaster Mechanicsburg, PA 17055 January 28, 2003 (215) 442-5668 FAX (215) 442-9727 REQUEST FOR CHANGE OF ADDRESS OR BOXI-IOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (ifa boxholder} for the following: Name: Aimee J. Leader Address: 899 Old Silver Spring Rd Mechanicsburg, PA 17055 'fhe following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). Th,.-re is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when' reqUester is an attorney or a party acting Pro Se- except a cOrporation acting Pro Se must cite statute: Process Server for McCabe, Weisberg & Conway, P.C. 3. The names of all known parties to this litigation: ' Citibank, NA, as Trustee v. Christopher R. Leader & Aimee j. Leader 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas 5. The docket or other identifying number if one has been assigned: 02-3271 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMISSION OF FnLSE n~ORM^~ION TO BOXI-IOLDER INFORMATION OBTAIN AND USE CHANOE OF ADDRESS INFORMATION OR WITH FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION AC~AL OR ~'ROSE~'CTIVE LmOATIOU COULD RES VLT IN CR~INAL ~'EHALTIES n':CLUDING A FINE OF U? TO $10,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR. CHANGE OF ADDRESS INFORMRATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SEC'rION 1001). I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND WILL BE USED LrrIGATION. SOLELY FOR SERVICE OF LEGAL PROCESS TI-L&T THE ADDRESS INFORMATION IS NEEDED AND LARRY DEL VECCHIO P.O. Box 3221 Warminster, PA. 18974 For McCabe, Weisberg & Conway, P.e. FOR THE POST OFFICE USE ONLY %L_ NO CHANGE OF ADDRESS ORDER ON FILE NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: POST MARK McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE V. CHRISTOPHER R. LEADER and AIMEE J. LEADER FEB 1 3 ZOO3V Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMBER 02-3271 CIVIL TERM ORDER AND NOW, this /Y~ day of f~~ , 2003, the Plaintiff is granted leave to serve a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Aimee J. Leader, by regular mail, certified mail, return receipt requested; and by posting the same by the Cumberland County Sheriff's office at the mortgaged premises known as 899 Old Silver Spring Road, Mechanicsburg, PA 17055. BY THE COURT: ! /.,,, McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE Vo CHRISTOPHER R. LEADER AND AIMEE J. LEADER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 02-3271 CIVIL TERM PETITION TO ALLOW SERVICE ON THE DEFENDANT BY REGULAR MAIL, CERTIFIED MAIL AND POSTING PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to serve a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Christopher R. Leader at the mortgage premises known as 899 Old Silver Spring Road, Mechanicsburg, PA 170551. However, the Sheriff advised that they were unable to serve the Defendant with the Notice of Sale after making several attempts. A true and correct copy of the Sheriff's Return of Service form indicating the same is attached hereto and marked as Exhibit "A." 2. Plaintiff searched for a forwarding address for Defendant. The Post Master advised that the Defendant, Christopher R. Leader has filed a change of address to 18 Bellmore Road, Camp Hill, PA 17011. A copy of the Affidavit of Good Faith Investigation indicating the same, is attached hereto, and marked Exhibit "B." 3. Plaintiff then attempted to serve a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Christopher R. Leader at the address of 18 Bellmore Road, Camp Hill, PA 17011. However, per Plaintiff's conversation with the Sheriff's office, advised that they were unable to serve the Defendant with the Notice of Sale as the address listed is the address of the Defendant's mother. The Defendant's mother advised that her son, Christopher R. Leader does not reside at this address as he is living at the mortgage premises of 899 Old Silver Spring Road, Mechanicsburg, PA 17055. 4. The Sheriff's office also advised that they mailed a copy of the Notice of Sheriff's Sale via certified mail with restricted delivery to Christopher R. Leader of 899 Old Silver Springs Road, Mechanicsburg, PA 17055. The letter was mailed on January 24, 2003 and was signed by a Betty Leader on January 24, 2003 then returned to the Sheriff's office on January 28, 2003. A copy of the Sheriff's Amended Return indicating the same is attached hereto and marked Exhibit "C." 5. The Sheriff's office attempted to serve a copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Christopher R. Leader at the mortgage premises known as 899 Old Silver Springs Road, Mechanicsburg, PA 17055. However, on February 19, 2003, the Sheriff's office, advised that they were unable to serve the Defendant with the Notice of Sale has someone is residing in the property but is avoiding service. A copy of the Sheriff's Amended Return indicating the same, is attached hereto, and marked Exhibit "C." 6. Plaintiff has checked the Local Telephone Directory and 411 Assistance for an address for the Defendant, Christopher R. Leader. There are no listings for the Defendant in or around the Mechanicsburg area. A copy of the Affidavit of Good Faith Investigation is attached hereto, and marked Exhibit "B." 7. Plaintiff has attempted to make inquiry with neighbors of the Defendant, Christopher R. Leader. Andrew Doughty of 897 Old Silver Spring Road, Mechanicsburg, PA 2_7055 with a telephone number of 717-791-6292 and David Reinert of 901 Old Silver Spring Road, Mechanicsburg, PA 17055, with a telephone number of 717- 691-1832 were contacted. However, Plaintiff left messages but received no response. Plaintiff has also attempted to contact JM Stofanak, of 895 Old Silver Spring Road, Mechanicsburg, PA 17055 with a telephone number of 717-766-5711. However there was no answer after several attempts. A copy of the Affidavit of Good Faith Investigation indicating the same, is attached hereto and marked Exhibit "B." 8. Plaintiff has made inquiry with l~he local tax bureau for an address for the Defendant, Christopher R. Leader. The tax office has a mailing address of 899 Old Silver Spring Road, Mechanicsburg, PA 17055. A copy of the Affidavit of Good Faith Investigation indicating the same, is attached hereto and marked Exhibit "B." 9. Plaintiff has made inquiry with the Social Security Administration and was advised that there are no death records for the Defendant, Christopher R. Leader under his name and social security number. A copy of the Affi. davit of Good Faith Investigation, indicating the same, is attached hereto and marked Exhibit "B." 10. Plaintiff has investigated the Defendant's Voter Registration Records for an address for the Defendant, Christopher R. Leader. The Defendant is registered at 899 Old Silver Spring Road, Mechanicsburg, PA 17055. A copy of the Affidavit of Good Faith Investigation, indicating the same is attached hereto and marked Exhibit "B." 11. If service cannot be made on the Defendant, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Christopher R. Leader, by regular mail, certified mail, return receipt requested at the Defendants last known address of 18 Bellmore Road, Camp Hill, PA 17011 and further by posting the same at the mortgaged premises known as 899 Old Silver Spring Road, Mechanicsburg, PA 17055. TERRENCE J. McCABE, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE CHRISTOPHER R. LEADER AND AIMEE J. LEADER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMBER. 02-3271 CIVIL TERM MEMORANDUM OF LAW If a resident Defendant has obstructed[ or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. TERRENCE J. McCABE, ESQUIRE McCABE, WEISBERG AND CON-WAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CITIBANK, N.A., AS TRUSTEE Vo CHRISTOPHER R. LEADER AND AIMEE J. LEADER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMBER 02-3271 CIVIL TERM CERTIFICATION OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff, hereby certify that I served a true and correct copy of the foregoing Motion for Alternative Service Pursuant to Pa.R.C.P. 430, by United States Mail, first class, postage prepaid, on the 27TM day of February, 2003, upon the following: Christopher R. Leader 18 Bellmore Road Camp Hill, PA 17011 Christopher R. Leader 899 Old Silver Springs Road Mechanicsburg, PA 17055 TERR'ENCE J. McCABE, ' ESQUIRE VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. Citibank, N.A., as Trustee VS Christopher R. Leader and Aimee J. Leader In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3271 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Christopher R. Leader and Aimee J. Leader, but was unable to locate them in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale, and Description as NOT FOUND as to the defendants, Christopher R. Leader and Aimee J. Leader. Several attempts of service were made on defendants at 899 Old Silver Springs Road, Mechanicsburg, Cumberland County, Pennsylvania, but contact could not be made with anyone. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 8, 2003 at 5:56 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Christopher R. Leader and Aimee J. Leader located at 899 Old Silver Springs Road, Mechanicsburg, Pennsylvania, according to law. Sworn and subscribed to before me This ... day of 2003, A.D. Prothonotary R. Thomas KI' , ' Real Estate Deputy Citibank, N.A., as Trustee VS. CHRISTOPHER R. LEADER AIMEE J. LEADER LARRY DEL VECCHIO PROCESS SERVER FOR MCCABE, WEISBERG & CONWAY, P.C. P.O. BOX 3221 WARMINISTEtL PA 19874 (215) 442-5668 (215) 442-9727 FAX COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 02-3271 CIVIL TERM LAST KNOWN ADDRESS: 899 Old Silver Spring Road, Mechanicsburg, PA 17055 LOAN NUMBER: 59-0884PA AFFIDAVIT OF GOOD FAITH EFFORT TO LOCATE DEFENDANT (S) I hereby certify that on January 28, 2003, a good faith effort was made to discover the correct address of said defendant (s), by: Inquiry of Postal authority; Postal authority states ALmee has no change of address; Christopher has filed a change of address to 18 Bellmore Rd., Camp Hill, PA 17011. 2. Examination of local telephone directories and 411 assistance; There are no listings for the defendant s in or around the Mechanicsburg area. 3. Neighbor Contacts: Andrew Doughty, 897 Old Silver Spring Rd., (717) 791-6292, left messages with no response JM Stofanak, 895 Old Silver Spring Rd., (717) 766-5711, no answer, several attempts David Reinert, 901 Old Silver Spring Rd., (717) 691-1832, left messages with no response 4. Tax Information: Tax office has mailing address same as property, 899 Old Silver Spring Rd. 5. Death Records: Social Security has no death records for the defendants under their names and/or SSN. 6. Voter Registration: - The defendants are registered at property, 899 Old Silver Spring Rd. I certify that this information is tree and correct to the best of my knowleClg, g.g~ information and belief. Larry Del Vecchio, Process Server NOTARY PUBLIC: Sworn to and described before me this ~.~'~ day o~ 03. B P.O. BOX 3221 WARMINSTER, PA. 18974 LARRY DEL VECCHIO , PROCESS SERVER FOR MCCA.BE, WEISBERG & CONWAY, P.C. January 28, 2003 Postmaster Mechanicsburg, PA 17055 (215) 442-5668 FAX (215) 442-9727 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish thc new address or the name and street address (ifa boxholder) for the following: Name: Christopher R. Leader Address: 899 Old Silver Spring Rd Mechanicsburg, PA 17055 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). Th,~e is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting Pro Se- except a corporation acting Pro Se must cite statute: Process Server for McCabe, Weisberg & Conway, P.C. 3. The names of all known parties to this litigation: ~ Citibank, NA? as Trustee v. Christopher R. Leader & Aimee J. Leader 4. The court in which the case has been or will be iheard: Cumberland County, PA, Court of Common Pleas 5. The docket or other identifying number if one has been assigned: 02-3271 6. The capacity in which this individual is to be served.: Defendant(s) THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSEPCTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMRATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATI~ P.O. Box 322l LARRY DEL VECCHIO Warminster, PA. 18974 For McCabe, Weisberg & Conway, P.C. FOR TItE POST OFFICE USE ONLY NO CHANGE OF ADDRESS ORDER ON FILE NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: \'70\\ POST MARK LARRY DEL VECCHIO PROCESS SERVER FOR MCCABE, WEISBERG & CONWAY, P.C. P.O. BOX 3221 WARMINSTER, PA. 18974 (215) 442-5668 FAX (215) 442-9727 Postmaster Mechanicsburg, PA 17055 January 28, 2003 REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish the new address or the name and street address (ifa boxholder) for the following: Name: Aimee J. Leader Address: 899 Old Silver Spring Rd Mechanicsburg, PA 17055 The following information is provided in accordance with 39 CFR 265.6(d) (4) (ii). Th~xe is no fee for providing boxholder information. The fee providing change of address information is waived in accordance with 39 CFR 265.6 (d) (1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: Process Server 2. Statute or regulation that empowers me to serve process (not required when reqUeSter is an attorney or a party acting Pro Se- except a corporation acting Pro Se mst cite statute: Process Server for McCabe, Weisberg & Conway, P.C. 3. The names of all known parties to this litigation: Citibank, NA, as Trustee v. Christopher R. Leader & Aimee J. Leader 4. The court in which the case has been or will be heard: Cumberland County, PA, Court of Common Pleas 5. The docket or other identifying number if one has been assigned: 02-3271 6. The capacity in which this individual is to be served: Defendant(s) THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE O~F ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSEPCTIVE LITIGATION COULD RESULT IN CRIlVIINAL PENALTIES INCLUDING A FINE OF UP TO $10,000.00 OR INPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMRATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 LI.S.C. SECTION 1001). I CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND THAT THE ADDRESS INFORMATION IS NEEDED AND WILL BE USED SOLELY FOR SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION. J~"'~"~ P.O. Box 3221 LARRY DEL VECCHIO Warminster, PA. 18974 For McCabe, Weisberg & Conway, P.C. FOR THE POST OFFICE USE ONLY NO CHANGE OF ADDRESS ORDER ON FILE POST MARK NEW ADDRESS OR BOXHOLDER'S NAME AND PHYSICAL STREET ADDRESS: From: O2120120O3 16:09 ,¢'/_2.7 P,002/002 Citibank, N.A., az Trustee V$ Chr/stopher R. Leader and Aimee ~I. Leader In The Court of Common Pleas of Cumberl/md County, Pennsylvan/a Writ No. 2002-3271 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendants, to wit: Christopher R. Leader and Aimee $. Leader, but waz unable to locate them in his bailiwick He thercfore returns thc within Real Estate Writ, Notice of Sale, and Description as NOT FOUND as to the defendants, Christopher R. Leader and Aimee $. Leader. Several attempts of service were made on defendants at 899 Old Silver Springs Road, Mechanicsburg, Cumberland County, Yenns. ylvania, but cont~t could not be mad~ with anyone. Depulics state that persons are inside the home, but no one will answer the door. Michael Barrick, Deputy Sheriff, who being duly sworn according to hw, states that on ~Ianuary 8, 2003 at 5:56 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in thc abovc entitled action, upon the property of Christopher R. Leader and Aimee $. Loader located at 899 Old Silver Springs Road, Mechanicsburg, Pennsylvania, according to law. R. Thomas Klino, Sheriff, who being duly sworn according to law, states that ho served the within Real Bstate Writ, Notice and Description in thc following manner: Tho Sheriffm~ilcd a copy of the pendency of the action by cerQficd mail, restricted delivery, deliver to addressee only, reOlrn receipt requested, to one of the within named defendants, to wit: Christopher R. Leader, to his last known address of 899 Old Silver Springs Road, Mechanicsburg, PA 17055. This letter was mailed on ~Ianuary 24, 2003. The return reoeipt card was signed by Betty Leader on Sanuary 27, 2003 and returned to thc Sheriffs Office on lanuary 28, 2003. Sworn and subscribed to before me This 2003, A.D. dayof Prothonotary So Answers: R. Thomas Kline, Sheriff BY Real Estate Deputy Exhibit C McCABE, WEISBERG AND CON-WAY, P.C BY: TERRENCE J. McCABE, ESQUIRE Identification Nun%ber 16496 First Union Building 123 South Broad, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff CITIBANK, N.A., AS TRUSTEE V. CHRISTOPHER R. LEADER AND AIMEE J. LEADER : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : : : : : NUMBER 02-3271 CIVIL TERM ORDER AND NOW, this ~ ~ day of ~ , 2003, the Plaintiff is granted leave to serve a true and correct copy of the Notice of Sheriff's Sate of Real Property upon the Defendant, Christopher R. Leader, by regular mail, certified mail, return receipt requested; to the Defendant's last known address of 18 Bellmore Road, Camp Hill, PA 17011 and further by posting the same by the Sheriff of Cumberland County at the mortgaged p~emises known as 899 Old Silver Springs Road, Mechanicaburg, PA 17055. BY THE COURT: Citibank, N.A., as Trustee VS Christopher R. Leader and Aimee J. Leader In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3271 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Terrence McCabe. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Advertising 30.00 Posting Bills 30.00 Law Library .50 Prothonotary 1.00 Mileage 7.59 Levy 15.00 Certified Mail 10.47 Law Journal 232.85 Patriot News 235.18 Poundage 1077.67 Share of Bills 25.21 $1725.47 paid by attorney 03/07/03 Sworn and subscribed to before me This I,Z r? day of~ 2003, A.D.~,Sff_,_. ~ ~/4.~_._5 ~,. Prothonotary R. Thomas Kline, Sheriff Real Esfa]te Deputy l'£° Ck_ THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of January and the 4th and 11th day(s) of February 2003. 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. My Cornrnission Expires June 6, 2006 '] NO'~R~" PUBLIC My commission expires June 6, 2006 REAL, E~TATE 8At. B ilit.~ CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Declaa~ ~l~ .l~owa ~aa=t v'~l= $ 233.43 ~ 'C~.mmt~ of ~ $ 1.75 ~;~l~ ~ ~ $ 235.18 ~ ~ ~,~ ~_ ~ ~ ~ Publisher's Receipt for Advertising Cost 3101 ~ ~. ~,~, ~u~. 1~8~, ~ _ ~~~f~~ ;o., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ~~~ ~ ~'3~, dge receipt of the aforesaid notice and pubhcation costs and ce~ifies that the same have l~, ~ ~ ~.A~ t4, t~; ~ ~'~~~~ By .................................................................... PARC~ ID'#lS-2~_~til-001. S~'G S~qOWN',~. ~ Old Siiw St~nss R_o~d,M~hanicSl~r~,PA ~0~5.. _ _ Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal. periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 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. R.~ ~,STAT~ 8ALi~ NO. 48 Writ No. 2002-3271 Civil Citibank. N.A., as Trustee VS. Christopher R. Leader and Aimee J. Leader Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Borough of Mechanicsburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly de- scribed as follows: KNOWN, named and identified in the declaration reference to be- low as "Walnut Villas Condominium" located in the Borough of Mechan- icsburg, County of Cumberland, Com- monwealth of Pennsylvania, which has heretofore been submitted pur- suant to the provisions of the Penn- sylvania Uniform Condominium Act, 68 Pa. Cons. Stat. Ann 3101 et seq. {Purdon Supp. 1988), by the record- ing in the Office of the Recorder of Deeds of Cumberland County. Penn- sylvania, of a Declaration of Condo- minium dated July 31, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, Page 147 being and designated in such declaration as Unit No. 899. As more fully described in such declaration, together with a proportionate undi- vided interest in the common ele- ments of such condominium as set forth in such declaration further and any amendments thereto hereafter recorded in the aforesaid office. Parcel ID //18-22-0519-001. Being Known As: 899 Old Silver Springs Road, Mechanicsburg, PA 17055. ~/~ Lisa Marie Co~p~f, Editor SWORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY, 2003_ (Purdon Supp. 19~. oy um ~= ..... lng in the Office of the Recorder of Deeds of Cumberland Cotmty, Penn- sylvania, of a Declaration of Condo- minium dated July 31, 1985, and recorded on August 14, 1985, in Miscellaneous Book Vol. 308, Page 147 being and designated in such declaration as Unit No. 899. As more fully described in such declaration, together with a proportionate undi- vided interest in the common ele- ments of such condominium as set forth in such declaration further and any amendments thereto hereafter recorded in the aforesaid office. Parcel ID #18-22-0519-001- Being Known As: 899 Old Silver Springs Road, Mechanicsburg, PA 17O55.