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Martha E. Von Rosenstiel
21 South 12th street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
GMAC MORTGAGE CORPORATION OF
PA
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment filed October 1 , 1997 in the
prior to the judgment date.
above Mortgage Foreclosure matter vacated as b nkruptcy was filed
Dated: 05/02/97
Mar ha E. Von Rosenstiel
A torney for Plaintiff
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UNITED STATES BANKRUPTCY COURT
FOR THE KIDDLE DISTRICT OF PENNSYLVANIA"""-.--
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IN RE: Keith Boyer
BANKRUPTCY NO
1-96-02473
CHAPTER 13
I
I . C ...
DEFAULT ORDlZ ON KOTION FOR RELIEF FROK AUT~~.~~ ,_.IlV
,/ . I jI
This J.:') day of ?~' , 1997, upon default, no
response objecting to the Motio~ having been timely filed by an
interested party and upon Movant's certification of Service and
Motion for Default, it is
ORDERED that the above-captioned Motion is granted insofar
as it requests relief from the automatic stay imposed by 11
U.S.C. Rule 362.
Movant shall, within five days hereof, serve a copy f the
within order on parties of interest and file a certificate of
service.
t/ r':,r'!"~ !. ....~iW\..'~'
United States Bankruptcy Judge
Martha E. Yon Rosenstiel, Esq.
21 South 12th Street ste 720
Philadelphia, PA 19107
Keith Boyer
929 spring Circle
Monroe Twp., PA 17055
Dorothy Feldman, Esq.
114 S. street
Harrisburg, PA 17108
Charles DeHart, Esq.
3631 N. Front street
Harrisburg, PA 17110
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Martha E. Van HOGen:;tll'l
21 South 12th street
Suite 700
PhUadelph La, PA I ~ 10'/
(215) 569-10,,8
Attorney 1.0." :,2G]~
Attol"n"y 101' Plilintlff
GMAC MORTGAGE COHi'OHNI'1 all
OF PA
3451 HAMr-lOIlD AVEIIUE
WATERLOO, IA 5070~
COIII,T OJ' CONr~OII PLEAS OF
CIIl.ll1l:I,I.AlIIJ COllN'I'Y
110.
v.
KEITH J. BOYEH and KIMIIERI8
K. BOYER hlw
~21 PARK DRIVE
CAHLISLE, PA 17013
CIVIL IIC'l'ION - MOR'I'GIIGE F'OIlECLOBURE
1. Plaintiff Ie; GI1AC 1.10rh),,'Jl.' CoqJO,"ation of PA, a
corporation ol'g~lnizcd i1nd l'..'>:i:;tinq 1II1dl!J: tile lil\'/8 of the
Commonwealth of Pennuylvaniil, \"lith oor'por"ate offices at 3451
Hammond ^vcnuc, \-Jtltc!I:loQ, l^ 1)()"JOtl.
2. lJefenLi"nt:;, I\"ith ,J. Boyer "ncl Kimberly K. Boyer are the
mortgagors und I"<,al 0,111<."":; 01 JlI"omi:;ou 'J29 spring CirCle, Monroe
TWp., PII 17055, horoln"lter c1ouoribocl, whose last known address
is in the caption.
3. Plaintiff brln'Ju tid:; "otion in mortgage foreclosure
against dofond<rntu, mort'Ji"Jor:; "I1Li "0,1] owners, to foreclose a
certain inclc>ntllf'c' ul l1\fll'tcliHJC' l\\ddC', (~xoclltcd ilnd delivered by the
above named doronLi"nt:;, Illo,.t""qo,',, allll real owners to GMAC
Mortgage Corpordt iOIl oj P^ IJII ,Juno J IJ1 1905 which mortgage is
recorded in the orrico or tilf' H,'conlo," of Deeds of Cumberland
County in NortqilCJo 11001: 12(>/ 1""Jo 'JflH, secured on premises 929
Spring Circlo, {.lullru(' 'J".-.IfJ. I I'^ I'/()'_j~), ,-\ true and correct
.
.
description of which is attached hereto as Exhibit I.
4. Plaintiff alleges each and every term, condition and
covenant in the aforesaid mortgage, and hereby incorporates them
herein by reference thereto.
5. The aforesaid mortgage is in default in that the
defendants, mortgagors and real owners have failed to make
payment of the monthly installments of pri ncipal and interest in
accordance with the terms of the mortgage, for the month of
January, 1996 and each month thereafter, up to and including the
present time.
6. Under the terms of the aforesaid mortgage, upon default
of payments set forth in the mortgage documents, the entire
principal balance and all interest due thereon are collectible
forthwith.
7. The following is an itemized statement of the amount due
plaintiff under the terms of the aforesaid mortgage:
principal $107,307.43
Interest from 12/01/95
to 06/09/96 at $ 19.10 p/d $ 4,632.30
Accrued late charges from
07/15/95 to 07/15/96 $ 311.67
Accrued escrow deficit (taxes
and insurance) from 01/01/96
to 06/01/96 $ 53.03
Monthly inspection charges from
01/01/96 to 06/01/96 at $7.25 $ 56.00
Attorney's fee per Mortgage $ 5,300.00
Title information certificate $ 325.00
Photostats and postage $ 35.00
Notarizations $ 10.00
Total $116,232.43
8. The original principal balance of the mortgage involved
in this action was $107,800.00; therefore this action does not
EXHIBIT
-or-
-J.--
DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises.
SITUATE, lying and being in the Township of Monroe in the County of Cumberland and
Commonwealth of Pennsylvania, more particularly described as follows:
BEGINNING at an iron pin on the Northern line of Spring Circle. said pin being at the dividing line
between Lots Nos. 93 and 94 on the hereinafter mentioned Plan of Lots; thence along said dividing
line North 20 degrees 02 minutes 32 seconds West, one hundred fifty.-five and fifty-six hundredths
(155.56) feet to an iron pin; thence North 77 degrees 45 minutes 00 seconds East, one hundred
twelve and sixty-three hundredths (112.63) feet to an iron pin; thence along part of the Western line
of Lot No. 96 and along all of the Western line of Lot No. 95, South 12 degrees 15 minutes 00
seconds East, one hundred fifty (150) feet to a hub on the Northern line of Spring Circle; thence
continuing along the Northern line of Spring Circle South 77 degrees 45 minutes 00 seconds West,
seventy-five (75) feet to a point; thence continuing along the Northern line of Spring Circle on a
curve to the left having a radius of one hundred twenty-five (125) feet, an arc length of seventeen
(17) feet, to an iron pin, the place of beginning.
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens, said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 135.
HAVING THEREON ERECTED a brick and aluminum bi-Ievel dwelling with integral garage, said
premises being known as and numbered 929 Spring Circle, Mechanicsburg, Pennsylvania.
TAX PARCEL NUMBER: 22-240-783-090
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Martha E. Von Rosensticl
21 South 12th Street
Suite 700
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D.# 526]4
Attorney for Plaintiff
GMAC r10RTGAGE CORPORATIDtl
OF PA
]451 HAMMOND AVErmE
WATERLOO, IA 50704
COURT OF COMMON PLEAS OF
CUf1BERLAND COUNTY
1. Plaintiff is GHAC r10rtgage Corporation of PA, a
NO.
v.
KEITH J. BOYER and KIMBERLY
K. BOYER hl'l
421 PARK DRIVE
CARLISLE, PA 17013
CIVIL ACTION - MORTGAGE FORECLOSURE
corporation organized and existing under the la'ls of the
Common'lealth of Pennsylvania, 'lith corporate offices at ]451
Hammond Avenue, tvaterloo, IA 50704.
2. Defendants, Keith J. Boyer and Kimberly K. Boyer are the
mortgagors and real O'lners of premises 929 Spring Circle, Monroe
T'Ip., PA 17055, hereinafter described, '1hose last known address
is in the caption.
3. Plaintiff brings this action in mortgage foreclosure
against defendants, mortgagors and real o'lners, to foreclose a
certain indenture of mortgage made, executed and delivered by the
above named defendants, mortgagors and real owners to GMAC
Mortgage Corporation ot PA on June 16, 1995 which mortgage is
recorded in the Office of the Recorder of Deeds of Cumberland
County in Mortgage Book 1267 page 988, secured on premises 929
Spring Circle, Honroe Twp., PA 17055, a true and correct
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MARTHA Eo YON ROSENSTIEL
A'I1'ORNEY AT I.A W
.:!l SOIJTIII2T11 STREET. SUITE 7!O
PIIII.ADm.pIIIA,!'A I'JI(17
(21~).:'iM.lll:'iK
. Also admlutd NJ
MARTIIA ..:. VON ROSf.NSTun..
August 12, 1996
Office of the Sheriff
Cumberland county Court House
1 Courthouse Square
Carlisle, PA 17013
PA v.Keith J. Boyer and
RE: GMAC Mortgage corporation of
Kimberly K. Boyer
our File# 5481ABH %
Dear Sir/Madam:
1rr5?
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Enclosed herewith civil Action-complaint in the above
matter, which I would like to have served on the defendants
as follows:
Keith J. Boyer
421 Park Drive
Carlisle, PA 17013
and
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
I have enclosed is a self addressed, s amped envelope
for the returns of service.
Thank you for your assis ance in this atter.
MEVR:amb
Enclosures
artha E. Von Rosenstiel
RECYCLE AMERICA ,C)Q
W
GMAC Mortgage Corporation of Pa.
vs
Keith J. and Kimberly K. Boyer
IN the Court of Common Pleas
Cumherland County, Pennsylvania
No. 96-4657 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to
law. says this writ is returned STAYED DUE TO BANKRUPTCY per
instruction from attorney.
Sheriff's Costs:
Docke.ting
Poundage
Law Library
County
Mileage
Postpone Sale
Levy
Surcharge
Advance Costs
Sheriff's Costs
Refund to Atty
_30.00
1. 67
.50
1.00
6.20
25.00
15.00
- 6.00
$85.37 Pd. by Atty. 10-22-96
$1,000.00
85.37
$ 914.63
THIS WRIT IS RETURNED STAYED DUE TO BANKRUPTCY
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R. Th;mas Kline, sj~;iff
SwoLn and subscribed to before me
this .;is' <;::: day of ({JLt,.0~/1996
'-. JL.,-t._ r; Ihdt!., / Lff'.r..'
" Prothonotary' .
by
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MARTHA E. VQtI ?OSENSTIEL, ESQ.
Attorney at Law
21 South 12th Street, suite 720
Philadelphia, PA 19107
(215) 569-1058
October 8, 1996
TO: Keith J. Boyer and Kimberly K. Boyer
929 Spring Circle
Monroe Twp., PA 17055
RE: NOTICE OF SALE OF REAL PROPERTY:
929 Spring Circle, Honroe T',ip., PA 17055
Amount of Judgment: $ 119,658.89
Date of Judgment: October 10, 1996
Court Term and Number: Court of Common Pleas of
Berks county, File No.: 96-4657 CIVIL
Plaintiff: GMAC Mortgage corporation of PA
Defendants: Keith J. Boyer and Kimberly K. Boyer
Dear Keith J. Boyer and Kimberly K. Boyer:
Please be advised that the property and improvements, if
any, located at and known as 929 Spring Circle, Monroe Twp. PA
17055 will be sold by the Sheriff of Cumberland County on March
5, 1996, at 10:00 a.m. in the New Courthouse of Cumberland
County, 2nd Floor, Carlisle, PA 17013.
This property and improvements are being sold pursuant to a
judgment entered as indicated above in favor of the above named
plaintiff, and against the above named defendants.
The name of the owners, real ownerR, and reputed owners of
the aforementioned property are Keith J. Boyer and Kimberly K.
Boyer.
A schedule of distribution will be filed by the Sheriff on a
date specified by the Sheriff no later than 30 days after said
sale, and distribution will b~ made in accordance: with the
schedule unless exceptions are filed thereto within ten (10) days
after the date of the filing of said schedule. Ybu should check
with the Sheriff's Office by calling (717) 240-6390 to determine
the actual date of the filing o~ /~chedule. f
S~ncere y yours,
/ ~
/
Martha E. Von Rosenstiel
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MEVR:amb
J
Martha E. 'Ion Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0, #52634
Attorney for Plaintiff
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/'"
421 PARK DRIVE
CARLISLE, PA 17013
COURT OF COMMON PLEAS OF
CU:1BERLAND COUNTY
NO. 96-4657 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith J. Boyer and Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
Your house and/or real estate at 929 spring circle, Monroe
Twp., PA 17055 is scheduled to be sold at Sheriff's Sale on March
5, 1996 at 10:00 a.m. to enforce the court judgment of
$119,658.89 obtained by GMAC Mortgage Corporation of PA against
you.
NOTICE OF OWNERS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take IMMEDIATE
action:
1. The sale will be cancelled if you pay to GMAC Mortgage
Corporation of PA the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must
pay, you may call (215) 569-1058.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the jUdgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the sale through other
legal proceedings.
You may contact an attorney to assert your rights. The
sooner you contact one, the more chance you will have of stopping
the sale. (See notice on page two on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1.
be sold
calling
If the Sheriff's Sale
to the highest bidder.
(215) 569-1058.
is not stopped, your property will
You nay find out the bid price by
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the
value of the property.
3. The sale will go through only if
Sheriff the full amount due in the sale.
happened you may call (215) 569-1058.
the buyer pays the
To find out if this has
4. If the amount due from the buyer
Sheriff, you will remain the owner of the
never happened.
is not paid to the
property as it the sale
5. 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.
6. You may be entitled to a share of the money which was
paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff on a date to be
announced by the Sheriff. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the Schedule of Distribution is posted.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
COURT .;DMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
(Address)
(Telephone Number)
Martha E. Von Rosenstiel Attorney for Plaintiff
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
GMAC MORTGAGE CORPORATION OF COURT OF COMMON PLEAS OF
PA CUMBERLAND COUNTY
3451 HAMMOND AVEIIUE
WATERLOO, IA 50704 110. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property
from levy or attachment:
(1) From my real property in my possession which has been
levied upon,
(a) I desire that my $300.00 statutory exemption be set
aside in kind (specify real property to be set
aside in kind):
I request a prompt court hearing to determine the exemption.
Notice of the hearing should be given to me at
I verify that the statements made in this Claim for
Exemption 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.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PA 17013
(717) 240-6390
DESCRIPTION
ALL THAT CERTAIN tract or parcel oi land and premises.
srTUA TE. lying and being in the Township oi Monroe in the County oi Cumberland and
Co=onwealth oi PelUlSylvania. more panicularly described as follows:
BEGINNING at an iron pin on the Northern line oi Spring Circle. said pin being at the dividing line
between loIS Nos. 93 and 94 on the hereinafter mentioned Plan oi Lots: thence along said dividing
line North 20 degrees 02 minutes 32 seconds West. one hundred fifty.-five and fifty-six hundredths
(ISS.S6i feet to an iron pin: thence North 77 degrees 45 minutes 00 seconds East. one hundred
twelve and sixty-three hundredths (112.63) feet to an iron pin: thence along pan oi the Western line
of Lot No. 96 and along all of the Western line of Lot No. 95. South 12 degrees 15 minutes 00
seconds East. one hundred fifty (150) feet to a hub on the Northern line oi Spring Circle: thence
continuing along the Northern line of Spring Circle South 77 degrees 45 minutes 00 seconds West.
seventy-five (75) feet to a point: thence continuing along the Northern line of Spring Circle on a
curve to the left having a radius of one hundred twenty-live (125) feet. an arc length of seventeen
(17) feet. to an iron pin. the place of beginning.
TAX PARCEL NUMBER: 22-240-783-090
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens. said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22. Page 135.
HAVING THEREON ERECTED a brick and aluminum bi-Ievel dwelling with integral garage. said
premises being known as and numbered 929 Spring Circle. Mechanicsburg. PelUlSylvania.
~
Martha E. Von Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
Attorney for Plaintiff
GI1AC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF PHILADELPHIA
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the
above action, sets forth as of the date the praecipe for the writ
of Execution was filed the following information concerning the
real property located at 929 Spring Circle, Monroe Twp., PA 17055
1. Name and address of owners(s) or reputed owner(s):
Keith J. Boyer
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
929 spring Circle
Monroe Twp., PA 17055
2. Name and address of defendant(s) in the judgment:
Keith J. Boyer
929 spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
929 Spring Circle
Monroe Twp., PA 17055
3. Name and address of every jUdgment creditor whose
judgment is a record lien on the real property to be
sold:
None
~
4. Name and address of the last recorded holder of every
mortgage of record:
None
5. Name and address of every other person who has any
record lien on the property:
None
6. Name and address of every other person who has any
record interest in the property and whose interest may
be affected by the sale:
None
7. Name and address of every other person of whom plaintiff
has knowledge who has any interest in the property which
,
may be affected by the sale:
None
I verify that the statements made in this af idavit are true
and correct to the best of my personal knowledge r information
and belief. I understand that false statements erein are made
subject to the penalties of 18 PA C~ section 4 04 relating to
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Martha E. Von Rosenstiel
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF ~UMBER1l\.I'JP COUNTY:
Tosatisfythedebt,interestandcostsdue GMAC Mortgage Corporation of PA
NO, 96-4657 CIVIL 19
CIVIL ACTION. LAW
PLAINTlFF(S)
fmm Keith J. and Kimberly K. Boyer, 421 Park Dr., Carlisle PA 17013.
(1) You are directed to levy upon the property of the defendanl(s) and to sell
at 929 Spring Circle, Monroe Township, Mechanicsburg
attached legal description.)
DEFENDANT(S)
Real estate located
PA 17055. (See
(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/are enjoined from paying any
debt to or for the account 01 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
Interest
Atty's Comm
Atty Paid
Plaintiff Paid
$119,658.89
from 10/11/96
L.L.
Due Prothy
Other Costs
$.50
$1.00
%
$110.24
Date:
October II, 1996
Lawrence E. Welker
REQUESTING PARTY:
Name Martha E. Von Rosentiel, Esq.
by-f
Deputy
Address:
21 South 12th. St., Ste.
Philadelphia PA 19107
Plaintiff
720
Attorney for:
Telephone:
Supreme Court 10 No.
(215) 569-105B
52634
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PRAECIPE FaR WRIT OF EXECUTION-:MORTGAGc FORECLOSURE)
P.R.'-? 3180-3183 & 32.56
GMAC Mortgage Corporation of PA
c; THE COURT OF Cm.DroN PL"EAS OF
~m~~C9WIT, tDmSn~~A
C:,vl.l Accl.o~ - :.xecuc::n
::-fa q(,-4fiS7 ~T\ITT _
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Keith J. Boyer and Kimpe~~__~QXg~/w
Jud~ ::-fo___
PRACEIPE FOR WRIT OF EXECLTION
(JJ:ORTGAGE FORECLOSURE)
T~ th~ ~tb.o!:!~t.?..!T
r..sue writ of .,,,,,,ution in the above =tter.
Amount Due
3119,658.89
Int=t from 10/11/96
.nd Co.ts.
::-rote: PI~ iurniail deoc:iption of P:-operty.
.J.t"'~ j";;h4 P!a.'ntirj (iJ-------
E. Von Rosenstie1
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DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises.
SITUATE. lying and being in the Township of Monroe in the County of Cumberland and
Commonwealth of Pennsylvania. more panicularly described as follows:
BEGINNING at an iron pin on the Nonhern line of Spring Circle. said pin being at the dividing line
between Lots Nos. 93 and 94 on the hereinafter mentioned Plan of Lots: thence along said dividing
line Nonh 20 degrees 02 minutes 32 seconds West. one hundred fifty.-five and fifty-six hundredths
(155.56) feet to an iron pin: thence Nonh 77 degrees 45 minutes 00 seconds East. one hundred
twelve and sixty-three hundredths (112.63) feet to an iron pin: thence along pan of the Western line
of Lot No. 96 and along all of the Western line of Lot No. 95. South 12 degrees 15 minutes 00
seconds East, one hundred fifty (150) feet to a hub on the Nonhern line of Spring Circle: thence
continuing along the Nonhern line of Spring Circle South 77 degrees 45 minutes 00 seconds West.
seventy-five (75) feet to a point: thence continuing along the Nonhern line of Spring Circle on a
curve to the left having a radius of one hundred twenty-five (125) feet. an arc length of seventeen
(17) feet. to an iron pin, the place of beginning.
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens. said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22. Page 135.
HA VlNG THEREON ERECTED a brick and aluminum bi-level dwelling with integral garage. said
premises being known as and numbered 929 Spring Circle, Mechanicsburg, Pennsylvania.
TAX PARCEL NUMBER: 22-240-783-090
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Martha E. Von Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
Attorney for Plaintiff
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF PHILADELPHIA
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the
above action, sets forth as of the date the praecipe for the writ
of Execution was filed the following information concerning the
real property located at 929 spring Circle, Monroe TWp., PA 17055
1. Name and address of owners(s) or reputed owner(s):
Keith J. Boyer
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
929 Spring Circle
Monroe Twp., PA 17055
2. Name and address of defendant(s) in the judgment:
Keith J. Boyer
929 spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
929 Spring circle
Monroe Twp., PA 17055
3. Name and address of every judgment creditor whose
judgment is a record lien on the real property to be
sold:
None
"
MARTHA E. VON ROSENSTIEL, ESQ.
Attorney at Law
21 South 12th Street, suite 720
Philadelphia, PA 19107
(215) 569-1058
October 8, 1996
TO: Keith J. Boyer and Kimberly K. Boyer
929 Spring circle
Monroe Twp., PA 17055
RE: NOTICE OF SALE OF REAL PROPERTY:
929 spring Circler Monroe Twp., PA 17055
Amount of Judgment: $ 119,658.89
Date of Judgment: October 10, 1996
Court Term and Number: Court of Common Pleas of
Berks County, File No.: 96-4657 CIVIL
Plaintiff: GMAC Mortgage corporation of PA
Defendants: Keith J. Boyer and Kimberly K. Boyer
Dear Keith J. Boyer and Kimberly K. Boyer:
Please be advised that the property and improvements, if
any, located at and known as 929 Spring Circle, Monroe Twp. FA
17055 will be sold by the Sheriff of Cumberland County on March
5, 1996, at 10:00 a.m. in the New Courthouse of Cumberland
county, 2nd Floor, Carlisle, PA 17013.
This property and improvements are being sold pursuant to a
judgment entered as indicated above in favor of the above named
plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of
the aforementioned property are Keith J. Boyer and Kimberly K.
Boyer. !
A schedule of distribution will be filed by he Sheriff on a
date specified by the Sheriff no later than 30 da s after said
sale, and distribution will be made in accordance with the
schedule unless exceptions are filed thereto with'n ten (10) days
after the date of the filing of said schedule. Y u should check
with the Sheriff's Office by callin (717) 240-63 0 to determine
the actual date of the filing of t schedule.
MEVR:amb
.
Martha E. Von Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
., -....
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith J. Boyer and Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
Your house and/or real estate at 929 spring Circle, Monroe
Twp., PA 17055 is scheduled to be sold at Sheriff's Sale on March
5, 1996 at 10:00 a.m. to enforce the court judgment of
$119,658.89 obtained by GMAC Mortgage corporation of PA against
you.
NOTICE OF OWNERS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take IMMEDIATE
action:
1. The sale will be cancelled if you pay to GMAC Mortgage
corporation of PA the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must
pay, you may call (215) 569-1058.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the court to postpone
the sale for good cause.
3. You may also be able to stop the sale through other
legal proceedings.
You may contact an attorney to assert your rights. The
sooner you contact one, the more chance you will have of stopping
the sale. (See notice on page two on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1.
be sold
calling
If the Sheriff's Sale
to the highest bidder.
(215) 569-1058.
is not stopped, your property will
You may find out the bid price by
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the
value of the property.
3. The sale will go through only if
Sheriff the full amount due in the sale.
happened you may call (215) 569-1058.
the buyer pays the
To find out if this has
4. If the amount due from the buyer
Sheriff, you will remain the owner of the
never happened.
is not paid to the
property as if the sale
5. 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.
6. You may be entitled to a share of the money which was
paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff on a date to be
announced by the Sheriff. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the Schedule of Distribution is posted.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
Martha E. Von Rosenstiel Attorney for Plaintiff
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
GMAC MORTGAGE CORPORATION OF COURT OF COMMON PLEAS OF
PA CUMBERLAND COUNTY
3451 HAMMOND AVENUE
WATERLOO, IA 50704 NO. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY
K. BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property
from levy or attachment:
(1) From my real property in my possession which has been
levied upon,
(a) I desire that my $300.00 statutory exemption be set
aside in kind (specify real property to be set
aside in kind):
I request a prompt court hearing to determine the exemption.
Notice of the hearing should be given to me at
(Address)
(Telephone Number)
I verify that the statements made in this Claim for
Exemption 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.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PA 17013
(717) 240-6390
DESCRIPTION
ALL THAT CERTAIN tract or parcel oi land and premises.
SITVA TE. lying and being in the Township oi Monroe in the County oi Cumberland and
Co=onwealth oi Pennsylvania. more panicularly described as iollows:
BEGINNING at an iron pin on the Northern line oi Spring Circle. said pin being at the dividing line
between Lots Nos. 93 and 94 on the hereinafter mentioned Plan of Lots: thence along said dividing
line North 20 degrees 02 minutes 32 seconds West. one hundred fifty.-five and fifty-six hundredths
(155.56) feet to an iron pin: thence North 77 degrees 45 minutes 00 seconds East. one hundred
twelve and sixty-three hundredths (112.63) feet to an iron pin: thence along part of the Western line
of Lot No. 96 and along all of the Western line of Lot No. 95, South 12 degrees 15 minutes 00
seconds East. one hundred fifty (150) feet to a hub on the Northern line oi Spring Circle: thence
continuing along the Northern line of Spring Circle South 77 degrees 45 minutes 00 seconds West.
seventy-five (75) feet to a point: thence continuing along the Northern line of Spnng Circle on a
curve to the left having a radius of one hundred twenty-live (125) feet, an arc length oi seventeen
(17) feet. to an iron pin. the place of beginning.
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens. said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22. Page 135.
HAVING THEREON ERECTED a brick and aluminum bi-Ievel dwelling with integral garage. said
premises being known as and numbered 929 Spring Circle. Mechanicsburg. Pennsylvania.
TAX PARCEL NUMBER: 22-240-783-090
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:':l::.i.:lt:.::
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3:.L;C :10RTGAGE CORPC?.AT:::::: OF
c::t:RT ')f :::.!!10:1 ::LEnS '..J:
C:""":'!9ER~:~ ccC':r:"!
:~51 HAl1MotlD AVENUE
\'iATERLOO, IA 5070~
:ro. 96-0.;657 C:.;:L
v.
~:Z:TH J. BOYER and ::::.!3EP.::L
:--. BOYER, h/w
~ 21 PARK DR!'lE
C.~LISLE, PA 1701:
-^.
Kei th J. and :\i::lber ~ " K. Boyer
421 Park Drive
carlisle, PA :7012
Jate of ~rotice: Sep":ember 26, :996
:~PORTANT NOTICE
'LOU ARE I:I DEFAUL7 3ECA~SE ',ot: 2..'\''''E ?~.ILED ':"0 ENTER ;,
~'iRITTEN nPPEARANC=: ?ERSC::ALL~ SR 3"[ .;T~CP":;EY r-.ND ?ILE ::r ~'iRITI:rG
;'iI"!H THE COt:RT 'LOtJR JEFE::SES ,:R OBJECT::::::S TO T:!E CL;I:,!S SET
"ORTH AGAIlIST YOU. L'lILS:SS 'lOU ;".CT ;iITHI:I ::EN DAYS FRO:1 THE DATE
OF THIS ::OTICE, A J~DG:-!E::T :'!A'l 3E S::ITERED ,:'GAI:1ST 'LOU ;iITHOUT .;
2EARING AND 'lOU HAY :'OSE ',OUR ??OPERT'L OR OTHER ::.IPORT.;lIT RIGHTS.
',OU SHOULD TAKE TH:S :10:-:::::: :-0 ,:, :-':';:'lER ,:.:: ONCE. IF ',au CO :IOT
:L;VE A u"WYER OR C.:.:INOT .:.FFORD elE, CO TO OR TELEPHOlIE THE
FOLLOIvWG OFFICE TO FI:ro OUT l'inERE ',OU CA.:l GET I.EGAL HELP:
4th
C:::RT ,;O:.II:rISTP.AT':'2.
Floor, :~rnberl3nd Ccun~y~Cour~~ouse
)13 I,
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~ec"vlel Fktanha E. VonRosenstiel. ESQuire
Suite 720
21 C~'""tI'l1Ztll :J1,...~1
Philaaelphia. PA 19107
Affixl" here In stamos
or mellr post8C1e ana
post malic lnaulre 01
Postma.tar lor current
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5, PO TAL SERVICE CE TIFICATE OF MAILING
~y BE USED FOR DOMESTIC AND INTEFlN....TlON....L MAIL. DOES NOT
OVIOE FOR INSUR....NCE-POSTMASTER
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for Plaint:'::
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In. ptlC. 01 orOlnalV m'll .Oelr....o to:
Keith J. Boyer and
Kimberly K. BO~Q~
421 Park Drive
Carlisle, PA 17013
PRAECIPE FOR WRIT OF EXECUTION.-{MCRTGAGE FORECLOSUREj
P.R.c.P. 3180-3183 & 32';6
GMAC Mortgage Corporation of PA
IN THE COURT OF CO:'.IMON PI.EA.S OF
CU:illERLAND COUNTY, PENNSYLVANIA
C~7il Accio~ - ~~ecuti=n
96-4657 CIVIL
:-ro
,,.
Keith J. Boyer and _ Ki~berly_.:<_,-_
J"udgt. :-ro_
Boy~s...!:!.. w
PRACEIPE FOR WRIT OF EXEcrTION
(}!ORTGAGE FORECLOSURE)
T~ tb.~ P:-cth~!!at.lI.!"T
Issue writ or e.:tecution in the above JJl3.tter:
.-\..mount Due
S 125 lRe, R5
Interest from 05/05/97
$_
__ and Costs.
:-rote: PI<=le iD111i.W. deodption ai Property.
___-1-
i .J.t'..orney j";th.. P!a.'ntiff (;j-------
Mm:tha E. Von HosenstieJ. '"( 12"
, ..2 ( ;Sgdli. /2 It 01., v~. U
p0-/J<...- PA Fi(Ol
2 ()-. .j6Q - (()j!r
.. -'....
"-
....
.'
.)
DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises.
SITUATE, lying and being in the Township of Monroe in the County of Cumberland and
Co=onwealth of Pennsylvania, more panicularly described as follows:
BEGINNING at an iron pin on the Northern line of Spring Circle, said pin being at the dividing line
between Lots Nos. 93 and 94 on the hereinafter mentioned Plan of Lots; thence along said dividing
line North 20 degrees 02 minutes 32 seconds West, one hundred fift-I.-five and fifty-six hundredths
(155.56) feet to an iron pin; thence North 77 degrees 45 minutes 00 seconds East, one hundred
twelve and sixty-three hundredths (112.63) feet to an iron pin; thence along part of the Western line
of Lot No. 96 and along all of the Western line of Lot No, 95, South 12 degrees 15 minutes 00
seconds East. one hundred fifty (150) feet to a hub on the Northern line of Spring Circle; thence
continuing along the Northern line of Spring Circle South 77 degrees 45 minutes 00 seconds West,
seventy-five (75) feet to a point; thence continuing along the Northern line of Spring Circle on a
curve to the left having a radius of one hundred twenty-five (125) feet, an arc length of seventeen
(17) feet. to an iron pin, the place of beginning.
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens, said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22, Page 135.
HAVING THEREON ERECTED a brick and aluminum bi-Ievel dwelling with integral garage, said
premises being known as and numbered 929 Spring Circle, Mechanicsburg, Pennsylvania,
TAX PARCEL NUMBER: 22-240-783-090
r
.
Martha E. Von Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF PHILADELPHIA
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the
above action, sets forth as of the date the praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 929 Spring circle, Monroe Twp., PA 17055
1. Name and address of owners(s) or reputed owner(s):
Keith J. Boyer
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
2. Name and address of defendant(s) in the judgment:
Keith J. Boyer
929 spring CirCle
Monroe Twp., PA 17055
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
3. Name and address of every judgment creditor whose
judgment is a record lien on the real property to be
sold:
MARTHA E. VON ROSENSTIEL, ESQ.
Attorney at Law
21 South 12th street, Suite 720
Philadelphia, PA 19107
(215) 569-1058
May 2, 1997
TO: Keith J. Boyer
929 Spring circle
Monroe Twp., PA 17055
and
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
929 Spring Circle, Monroe Twp., PA 17055
Amount of Judgment: $ 125,386.85
Date of Judgment: May 5, 1997
Court Term and Number: Court of Common Pleas of
Cumberland County, File No.: 96-4657 CIVIL
Plaintiff: GMAC Mortgage Corporation
Defendants: Keith J. Boyer and Kimberly K. Boyer
Dear Keith J. Boyer and Kimberly K. Boyer:
Please be advised that the property and improvements, if
any, located at and known as 929 Spring Circle, Monroe Twp. PA
17055 will be sold by the Sheriff of Cumberland County on
September 3, 1997, at 10:00 a.m. in the New Courthouse of
Cumberland County, Community Hearing Room, 2nd Floor, Carlisle,
PA 17013.
This property and improvements are being sold pursuant to a
judgment entered as indicated above in favor of the above named
plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of
the aforementioned property are Keith J. Boyer and Kimberly K.
Boyer.
A schedule of distribution will be filed by the Sheriff on a
date specified by the Sheriff no later than 30 day after said
sale, and distribution will be made in accordance ith the
schedule unless exceptions are filed thereto with' ten (10) days
after the date of the filing of said schedule. Y u should check
with the Sheriff's Office by calling (717) 240-63 0 to determine
the actual date of the filing of th schedule.
ly yours,
Ma tha E. Von Rosenstiel
MEVR:amb
Martha E. Von Rosenstiel Attorney for Plaintiff
21 South 12th street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
GMAC MORTGAGE CORPORATION OF COURT OF COMMON PLEAS OF
PA CUMBERLAND COUNTY
3451 HAMMOND AVENUE
WATERLOO, IA 50704 NO. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Keith J. Boyer and
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
421 Park Drive
carlisle, PA 17013
Your house and/or real estate at 929 spring Circle, Monroe
Twp., PA 17055 is scheduled to be sold at Sheriff's Sale on
September 3, 1997 at 10:00 a.m. to enforce the court jUdgment of
$125,386.85 obtained by GMAC Mortgage Corporation against you.
NOTICE OF OWNERS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take IMMEDIATE
action:
1. The sale will be cancelled if you pay to GMAC Mortgage
Corporation the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay, you may
call (215) 569-1058.
2. You may be able to stop the sale by filing a petition
aSking the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to postpone
the sale for good cause.
3. You may also be able to stop the sale through other
legal proceedings.
You may contact an attorney to assert your rights. The
sooner you contact one, the more chance you will have of stopping
the sale. (See notice on page two on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU MAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
is not stopped, your property will
You may find out the bid price by
1.
be sold
calling
2. YoU may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the
value of the property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened you may call (215) 569-1058.
If the Sheriff's Sale
to the highest bidder.
(215) 569-1058.
4. If the amount due from the buyer is not paid to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have 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.
6. You may be entitled to a share of the money which was
paid for your house. A schedule of distribution of the money bid
for your house will be filed by the Sheriff on a date to be
announced by the Sheriff. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the Schedule of Distribution is posted.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
yOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR cANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR
4th Floor, cumberland county courthouse
carlisle, PA 17013
(717) 240-6200
Martha E. Von Rosenstiel Attorney for Plaintiff
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
GMAC MORTGAGE CORPORATION OF COURT OF COMMON PLEAS OF
PA CUMBERLAND COUNTY
3451 HAMMOND AVENUE
WATERLOO, IA 50704 NO. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property
from levy or attachment:
(1) From my real property in my possession which has been
levied upon,
(a) I desire that my $300.00 statutory exemption be set
aside in kind (specify real property to be set
aside in kind):
I request a prompt court hearing to determine the exemption.
Notice of the hearing should be given to me at
(Address)
(Telephone Number)
I verify that the statements made in this Claim for
Exemption 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.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PA 17013
(717) 240-6390
... -...~.
DESCRIP110N
All- THAT CERTAh'l tract or parcel of land and premises.
SITUATE, lying and being in the Township of Monroe in the County of Cumberland and
Commonwealth of Pennsylvania. more panicularly described as follows:
BEGINNING at an iron pin on the Northern line of Spring Circle. said pin being at the dividing line
between Lots Nos. 93 and 94 on the hereinafter mentioned Plan of Lots; thence along said dividing
line Nonh 20 degrees 02 minutes 32 seconds West. one hundred fifty,-five and fifty-six hundredths
(155.56) feet to an iron pin; thence North 77 degrees 45 minutes 00 seconds East. one hundred
twelv.e and sixty-three hundredths (112.63) feet to an iron pin; thence along part of the Western line
of Lot No. 96 and along all of the Western line of Lot No. 95. South 12 degrees 15 minutes 00
seconds East, one hundred fifty (150) feet to a hub on the Northern line of Spring Circle; thence
continuing along the Northern line of Spring Circle South 77 degrees 45 minutes 00 Seconds West.
seventy-five (75) feet to a point; thence continuing along the Northern line of Spring Circle on a
curve to the left having a radius of one hundred twenty-five (125) feet, an arc length of seventeen
(17) feet, to an iron pin. the place of beginning.
BEING Lot No. 94 on Plan No.9 of Trindle Spring Gardens. said plan being recorded in the
Cumberland County Recorder's Office in Plan Book 22. Page 135.
HAVING THEREON ERECTED a brick and aluminum bi-level dwelling with integral garage, said
premises being known as and numbered 929 Spring Circle. Mechanicsburg, Pennsylvania.
TAX PARCEL NUMBER: 22-240-783-090
Martha E. Von Rosenstiel Attorney for Plaintiff
21 South 12th street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney I.D. #52634
GMAC MORTGAGE CORPORATION OF COURT OF COMMON PLEAS OF
PA CUMBERLAND COUNTY
3451 HAMMOND AVENUE
WATERLOO, IA 50704 NO. 96-4657 CIVIL
v.
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
CERTIFICATION
I hereby certify that I am the attorney of record for the
plaintiff in this action against real property, and further
certify that this property is:
(XX) FHA - Tenant occupied or Vacant
( Commercial
( ) As a result of a Complaint in Assumpsit
( That the plaintiff has complied in all respects
with section 403 of the Mortgage Assistance Act
including but not limited to
(a) Service of notice on defendant(s)
(b) Expiration of 30 days since the service of
the notice
(c) Defendant(s) failure to request or appear
at meeting with mortgagee ox' Co sumer Credit
Counselling Agency
(d) Defendant(s) failure to file a plication with
the Homeowners Emergency Assis ance Program
I further agree to indemnify
for any false statement given he
less the Sheriff
artha E. Von Rosenstiel
ttorney for Plaintiff
'f
GC Mortgage Corporation of Pa.
vs
Kcith J. Boyer, Kimberly K. Boyer
In the Court of Common Picas of
Cumberland County, Pennsylvania
Writ No. 96-4657 Civil
Weslcy Cook, Deputy Sherin~ who being duly sworn according to law, says on June 30, 1997
at3:51 o'clock P.M.. E.D.S:r.. he posted the property of Keith J. Boyer and Kimberly K. Boyer
at 939 Spring Circle, Meehanicsburg, Cumberland County, Pennsylvania with a copy of Real
Estate Writ, Notice Poster and Description according to law.
Brian Barrick, Dcputy Sheriff, who being duly sworn according to law, says on June 4, 1997
at I :49 o'clock P.M., E.D.S.T., he served a true copy of Real Estate Writ, Notice, and
Description, in the above entitled action upon one of the within named defendants, to wit: Keith
J. Boyer by making known unto Kcith J. Boycr at 929 Spring Circle Mcehaneisburg,
Cumberland County, Pennsylvania, its contcnts and at the same time handing to him personally
the said true and attestcd copics of the same.
R. Thomas Klinc, Shcriff, who bcing duly sworn according to law, says he made diligcnt
search and inquiry for one of the within named defendants, to wit: Kimberly K. Boyer but was
unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County,
Pennsylvania to serve the Real Estate Writ, Notice, Postcr and Description according to law.
YORK COUNTY RETURN: NOW: July 11, 1997 at 12:25 o'clock P.M. served the within
Real Estate Writ, Notice, Poster and Description upon Kimberly K. Boyer at 196 Locust Grove
Road, DiIlsburg, Pa., by handing to Kimberly K. Boyer a true and attested copy of the original
Real Estate Writ Notice, Poster and Description and made known to her the contents thereof.
So answers: William Hose, Sheriff.
York County return hereto attached.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served Real
Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed one of
the within named defendants, to wit: Kimberly K. Boyer a notice of the pendency of the action
by certified mail marked DELIVERY ONLY TO ADDRESSEE, to her last known address at
196 Locust Grove Road, Dillsburg, Pa. 17019. This letter was mailed under the date of June 30,
1997 and was receive on July 7, 1997 with return receipt card signed by Kimberly K. Boyer.
Return rcceipt card is hereto attached.
Dawn KclI. Deputy Sheriff, who being duly sworn according to law, says on July 1, 1997 at
12:06 P.M., E.D.S.T., he served a true copy of Real Estate Poster in the above entitled action
upon one of the within named defendants, to wit: Keith.l. Boyer by making known unto Keith J.
Boyer at 929 Spring Circle Mechanicsburg. Cumberland County, Pennsylvania, its contents and
at the same time handing to him personally the said true and attested copies of the same
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that hc served Real
Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed one of
the within namcd defendants, to wit: Keith.l. Boyer a notice of the pendency of the action by
regular mail to his last known address at 929 Spring Circle. Mechanicsburg, Pcnnsylvania 17070.
This lettcr was mailed under the date of July I, 1997 and was never returned to Sherif!"s Ofliee.
R. Thomas Kline, Sheriff. who being duly sworn according to law. says that he served Real
Estate Writ, Notice, Postel and Description in the I<lllowing manner: The SherilTmailcd one of
the within named defendants, to wit: Kimherly K. Boyer a notice of the pendency of the action
by rcgular mail to her last known address at 1% Locust Grove Road, Dillsburg, Pennsylvania
Martha E. Von Rosenstiel
21 South 12th Street
suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
v.
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 96-4657 CIVIL
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF PHILADELPHIA
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the
above action, sets forth as of the date the praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 929 Spring Circle, Monroe Twp., PA 17055
1. Name and address of owners(s) or reputed owner(s) :
Keith J. Boyer
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
2. Name and address of defendant(s) in the judgment:
Keith J. Boyer
929 Spring Circle
Monroe Twp., PA 17055
Kimberly K. Boyer
421 Park Drive
carlisle, PA 17013
3. Name and address of every judgment creditor whose
judgment is a record lien on the real property to be
sold:
None
4. Name and address of the last recorded holder of every
mortgage of record:
None
5. Name and address of every other person who has any
record lien on the property:
None
6. Name and address of every other person who has any
record interest in the property and whose interest may
be affected by the sale:
None
7. Name and address of every other person of whom plaintiff
has knowledge who has any interest in the property which
may be affected by the sale:
None
I verify that the statements made in this a
and correct to the best of my personal knowledge
and belief. I understand that false statements
subject to the penalties of 18 PA C'A' section 4
unsworn falsification to authoriti~.
fidavit are true
or information
ere in are made
04 relating to
/
Martha E. Von Rosenstiel
Atitorney for Plaintiff
!
!
I
,..'
MARTHA E. VON ROSENSTIEL, ESQ.
Attorney at Law
21 South 12th Street, suite 720
Philadelphia, PA 19107
(215) 569-1058
May 2, 1997
TO: Keith J. Boyer
929 spring circle
Monroe Twp., PA 17055
and
Kimberly K. Boyer
421 Park Drive
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
929 spring Circle, Monroe Twp., PA 17055
Amount of Judgment: $ 125,386.85
Date of JUdgment: May 5, 1997
Court Term and Number: Court of Common Pleas of
cumberland County, File No.: 96-4657 CIVIL
Plaintiff: GMAC Mortgage corporation
Defendants: Keith J. Boyer and Kimberly K. Boyer
Dear Keith J. Boyer and Kimberly K. Boyer:
Please be advised that the property and improvements, if
any, located at and known as 929 Spring Circle, Monroe Twp. PA
17055 will be sold by the Sheriff of Cumberland county on
September 3, 1997, at 10:00 a.m. in the New Courthouse of
Cumberland County, community Hearing Room, 2nd Floor, Carlisle,
PA 17013.
This property and improvements are being sold pursuant to a
judgment entered as indicated above in favor of the above named
plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of
the aforementioned property are Keith J. Boyer and Kimberly K.
Boyer.
A schedule of distribution will be filed by the Sheriff on a
date specified by the Sheriff no later than 30 days after said
sale, and distribution will be made in accordance with the
schedule unless exceptions are filed thereto withun ten (10) days
after the date of the filing of said schedule. Y0U should check
with the Sheriff's Office by calling (717) 240-6390 to determine
the actual date of the filing of thr schedule. (
Sincer ly yours,
\
I
I
i
Maritha
!
E. Von Rosenstiel
MEVR: amb
i
I
i
I
i
,
I
Martha E. Von Rosenstiel
21 South 12th Street
Suite 720
Philadelphia, PA 19107
(215) 569-1058
Attorney 1.0. #52634
Attorney for Plaintiff
GMAC MORTGAGE CORPORATION OF
PA
3451 HAMMOND AVENUE
WATERLOO, IA 50704
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
v.
NO. 96-4657 CIVIL
KEITH J. BOYER and KIMBERLY K.
BOYER, h/w
421 PARK DRIVE
CARLISLE, PA 17013
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property
from levy or attachment:
(1) From my real property in my possession which has been
levied upon,
(Address)
(Telephone NUmber)
(a) I desire that my $300.00 statutory exemption be set
aside in kind (specify real property to be set
aside in kind):
I request a prompt court hearing to determine the exemption.
Notice of the hearing should be given to me at
I verify that the statements made in this Claim for
Exemption 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.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PA 17013
(717) 240-6390
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO,96-4657 CIVIL19_
CIVIL ACTION. LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
GMAC Mortgage Corporation of PA
To satisfy the debt, interest and costs due
from Keith J. Boyer, 929 Spring Circle, Monroe Twp., Mechanicsburg
17055 and Kimberly K. Boyer, 421 Park Dr., Carlisle PA 17013.
PLAINTIFF(S)
PA
(1)
at 929
DEFENDANT(S)
Real estate located
PA 17055. (See
You are directed to levy upon the property of the defendant(s) and to sell
Spring Circle, Monroe Township, Mechanicsburg
attached 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 tollows:
and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are 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 ofthe defendant(s) not levied upon an subject to allachment is found in the possession of anyone other
than a named garnishee, you are directed 10 notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due
Interest
Ally's Comm
Ally Paid
Plaintiff Paid
$125,386.85
from 5/5/97
$1.00
%
L.L.
Due Prothy
Other Costs
$208.11
Date:
May 29, 1997
Lawrence E. Welker
by:
Deputy
REQUESTING PARTY:
NameMartha E.VonRosenstiel, Esquire
Address: 21 South 12th St., Ste. 720
Philadelphia PA 19107
Attorney for: Plaintiff
Telephone: (215) 569-1058
Supreme Court 10 No. 52634
.
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In The Court of Common Pleas of Cumberland County, Pennsylvania
CMi\C Mortgage Corporation of Pa.
VS.
Kllllbcrly K. [layer
No.
96-4657 Civil
19
Nnw, .June 27, 199j'.l_, I SHERIFF OF CUMBERLAND COUNTY, P A do hereby deputize the Sheriff of
York County to execute this \Vrit, this deputation being mudc at the request and risk of the Plaintiff.
,"
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~a.<<
r. .......,:..-.:..,,;.
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'0.
Sberiff ofCumberlaod Couoty, Po.
Affidavit of Service
Nnw,
Jlflv 11
19 97 ,lit
12:25
o'clock P.
M, served the
wllhin
Rp~l R~~~~p Wrir
Kimberly K. Boyer
l\Jrd-i("p. Pf"'Ic:::rpr L
n,,:,.cf""ript-ion
upon
at 196 TLY'ust Grove Roan. Dil1shllrc;. PA 1701g
by handing to Ki mhPrl y K Rrypr
IIltested copy of the ori~inlll Real Estate Writ, Notice Poster & Description
her the contents thereof.
a true and
and made known to
So ans""crs,
//~///~(
,"'; L
Sheriff of YORK County, PII.
Scott Tyson, DEPUTY SHERIFF
COSTS
Sworn and subscribed before
SERVICE
MILEAGE
AFFIDA VIT
S 40.77
19.J!l.
, vork. York' County
.1,~,~::-~,.. .'fon Expires April 20, 1996
S 40.77 PAID
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No 587 Aooro,ed Ma, 16 1929
COJIIIol:l:wa.lth ot PeDZl.ylvu.1a, County at Dauphin} ..
hfkhaeJhfarro~ being duly sworn according to low, deposes and says:
That he Is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with Its principal office end 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 Merket
Street, in the City, County and Stete 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 allached herelo is exaclly as printed and pUblished in
their regular andlor Sunday and Metro editions/issues which appeared on the 22nd and 29th days of July and the 5th
day(s) of August 1997.
That neither he nor said Company Is interested in the subject mailer of seid printed notice or advertising, and
that all of the allegations of this statament as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and Is vlrtua 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.
COPY OF PUBLICATION
1.1 -lL.UttltC.^,
--_________~____:--------__:'----....c'+-----
Sworn to and subscribed before methl~,',8,th dayj~Ugu~t 1997, A.D.
Now,a! Se'" ,,' / {/'. f- ~k..u-"".e -L (
T~;r"~b~~~~~~!~~~ ~ tto"tary PUbllc"---" ---
M, COmlnlSS10n E:rpl/us 6 .. . J 6 1998
slon expires una ,
_.PL~"""""""'~r_
CUMBERLAND COUNlY SHERIFFS OFFICE
COURT HOUSE
CARLISLE, PA. 17013
SA L E #8
Statement or Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached hereto on the
above stated dates. $219.71
Probating same $ 1.00
Total $220.71
Pub1isher's Receipt for Advertising Coot
THE PATRIOT-NEWS CO., publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
THE PATRIOT-NEWS CO.
By....................................................................
/.! [0 rd..'
PROOF OF 1'1'111.1< '\TIO\' OF \'OTH'E
1\ ("II,\IIII':I(L\\I> "\,, .IOl'I(N'\1.
(lIlldn ;\c'l Np, 'iS7. "1'1""I,,'d ,\1;" Ir,. l'le"l. I', I. 17S.1
STATE OF I'ENNSYLV'\I'\L\
COUNTY OF (,1I~IIlERL,\1'\1>
S,\.
Ro~cl' ~1. ~lol'~clllhal, Esquin'. hlilpl' d1' [111' ( 'lilllll,'rl;III\.1 1,;1\\ .Iillll'II:II, ,11 till' (\ Hlllt)'
and Slale afol'l','Iaid, being duly ";WIlnl. ill'L'lll\lillt! 10 1;1\\, dq)( f\,'.... and....;t)'" IIl;I! Ihl.' ('ullllwrlillld
Law J'Hlm,,!. a kg,,1 pc'rilldic',d pllhli,I1I'd ill Iii,' Illlr"lI~11 III ('"r1i,iI' ill Ill\' ('''lIll1Y "Ild Slalc'
aforesaid. \Va,"i l'stahlished January:!, 11))2, ;llHl dl',\igllilh'd hy till' ItlL.:IIl'tlul'l,... a,\ tilL' official
legal perioJic:al fill' 11ll' public:alioll IIf "II iI'~"llIolil'l", '"ld l1a,. ,illc'e .r"1l1l'1I'Y 2, 11):;2. beell
regularly i"ut'd \wekly ill tl1c',,,id ('1""11)'. alld II1"tll,,' prillll'd ''''tic:c' III' plll1lic'"tillll "u"dlt'd
hereto is CXi.ll'lly the sal1ll' as \Va.'" prillll'd inlhl' n,'~!lIlilr l'ditiilll" alld j,.."...W,.,... Ill' till' ,...aid
Cumberland Law Journal till tilt' ftlll11willg dall'.\.
viz:
JUIXil,2:;L!\L'Ji(12:1I,I'JlJ7,
Amall! furtl1n de po,,', Il1atl1l' i, "lIll1,,,'ill'd III Inif)' Il1i, ,tatelllC'llt b)' tile ClIlllberland
Law Jllumal, a kgal perilldical IIf gl'Ilt'J",i1c'il'c'ld'lIillll. '"ill that Ill: is I1l1t illlc'I'c','tl'd in thc' subject
matter of the aforesaid 11Otkl' III' adVl'rtisl.'llh.'lll. and \l1al .tll idk'gatitllls inlhl' foregoing
statements as tp time. place illllll'hanll'h,'f' Ill' pllhliL'i1titlll art,' [rul'.
REAL ESTATE SALE NO.8
Writ ~f), ~Jfj-.HiS7 Civil
G:vJAC Mortp:a~l~ Corporatloll of POI.
vs,
Kl'lth d. BOYN and
Kimb('rly K. Boyer
Atty.: Marlha E. Van[{ost'lls11el
DESCf<lP1l0~
ALL THAT CERTAIN tract or par.
ce! of land and premises.
SITIJATE, lying and being In the
Township of Monr()(~ In the County of
Cllmherland and Commonwealth of
Pl:nllsylvanJa, more parUcularly de.
scril)('d as [ollows:
nrWINNING at an Iron pin on tll('
~()rllH'rn line of Spring Clrclf', said
111111)('ll1gal tlwdlvldlnglllH' he{Wl'l:11
Lots Nos, n:~ and n.1 Oil Il1e Il<'rt'lllaf-
l('r IlIt'nllOlwd Plan of Lois: th{'I1C'l'
alollg said dlvlclln,[l; IIrw North 20 dt',
gn'('s 02 minutes 32 s('cCltuls WI'S',
Ollt' hllllcln'd flfty.flw and nfly.stx
hlllldr{'c!tlls (155,Sfil f('('t to alllroll
pill: ,ht'lIU' :";orth 77 degn'('s 45 mlll-
HI('s 00 s('('onds [~ast. 011(' hundn'd
tw('I\'t' and slxty-tiln'e hundredths
(I 12,n:'1 f('('t to an Iron pin: th('net'
nlong part of tll(' W(~stcrn line of Lot
No, mi and along all of the W('st('rll
line of tot No, BS. Snuth 12 d('~n'('s
15 1ll1nutrs 00 seconds I~ast, nile
hllmlrt'd nfty (150j f('e1 to a huh Oil
tJw NortlH'rn line nf Sprln~ elrel(':
thence conllnuln~ f11()n~ the North.
rrn Illw of Sprln~ Circle South 77
clt'~rl'I'~ 1fi mllllllt''-\ 00 s('cntHI" \Vf'!it,
~f'VI'IlI\',lt\'I' (7;,) kf" III :1 p"ln1;
t1WIW''- l'0I111Il11I11~ alollJ!. 1111' :\01111
l'rJ11t11l' ufSJl1'11l1-\ (~In'k OIl a nllVI' If I
IIU' Idl 11;\\'1111-\ a IOldltlS of 0111' hUll
<Ired IWt.llly-flvt, II:.!!)) 1'('1'1, an an'
kllglll of SI'\'f'III1'I'1I (171 1'1'('1, to all
tnm pIll, till" plHn' oj' 1)I'1-\'lIl1ll1g,
BEI!'-:(i Lol Nu,!J.1 olll'l;III1'\O,~' ol
Trllltlh' Spring (iard"lIs, said plan
lwlng n'('lInkfl ill 11\l' ('llllll,I'lldlltl
(~tl1JlII\, Iknllllr'r',-\Cllfln' 111 I'Llll 11.",1,
:.1.:I.,I'.IItI'I:I:1,
II^VI~C" Tllt-:UI':tl~ EW':CTI':11 II
Illllk i111l1 illl111i111l1111111 k\'d,lw,'lllJll~
willi lnl('gral ~ara~", salfl pn'lll\st',.,
!wlng Imown a!i and Illllnht'n'd H20
S]lrlll~Clrdt" :\1t'I'lwlllt'sllllrg, Pc'nl1'
sylv:mla,
TAX I'AHCEI. 1'\llMBEI~; 22-2.1{).
7H:l,OnO.
/// )}141 . '---.,
RIIger'M. Mllrgellthal, Editllr
SWORN TO AND SUBSCRIBED before me this
-.i_day III' AlIGlIST , 1')1)7
~L J__ j'.n.
N'lt::r~
r---~~--~oT;;,:L,S[Al '
I lOts E_ St":l'DER, N.Hm)' ~l\1blk
Corliu. !\tJro, Cun.iarlanJ County, PA-
I M'f C~16~~~.~"~~:'~~~~
,1