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HomeMy WebLinkAbout00-00348 , "-l^ . . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIF1CATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADEL1'HIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION PRINCIPAL RESIDENTIAL MORTGAGE, INe. 711 HIGH STREET DES MOINES, IA 50392-0780 Plaintiff TERM NO. dm -- J4$> ~ v. CUMBERLAND COUNTY mSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATIEMPI'ING TO COLLECf A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN AlTEMPT TO COLLECf A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARUSLE, P A 17013 (717) 249-3166 Loan #: 11683745 i-', ,-, , """, 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 and each month thereafter are due and nnpaid, 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. L , ~ '_'0 J""" - 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1199 through 111100 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 111100 Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged, 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Pair Debt Collection Practices Act, 15 D.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispnte the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 111100 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~~:r; /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff J ALL rHA T CERTAIN lot or piece 01 ground with the i'mprovemcn!s thereon erected, situate in tile 8araUdll 01 Warmle"'sbt~ra. ClJmberkmd eOl/IIly. Ptmnsy!v4nja, houndt1d oM dsscribed in l1~co/fjanc.e wit/} the Amended FJila/ Subdivision PIBff No. 1 entitled "Foxcro(t': prepared by Michael C. O'lIl1gelo. R.S.~ dared August 7. 19.7/. Illst revised on JI./Iy /1 1984 and recorded in tbe Of/ice of rhe Recorder of Deeds in Imd for Cumbe"r-/8nd County in Plall Book 45. Page 110. ;IS follows: BEGINNING at a POillt ar rhe northw8sferll comar of Lor No_ K~4 set on the dividing line hotween lots /IIos. 1(-4 and K.3 where siJid divirIJi).!1 DnlJ JiJferseCTs JIIIltJJ Ilt:rB of knd desigllated as P.H.O.A. 1I!i- thenco along F.H.O.A. 115. North 61 degrees 49 minut/:s 47 seconds East, 8 dIstance of 24 feel to the dividing lins between lols II/os. /(.4 Hnd K.5; I/Jilf}f:e DIone said diviiilnl/ fine Bnd passing through a pil/'tilion wail South 28 degrcl1s 10 mil/utes 13 seconds East, (J di$lance of sa feet to line of Lot No, J-B: thence akmg lots. /liDS. J-6 Md J-5. Sour/J 51 degrees 48 mlnJJles 47 seconds WesT, 8 distance of 24 fB~t to the dividing line between Lots Nos. K-4 8m! K-3; thence along S6;(/ dhdding lille and P6ssitrU through a partition wall. North 28 degrees 1 D minutes 13 :ser-onds West, a distance of sa feet to ;J po/ill, the place of BEG/NIIING. O-EINlJ lor No. K.4 on rhe above Plan and blling known iJnd numbered 3S 508 PorslJd Terract.'. 6EJNG rhe S8me premises whkh Fo~Cfoft ToVIIllhouSB Associ,ltCS, a Penm;yIVim;a itil1iled p;1rtflfirshlj,I, by d(J.r~d d<J(ed December 31, 1985 <7nn recorderl in Oeed Book 31-R, Page 114, granted ami conveyed liMn SCiJrhorot.lgb Real E:;r3/e Fund 85-1, a Pennsylvania limited parrncrship, the grantor herein. PREMISES: 508 PORSHA TERRACE VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: 1- IJ -oD ... , . , , FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 D C> 0 c: 0 'Tl <~ -coj s:; --I ::r:. mn'l -;;t.::' rn,]] Z:J] ,- z;;:: '-nrn (fl ". \.0 -r~1'" ~-- i::) :s KO 2_-11. ...,., i!5 :.13 ;,;'0 ::J:: boO ~- 1::-) Pc: l);l 5rn Z ..., ~ -:::> ?i'i '0 -< '.' -,. ;7 I , ~. ~-~ - ~ k FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563-7000 Attorney for Plaintiff PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Cumberland County No. 2000-348-CIVIL Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. 7-~ +~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: February 8, 2000 iillii&r.MIi_lllIi~'''~=!llr'i1ll'' ~ ~ Ildlli ~~. ~"-'''''~;l:'<,!Ii''A'''"='=";' ~~~- - - Jill ,'~. 0 C_l Ci: C C.J n ~: -" LJ C) nj -" 92~li -C-:0 , ., 0.;s~ i:):-==: .:]~~ ;::'0 -0 :;;: --.:..-1' ;~l::< -"... Cd C) --0 N .c:~-fn )>c 0, :z: ';:;' :< w :0 en -( -,. '1 , 1 ""~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY JUSTIN B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY JUSTIN B DEFT. MOVED, LEFT NO FORWARDING, RETURN NOT FOUND AS PER ATTY 2/4/00 Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 6.20 5.00 10.00 .00 39.20 S?~-d'/ R. homas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this .2S~ day of d~ ~ A.D. ~&L a. '"l1.1.1etL, Ak"' Pr t onotary / ,- ~ ^ , -- SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY RICHARD E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY RICHARD E DEFT. MOVED, LEFT NOT FORWARDING, RETURN NOT FOUND AS PER ATTY 2/4/00. Sheriff's Costs: Docketing Service Not Found Return Surcharge So ~ 6.00 .00 5.00 10.00 .00 21.00 R. Ifhomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this dS ~ day of. f~,,;u7 J.()1YO A. D. ~ Q. ~.NJ~-v J~~~ Pr h notary , " ,~ ~ -"'1>10I 100' , SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY DIANE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY DIANE M DEFT. MOVED, LEFT NO FORWARDING WITH P.O., RETURN NOT FOUND AS PER ATTY, 2/4/00. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 So answe ~. /~ R 'Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this d~- day of j~u~'7 clb-v-O A . D . ~ (;\ ~'dti,. ) ,n~"~ - Pr onotary -"~..~ - ~ ~ " ! ,i, , r FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PillLADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 illGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION Plaintiff TERM NO. dJn;-u ---j '-I P ~ v. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT TIllS FIRM IS A DEBT COLLECfORATIEMPIlNG TO COLLECf A DEBT. ANY INFORMATION RECEIVED WIIL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUI'I'CY AND TIllS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECf A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, yon must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or reliH requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~,(i;()pyF'AOM~,' , .. f_.... .-....... " - . ' ... ," ".,'" "''''':-' I hereunto...,.. ,.,' ~of . touat~:!boJ We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN - ~ ' W 'lI'. ~ 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in snch payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. .. , - " '! , I ! :1 I , 6. The following amounts are due on the mortgage: Principal Balance Interest 7/I199 through IIIIOO (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to IIIIOO Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 - 88,057.75 II 'I I , I I I I ,I , I, I -I: I' I 'I I" 1;1 I,! :1 1 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days ofreceipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant( s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the snm of $88,070.20, together with interest from IIIIOO at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff i". .' All. THA T CERTAIN lat or piece 01 grol/nd witll Ihe improvements thereon el'ected. situale in Ihe 8oToua,h 0/ WormlevsbUTo Cumberll1nd CoUnty, Pannsylllsnia, bounded and dsscl'ibed in accordance witll (he Amend.gJi Fii}iJ/ Suhdivision PJIJI1 No" J entitJciI "'Poxr:.rolt': prepped by MlJ;hsIel C. D'Al1gel~ n.s... dared August 7. 1571. Inst revised on July Il, 1984 cmd recorded in tile Office of (he Recorder of Deeds in and fnr Cumbe_dtJnd County in Plan Book 45, Page 110. .1S follows: BEGINNING at 11 pOlil1 ar the nOrrhw8stem comor of lot No. K-4 set 011 tile dividing line bOtWtf/!11 lots Nos. /(.4 and /(.3 where said dividing line nlfers8crs with 11"11 of land dcsf!1l1ared 3S PoN.O.A. #5; tllenco along F.H.O./t 115. North 01 degrees 49 minutes 47 seconds East. a distance of 24 feet (a the dillJt:fing Ilns between lots Nos. K.4 and K.5; thence along said t1t-"'idiiJgline I/nrl passing (IJrolJgl1 s parrition wall, South 28 degrees 10 millutes 13 seconds East. i/ distance I1f 90 feer to line of lor No. J.6: thence along Lors. Nos. J.6 nnd J-5. Sourn 61 degrees 49 m/rl1lfDs 47 seconds Wesr. 11 diS[am:s uF 24 fset to rhe tlividing ling between Lots 1I/0S'. K.4 {lnd K-3; thence along sqid dividing litle and p~ssil1g through a p8rtition WI/II. Nor(h 28 degrees 10 minutes 13 seconds West, a distsnt:e of 90 feet to ;J poliu. rhe place of BEfJINNING. DE1Na LOl No_ K-4 on fhe iJhove Plan and bein[l known al1d numbered 3S 508 l'arsllt3 Terrace. BEING the :Ui/ne premises which Fo~croft TowlIl/ouse Associates, a Pennsylvania /Iinited p,7rrnlirsIJip. by d(J.r-:d doled DeccmluH 31. 1985 ,1nrf recorded in tJeed 8aok 31.R, Page 114. pramed Bud conveyed linIn Scarhorouglt Real c:m3te Fund 85~1. a Pennsylvania limited partnership. tho gramDr herel"'. PREMISES: 508 PORSHA TERRACE ,'- . A-- ~ , ~'""C VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER ofpRINCIP AL RESIDENTIAL MORTGAGE, INe. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: 1- u -on , . ~ ,"l'.?~_ -.-:r;--. 't/; l~ '1: /\-'i), S t'; N 3d i c", ; ,- "I'",,~ , \: 00. HV 611 b OZ IIVf ~;~'I ~~"'':V ~~ ;'_i~ij';;;",_o . 'f ~,:.....:~ni[13 .:HiuJH~~ j,\ll ~c J:JL:UO r:.'.'" FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 , 1 ,'" , j ".",'J 1::;';;11 f'!::!""" ~l~ ~ "' ,-, " ,J . .~ ,~~ ' I ,,-'>>' is' 1 ~ ,-" ", . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PlAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM .-:J H-rJ ,~,] 'tttJ NO. ~\; <r '~~ v. CUMBERLAND COUNfY mSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTORATIEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if yon fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to yon. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNfY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 TRUe ';, ' ' , ,(717) 249-3166 II r t.OPY FROu ~ .. ~ WhereQf, I here ulIt/). '...,falIIIlIIJ '"' of I Cw CarlIsle Illo ~ :J.P-tV We hereby certif>J the within to be a true and corree! cOP'! of tho orlg!n~,d W8d of rocord FEnr:;I~~f,~'~ "']\'1"\ 1:1'-'-,," ^,M '-'...... .n..;'""'tl,-, I"'t "........ -, "t:~~-Jo'il'~ , .,.,. , .-1 ., ~, .~ 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: mSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, execnted and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 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. '~ . - '-" -~;~.-:1 , ! ~,' ,- . 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1199 through 111100 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 111100 Cost of Snit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Snbtotal TOTAL 0.00 12.45 12.45 $88,070.20 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 D.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant( s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the snm of $88,070.20, together with interest from 111100 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .. "":,;,,ab_,_~e~ . "~ ~.~;,;;. ..... 0' AU. THA T C~RrAIIV lot or piece of ground with (he improvements chereon eJ'ecreti situate in the 811J"Du{!11 of Wormlevshl.lrQ. Cumberkmd CDIJI/IJ', PCl1nsylvania, Bounded .3ntf descflbed in 8c&ordance with The Amend.'1d Ffilal Subdl-vision PIBn /Vo. 1 entitled "Foxr;roft'~ prepared by Michael C. O-Angelo, fl.S.~ dated August 7. 1971, Inst revised on July 17. 1984 and recorded in tile Office of rhe Recorder of Deeds ;n and tfir CumbedlJnd Caunrr /n Plan Sook 46; Page' fa.. as {al/ows: BEGINNING Dr a poi/It ar rha norrhwsstem CQmor 01 lot No. K-4 set 0'1 the dlviding line hotw(iiNl l.olS Nu.'.', /(.4 iInd K.3 where said dividlilg /Ins ,iltersecrs with/inR of land tlc3;glJared JS r:,J.J.O.A. 115; tlJencD along F.H.O.I~. 115. North 61 degrcos 49 minutes 47 secOJlds EDst~ B disti!Jnce af 24 leer to rhe dividing line between tot: /r/os. K.4 <fad K-5.: tlleflee %17g said dividing line Hnd passing thravgn <I pe/"tltiap wO'JI, Saulll 28 deqrec.J- 10 mil/utes 13 secand.$ EasT. {J distance of 90 feet ta line of Lot No. J.6..' thence along Lots. /lias. J-6 ..md J-5. SOUTh 51 degrees 48 mlnlltcs 47' seconds Wesr. /1 distance of 24 leet to the dividing /iJ78 between Lots Nos. K-oj 6nd K-3; thence along slJid dividing lilJe and pBssil1g through a iJ8rri/lon wall. Norrh 28 degrees 10 mInutes 13 scr:onds Wc.rr, a distance of 90 leer ro ;I pOli1l~ the place of BEGINNING. bEING Lol NQ. K-4 on the above Plan and bfJing known al1d numbered 3S 508 ':'arslJa Terrace_ BEING the ::ame premises which Fa~crolt TowlIllause ASSOC':1rIIS, a PennsylvalllJ flimled p,1rt/U.'rsIJltl. by der-:d dated December 31~ 1985;md recorded in Oeed Book :J1-R, Page 114. gr<Jnred 1I11lJ conveyed unta Scarooro/./!JIJ Real ESI,3/e Fund 85- J~ II PennsylvaJ1ia limited parrners!Jip. tlIe grantor herein. PREMISES: 508 PORSHA TERRACE ~. - ,- "., _ '. -'1..'", ,-;',_j.-,U-~_ ,"'- ';',6;'''' _ . _ __,,, : -" "I.cj'..",,",__, ",-co' , VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER ofPRlNCIP AL RESIDENTIAL MORTGAGE, INC mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief The undersigned understands that this statement is made subject to the penalties of 18 Pa. CS. Sec. 4904 relating to unsworn falsification to authorities. 'J~~ DATE: 1- II-On ~' ~;;; ~.' ~ . FEDERMAN AND PHELAN Suite 900 Two Penn Canter plaza Philadelphia, FA 19102 t215) 563-7000 tf! ~,I\"/~, l.~ c: ;;"1 to_):j ~ ~ , ! ' I, ! t ,,-", V ]. '_' (. '-";(,,' 00. ~!V OS 6 oZ NVf A.:i;i'<"'J ,,; " .jcii.~no ,L.ili3 HS '0,,1 ;10 301~AO ,I ~ ~ fiij ~' /r;;}j ,'--'~--'~ c.'; p ,,~_ I~.,.,;,~" - " -~: FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATIORNEY FOR PLAlNTIFF COURT OF COMMON PLEAS CML DMSION PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 Plaintiff TERM NO. ~~.3~; ~~ v. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION . LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECfORAlTEMPIlNG TO COLLECf A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AlTEMPT TO COLLECf A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 TRUE Cl.'OPY ,~&. Rf()(:)Ro, ' It T........... ' 'nvtIIII ... -,....., WhenIot. j hete unto.__ , of ., Carflate. fIl. , '~ frlJl We hereby certify the within to be a true and correct copy of the original med of record FEDERMAN AND PHELAN '., ~; - -.;~- ,',1 "i',.. .,_10: IlKJ 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 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. - ,',,~" '''-';''~''',~,'" _', ,<-,~",-", ""'~__:.__:J__ ~,-" .",~-- .;'I^'-i,~"-- "' 6. The following amonnts are due on the mortgage: Principal Balance Interest 7/1/99 through 1/1/00 (Per Diem $15.44) Attorney's Fees Cnmulative Late Charges 9/29/97 to 1/1/00 Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal TOTAL 0.00 12.45 12.45 $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 D.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispnte the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 1/1/00 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -'-.' ALL THA T CERTAIN lot or piec8 of grol/nd with the i'mprovemcnts thereon e}'Bereft sifll3le in the 8nrDUl1/1 01 Wormlevsburo Cumber/{1nd COU/1ty, Pennsylvania, bounded and described in accordance with the Anltmd.'i1d FtiJal Subdivision PI8n No.1 entitled "Foxcroft'~ prepared by Mlr.hael C. O"Angelo. fl.S_. dated August 7. 1971. l;Jst revised on July 17. 1984 and recorded In tile Office of rhe RecordsI' of Oeed$ in and for Cumbe,,/tmd Counr;- /n Plan Bonk 46. Page lla. ."1S fa/lows: BEGINNING ar 8 pOliti at the northwestern comor of Lor No. 1(-4 set 0/1 the dividing line botWtlBII lots Nu:.'" t.".4 and K.S wlrere said divitililO linll/iltersecrs wjllllriJa of land desig/1ated as t:.H.O.A, 115;< {/,encq along F.H.O_,~. #5, North 61 degrees 49 minutos 47 seconds East. a distance of 24 feel ta the dividing lins be/ween lot~ Nos. 1(.4 and K.S.. tiM/Ice along said divining/ine Hnd passing through 8 pa.'tltiOI7 wall, SOUl/} 28 degrees 10 millutcs 13 seconds EiJ~r, 1/ distance of 90 feet to line of lot No, J.~. thence along LDts. NO$. J~6 .-md J~5. Sourh 61 degrees 49 mlnlltcs 47 seconds We.:rr, B distancB of 24 fset to the dividing liJ7s between LoIs Nos. K.4 spd K.3; thence along said dividing 1/;Je and passing through iJ Pi1rtitian WillI. North 28 degrees 10 n,;nutcs 13 sur-onds West. if distance of 90 feet to {I PO/ill. the place of BEGINNING. BEING Lor No. K.4 On the above Plan and being known aod numbered <IS 508 l'orsl1d Terrace. BEING the S8me premises whlch Fo.(craft Townhouse Assod,7tCS, 3 PennsYlvania limited pi1rtnl1rshill. bv dMd daled O(!Cl1mQer 3!. !gaS ,7nd recorded Irr Oeed Book .3!.R, Page! 14. griJnr,~d amI cOIT/rcyed (11T(tl SCiJrhorough Real f::fate Fund 85.1. a Pennsvlvama limited partnership. fhe grantor herein. PREMISES: 508 PORSHA TERRACE "', ," ,,~, , ^ '>"U", "" ,-" :..-:,--,J,.t ' .",. "", .':,~", ,':,,~,l.:.:.~, , VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER ofPRlNCIPAL RESIDENTIAL MORTGAGE, INe. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. e.S. Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: 1- U -oD , '" V!HV/\ . c : I ~J:-'j (J Jr._ . ::l--r ,'. ''..'1"", ",1 I ",I 00. Htr OS G 02 NVf A.i!< <,'. . ':,--.;Ji'tn~ .:JdnUHS 3Hl .DO 3nl.:LiO FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19"102 (?IS) 563-7000 ~. lriill JiiJ .~ -.'", H' , . ',,'- FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PIDLADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 IDGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CML DIVISION Plaintiff TERM NO. ~o--o-o - .l4P ~l v. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant(s) CIVlLACTlON. LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATtEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATtEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set fortb against you. You are warned tbat if you fail to do so tbe case may proceed without you and a judgment may be entered against you by tbe court witbout further notice for any money claimed in the Complaint or for any otber claim or relief requested by tbe Plaintiff. You may lose money or property or otber rigbts important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 We hereby certify tile '''I'H\;n !'~ L. , V(f [,.. v vi;) ,:1 ~rue ;:nd C0O<:'!.'lC. (~(""f ..+ " "d,~ 11 ~""'~.J;. e,l In8 originl:1ll'ilccl of mcord F"-,, -,.." t::ul:;u"""~'<l1AN AND PHEU~J\J ^,'." " .' '.' '1--'- ~,,__. ~, ~ 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known addressees) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 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. ^h "- < ,-""--"",,.. ""t'.. ,- , ~~ I . .' 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1199 through 1/1100 (per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 111100 Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days ofreceipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant( s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PlAINTIFF demands an in ~ Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 111100 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ",,^",,,' .,,_. ~-, ""' " ,'~ ,~.. ,~ ~. ~ -, '- "" -~"-- All TIM r CERTAIN lot or piece Df ground with {ne i'mprovemcnts tbereon eteered. situate i'n tl/8 80rDlJer" 01 WDrmlevshurq. Cumber/6nt/ COUIlfy,. FCnn$ylv6fl18, uO(/lIdcu and tf~sr:tilJeri in accardi/nee witll the 4mendsd Pii,al Subdivision f'ltm No.1 enrft!l!d NFoxt:roft'~ prep6/11r1 by Michael C. O'Angelo. R.S.~ dared August 7. 19.71, Insr n!Ylsed OfT July!? 1984 <1nd recorded in (lie Office of rlJll Recordfll' of Oeeds in and fl1r Cumhedend Cal/nry in Plan Sonk 46, Page 11a. .1S Fallows: BEGINNING /1r 11 pOilU at rhe nor/hwesferll l:omor 0/ Lar ND. /(-4 set an tile dividing line bl.1tw~~/' !.ots Nu~'. K.4.f1nd K.:J where suit! divitililg Jiml iNtersects witll lioN of /and dc.rigmlt~d i3$ AN./J.A. 115; tllenea ;HOl1g F.H.O..4_ //5. Nortll 61 deQrus 49 minlltbs 47 secoNds East~ 8 dlst;;m:e 0124 feet to thle dividing line be/ween !.ots Nos. K.4 and K.5; tllence along saia dividing line I/nd passing through a pa!'titian wall, Sou!11 28 degrees 1001lill.Jtcs 13 seconds tasr. 6 distance of 90 feet to/ine of L1)t No. J.6.: thence 11/011d lots. /IIos_ J.6 ,7m! .J-s' Sourh 51 degrees 48 mll7Jlfcs 47 seconds Wesr, 8 distancs Df 24 fact 10 the diyjdinglo18 be/ween 10ls Nos. K-4 8nd 1(-3; thence along 3sir./ dividing lilJS and pBssillg through a partition wall. North 28 degrees 1 a minutes 13 secDnds West. a distance of 90 leer to II pOIiJf. 1M place of BEG/IIP/NG. PEING lol No. K-4 on ,he iJbove PIon and being known and numbered JS 508 l'orsha rerfiJCD. BEING the same premises which FoxC/ofr Townhouse Assor:/~7rcs. a FennsylVimia limited Piufnrtrslu'p. by d/1.J-~d villed DCJ;cmher J1, 1985 .7mf recorded il7 Oeed Book 3J-R, Page J 14" granted H{Jll cCJl1l1'ayed unro SC/:1ruoroJJg), Real t.':f3te Fund 85-]. a PennsylvaJJia limitod partnership. the granrar herein. PREMISES: 508 PORSHA TERRACE 1"- . -, ~". ,t ,~,>',,- -~ VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 'J~~ DATE: I-II-OD l ..:. FEDERMAN AND PHELAN Suite 900 TWCl Penn Center Plaza Philadelphia, P A 19102 (215) 563.7000 @aj) -\ !~U, ~'~-:1 ~l:;;z~ ~ """"""""""--' VIN'ii\l t,SN.~~Jd -:j..' c'--,: :",' ~j : ',", . DO. WV os 6 02 1I11r f~ ^; W";,~ ;h' ;L:_~HIHI~ .:ldl'B';:4'HS 3~Jl:10 3;)~;ljO I ~ v;:nl ~~ ~ liV1l ^'.~ "-," ',I ',',' I - ; ':"_i--,~~"'",,-~~,,,,, '^": . ,"',~' ""'c,' .>; .,,," -.t ',. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO.~hH.) ~.J4J> ~L v. CUMBERLAND COUNTY mSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION. LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATIEMPi' TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A liEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against yon by the conrt without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 TRUE OOPY FROM AEOORD 111 ~ wtIeroof, I here unto lit ftlY 11IIIII8 .. - of, d Court Car1"'~C~ We hereby certify the within to be n true and correct copy 01 tilo orig:nal Elod oT IOGord FEDt=:RMAN AND PH::ELAf\P\ <"~-~"~'" ~"~ ,~",'k,~,"j,:I_'?c'_" "';, ",~,<':<~:;, ;;,~I:.:,_ ' 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name( s) and last known address( es) of the Defendant( s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9129197 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest npon said mortgage due 8/1/99 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. '," '~" ',- ':~" ' ":. A:" ,,,-,-,v,,; -'b',~'-_.",'^'c'C - ~ .~IL'::'. , 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1199 through 111100 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 111100 Cost of Snit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 D.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant( s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the snm of $88,070.20, together with interest from 111100 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '"" ..' ALL THA T CERTAIN lot or piece of grovnd witlt (he Improvements thereon ereCTed situate in the 8aroucth at Warmfevsburo. Cumberl8nd Catillty.. Peflflsylv8niB, bounded and ds.rtdbed in Bccordance with the Amena.'iJd F1;.al Subdivision Plen /Va. 1 entitled "Fox/Sroft': prepared by Michael C. D'At1ge(o.. n.s... dated August 7. 1571. lost revised on July 17, 1984 and recorded in the Office 01 rhe Recorder of Oeeds in and for Cumber/and COlmr;, in Plal1 Sank 45, Page l1a. .1$ follows; BEGINNING ar 8 Po,;!t at the l'1orthwestem comor ollar No. K.4 set on the dividing line hetwliell l.OtS Nos. }.;".4 and K.3 where said dividlflJJ fins liltersect3 witllll"Fl of land dcsiflJIared as ~H.O.A. 115; thence along F.H.O.A. liS. North 61 degrees .1./9 minutcs 47 seconds East.. B distance of 24 feet to the dividing line between lots Nos. K.4 and K.S: thellce along salcl dillid/itg line Bnd passing through {1 partition wall, South 28 degrees 10 mil/utes 1:1 seconds East, {J distance of 90 feer to line of lor No. J-6: thenCe 1I1ong Lots. Nos. J.B .,nd J.5, Sourh 61 degrees 49 minl/tes 47 seconds West, B distanr:a of 24 fset to the diJliding lil1l1 hetween Lots Nos. K-4 ODd K-:1: thence along $8id dividing lit/I! and p~ssif1g thraugh a Pluta/on waIf. North 28 degrees 10 minutes 13 $cr;onds West, a distance of 90 leet to ;J pOlill. the place of BEGINNING. PF;/NG Lor No. K.4 an rite ilbove Plan and being known .and numbered JS SOB l~arsl1a Terrac!.'. BEING (he ::ullne premises which Foxcroft Tawt/hol/se ASSOCI:"ltcs, a PennsylvalJio flillited p,7rttwrs!Jip. by d(J.t-~d dated December 31. 1985 ,"lnd recorded in Geed Book 31-R. Page J 14. gran{/~d Hml conveyed limn SCilrhoroug/1 Real Estate FlJnd 85-!. a PeflflsvlviJnia limited parrners!Jip. tilt! grantor herein. PREMISES: 508 PORSHA TERRACE " ',,' i-". , ~ ,'",- , ",,;,,ti.,:;,;,,~';"',l,,~ '" ,",,,,:,:_ 0" C'_ ,,' ."I'L jj';;, , '. VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER ofPRINCIP AL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: l-1I-0D >>-,..,..,,,...,,,,,,,,,"_'- ~ , FEDERMAN AND PHELAN Suite 900 TWQ Penn Center Plaza Ptl\ladelphia, PA 19102 (?15) 563-7000 "., I' \1 \-1 .' '~I.' ," '., 1'1 :l d .. , ,,1 i\..=:I 11 4 --' '~~i'-" ~ "', ~ ' '1 ~1, ~~;. ;,;;;:,.,. ~!~; ~,-<~" '~~ ~ ;il~U;3:M'S ",!hi\. ,0:10 .3""I.JlJli$ ;".i,": ;' ," ".' ,_, "ii~ittt~ ~ GVil E t!!S IiVi.1 CD. iif, tlS 6 Hl tllf . , - . " . " I" , ~ , c" i','-" J 'J'" ' ~ .',. ,'-""","".~' FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, P A 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CML DMSION Plaintiff TERM NO. cXHnJ ~ J I-f f ~~ v. CUMBERLAND COUNfY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION. LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPf TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNfY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 'TRue I;,^~ (717) 249-3166 ..~ -.w'T FROM REOORD _Ibt,,-i~t, 'here~ut,.,_ . .; Cou Catf~ We hereby certify the within to be a true and cermet copy 01 tho original filed of record FEDERMAN AND PI-lELAN " ~ ", 1<, ,,, ,I' , """'.;""cl-"~ cc< .. 0):""., : , ' .~,:~~;~~" 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 7I1 HIGH STREET DES MOINES, IA 50392-0780 2. The name( s) and last known address( es) of the Defendant( s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who islare the mortgagor(s) and real owner(s) of the property hereinafter described. 3. ,On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1199 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. " ," , 0 . I ~,' , -", ',:'l;,,~,""""""'"'' '" :<,,"I~c " 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1/99 through 1/1/00 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 1/1/00 Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal TOTAL 0.00 12.45 12.45 $88,070.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 D.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant( s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 1/1/00 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "' ''1 All. THA T CERTAIN lat or piece of ground with the improvements thereon e}'ected. situate in the 8nroul1f, of WormlevsburQ. Cumber/pnd COUIIly" Pcnnsylwmil1; bounded ilfld dliScribed in accordance witll rhe Amend,9d Frilal Subdi"ision PllJn No. 1 entitled NFoxcroft': prepared by Michael C. O'A17gelo. n.s_. dated August 7. 1571. last revised on July 17. 1984 and recorded in tile Office of rho Recordsr of Oeeds in and fnr CumbedlJPd Counry in Plal1 /Jonk 45. Page lla. .7$ follaws: BEGINNING ar II pOliti <}r rho northwestern comor of lot No_ K~4 set on the dividing line bOtWff811 lors Nus. 1(-4 and K.3 where said dividlilg linq ';ltersBcrs with If'~R of land dC.$igl1ared as F.H.D.A, U5;- tltenr.D along F.H.O.,1.. 115. North 61 degrees 49 minutes 47 secOJlcls East, s distance of 24 feet to the dividing line uetween lot3 Nos. K.4 and K.5: thellce along said dividing line gnd passing through a pi!!'tition lIlIall, Soutlt 28 degrees 10 filii/utes 13 seconds Eilsr. IJ distance of 90 feet ta line of Lot No. J-G: thence illeng Lots. Nos_ J-B Md J~5. Sourh 61 degrees 49 minutt!s 47 seconds Wesr. s distanr:s of 24 feet to the dividi1l!/ liJ78 between Lots Nos. K.4 lIf!d 1<.3: thence along $/1;(/ dhliding 1';18 and passil1g thraugh a parrlt/on WHIt. Noah 28 degrees 10 minutes /3 seconds Wesr, a distance of 90 leel to ., polill. rhe place af BEGINNING. PElNG Lor No. K-4 on rhe above PllIn and being known ill1d numbered liS 508,t:tarsIJ8 Terri1cl.'. BEING the saffle premises which roxcrofr TOWllhousl1 ASSOC';7((!S, a Pennsylvan/a limiled pc7rtnttrsIJIJI. hy d(!.t-~d riated Decl!lI1her 31. 1585 ,7nd recorded in Deed 8l1ok 31-R, Page 114. granted amI convc.ved Urttn SCiJr/Joro/Jgb Real E.'nate Fund 85-1, a Pennsvlv1Joi'a limlfed partnersllip, the yranror herein. PREMISES: 508 PORSHA TERRACE . H In'" ~ ! -oj . ," VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \j~~ DATE: 1-1I-0D . .",.-..,,,,,",,,,' " ~.-_.,." . p,." ~,~~t: " ~"~~"~" ~,.r'.t'U ~~~~:~i C:~~,~ [~'~": V! i~; ~/ \ "') ; (, '_3 ~ 1 3 d . . :! '~.: '1''-' I /~ ~) :", :_:' .,- . , , !OOt~V 'tisS liz ifIVf ",,,,,;, ~'::laE::irfs: '!;l~ .i':,,:""f'l,,!, ~, .J",I;;:j 0.. ""~- FED EHMAN AND PHELAN Suite 900 Two Penn Canter Plaza Philadelphia, PA 19102 (215) 563-7000 .' I . . .. @;i) Inn! !U"O;1 i.;;.;!t,..;V ~$ tnnl y"C "~ ' ',~,' ""',,',,,' ,,' "',' ;':b;",,j' ''''-''''-" SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY JUSTIN B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY JUSTIN B DEFENDANT NO LONGER LIVES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 9.30 5.00 10.00 .00 42.30 .~ . Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this .l.14 day of ~ :2Irvv A.D. 9tt, a~ ~ Pr h notary , 1.[ ." . '., ~,,,'~ ,.\ '-Ie ;;, '" ~ . ~ ", SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY RICHARD E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY RICHARD E DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 6.00 .00 5.00 10.00 .00 21.00 R. Thomas Klin Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me t hi s "l, /,A..f- day of ~ J.AnrO A.D. ~"a.~~ " pr t onotary , &~~" ,-" ",---".' .:1,; ;"',_', ;',;,.",,,".' ,.I"" " SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY DIANE M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, , NOT FOUND , as t8 the within named DEFENDANT , GOURLEY DIANE M DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 6.00 .00 5.00 10.00 .00 21.00 ~ R Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me thi s :1.I.M- day of ~ C)o.vv A.D. ~a ~ ur:"- P 0 honotary , , ,['"C',. 'J..;- '.' . : I " " ~ -< .r- . . ---- FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PlAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. d-.rro-D - J4cP /f'()- L-<..~~ v. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant(s) CIVIL ACTION . LAW MORTGAGE FORECLOSURE NOTICE (") c ~ c: 0 ~c '1 .~: ""0 '- .. C1 :=. " ~"~" / ::.:-..:: c -, :::'; u;:, ~ ~ .- ~~- - ~ - ";;.' C~J -- j; ~ ::-: c: ..' 2~ :::;) 53 ~ -< \ :;) -< PLEASE BE ADVISED THAT TIllS FIRM IS A DEBT COLLECfOR ATIEMPTING TO COLLECf A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCllARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECf A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the conrt your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 F~Ri';;.'\N Aim ;:::-::::,:;JRUE COPY FROM RECORD All OHPJEY nLE CG;lryTestlmonywhereof, I here unto set my hand PLEASE R:::T' H~I\J' and the of said Cou at Carlisle, Pa. -'Vll This Y Loan #, 11683745 We hereby CGI"!;fy the ':l!th~i1 to be n t~uo afld ,1: ''''_1'''\ CCTi'\.:ct CCPY vi i.: ,..;... .. "....rl~fr-"'-d .~,-..... 'f.,' f.o' 't 0.,.", ,'.-.., .......J... ....'.;~ ...,.1..... . -- ,-~ .." AN' ", ::'-'"=LAN Fi::Dt',hr'hA'~ I '!J I 11..- - ry 4 ,~, ,.j '.- . ~" "'I" a~. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 TERM Plaintiff V. NO. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION . LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS F1RM IS A DEBT COLLECfORATIEMPfING TO COLLECf A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECf A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPEBTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 We hereby certify the \;'1+H~:.,.1'." r-,,~. n .}-. '1:\ .....,.... ~, 1.1', .'~~ ,.J"'; L. '.,1...0 ....., IU Loan #: 11683745 Ct:;':' :'1",,;. ,-,..--~., ,-f .:.:..,.,:) ......,.-'......-....'....;.,':/ V. U,"-' C.~-t.,~::-.....,ll'.~'r.."" ,...,(. ["'.-.,..nrd d.l,.." _ ".'-."..... v~ "u~v r: ~ - ,..,...",l.,,,....i ,-,'.:::;\1" ,~ . ~ . ~~~ .L ,.;:. 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known addressees) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in defanlt because monthly payments of principal and interest upon said mortgage due 8/1/99 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. ."" ,I ,I,':, 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1/99 through 1/1/00 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 1/1/00 Cost of Suit and Tille Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant( s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Connsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 1/1/00 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff , ,- . 10.0... " ALL THA T CERTAIN fot or piece crt ground with {he /mprovemcnts thereon el'eered, situate in the .BnrDue" 01 Wormle~sbaro Cumber/Hnd CO(J1t(1'. Prmnsylvt!/nia. oounded dntl dest:ribetl in 8~cordance witll the Amend.9d FJi,a/ Subdivision Pion No.7 entitled "Foxcroft': prepared by Mir.hael C. D'Angelo. R.S.. dated August 7. 15,:'1. t?st rcwsed Dn July 11. '984 and ret:tJrded in IlJe Office 01 rhe Re~D,.dgr 01 Deed.s in $nd 101' Cumbed8nd County in Plan Sook 46. Page " a. as fo/laws: BEGINNING tJr a p,"itt ar rhe norlhwester/1 comor al1.or No. /(-4 set a/I tile dividing line betWtll:111 Lars Nus. 10.".4 and K.3 where saki dividlno lins /ilfersecrs willi J1nR of lt3nd dcsiflJJartul JS r.H.O.A. #5; thent:D along r.H.O./~. 115. North 61 degrees 49 minutes 47 seconds E(Jsl~ II distance 0/24 feel to rhe dividing line between Lots /1/os. K.4 ilnd K.S: the1lce along said cfilfiiJing line qnd passing through /I partition lNall, South 28 degrees 10 nlliu!tcs 13 seconds ~asr. II distance of 90 fsst fllline of l.ot No. J.6;,. /hence along Lots. /Vas. J.6 .'lnti J.5. South 61 degrees 49 nllir1lfos 47 seconds Wesr~ B distance 0' 24 Iset to rite dividing linti bstween Lots Nos. K.4 8mi K$: thent:e along s6i'Q tlividing !ti18 anti pass/lIg t/trough a partition wlJll. Norrh 28 degrees 10 mlnutcS' 13 seconds West, a drstaf1ce of 90 leet to 3 porill. the place of BEGINNING. BEING Lot No. K.4 on rile i:Jbove Plan and being known and f7umbered liS 508 f'arsll,;, Terrace. BEING the same premi!:8S which rQ~croft Townhouse Assac';7/cS, a ?ennsylvaniiJ lirw"ied p,7rtflttrsllip. by dar-'1d dated OcccmlJef 31, 1585 ,.nd recorded in Deed Soak 3J.R. Page 114. grafftlld ilf/U conveyed unftf SCiJrhorol/g/J Real ~:;r3te Fund 85-1. a Pennsvlv311/a limited psrrncrship. tile !fraMor herein. PREMISES: 508 PORSHA TERRACE - " . : .O-.,,~ .-,J ,. ,1"_;. ,..' '~. '. VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER ofPRlNCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true, and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: 1- II-On ,~ ~ ,- "~;.;:--. .~~,;~ (~o~ ' tEj:i = fib'l:lo,' '-; ill ,~:5 \ 'A iRJ i'M' ,'~' > ~^ OFF\CE or iqF ;::\1:~',"i':~r. C~)l!;' _" .': II ';~'-',:.',/ fEll II 3 05 PH '00 '.,.'J DE:.1 i It" , i ~_. "( i" [~ i j.\ .. -q,. '0 ....".. "^' ""-',, 'f" . ;," ~ ,~) ;,: ,-( \ j' ~i, ,_". ~,,' it t~\ ~~;>7~ ,...,,!i:li. ',' '0., ~> .... ,~. '^~~141_:~fr,,~", !~Jl!IJ,",. ""'.".ri.Yi '"__J"';' _ ;,';;);:c~=: .'''''''''<"''' ..~ .;;:;i~~~ ." ,~l.,"'1\,' ";'" .-', ~..:", ,'"' d' ,', < ~, I" "'",,-,;";",,_ or- '" ",. .=--- FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. ~rn-o - .J4? c;:~. v. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE (') c ~ c.:: c::: ~, -~ ;~--- '"1"] " ., ~ :=. , , ~ (=-.. ."- /.:. v; G ., - . :~- . -- ~ ..:;... ~ - - / ;~- -" ; 5> ',' r:-? ::'.1 c: .~. ." 2' :::> -,.' -< 5j , ;:) -~ PLEASE BE ADVISED THAT THIS F1RM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT. ANY INFQRMATlON RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU SAVE PREVIOUSLY RECEIVED A D1SCltARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 F~Mr;;.'\~! Arm ;:::-i=~-,~:rRUE COpy FROM RECORD All OHNEY FiLE CG;j;testllllO!lywliar~of.1 here unto5tt my hand PLEASE "'~-(; 'q " aM th8 seal of said Coo at Carlisle. Pa.~ 11_.u..IJ ThI ~o 2~ tV< Loan #: 11683745 ProthOnotary We hereby CG;-l:fy the '!.L" .J. :-........, .e.~un ~!"\d \;"lr~~~ll LO L..U c...i t.l <r".; C, t ........ .... ...._,~, ~1; ~~~" CGI ivLi. ~V;J'l L,l ", ,'-' ., ,,... -".J ....& fO ..'.....d or::;l;-,2., I~.~~.J 1....1 ....,~....j F-n'-C'i '\'\' A\!D :::-r=L.AN cL/::> ~1'~.1"'\ \j. I. -- ' ,;;-- ., '''-, I ",,,,.' , '~i...~ "'I FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v. NO. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant(s) CIVIL ACTION . LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FlRM IS A DEBT COLLECI"OR ATIEMYI1NG TO COLLECI" A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECI" A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you mnst take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 We hereby certify the 1,~.;H~l.., ~"~, J-,"'< r' .}:-"'~O 1"'1,,,,", \i.. 1." " '~~.1 ,.~....., ...... ,-, 1........ ~~, iU Loan #: 11683745 C,"",,:<,-)(';. -"".._',y -,~ ;:'-1'" ..~.. -..'.J~ '-.;.,_..-' VJ!..i...... t"'I.~!,.~i'"H...l ~':\r~ ....': ...r"'I.... d V.l,I,lo,... /.:,)..... v) !,\;vnr r.:, . .' i ' '~. -. ,1\1 . .. ..,-"',, "'"\'\'-.1" J I .~.._r\J\1 , , ;..' l".'~ < 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known addressees) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 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. j' ~" , ",: ~ ~' 11 , "'",,,1, " < 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1199 through 111100 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 111100 Cost of Snit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12.45 12.45 TOTAL $88,070.20 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant( s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in ~ Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 111100 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,J.." 1__ .~" . AU THA T CERTAIN lot or piecs Dr ground with rhe improvements thereon erecTed, siruate In the .8nrDua/J 01 Wormlevsburo. Cumberlllnd Coultty. Pcnnsy/v.Jni8, bounded and d6St:ribed in eccordance with rhe Amendgd Ftili1/ Subdivision Plan No. 1 enfftled "Foxcraft': prep"red by Michael C. O'Angera. fl.S., dared August 7. 1571. In~r rellised on July 11. 1984 and recDrded in tile Office of rhs RecDrdsr of Oeeds in ami fo,. Cumbe"/and Counr~' //1 Pial} Sonk 45. Page' 10. .;s folfows: BEGINNING at a pal;1l at the northwestern comor 13f Lor No. /(-4 set 0(1 (he dividing line botWt;1!1I lars Nu~'" t,".4 ana' K.3 where said dividlllO lins li,tersecrs witll lilra af Ii/nd desigl1ated 3S ,t:.H.O.A. 115; tl'eflCO alono F.H.O_A_ #5. North 61 degrees 49 minutes 47 secaJlds East, B distance of 24 feet to the dividing/ins lietwesn lals /1/(/$, K.4.md K.5: II/ellce qlong saId di".iding line tH1t1 passing througn " pt1."(l'tion WillI, Soulll 28 degrl1cs 10 mi"urcs 13 s8cDnd~ East. 11 distance af 90 feet to line of Lot ND. J.6: thence I1lcng Lors. Has. J-6 .wd J-5. South 61 degrees 45 mil1/11DS 47 secrmPs We.sr_ 8 diStiJnca Dr 24 lael ID ths dlwiJilJ!/ lins bat ween Lots Nos_ K-4 {Jr,d J(.3; thence along sold dividing IirlS and pBzslJlg thraugh a partition wall. North 28 degrees 10 mInutes 13 seconds West, a di$rllnce of 90 leet to ;I pohrc. rhg place of BEflINNING. BEING loot No. K.4 on rite above Plan and buing known and numbered 11$ 508,00rs114 rerrc1Cl..'. BEING the same premises which Fuzcrofr Towl1hoUSI1.4sS0C,;,tCS. a Pennsvlvania l,il1ileq p,1rtnljrslJip. by dar-~d dated December 31, 1585 Imd recorded in 08~d Saok 3/.R, Page /14, Drunl2d Hml convc.ved unto Scarborough Rtii11 E.~t03te Fund 85-1. iJ PennSvlv.'1l1f"a limired parrnerslup. the grantor herein. PREMISES: 508 PORSHA TERRACE ,"t 'A',' . ,:,1" ...J.J'i',- '. , VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. \j~~ DATE: 1- II-On . '0" ~1 _.J OJ. - - .....!j ~J~ _ -~H~ ~Xn.uFf Ofr\~t: Or ", " ',,'" G\}l r fER \ \ '3 nS Pr\ 'UU or' ';-\',.,',~,~ '; 1 -,,' ;\h \A [C'L'Ai1'-..) I' , ~ F;"}",,. . r 'i1.1 /i/~, \~,,~:", ': .':", ''''''.1/1,'''1'-''', ~.".:" \.. _:.,J.!:i}I!!;J,:fli;-~:: 'i~'P''''~'', lfi!!!f(-.."..L ",~-. :- ~..tj .,,-~-.~..! :~~J :~~ jV,"-,<<; """:~j (. ", _ ~,x.:;,,: , .,-- '-'.-"j' I.., .". , or- .. ----- FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION Plaintiff TERM NO. rAo-D'U - d4P -.. ()- C!A.,~, V. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE n c 0 c: 0 ""'t':; ~..: ..,:: r.-j " ==-~ .,.- ,.:. C ~~ 0 " -' ',' . " ..::.... - ,~ - - ~2..: /-:, -. ,. )> ......' N -, ~1 (:: ' ' ," .-:.: ~ '.' -< c.;;'T , ~ =< PLEASE BE ADVISED THAT THIS fiRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~EC::Rr,c"~1 '.""', '-', .-. .'r.RUE COPY FRO,M RI!:!:'CORD -. ..' .....u..:l.,J -'.-.... "\14 IE; AITa~p~EY mE c'6:Wre5tlmonyWhereof, i here unto set my hand PLEA~E RETJHl\jand the of said Coo at Carlisle. Pa. T day Loan #: 11683745 We hereby cGrt\r; the \!llth~~ to bc n t;uo and :; ,~l~..... ""'.....-...("~ ...._:""y "~I '0 '. ~ i........;r. \...V~J 'oJ r........ . 'J'" rl....$ fo,"'''-d or::::l,2.1 1:.Sd '....; '....,.....it F-=-D' P::'"I: 'IN AND ;::H3.AN 1.-1 0-.'. ..r'\. _,I r^ '" ~ " FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v. NO. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, P A 17055 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS fiRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFlRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,P A 17013 (717) 249-3166 Wo hereby certify the \;..,w~:.., ~"',". b." n 1':-"- '(:.\ ""'7'''' .. '...,. .~~ ..."...... L!. .,l..... ~.Ii.J Loan #, 11683745 CG:';',.~Gi CC;:y ej: til0 (i'~i':i~;'!~"~ ;':'~:xi ;:;r rcc::>rd r.:.. '. ),.,,'. ,.,-' ~.\ .,,, ~ ....\.~ , '.__-rl:.J'J 'u,,.,.l -I.,. .......: .. 1. Plaintiff is PRINCIPAL RESIDENTIAL MORTGAGE, INC. 711 HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known address(es) of the Defendant(s) are: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9/29/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1408, Page 923. By Assignment of Mortgage recorded 10/29/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 560, Page 725. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/99 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. "M . ._1.__ "' " 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1/99 through 1/1/00 (Per Diem $15.44) Attorney's Fees Cumulative Late Charges 9/29/97 to 1/1/00 Cost of Suit and Title Search Subtotal $80,521.15 2,840.96 4,000.00 145.64 550.00 88,057.75 Escrow Credit Deficit Subtotal 0.00 12,45 12.45 TOTAL $88,070.20 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. ~ 1692 et seq. (1977), Defendant( s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $88,070.20, together with interest from 1/1/00 at the rate of $15.44 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff " ~ Ji.~..~,. - , Al/. THA T CERTAIN lot or plec8 0/ ground with (he improvements rherean erecred. situate in file .8aroufIh of Wormfevsbufl1. Cumberlgnd Coumy. PennSy!v8nJa, bounded and dsst:ribed in accordance with fhe Amenriad '";ita/ Subdivision Plan No.1 et1firJcd "FDxcro(t'~ prep{lred by Mlr.hael C. O'Ange/o. fl.S.. dated August 7. !571. Inst revised on July '7. 1984 dnd recorderl in (he Office 01 rllll Record'er 01 Oeeds in and far Cumbef'/end COU!1r}' /n Pia" Sonk 46. Page' 10. as Follows: BEGINNING at 8 po/ill ar rha northwestern comor 01 lor No. K.4 set an tile dill/ding line botwlit/1I lors Nu:.'. 1(.4 dnd K.:] whers sakI dividtilg lins lillersscrs witll /inR of land designated as r.H.O.A. liS; tllenr.o along F.H.O./~. 115. North 61 degrees 4S minutes 47 seconds EOJst_ 8 disrancl! of 24 feet to the dividing lins between lots Nos. K.4 imd K.S: thel/ce along said dividing line l/nd passing through II parritian wall. South 28 degrees 10 milrutes 13 seconds €i/sr. . distance af SO (eec fa line of lot No. J-6,.. tllence along Lots. Nos. J.6 ,7nd .1-5- South 61 degrees 45 mlnutc$ 47 seconds Wesr_ II disrant:8 of 24 leet to the dividi'1g linfl between lols Nos. K-4 IImi K-:J: rlrem:e altllTg 36/(/ dividing ldl8 i1nd p6sslNU rlval/g)1 a parritkm wall. Norrh 28 degrees 10 minutes 13 seconds We.s-t, a distance of 90 feet to OJ PO'flt. 1hll place of BEGINNING. DE/NG L.ot No. K.4 on rbe above Plan and being known and numbered 8S 508 l'orsfJiI Terrace. BEING the :;ame premises which Fo~crofr Townhouse AssaC/~1tcS. a fenns'Ilvi/llia I,;ni"ed pi7rrntirslJ(J.I. by der~ri d<:lred December 31. 7985 ,7nrf recorded in Deed 800/( 31.R. Page' 14. !/fanUd emU can'l'cyed U('7tf7 SCilrl.Joroug/1 Reat c";rJ(1! Fund 85-1. i1 Pennsv/v311ia limitcd p<irmcn;!lip. rite granror herein. PREMISES: 508 PORSHA TERRACE ,,,l. ., .,..;1.:. .&!iM; VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL RESIDENTIAL MORTGAGE, INC, mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S, Sec. 4904 relating to unsworn falsification to authorities. \J~~ DATE: (. \\ -OD ,/ j: !ilf iJ ~' I\) " ~~ ~,'1 oJ -jy ~J [;'j'I\"'~" ,C',: ~", ,',,', '''", ,'""" """ ~, ~. ,~-";:',.' <, <,.~-," "'- r-.'..r:..~ '.-,-, OF'::Jcr!if:' ~"-. Ctru - .' ' .Sl1t~;f!~F v :;';~:~..: r~~J n..,.,,,,.-~ -l-:&_t'~"! 4ii~ FES II PE; - , ~ . . "-; ,. __?"",~" -';1"'~I"': ."~ :1 os PN 'GO ". \,,' ::~ i,,' /- /\ ~~~' :'~mr~ ~_ ., '" ~~"_ ~, J_. _'. t'J '" ., .' c~J, .'.r-"_ '",-,.["~ "~' . -~-: ~-; --- "~,. = ,'.- -~.., . FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Common Pleas Civil Division Vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL CERTIFICATION OF SERVICE I, Lisa D. Blankenburg, Esquire, herby certify that a copy of the Motion for Alternate Service has been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. JUSTIN B. GOURLEY,RICHARD E. GOURLEY, and DIANE M. GOURLEY at: 508 PORSHA TERRACE CAMP HILL, PA 17011 8 WEST SIMPSON STREET MECHANICSBURG, PA 17055 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. L~g, Eeg","e Attorney for Plaintiff Date: March 28, 2000 ~,,'P . ~ 2_". :2:r" (j) 5~' -<.." !KC' 1>(':- ~(-) )>C :2: -I -< " - g CJ 0 a -n <~ ;b ---1 " Q) " --,,- :-L.;;-ri nlrf\ ;;;0 '.,...... ~ .. ", , I {j'", ;~? --;CJ ~~ :~';1:1 <::;.:.. :< ~. ::;;:: N --.j _0 ~""'"'" FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Common Pleas Civil Division vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL ORDER AND NOW, this 10" day of A 10"'/ , , 2000, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP lULL, PAl 7011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: ~ 00 V{\O'.\~ ~'(' d,\ ~~ , M'~ ,~~- .".~- . F!LE[}-OFFlCE 0::: fJ::~r~Tf-'!Oi\!OTARY 00 APR 10 Plj 1.1: 15 CUM8cFiLi~i[J COUNTY PENNSYLVANIA ." A",.~,.,l~~~[fflJ'"TT - " - ~. ~ -, fi'~ ~..."...-'ll'"_,, _ ~~ _ _. ,",."1, !I!i 1- > FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Cornmon Pleas Civil Division Vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY No. 2000-348-CIVIL MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011 and in support thereof avers the following: 1. Attempts to serve Defendant (s) with Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". ~ ~ , ~jJ -- ""-~-c . , 3. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail and by posting of the premises. nke g, Esquire FOR PLAINTIFF - ,,- ile', FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.2000-348-CIVIL vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant( s) and the reasons why service cannot be made, Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. GOn7~lp., v, Pol;" 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address," Aclnp1ion ofW"lkp.r, 468 Pac 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (I) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, , local tax records, and motor vehicle records. As indicated by the attached Sheriff I s Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". ~W"lllt'l WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail and by posting of the premises by the Sheriff. Respectfully submitted: Li~SqUire Attorney for Plaintiff - SHERIFF'S RETURN - NO~ FOUND C~SE NO: 2000"00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY JUSTIN B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, NOTICE NOT FOUND , as to the within named DEFENDANT , GOURLEY JUSTIN B DEFENDANT NO LONGER LIVES AT ADDRESS STATED, SXH18trJ! LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Service NOT FOu~D RETURN Surcharge 18.00 9.30 5,00 10.00 .00 42.30 So ans~~ Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ~ - . ",~ SHERIFF'S RETURN.- NOT FOUND ,,-~SE NO: 2000-00348 P r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY RICHARD E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, NOTICE , NOT FOUND , dS to the within named DEFENDANT , GOURLEY RICHARD E LEFT NO FORWARDING WITH THE P.O, ~1t1811" ~ DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, Sheriff's Costs: Docketing Service NOT FOUND RETDKN Surcharge 6.00 .00 5.00 10.00 .00 21.00 ~~~~~ R. Thomas Kl~ Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this day of A.D. Prothonotary 1'- :,.L - ~Jw,~_"._,_,__~, ,F;,,,,,,,,,,, .- ~ ~~ "~I SHERIFF'S RETURN- NO~ FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY DIANE M but was unable to locate Her in,his bailiwick. He therefore returns the COMPLAINT - MORT FORE-REI, ~llJtr Ji NOT FOUND , as to the within named DEFENDANT , GOURLEY DIANE M DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Service NOT FOUND RETURN ' Surcharge 6.00 .00 5.00 10.00 .00 21.00 ~,~,.,~' , .,~/~ ~b-...-' r R Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this day of A.D. Prothonotary 1;'--': i ~ - ~-..),,,p--,,, .", y, _ ~, ,_J "' _~~ I,~u 'J..---<<" SHERIFF'S RETURN. - NOT FOUND "J"'f2 " CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PRINCIPAL RESIDENTIAL MORTGAGE VS ~/blt4 GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY JUSTIN B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND , as to the within named DEFENDANT , GOURLEY JUSTIN B DEFT. MOVED, LEFT NO FORWARDING, RETURN NOT FOUND AS PER ATTY 2/4/00 Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 6.20 5.00 10.00 .00 39.20 s07~~~~< R. '1.homas KI ine Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ;"@ - , I "~, . ~ ;. SHERIFF'S RETURN, -'NOT FOUND CASE NO: 2000-00348 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND- PRINCIPAL RESIDENTIAL MORTGAGE VS ~/8J~4 GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY RICHARD E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTI CE NOT FOUND , as to the within named DEFENDANT , GOURLEY RICHARD E DEFT. MOVED, LEFT NOT FORWARDING " RETURN NOT FOUND AS PER ATTY 2/4/00. '. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 So ans~we : ",//~"",,~. _.-">,.,,-;7 ./ !r'':> - """"/,),~~ -- p- R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this day of A.D. Prothonotary Ii' J' I '.~~. . L'-'1 .",' -4" SHERIFF'S RETURN, - .NOT FOUND CASE NO; 2000-00348 P CpMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND '. PRINCIPAL RESIDENTIAL MORTGAGE VS ~8J~ 4/ GOURLEY JUSTIN B ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GOURLEY DIANE M, but was unable to locate Her in his bailiwick, He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , GOURLEY DIANE M DEFT. MOVED, LEFT NO FORWARDING WITH P.O., RETURN NOT FOUND AS PER ATTY, 2/4/00. Sheriff's Costs; Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 S:;~~~C;/ R l'Thomas Kl ine Sheriff of Cumberland County FEDERMAN & PHELAN 02/04/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ~<'''''- = ~._.- ~ , "'J '~,b' ,'{ . " P ANJ, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 00-578 Attorney Firm: Federman And Phelan Subject: Justine B.& Richard E. & Diane M. Gourley Current Address: 8 West Simpson S1. Mechanicsburg, P A 17055 Property Address: 508 Porsha Terr. Camp Hill, PA 17011 Mailing Address: 8 West Simpson S1. Mechanicsburg, P A 17055 Last Known Address: 8 West Simpson S1. Mechanicsburg, PA 17055 I. II. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Justin B. Gourley -163-52-5777 Richard E. Gourley - 202-36-9644 Diane M. Gourley - unknown B. EMPLOYMENT SEARCH Justin B. Gourley - unknown Richard E. Gourley - unknown Diane M. Gourley - unknown C. INQUIRY OF CREDITORS: The creditors indicate that Justin, Richard & Diane reside(s) at: 8 West Simpson St. Mechanicsburg, PA 17055 INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH This is a non published number. 8 West Simpsoll St. Mechanicsburg, P A 17055 INQUIRY OF NEIGHBORS Rob Buckheit 15 W. Simpson St. and he verified that Justin, Richard & Diane reside(s) at: 8 West Simpson St. Mechanicsburg, PA 17055 INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE: Justin,Richard, & Diane Gourley - MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE Per the Pennsylvania Department of Motor Vehicle Justin, Richard & Diane reside(s) at: 8 West Simpson St. Mechanicsburg, PA 17055 OTHER INQUIRES A. DEATH RECORDS '..IXHIBIT B III. IV. 8 West Simpson St. Mechanicsburg, P A 17055 V. VI. ,,~" ~ "" ~...;, :,'; . : '. As of Jan. 1,2000 Vital Records has no death record on file for Justin, Richard & Diane. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.) None }'ound C. COUNTY VOTER REGISTRATION The Cumberland Cnty. Voter regis. has no registration for Justin, Richard & Diane. 508 Porsha Terr. Camp Hill, P A 17011 VII. ADDITIONAL INFORMATION OF SUBJECT A DATE OF BIRTH Justin B. Gourley - YOB - 1972 Richard E. Gourley - YOB - 1945 Diane M. Gourley - unk. B. A.K.A. None Gtf; tit ~ fa AFFIANT Steven , Ruffo Sworn to and subscribed before me this 1=1- "'" day of VAN 20t;lC) EXHl8JrEl ~OL-Q,cilM- N TARYPUB C P ANJ, INC 43 Wilson Drive Sicklerville, NJ 08081 Phone: (856) 740-0919 :',-"==~'==-- NeT AP:iAi~Erri7~I~~~~'--~v-~-~ I' S!f f !E Ar-,;i-J i' 11r~1 N"",c-nr PA...q.... l 61;;;';i ?1~!'\~a\l~~~I~a: F"l::~;;~.'Cc~',;;~; . J r.f /.~~:::.:;:~~9~;.Exp~~'~Ja:~. ~.::..:~::~_Q.~. -' "'-0 .'~k . , ' V E R I F I CAT ION : " Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 28, 2000 ~~y ~.. Lisa D. B anken~g, Esquire Attorney for Plaintiff ~OOl l - 'Mdlf I. .' . . .'>~ .~. h ,::::1 () c-} ~d c: ~- ~~ ~f~1 " c"l -',~. J , - " " -;7 ~_. ~~ ,<, ~;C> """.f") >c "7 ~ ~ ~--,~ _....-~ ',~ ,.L., '~'~,I -,.--n ~~~'~ -, ::0 -< t.n ," ..... '. " -" ~ >-~ . FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Cumberland County No. 2000-348-CIVIL Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ."1-~, +-.f'.h FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: April 18, 2000 '"", . l~ ,,-,,-, 1>-" ~ii!IIll1IliI..IIl.' b""~.' ''''_ ,,, ..... C) 0 C (:;.:) ::-h ::;''''" -j "{J i" fTI L ::1.. 7r'- ;"-.1 (75)::-: C J -" ~~ -:-;(-:) V ~~~S 2: 5"C 1',) ~-rn 0 2: c--I D -,.=- =< ::0 CO -< L, - ---.J ," .,-~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (?1 'i) 'ilii-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Attorney for Plaintiff : COURT OF COMMON PLEAS Plaintiff : CNIL DNISION vs. : CUMBERLAND COUNTY mSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY : NO. 2000-348-CNIL Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT RV M A IT, PTJRSTJ A NT TO COTJRT ORORR I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to JUSTIN B. GOURLEY, RICHARD E. GOURLEY and DIANE M. GOURLEY at 508 PORSHA TERRACE, CAMP fiLL, P A 17011 and 8 WEST SIMPSON STREET, MECHANICSBURG, P A 17055 on April 2ti, 2000 ,in accordance with the Order of Court dated APRIL 10,2000. The undersigned understands that this statement is made subject to the penalties of 18 Pac C.S. 94904 relating to unsworn falsification to authorities. Date: April ?Ii. ?OOO 1-~ 1-4 --- FRANK FEDERMAN,ESQUIRE Attorney for Plaintiff , I \ \ \ j ! ..JlIf" ~ _~;"Lb " ~.:.. - -~~ - -~'~'>'-'~j~" ~,=""""", I"",. '"""'1 "', - " '" " 0 <:::) 0 c: a 'Tl "'" :z '-; -Om :.:;. .. t;pg] -< f~12! I -Dm z'~_. '-0 o:>::t: W OJ ;:S:L'. '~~ ~, '- , ~~ <J :r:rl Po :z s;;!o ~o ~ oITl ~ ~ -<;; (J} -< OM _., '! I >~f:; ";1;:. - - ,,' . 1_- ... "'i< FEDERMAN AND PHELAN By: FRAJiKFEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. 711 High Street Des Moines, IA 50392 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff VS. : CIVIL DIVISION Justin B. GourIey Richard E. GourIey Diane M. GourIey 508 Porsha Terrace Camp Hill, PA 17011 : NO. 2000-348 Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Justin B. Gourlev, Richard E. Gourlev and Diane M. Gourlev, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 111/00 to 6/1/00 $88,070.20 $2,362.32 TOTAL $90,432.52 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: . ),. AJE.... .) 2000 ij f2A -:Ii.:...J~ ~ , , PRO PROTHY - c- "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIIAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROIlERTY. .* ." 0'- FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant(s) TO: JUSTINB. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249.3166 Frank Federman, Esquire Attorney for Plaintiff ... .1' .\ j, FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: RICHARD E. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff .'.~ 1,['- J.. .l __c'_' , -;./~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: DIANE M. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. 1.0. #78020 Ste. 900/Two Penn Center Plaza ,Philadelphia, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. '~"U"""""""""",","',","",",',.',",,',',"',','" : , '-"'''''''''. , APR.- 7;~~ ATTORNEY FOR PLAINTIFF "-.-- ... Court of Common Pleas Civil Division vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY CUMBERLAND County NO. 2000-348-CIVIL ORDER AND NOW, this I () day of --.fi-r r:! \ l ,2000, upon consideration of Plaintiffs Motion !Illd the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defend!lllt(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true !Illd correct copy of the Complaint by certified mail!llld regular mail to the defend!lllt's last known address, !Illd to the mortgaged premises located at 508 PORSHA TERRACE,CAMPIDLL, PA17011. Service of the aforementioned mailings is effective upon the date of mailing !Illd is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office a,,'l Affidavit as to the mailing. BY THE COURT: J5) -f~rUrJ j. i/1<Y J. t__ d_" FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PrincipaI Residential Mortgage, Inc. : Cumberland COUNTY PIaintiff : Court of Common PIeas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 CiviI Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Justin B. Gourley is over 18 years of age and resides at present whereabouts unknown. (c) that defendant Richard E. Gourley is over 18 years of age, and resides at present whereabouts unknown. (d) that defendant Diane M. Gourley is over 18 years of age, and resides at present whereabouts unknown. This statement is made subject to the penalties of 18 Pac C.S. Section 4904 relating to unsworn falsification to authorities. ~~ FRANK FEDERMAN Attorney for Plaintiff " , > ,~ "j (Rule of Civil Procedure No. 236 - Revised) Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) Notice is given that a Judgment in the above ,captioned matter has been entered against you on June :;l. . 2000. ~, '~L [?~/hTfDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMl'TING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMl'T TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ,Ii ...- :......~m". "-~~ - ,,,'-'-, --'~' .~,- """- -"". .~- t r ~ (ls' ~ -0 ~ YJ ..0 -..a ~ , K , - ~ ~ ~ ~ g lp! ~~ ~ I I. o c: -~ "'- "OGJ m...." 2: :u z~ ~~ kG ~o >0 ~ - "[, Ii c.::> a c... ~ Z f l'V o ~}J ~'B8 ~~ ~~~: ~~6 (5,~n "'" :i'J -< """ ::t:: S' "'" (1) , -~. i ." ~ ~"~ .l ,-' . , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3I83 Principal Residential Mortgage, Inc. Plaintiff, Cumberland County v. No. 2000-348 Civil Justin B. Gourley Richard E. Gourley Diane Gourley Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $90.432.52 Interest from 6/1/00 - 9/6/00 $1.457.26 and Costs (per diem - $14.87) $91.889.78 TOTAL F Note: Please attach description of property. No. ~1Il"'" _iI!I'liMJI<il!W~.~""-'...Aml~''''"'''''''''li1I~i_..~--_"" "jll>ftj;j~.llIililit",,_;;j[:(""--, .. "" ~ < 1lii:.llII[ ". -mlil;!'-"'''''' 'UJj:tll" ~ ~ , I:f,.:' " i I . ~~ = Z ~ 0 .... .fa 00;> cJ Eo-< ~~ >;;l = "1:i = >;;l .... u " "'"00 ,; ~i ....ll i: ~~ CIl ~ "'.... = " .. ~~ r-1 ~ ,,<= 0 en CIl ~1: f ~ ~ " Q 0r-1 t: ~ 1: ~ ... 0 .n ~~ 0 .. = '" o<:l ;:: g ~ :s -< '" ~ < ~ ~ ~ = 0 i: '" g"-t:E-<~~ 0" = E-< .. 0 O~ - .; " "~ ~~ "~=.a= '" 0 u~ .. "r-1 o .. 1il 0 .. 0- ="CI"~== ... i:ll"CI'" ~ <'l = ~ g "'0 '" = .. = .:::~ El 1; '" 0 ~ '" Ou "CI .... ~ C': . ..cI = ~ a '" 0.. .. .......= .... Ot: ~ ("J C': 00 C': ~ " '" r; "'~ " !:2~ ~ = i:il.. <= .. .... Eo-< ""i:il ... 0 "" ~Vlu~ " >;;l~ - r-16 ~ .. ~ 8;j ~ .... en .. U en .. ~ r-1r-1 = ~ .;; .. =i:ll .. " ~ ~ .... E-<~ .- ~ ... ~>;;l u , ,4~'''~H'':' "~=,...,~ ~" - - . DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, simate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No, 1 entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern comer of Lot No. K-4set .on the dividing line between Lots Nos. K-4 and K-3 where said dividing lille intersects with line, of land desig$tedas F.H.O.A. #5; thence along F.H.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos.K-4 and K-5; thence along said dividing line ana passing:; through a partition wall, South 28 ,degJ:'ees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots.Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the placeqf BEGINNING. . BEING Lot No. K-4 on the abovelhan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a P A limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. ii'IItliitl_rfl~.iit>i!ll~f.~- _ ".~~_~"" M'~~I - ~"",M""~'~ ~"~~~"'Ilsi~t!cI'I'lifuj..", "<I 1"'" " ~'-'-"'" _ J _.~_. ~ ~ w~ {"J 1v L t ~ Iv ~ ~ -a .... - - - --0 ~ ~ 0 d . , . 8 . ~ <3 0' 0 8 ~ 0 ~ ~ ~ 0 c c () D n ~ d 0 I' .' .' '=' ..., \ '- t '- " C: Q ~'ii I 1\ , ? () I t "U-~ ,- I (i_n) c::: "- ~ irn -...'"' '~.i2 Z:x; ".i_ ~ t ~ ~ ~ , th~; .-C-Ji"n .. " .... - (P " ... ... ~ ... " - [~N ~ ... -<.,- ~t) """ 0 .. " .. ~ ~ eo ~ ~ ... "' - ... ... ~ ~ ::r ~ "' :;;io .... - - .... ... - ~ h -j \V Y-; ...] 5:; -< . 1M - ,"",'"~' .' ~ ~~~ - '--", FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Principal Residential Mortgage, Inc. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION Justin B. Gourley Richard E. Gonrley Diane Gourley NO. 2000-348 Civil Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. mtl;i!l~~_~""';'~''''.''''''''''''"~i.'~'i'l,.~~~~.iilliilIU ,.:c ~'"""illllilr8KltiJlli-r-'" - . - -~ ..- ~ (") c J1~ Z::c t5S~': 2iiS j;: '=0 r-o Pc: Z :< -.J f5 c._ r..:; Z o ''l '1 ;c) -,"jrn .,c' 1"',')( .~~~J ~'~~) :tJ <---C) $;=::n .:;::~ ~- :n -< .<:- ~ =e: , ~-- <. , ~- " Principal Residential Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Justin B. Gourley Richard E. Gourley Diane Gourley CIVIL DIVISION NO. 2000-348 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) Principal Residential Morte:ae:e. Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQillRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 508 Porsha Terrace. CamD HilI. PA 17011. l. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Justin B. Gourley 508 Porsha Terrace Camp Hill, P A 17011 Present Whereabouts Unknown Richard E. Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown Diane Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ;!-'~~ " ~.. . ~" - ~ " i"'1 'r " 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 508 Porsha Terrace Camp Hill, PA 17011 Domestic Relations of Cumberlalld County 13 North Hanover Street Carlisle, P A 17013 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 Pac C.S. Sec. 4904 relating to unsworn falsification to authorities. June 12. 2000 DATE _M!&li~!OOii~MiTiMil:iIM1:i-"-""ll'Ji<f&~_'~~~"''rt,.".,f'i~'''!-''-';''~'-'~- u, - ~~ '_"..N,' ~ ~--~~. .' _,_1 - ~.~- ,~~, ,~'....... ~ ", ~i ; '''", 0 0 0 C 0 ~ "T! l]t-,--, '- '11;-;< c:: Z:Xi -::r:-r ~JJ 2:c:' r- W ~-> ::;[1:1 -(".::' ". j---' r;::"-7; , ; <'-.. ~ '~() ~' f~~~ y- 7:") :r );C! C .. om 2: :;::f :< ~--- --.J :D -< ~ ~"".~ <-.-'. .,. \ Principal Residential Mortgage, Ine; Plaintiff, CUMBERLAND COUNTY v. No. 2000-348 Civil Jnstin B. Gonrley Richard E. Gourley Diane Gourley Defendant(s). June 12,2000 TO: Justin B. Gourley Richard E. Gourley Diane Gourley 508 Porsha Terrace Camp Hill, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at 508 Porsha Terrace, Camp Hill, PA 17011, is scheduled to be sold at the Sheriffs Sale on September 6, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PrincipaI Residential Morte:ae:e. Inc. (the mortgagee) against you. Ifthe Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may call: (215) 563-7000. 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. . ^~,~ ~ -- ~~ . , - ~-' j , " , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IJi' THE SHERIJi'Ji"S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 ="~~ ..- '" ~ .. ',. . ' , DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No. 1 entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.R.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No, K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a P A limited partnership dated 9/29/19Cf7 and recorded 10/3/1997 in Deed Book 165 Page 697. '- ,',,' -.......;a~~" 'Y_"~ -~ , -~",.1J-,,1,~~' -llii'-"l(I"~ -'-fMj .~ ~,' . - -~ '^" , -'"''';"'';~~.Il!1;tililj!!illll j <~.' . ~ ,,' '" (') 0 0 C 0 ',., ~ (- :~j \Jfij c:: n1rn :e: ;-:;~i ,J] 2:=,-, r-- 2:c- ::323 v5J~' .~ -<:2:: ,~1~ ~l::. "'" 2:C; ::a: ~("""'i - .J> .- - C:;rn C 2: --"-j :< 55 ".., -< !c! , ., "" ,'" "~ "',CO",~ J ..:., " ~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF SUITE 900 - TWO PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215) 563-7000 CUMBERLAND COUNTY PRINCIPAL RESIDENTIAL MORTGAGE, INC. vs. COURT OF COMMON PLEAS CIVIL DIVISION JUSTIN B.GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL VERIFICATION I hereby certify that a true and correct copy of the Notice of Sheriff's Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person (s) JUSTIN B. GOURLEY and RICHARD E. GOURLEY and DIANE M. GOURLEY on JUNE 13, 2000 at 508 PORSHA,TERRACE CAMP HILL, PA 17011 in accordance with the Order of Court dated, APRIL 10, 2000. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unsworn falsificaton to authorities. DATE: JUNE 23, 2000 , ^",1.""~ .~~ " r r I -0 '" ." o :lJ s: ~ o o en m 2 -i ~i= p o ~-i ~ . ~ H 'S'!,~ ~j~o 7\ JII" ~ r ~ ~ o. 'j I ~ ~ ,~ .. "\ mz~ ~ ;, ~ ... -\ :,;' g ,~o i"- ~ - ~ ' , ~ ~ " c' , .' , l"'~. ~ P 974,910 9-99 "'" " m m m " 0 ~ S m co fri ~ ~ ~ 1 c (f) '~ i (f) <1> ~ < 5' <1> Q. o CD::C ...CD ~n ::!!CD CD -. c.'S s:0' ~... :~~:-~:':;-':' ;' ; IMPORTANTIPLACE,snCKER AT TOP OF ENVELOPE TO THE RIGfrr- OF RE1U~~ ~D~E:~~__~ ... .~';-..;:J(''2f::,b;L~' j 't-__;-'.;<:.-.;:-~ P 974 914 439 -0 " -~ ,,' ~~,,- ---\cn "' " " en m m m I ,.'m 11 0 c! ." '2 m hi ~ " 0 ;-i z :lJ " Iii, '..; I s: ,9 '" I (Xl 0 n ~ , 0 m m 0 I ~ ~ ~ , ffi ~ m 0 I ~ 0 m g C + ~ I ~ (f) 2) ~ ~ ~ , z I ~ , _.'~-~ 1 CJl ~ ![ m ... . I ; (f) ... <1> ~ I < 15' <1> I 4 :'j,1." f , 1~ J . . ._-..... .. . I O::c I Ij ~CD ~ = I ~n ~ -0 I ::!!CD '" ... l CD -. = ~ c.'S = = I s:- = ... 1 ~ ~ ,~ ~ k ,~ ~ = i1 ... = .. = = = '~ c (f) ~ 'CJl ![ (f) <1> ~ < 1'r <1> O::c CD CD ~ _.n ::!!CD CD .'-. c.'S s:0' !!!.... P 974 I ~ ,. - , 910,,998 :1 (j) en JJ JJ I m !B ~ 2 1 ,z ~ "6 JJ .-1 m -l Z I d 111111 J H; ~ m ~ wi 0 ill ~ ~ '~ ~ -1 ,;, -01 en ." o :lJ s: '" gJ o I I ....~,-_..' IMPORTANT! PLACE snCKER AT TOP OF ENVELOPE TO 11lE RIGHT OF RETURN ADDRESS. - '----" APR.- 'I i,[J~~ FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. 1.0. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MOP.TGl\.GE, INC. Court of Common Pleas Civil Division vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL AND NOW, this I() ORDER dayof-1lfQ\ l , 2000, upon consideration of Plaintiffs Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be . done by Plaintiffs attorney, who will file with the Prothonotarj's Office an Affidavit as to the mailing. . . 'to "J' BY THE COURT: , Js,J ~Wn J,.1f,I1DJ J. ,J~_., _< '~_ .1Wil~J.lil;.. :iM4IMf'ff --, - .Mlik...~~,IIl<OlI_~ "' l~ . " . .. .....~ .. " . " """, if" ", ,'." 0 C> 0 C Cl >or; ;;:: '-- "-~ -urn c:: ""hpg n1rn -,~ - Z:n ", -CJ,n zr" 00 'T (fJ )::,. c"...... ~7- >:1~J r:~- ;<0 <J " -H ~G - t'5-. -,"-",0 5>0 N Om ~ W :;;! -j :n -< (:J -< ~-~ '0" t' il I' II il II I' I I :1 II :1 II \ " II I, I ", . fror C~~~ o^__ , . 1- ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff CIVIL DIVISION vs. No. 2000-348 CIVIL JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE GOURLEY Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for PRINCIPAL RESIDENTIAL MORTGAGE. INC., hereby verify that on JUNE 13. 2000 AND AUGUST 23.2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on JUNE 13. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ~~~~~ . FRAN FED RMAN, ESQUIRE Attorney for Plaintiff Date: Auaust 28. 2000 "~~ , I ~" ' Principal Residential Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Justin B. Gourley Richard E. Gourley Diane Gourley CIVIL DIVISION NO. 2000-348 Civil Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) Principal Residential Mortt!:at!:e. Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 508 Porsha Terrace. Camn Hill. P A 17011. 1. Name and address ofOWlIer(s) or reputed OWlIer(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Justin B. Gourley 508 Porsha Terrace Camp Hill, P A 17011 Present Whereabouts Unknown Richard E. Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown Diane Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Providian National Bank 295 Main Street Tilton, NH 03276 ~-L ~'" k , _ ~~;I. Foxcroft Homeowner's Association c/o PMI P.O. Box 622 Lemoyne, P A 17043 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 508 Porsha Terrace Camp Hill, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 28. 2000 DATE , ESQUIRE , I "~ ~, "'.., -'0 - g e. - - '" ~ z '" ... r"c ~. ~ Q.~ "0 '< ~ '" 0 5- ~ ~ - N - - - o ~g ~ ~e:. ~ ~'Z ~ Q.~ ..... eO" 'ot.I 6'~ ~~ "'~ O:!! ... Sl g "....J o 0 .... 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"'CoB " ., " = " .. c.. ~ = ~ Co ~ o' o Z c 3 " ~ I ""..,"l "'~I"i _..., .... -0.. .....I"i Co,,~ !!.= 'g.= -. ('l > ,!'I ft) Z "'CS-Rc >~-= -"":r: ~;'tr1 ""Nt" NJ= > "'z e. ... " '" "" "" '" ~ ~ ." o o " ~- ~< ' '. ~ ". Received From: ~Fn~RMAN ANn PHFTAN TWO PENN CENTER PLAZA, FMILABELFHIA, FA 19102 One piece of ordinary mail addressed to: PROVTDTAN NATIONAL BANK 295 MAIN STREET TILTON, Nil 03276 DMK RE : GOURLEY PS Form 3817. Mar. 1989 U,S. POSTAL SERVICE CERTIFICATE OF MAILING MAY. BE USED FOR DOMESTIC AND tNTERNA TIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: FEDERMAN AND PHELAN TWO PENN CENTER PLAZA, paII~EIFaIA, FA '9'07 One piece of ordinary mail addressed to: 622 PA 17043 PS Form 3817, Mar. 1989 L ~Ii-:I ~1~~ o\~~i o ''': iKt'~t'~.~ to,; i g;~~,...,~~' \ L~ c..i\l',"''''( ',' ,g; ~'.iv}bo'~~:j . ~ ~ II:~~U . ~Ji[l 0- ~llIili o ~IIH it i ~r~Ftu ."'.;r"'''.~~''*kll;''' . "0' RESTRICTED OEUVERY /-;J<O"~ ~ <tJ RECEIPT ,." '\ 1 _ '<';''''\ 9 0- J CERTlFIEDFEE+RETURNRECEIPT . :,'( ,,~~, '. SERVICE , Jlh{;, \ W" 0- TOTAL POSTAGE AND FEES . ~f2cJ c< >" 13 ) .~.', ZU- NO INSURANCE COVERAGE PROVIDED- .~ W CJ SENT TO: NOT FO~S~~~~:1JI~~AL MAIL .. U. ... .- 0 .." tUUJ I ~ .. 0- ~ , ......_~-~~~--/" g ..HlStl'-'! b.. GO'URL.t"Y . !:i :r 5Cll t'OIl.Sl'i\ TEZllAC;I. ('- "' IT' CA.'lP HIl.i.... 1'1\ l10li w " " c. DVl'lK tii w !il .. .. -. -- a: c c q ~i ~ U- a: U- C >- :r: C E U- ~ PS FORM 3800 US Postal Service !ii ~ o .. ;! Receipt for Certified Mail '-------------- --:sr r-'--,-~~-----.------- , I POSTAGE RESTRICTED DELIVERY tr IT' tr RETURN RECEIPT SERVICE POSTMARK OR OATE o ,. w ~ .. w > " w u. O. 0.' 0' ,., !:i "' w. ", ", [;;: w !il -' 0. CERTlFIEDFEE.,.RETURNRECEIPT ; \-v~ <'1/Jiill'<' . "I 1 , 2fin1 i. _.......,-,,~,:;.~..,/ o ... tr SENT TO: TOTAL POSTAGE AND FEES NO INS RANCE COV~RAGE PROVIDED ~ NOT FOR INTERNATIONAL MAlL SEEOTH SIDE a :r ('- 0- it.ICbARli E. ,::.oUR.i...Zi 50il ?(H-;,;;i'.A. rF1U(.;:V:1:' CA.'!P lil;";:', PA i7011 c. o io/lK PS FORM 3800 US Postal Service Receipt for Certified Mail ~ ;; "' o 0. ;! ~~-.:==;..~-=--.=.-::.:.=..--=- -==.-:..::::::-.. -===..-.:.=::., ::::.:.-.:--=:::.....::::::;;; ===-- -==.:.-:.:.:.:::..-.::;:=..-~.:::=::-=~~ IT' fTl :r \ POSTAGE POSTMARK OR DATE RETURN RESTRICTED DELIVERY , RECEIPT \::! "- J CERTlRED FEE + RETURN RECEIPT . SER\I\CE 'nh~' " TOTAL POSTAGE AND FEES ;~.20 , SENT TO: NO I~!'...URANCE CQ:ffl~AGE PROVIDED - ", 1~ \ NDTFO~i~~~~~2~ALM~L " , ,/ : !l1A.~ G:nJRL'fY \ '1:1';0'0 - .:'-.",-,~.~ SOil PC,l!S,lA ITRll.i\Ci.'. CAli" nIl~l 41'tI. 171111 o i11 K: ~ ;; "' o .. ;! :r ... 0- g "' 0- 9 w > z' w u.' 0' 0., 0.- ,., "" " "', "' ", I1c ,.. "'- , W. "e oi:(!.! ..J::: 0.' :r ('- <r c. PS FORM 3800 US Postal Service Receipt for Certified Mail ,.~"._~ ~ -." _1. 0'."0 . - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff CIVIL DIVISION vs. No. 2000-348 CIVIL JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE GOURLEY Defendants ..A.RMAN ANO~' ~.. A111JMEYAlE COPf PlEASJ= Rrnml AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY FEDERMAN AND Pttt:LAH ATTORNEY ALE COPY plfME RETURN I, FRANK FEDERMAN, ESQ., attorney for PRINCIPAL RESIDENTIAL MORTGAGE. INC., hereby verify that on JUNE 13.2000 AND AUGUST 23.2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on JUNE 13. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. AND PHaut f~~~ ALE COM , PlEASE RErniUli ~~~~~~ , FRAN FED RMAN, ESQUIRE Attorney for Plaintiff Date: AUQust 28, 2000 ~~" - ~J 1 il~ , , Principal Residential Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Justin 8. Gourley Richard E. Gourley Diane Gourley CIVIL DIVISION NO. 2000-348 Civil Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Principal Residential Mortt!:at!:e, Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 508 Porsha Terrace, CamD Hill. P A 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Justin B. Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown Richard E. Gourley 508 Porsha Terrace Camp Hill, P A 17011 Present Whereabouts Unknown Diane Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Providian National Bank 295 Main Street Tilton, NH 03276 '1,-, = '~"L_ _. .1'- . w~~. ",-, , Foxcroft Homeowner's Association c/o PMI P.O. Box 622 Lemoyne, P A 17043 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 508 Porsha Terrace Camp Hill, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 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. Sec. 4904 relating to unsworn falsification to authorities. August 28. 2000 DATE ........."-,"I--,.,.~ ,w ~~_~. - ~ "~- ". ._,i;ll.Iil/ll~!~ ., .-, , " ,.,' ~. "-",'.- -wL <-- ~" (") !:;; :S~ ~tf' [::~ :i;;(_, 2: .' --,0 Pc::: ~ "'.J rv ~;: (-:-) c.:J C0 ;---j - .J -,~ , -' ?~?f~ Om 5' ':xJ -< 1'0 Iii ~'<~ '1, ,- _'C'__ ,J- _.., ",.,- Principal Residential Mortgage Inc. -vs- Justin B. Gourley, Richard Gourley Diane Gourley In the Court of Common Pleas of Cumberland County, Pennsylvania No.2000-348 Civil R. Thomas Kline, Sheriff, who being duly swom according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail Levy Postpone Sale Surcharge Share of Bills Law Journal Patriot News 30.00 17.51 15.00 15.00 .50 1.00 12.40 3.51 15.00 20.00 40.00 23.53 339.80 360.00 $ 893.25 Pd By Atty 09/05/00 Sworn and subscribed to before me This f~ day of ,j~J. , 2000, A.D. ~~ ~fizi. SO~~ft-t:~ R. Thomas Kline, Sheriff Byet.~ Real Estate Deputy "1'1 jsDd<:,J '1 (,( D'- J ;iJ17~ .c.v-- "~ - J Principal Residential Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Justin B. Gourley Richard E. Gourley Diane Gourley CIVIL DIVISION NO. 2000-348 Civil Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PrinciDal Residential Mortl!:al!:e. Inc., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the , ' , following information concerning the real property located at 508 Porsha Terrace. Camp Hill. FA 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Justin B. Gourley 508 Porsha Terrace Camp Hill, P A 17011 Present Whereabouts Unknown Richard E. Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown Diane Gourley 508 Porsha Terrace Camp Hill, PA 17011 Present Whereabouts Unknown 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~- . ~ I " ,-, .,-- ~' 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 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: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 508 Porsha Terrace Camp Hill, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. June 12.2000 DATE "" ~~ "", Principal Residential Mortgage, Inc. Plaintiff, CUMBERLAND COUNTY v. No. 2000-348 Civil Justin B. Gourley Richard E. Gourley Diane Gourley Defendant(s). June 12,2000 TO: Justin B. Gourley Richard E. Gourley Diane Gourley 508 Porsha Terrace Camp Hill, PA 17011 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 508 Porsha Terrace. CamD Hill. P A 17011, is scheduled to be sold at the Sheriff's Sale on SeDtember 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by PrinciDal Residential Morte:ae:e. Inc. (the mortgagee) against you. Ifthe Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff's Sale. NOTICE OF OWNER'S 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To [md out how much you must pay, you may call: (215) 563-7000. 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 need 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. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4; If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ihI'__~.' ~~ ~. l__ I ~ ,~ ~"',-. DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No.1 entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.H.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No, K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane NI. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a PA limited parmership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697, .. , . > . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND NaoOO-348 CIVIL 19 CIVIL ACTION -LAW COUNTY: To satisfy the debt, interest and costs due Principal Residential Mortgage, Inc. Justin B., Richard E. and Diane Gourley, 17011 (Present whereabouts unknown) PLAINTIFF(S) 508 porcha Terrace, Camp Hill from PA DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell REal estate located at 508 porcha Terrace, Camp Hill PA 1701 (See attached legal description.) (2) You are also directed to'illlach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and 10 nolify Ihe garnishee(s) that: (a) an atlacl)ment 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 of the defendant(s) natlevied lipon an subject to attachment iSfouo<;l inth\! po,~,sessioD of anyone other than a named garnishee, you are directed tonotjfy him/herthat he/she has been added asa garnishee and is enjoined as above stafed, Amount Due$90, 432.52 Interest 6/1/00 - 9/6/00 $1,457.26 $14. 87/diem Ally's Comm Ally Paid $ 2 3 7 . 50 LL $.50 $1. 00 % Due Prothy Other Costs Plaintiff Paid Date: June 14, 2000 CURTIS R. LONG Prothonotary, Civil Division by: f} '1"1 - (2. 'tJ..ud. ~ - Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza, Ste. 90 Allorney for,: Telephone: (215) 563-7000 Supreme Court 10 No, 12248 Philadelphia plaintiff PA 19102 III~'"__~""-.U ., 'U'JWi.iw_llt':Ii:wr~ ,~,.' ," ,...." "" ~ ~......".' " , . .~ I I I REAL ESTATE SALE NQ. $~ onr IS: 2..rr'C> the sheriff levied upon the defendants Interest In the real property situated In~d'MV fd~ ~-J{Jd1f Cumberland County, Pa., known and numbered as:5d g (J.--f'IL.Pi and more fuil)' 1f!scnbed on exhibit "A" filed with this writ and oy this reference incorporated herein. oatecy-.-l5~ ~~ e ~ c:u;J c:;::::l @ r;:;:@ j,-,! (''.T' I. . , 2 l;! ?;~r , " .:fda:~H:~ ;.. ..1. ;:; ,-.' ~>:.L:;__W .~ll~j;\" ~ ~" ~~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, v. No. 2000-348-CV JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $90,432.52 ./ Interest from 9/712000 to 6/11/03 (per diem -$14.87) $14.988.96 and Costs TOTAL $105,421.48 *1Ulmk~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ~1WiI~~" ,. -~ "11111;'''''''='- - ....., '~~6!i;,;Ma&.~' " r..:$ O~ ~> f;1;1~ ""'rLJ ~Z Zz 0f;1;1 ~~ ~ ~ O~ UZ r..>;;l 00 E-<U ~~ >;;l~ 8; f;1;1f;1;1 == E-<~ Z>;;l ....u " r.i' ~ ~ o ~ ~ .... E-< . ZU f;1;1Z s.... rLJ ~ ~ ~ .... U Z ;! ~ ~, c j"""""" . .; ~ ><~>< f;1;1;f;1;1 ;>;;l; >;;l0>;;l 0,-,0 '-' .'-' . f;1;1 . =s~ i5:;:f;1;1 r;;=~ i:lu.... "';!~ Z o .... ... >;;l U ~~ f;1;1 = '" r.. 0 o<:l E-< ~ ;!~ ~~ ~ 01 o~ r.. ~ f;1;16 ~ .... U ~ ~ i:t:: ":g '8 ~ >-< <2 ;>, Q) J~ ] ll' ~ \"t -' ..' o <;;; '. "1::Jif, mrr, Z:-:~_, 2i (f;;2~_c ~;.'.::- ~\_- )i::c' z .' =() ..- c: Z =< ........ .... ........ .... 000 t'-t'-t'- ........ .... <<< ~~~ ..s..s..s ""'''"'''"' ........ .... === ~~~ ~~~ uuu r.i'r4'r4' UUU.,s ~~~~ f;1;1f;1;1f;1;1Q) E-<E-<E-<,o <<<l? ===S ~~~~ o 00 ~ ~~~p, OOOOOOll) 000,,", ",,,,,,,Q) ~ 00 Ul j ~ "', ..\.. C;) -Li) s:f; .Y; c. ""'1'1 y" :t"'.l:> ....;.'". C1 ,'~ g~~ -I "> :n -< '-P. U1 ~ - ..J ~ DESCRIPI'ION ALL THAT CERTAIN lot or pi<::ce of ground with the improvemeuts thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No, I entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern comer of Lot No, K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O,A. #5; thence along F.R.O.A, #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E, Gourley and Diane M. Gourley, husband and wife, and Justin B, Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a PA limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. Property: 508 PORSHA TERRACE CAMP HILL, P A 17011 ?- ~.IiI!i~ .. .. .~. ~ <~" ....... , .~_.e.iIiiIlii~'&_iflW,l!:i..dl N.<.-_ - :JI!llilGi~'-'-'~ ~ - --F' \~ (y (..~' '. 0 \}-> J \VDI~ ~ '\ J -, 1; ....", .'" )-. , i ~0 I ,:si \ ~ 4::- -,-V \ ()-o- t:--~ lJ'l -P<=><v C><\'I C> ~- 0<;.>" t; ~ :-. ~ ~ I . .-..J -\ ~- ~ ~ Cr, ~ ~ \.>.>?\ G. i::} a ~ . Ii ~ ~ (f:" 0J) 0 C! 0 ~ G...) -q lJ6~ :::f;;: ---- -"';:~ nlrr :J .-.,.., 2~x- z[ ~i:9 ~~::. <:;) '.-},.-, re-', ~I ::'r~ :<'- PC'" ,--~ t3 2:' ,- 5>g ,.0 ;~ rn '-' 2: ---1 U1 )> --1 :0 -< -< ~ ,,"~~ .~w.._''''_~ ~ , _.~--, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-348 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff (s) From JUSTIN B., RICHARD E. and DIANE M. GOURLEY, 508 PORCHA TERRACE, CAMP IDLL PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 508 PORCHA TERRACE, CAMP HILL PA 17011 (SEE ATTACHED LEGAL DESCRIPTON) . (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 attaclnnent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attaclnnent 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 $90,432.52 Interest 9/7/00 TO 6/11/03 @ $14.87 per diem Atty's Comm % Atty Paid $1,143.25 Plaintiff Paid Date: MARCH 10, 2003 L.L. $14,988.96 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Pro~ry JJ ~ By: fL-v.-t, ,.u.7- De~uty REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER@SUBURGAN STATION 1617 JFK BLVD., SUITE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No, 12248 -. ~....... " ~'.=~ - " .. he , PRINCIPAL RESIDENTIAL MORTGAGE, INC. PIaintiff, CUMBERLAND COUNTY v. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY COURT OF COMMON PLEAS CIVIL DIVISION Defendant( s). NO. 2000-348-CV AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No.1) PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,508 PORSHA TERRACE, CAMP HILL, P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, P A 17011 (pRESENT WHEREABOUTS UNKNOWN) DIANE M. GOURLEY 508 PORSHA TERRACE CAMP HILL, P A 17011 (PRESENT WHEREABOUTS UNKNOWN) RICHARD E. GOlURLEY 508 PORSHA TERRACE CAMP HILL, P A 17011 (pRESENTWHEREABOUTSUNKNO~ 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFT HOMEOWNERS ASSOCIATION C/O PM!, P.O. BOX 622 LEMOYNE, PA 17043 PROVIDENT NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 ~.~... ~~_..." ~~ "0< ,. ~'" - . 4, Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occnpant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 CommonweaIth of PennsyIvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 6. 2003 DATE ~/1/hJt::;:;~?~ FRJV{KFEDE~AN,ESQtmRE Attorney for Plaintiff ~_~I'~, lM1if._~~ ." ""'~M -,.'liltailt.l!tm~~ill""",'~'"" u~ bll - I '-' ~ w (") c~ C) C ',..-., , '"" "1"1 vti.' _.oL~ nln, "C_~~ ;?; ~:z- ::;0 , ".r :JJ ~t~ C) '0' , " G) ~c' ..1-> --'."' ,'~_~? iJs 6(~; po> '0 (5rn C 2; :.n ~ =< 5.., -< . , \i I' fl -- ..'~~ """'" FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. PIaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CV Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pac C.S. Section 4904 relating to unsworn falsification to authorities. .~~F~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff iBtlJ7~"~"L~.,,,,~- .- ~"r" ~~.~ -1l111" i ill'iti~'1ffii!:I_~_' ~. '~""IIIIU" " , ""-. Jl!jjj~ ~,~_.~> .. it-_: 0 0 " c (.c) '-' -q :-2"' ~ -o;-;~~ mr~":' :-,':'_rI- Z::r ':;',i;.l z: C. '''n r . " ~~;;;: 0 ~. , ..-' () c;:: ~, i: j;: ~ --;~: z c :-J () (""'; ;.;: c:: ...0 im z :JI ::;:l , -< . - __n_________ ~ ~ " ~-"'". ,"- '..~.. PRINCIPAL RESIDENTIAL MORTGAGE, INC. PIaintiff; CUMBERLAND COUNTY v. No. 2000-348-CV JUSTIN B. GOURLEY RICHARD E. GOUJRLEY DIANE M. GOURLEY Defendant(s). March 6, 2003 TO: JUSTIN B. GOURLEY RICHARD E. GOURLEY , DIANE M. GOURLEY 508 PORSHA TERRACE CAMP HILL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 508 PORSHA TERRACE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriff's Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $90.432.52 obtained by PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. j-'"-"~"' -., ~ .......- 1- , ~ "M ."~_ ""'_ , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice 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. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PAl 7013 (717) 249-3166 (800) 990-9108 - DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No. I entitled "Foxcroft", prepared by Michael C. D'Angelo, R,S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as foUows: BEGINNING at a point at the northwestern comer of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.H.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. Jc6;thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGfNNING, BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Ta,"{ Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a P A limited partnership dated 9129/1997 and recorded 1013/1997 in Deed Book 165 Page 697, Property: 508 PORSHA TERRACE CAMP HILL, P A 17011 ~~ Milimitii__-' ., 'rHl~- <~, ..w>;j~~_ TV "-"'.j:....<lli!f - .,,- "-,' " ">'AiI Hi 0 C) 0 ~ (.,) ""n -':~ :-r,: -~, V Ct:' -':;'" "',.' mr-;"', ::.:0 ~ :z.'"; "-,-' ~:I_~ zt' 0 ~-:! ~:i2:c :2(~) r-r' T=.z :.:::::,,-,.- ~ C~?(l..; ~G ~ __t 1 .0 ~;f\ '>C ~ U'I ~ . ....-< -- ~_J __ "~'~i'it"':-lolro FEDERMAN AND PHELAN BY: FRANKFEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 - ONE PENN CENTER PHILADELPHIA, PA 19103 215) 563-7000 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. vs. COURT OF COMMON PLEAS CNIL DNISION JUSTIN B. GOURLEY, RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CV VRRTFTrA TJON I hereby certify that a true and correct copy of the Notice of Sheriff's Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s) on 3/10/03 at 508 PORSHA TERRACE, CAMP HILL, PA 17011 in accordance with the Order of Court dated, 4/10/00. The undersigned understands that this statement is made subject to the penalties of 18 P A. C.S. s4904 relating to unsworn falsificaton to authorities. ~~ F ERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF DATE: May 12, 2003 oJ~ LJ ~. ........~.~ ., ~~~ ~ -...... " 71bO 3~01 ~844 2421 2847 TO: DIANE M. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 SENDER: KMD-LAS I' TEAMS I REFERENCE: PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail >40 Insurance Coverage Provided Jo Not Use for International Mall -"--'~'-~"-_._-~>-.-~---~. --~--~._-~---~-,....,~- .r~'-~-~ ~ .1 ,- 71bO 3~01 ~844 2421 2823 TO: RICHARD E. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011, SENDER: KMD.LAS I TEAMS-' i 1 REFERENCE: "I PS Form 3800 June 2000 1 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted DeliverY Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage ProvIded Do Not Use for International Mai1 1 71bO 3~01 ~844 2421 2861 i TO: JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 SleNDER: REFERENCE: KMD.LAS ,- TEAM ~ " - .. . - "..-.. .-.. PS Fonn 3800. June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ,----,.."~-~----~-.--.----- --..----~- ---~- -,- .'''''''''''''ail j~ -_.~_>- c - ...~lIlIill ...'~" ""'''';I<l~IOll'~ ~'"'~"'~.:., 'U~'~ ~~, ' .. ~-~~- ......~ ~- ~I 0 0 0 C (..5 -n s: _I;", -- 'lJ'''- }~J" -T"_ fTlri" -< ' .-= Z --- " r Z C-' (J! ,- '" y r' n , < "'D --1'1 )> 'l_._ Z "- ,- _'~C) )> C; ~'2 '_:",,-rn C '~ ", z r- ?o -~ -< <...:l -< - ".'~--- .~~ 0- ~ =,~ ,,~ ,- , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: PRINCIPAL RESIDENTIAL MORTGAGE, INC. ) CIVIL ACTION ) vs. JUSTIN B. GOURLEY, RICHARD E. GOURLEY DIANE M. GOURLEY ) ) CIVIL DIVISION NO. 2000-348-CV AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for PRINCIPAL RESIDENTIAL MORTGAGE, INC. hereby verify that on 3/10/03 & 4/22/03 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Mav 12, 2003 ~A~~ESa:: Attorney for Plaintiff -., - j;""'" ~ .-="~ ~"'IliiI_ = f ~.~ ~ E ;:'z ..~ ,,~ ~o "," ~ 0 ~ ~ ~ ~ u. ~c/ c: o " g. ..... ~ ~ z ~~ g~ ~ ~~ ~ 0'" aii 8a ~ "'''' ~ ~ g ~ sa 'Ii . ,,-" Ul ~ '" ~ ~ ~ 0 ~ i:' g s: 0 ~ ~~.....; ~&(II=r oo.;o'(jl (II en;dtgE: ~(II 8"::l 0: wE roo '" 2 ~ x ~g p; e;Er~-g.g ;e s g,; g. - _,~..., 0 g'~g6~ S'~b~if =__. 8~ ft~"C ::t,;;:;- g-"C!!l g.til ffi~ g G'.t:l o er (> c...~' ;'ire;gg. 0.'. 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" Z H I::l_ Ul ;J>< .~ ~c!3 ~ I-'J () = 0 H .tI1 ., .tI1 ~ u. 0 0 0 tI1 Z ~ 00 () .>-l '" ~ (l 0 ::l ...... '" 2:l 1;; ti 0 2:l F ~ ~ ~ .~ '1:J .t:: '" ~ .t-< :;: >- ~ H '" '" >- ~ >- -J :::; 0 ~ 0 ~ -J W '1:J 0 ~ () 0 N ~ .tI1 ~ -J ~ ~ '" 0 ~ OJ 0 ~ :><: '" r tv ~ tv ~ -J 0 ~ ~ ~ N ~ ~ ~ o '0 00 -J '" (,.t-~P~ '" ~ &~.......... if ~ ~P4 -~~~ :) ~ PITNEY BOWES 02 1A $ 01.800 0004300371 MAR 1 0 2003 MAILED fROM ZIP CODE 1 91 03 I ~ ~ '~ " " o>Z t""' ""'",.. ~. "''''g ...., .. ... ff ~ w N ~ = .. .. ~ 00 ... '" V> ... ~: CJ .- ~ ~ - ~ 0 '" ~Z V> ... w N ~ ... ", Cc *g. . ~ Z~ I 0.. * o-~ . '< 0 * . S 0' ~ * . '" * . cr ~ 9 " " 0. ~ Z <"J-'" !""'<"J . .... . ., 0 .. Wci ~ ::!.'2S P..~ ~ "'O~ -.0 ft o Ii' F::ta.. "'~~O fa, ~~~ 2. ..... "'0 ~ Z ~='" =... Z > o.~ ~ . . ~h~ 0- ~~~ 1:0- ~15[ ft ... ~ =' < -. . ..,/: ~~ o ~ _.0 ~ 0 ..." = .. :iJ;j ~ -~ ",. ;I> ~ 0:::2 _0 - " "'n ERg b;; " ~ ... ;io !' =!'j(/)> ~ 3<"J - o . -= '" ....'" '" fZ", . ~ ~ '" ",.. ~ . ~~ .a "'~!!i ~ ;!. > t""' ~ . '" .. = ts 15. ...."'~ .. "'t" <"J < ....~ ~ 0 ~ '" 8 = 0 = ~ . ..... q > - .... S::: 0 00. S ....'" 5:: 0 "s 5:: " > .., 0- !'j b; ft .... .. ~ 0 ~ 0:> . 0 ~ 6' g <' ir '" ,-- ,/" ?~ ItA i~'1 ,--' -"':<',.' '~~: Y~;1 \~.f;? ?f "ti- ~ /!! ~' ',~ ........... .. Z t, ~V"~~ '::l '~f'lTNEYBO,\;'VES $ 01.800 0004300377 APR 22 2003 MAILED FROM ZIP CODE 19103 -- <"~, -. " '"~~"""'>~-l!!d\'fJ~Jijlii'I!Ii~~ ._O'~ .ml!4lII!' " , " ......... ~, 0' ", o c: :7 ~t;3 zc u' ' ~: ..::; "'- ZC 5~ -< o w :; ","c"lt =-<. -- , o -n .r=- " -~-n "'E ii,_-', ~j ',-;" ) ,-~ , '._~ -r"-'T; -",..,-"\ '..-~(-::S ,',~rn '~i ~~1 ~"' ~ :sz ~....~ ry ;:- <.:> .~....""'=,-~ _ '"--"],- Principal Residential Mortgage, Inc. VS Justin B. Gourley, Richard E. Gourley and Diane M. Gourley In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-348 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing Poundage Surcharge Law Library Prothonotary Mileage Certified Mail Levy Posting Handbills Advertising Law Journal Patriot News Share of Bills 30.00 14.89 40.00 1.00 10.35 13.26 15.00 15.00 15.00 316.55 263.20 25.24 $ 759.49 paid by attorney 6/11/03 Sworn and subscribed to before me So Answers: ThisJJ.!!..daYOf~ ~~.,.~t:.~~ fl - R. Thomas Kline, Sheriff 2003,A.D'~F-Q, ~'~ByJ Prothonotary Real E ,.? . ett y 1J6'1 ~ /Y1076 -~,~.... - "" l,!,_ PJ,UNCIP AL "RESIDENTIAL MORTGAGE, INe. PIaintiff, CUMBERLAND COUNTY v. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY COURT OF COMMON PLEAS CIVIL DIVISION Defendant(s). NO.2000-348-CV AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) PRINCIPAL RESIDENTIAL MORTGAGE. INC., FRANK FEDERMAN, ESQUIRE, sets forth as of the. filed the following information concerning the real pr' CAMP HILL. P A 17011 . aintiff in the above action, by its attorney, , rthe Writ of Execution was CE ,'''''','" COpy 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, PAl 7011 (pRESENT WHEREABOUTS UNKNOWN) DIANE M. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 (PRESENT WHEREABOUTS UNKNOWN) RICHARD E. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 (PRESENT WHEREABOUTS UNKNOWN) 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFT HOMEOWNERS ASSOCIATION C/O PMI, P.O. BOX 622 LEMOYNE, PA 17043 PROVIDENT NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 ,_c' " I ~-.,'" iiv 4. Name and address oflast recorded holder of every mqrtgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name, and address of every other person who has any record interest in the property and whose interest ll1ay'be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occnpant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 6, 2003 DATE ~/l/Vnk~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~,"'''''','' . ~~ ~ ,-.-,. , ~" j .''''--\''' PRINCIPAL RESIDENTIAL MORTGAGE, INC. PIaintiff, CUMBERLAND COUNTY v. No. 2000-348-CV JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY IDefendant(s). March 6, 2003 TO: JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY 508 PORSlHA TERRACE CAMP HIlLL, P A 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 508 PORSHA TERRACE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriffs Sale on 6/11/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $90.432.52 obtained by PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. .0- - "~i ~ , -, --\, J You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice 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. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe 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 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 -v r- ~~ DESCRIPTION ALL THAT CERTAIN lot or piece of ground willi the improvements rhereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No. 1 entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7. 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows; BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.R.O.A. #5; thence along F.R.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos, J-6 and 1-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a PA limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. Property: 508 PORSHA TERRACE CAMP HILL, PA 17011 ,> .~ ~....... ~ @~" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff (s) From JUSTIN B., RICHARD E. and DIANE M. GOURLEY, 508 PORCHA TERRACE, CAMP HILL PA 17011 NO 00-348 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property ofthe defendant (s)and to sell REAL ESTATE LOCATED AT 508 PORCHA TERRACE, CAMP HILL PA 17011 (SEE ATTACHED LEGAL DESCRlPTON) . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $90,432.52. Interest 9/7/00 TO 6/11/03 @ $14.87 per diem Atly's Comm % Arty Paid $1,143.25 Plaintiff Paid Date: MARCHIO, 2003 L.L. $14,988.96 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) By: REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER @ SUBURGAN STATION 1617 JFKBLVD., SillTE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ill No. 12248 ~m&~Il'"'...,~dlti&I;lol,..iiIl~"""llil;j,~~illW~"~\\""'\!:I~f~?J'cl""-)"",fi""",,~iIidiiiI::IIi~iilJtml!im/il!l;!i~~. ~ifa,jj~-'''~ -" . >""~~ Real Estate Sale # 66 On March 17,2003 the sherifflevied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA known and numbered as 508 Porsha Terrace, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date:. March 17,2003 By~~ Real Estate Deputy """""".......... , I I l I ~ ~ ~ ~ ."-_.~~;." I , ._ .J J " ~" ...r" , .. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. 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 Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of April and the 6th day(s) of May 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. PUBLICATION COPY SALE #66 S CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , 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 $ 261.45 1.75 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-New~. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... . 1 ~ ,< I I I r , , , RlML ESTATE SALE NO. 66 Writ No. 2000-348 Civil Principal Residential Mortgage. Inc. vs. Justin B. Gourley. Richard E. Gourley and Diane M. Gourley Atty.: Frank Federman DESCRiPTION ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected. situate in the Bor- ough of WOrmleysburg. Cumberland County. Pennsylvania. bounded and described in accordance with the Amended Final Subdivision Plan No. 1 entitled "Foxcroft". prepared by MI- chael C. D'Angelo, R.S.. dated Au- gust 7. 1971. last revised on July 17. 1984 and recorded In the Of- fice of the Recorder of Deeds in and for Cumberland County in Plan Book 46. Psge 110. as follows: BEGINNING at a point at the northwestern comer of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said divid- ing line Intersects with line of land designated as F.R.O.A. #5: thence along F.H.O.A #5. North 61 degrees 49 minutes 47 seconds East. a dis. tance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence aloug said dlvlding line and passing through a partition wall, I, South 28 degrees 10 minutes 13 sec- onds East. a distance of 90 feet to line of Lot No. J-6; thence alougLots Nos. J-6 and J-5. South 61 degrees 49 minutes 47 seconds West. a dis~ tance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along sald dividing lIne and passing through a partition wall. North 28 degrees 10 mInutes 13 sec- onds West. a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the ahove Plan and being known and num- bered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275. TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley. husband and wife. and Justin B. Gourley. Their son. single. as joint tenants with right of surv1vorship between parents and son by Deed from Scarborough Real Estate Fund 85-1. a PAllmlted part- nership dated 9/29/1997 and re- corded 10/3/1997 in Deed Book 165 Page 697. Property: 508 PORSHA TER- RACE. CAMP HILL. PA 17011. \ \ ! I r \ I [ l , i \ I , \ I I \ t I \ I i I ! i , I I PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.l784 iSTATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 25, MAY 2,9,2003 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. - SW TO AND SUBSCRIBED before me this 9 day of MAY, 2003 SEAl. LOIS E. SNYDER, Notary Public CarlIsle 110m, Cumberland County My Cotl'i!nis8lon EJcplIl8 Maroh 5, 2005 ~. - II ~ I. ':"J; .' ..... PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PRINCIPAL RESIDE:-ITIAL MORTGAGE, INC. Plaintiff, v. No. 2000-348-CV .ruSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). TO THE DIRECTOR OFIHE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $90,432.52 Interest from 6/2/00 to MARCH 3, 2004 (per diem -$14.87) $20,371.90 and Costs TOTAL $11 0,804.42 FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. 11_1'"'- -.'jl8l --." -9~o'<-, ~l1Iilliili... >- 0:: is we;; (.)...0.:" rr-C f,-'~'. .J....-'-_ n,:::: "'-', alY.~ life] ;~lU --;;r ;-::: ~ .u._' r~.', A ~." ....;;; OZ 00< <>; i:l;l- ....... =.00 ZZ OZ :;;~ :;;,; 0"" UZ ....::J 00 ""U ,,~ ::JZ 0< U~ i:l;li:l;l =~ "":;; Z::J -U 0\ -" en JC < ~ Z :::J 0:'1; O~ 9~ ~(J) ..::JZ ~~ a to C'-i Q.. I.L! en M <:::> '~'>j(~~jMili~;,"""'lI< r.f c; < c; "" " o :;; .... < - "" . ZU ""Z ~- - 00 S2 .... ~ - U Z ~ =. "~' . '. .; ~ ... "'i:l;l... i:l;l...li:l;l ~~~ ::JO::J 0"0 c;'":c; . i:l;l . ~~:;; Z"i:l;l -<Z ""=< OOU_ ~~~ -Jij,--~~~~ Cir.o~:::::~ ~J' ~ " GOO o ry 0 t,) 0'- .... ~"'>~ . ',~ I I I v .;) 0 0 o "'l 0 0 ......ry-.....:. rt~I"'("( Z o ..... f-< ::J U !oJ~ :-< ~ !oJ = '" ... = 0] "" ... ;:~ ~~ ,,~ 01:: ... = !oJ:;; =-.'-' - U !oJ ~ =-. . . . . ~~, i~i.i"~...,^ . , ~ I f . ';. ':. ... ~ " :; ';. I , \ ,.- " ~ ~ tl-() 0 0 '0' ~ '""::(-'1~OO~ . ()o.:~ . - r-.:. s.t Vj,~ 0'-1.] vi _I " 0" ~ ...." ~~ Q II) Q .1' ~- ~:; "d' :;;1:1:: i:l;l;;;l ...l~ <00 ooU ~Z i:l;l< ..= ."U -i:l;l ::::;; Ul Ul OJ ... -0 -0 -< d 'Cl a ~ ~ OJ 1: OJ Ul OJ .rJ >, co E r:; OJ lit 0. OJ ... OJ .c :s: ~ ~ o r<) ~ c.J ~ ...j r6 ~ --. ~ . -- ; .... 1 Jl -J-. 'J 3 .J li dJ ~ 0(: Il1 ~~ ,< .- . ALL THAT CERTAIN lot or piece or ground wich the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No. 1 entil:1ed "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page !l0, as follows; BEGINNING at a point at the northwestern comer of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. 115; thence along F.R.O.A. 115, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line betweea Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, Souch 28 degrees 10 minutes 13 s=nds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGlNNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Ta.'I: Parcel 1147-18-1302-275 TITLE TO SAID PREivITSES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a PA limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. "~ ~'-''''r,i~;.;!.,,',. -~.~ - tIilI;,~. . ~~~~~ - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLV ANTA) COUNTY OF CUMBERLAND) NO 00-348 Civil CIVIL ACTION - LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRlNCIP AL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From JUSTIN B. GOURLEY, RICHARD E. GOURLEY AND DIANE M. GOURLEY (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subj eel to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $90,432.52 L.L. Ioterest FROM 6/2/00 TO 3/3/04 (PER DIEM - $14.87) - $20,371.90 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $1917.74 Other Costs PlaintiffP~id Date: SEPTEMBER 25, 2003 CURTIS R. LONG (Seal) Prothonotary n .Bv: .ll A D__ 11 - c:. 71{0lA'Y.. / Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 .~ """" -, . <-,,- ~- .- -~~ ~" - -^'"'" FEDERMAN and PHELAN,LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DMSION JUSTIN B, GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). NO. 2000-348-CY CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ~) non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,)1 ()r\~jo~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,'" :1 .' iiIlJ~~~"" ~-. ,." . I! Ii ~ Ii i C) C;, J , c: c.,:} "ri $: (,1) -, ~(D ", ;:'~"'i::r- } (n -n ;:0 N ~;~~ ZS;: CI)~ ,"-,n ~e '".,,~ :>> c:cl ~Q :z ~M -0 \D ~f )>c '-~ -4 Z :;;- ~ -l --< \0 ,~ ~"'~"""".J.~k-. . .. ~ .~~ ' --" ..,~" .... "PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). CIVIL DIVISION NO. 2000-348-CV AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,508 PORSHA TERRACE, CAMP HILL, P A 17011 . 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 Z. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFT HOMEOWNERS ASSOCIATION C/O PM!, P.O. BOX 622 LEMOYNE, PA 17043 PROVIDENT NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 "kf"~",""" ~~ -,;" .. .4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occnpant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 CommoIlweaIth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 19. 2003 DATE ~~~ ~\}_dLJ\ rrtJ) ~ - FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff IilI r'~~/c'_ , r ~ ~~^""-'I'M\;l.~~~"""" -Ii _ ~XCo"_, " ~ _ ."--'~, .i ~~ ,~'" ., " .it' . .-.. (') 0 C C Co) "r; ?; U) .~ -O,t)J r"1 ;\:':n mfr~ -0 ,.. 2:D N -,r; 0'9 (J)~ (;..-q ;c,"') ~.;~. "-0 :.::;C ".. ~-J,..; {~:!J 3Eo ::x '70 5>0 '!? om ; ;:- ~ ~o -< _U ,...",11 Lt>. ~"" . ~~ ~" ~~1l'1 PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No.2000-348-CV JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). September 19, 2003 TO: JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, P A 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at, 508 PORSHA TERRACE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriffs Sale on MARCH 3. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $90.432.52 obtained by PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. ~"----" ,~~~ ~~~ . ,.~- _ ~~Jr~. . ,~ J_ ._ _~,= '~'"'&: '"' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice 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. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe 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 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ~~"-""" " , ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance wich the Amended Final Subdivision Plan No. I entif!ed "Foxcroft", prepared by Michael C. D'A.ngelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.R.O.A. #5; thence along F.R.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line betweell Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 s=nds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and 1-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Ta:< Parcel #47-18-1302-275 TITLE TO SAID PREMISES rs VESTED rN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a P A limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. ," ':' ~ ,,""-:~'~",<..:R;:~ .~IIi1'-""''"'''''' ~" ,~t,y ,_, ~''''~~.ilC"g,,!i;~~~~ij '"" -, "'ok .~ ' I; -, ~ 0 () (,f) ~'n U) ;t;:n !fR rT'! " ,- 'r- ::J:; r>,> "'",,-,rn C -:'(0 ~~ <.11 #j ~e 1Q ". , -', '< :~-n )>c 3: ',;; r> Zej 1.0 ~, n >c ~ z "'" =< \0 -< -- - ,-,. " , .~ ~,. APR - 'I "14.1 \ , ul fl" FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. 1.0. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Common Pleas Civil Division vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL ORDER AND NOW, this I() day of A.fQ.,L , 2000, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the C~mplaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, P A 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with h'1e Prothonotary's Office an Affidavit as to t.'1e mailing. BY THE COURT: J 5 J 1~rtffJ j, 11. f) {)/ J. ,. <I""' ~-- - ^~ .~~ -_. ~ , ~1-_..I r,SBC PAM - LNE - V2.2 - Docket Report Page 1 of3 PlnDue, NoMatrix, SchedsDue, DISMISSED, CLAIMS u.s. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:03-bk-03428-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 06/10/2003 Date Terminated: 08/01/2003 Date Dismissed: 08/01/2003 Justin B Gourley 1115 Jerusalem Road Mechanicsburg, P A 17050 SSN: 163-52-5777 Debtor Charles J DeHart, III PO Box 410 Hummelstown, P A 17036 717-566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 (717) 221-4515 Asst. U.S. Trustee represented by Justin B Gourley PRO SE Filing Date # Docket Text 06/10/2003 1 Chapter 13 Voluntary Petition missing Schedules, Statements, Matrix and Plan. Filing fee due in the amount of$ 185.00 Filed by Justin B Gourley. (Dunbar, Daneisha) (Entered: 06/1 0/2003) 06/10/2003 Receipt of V oluntary Ntition Filing Fee. Receipt Number 596324 Fee Amount $ 185.00 (RE: related document(s)l). (Dunbar, Daneisha) (Entered: 06/10/2003) 06/1 0/2003 2 Notice of missing documents (RE: related document(s)l). (Dunbar, Daneisha) (Entered: 06/10/2003) https:/ /ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?71 0566866893739- L _82_0-1 9/19/2003 ~. .~ 1iIJIir" -~ mK .......,_, ~~ ,_l.,..JoJ....~".~ ,j' ... ~ ,~ , .' ,~~BC PAM - LNE - V2.2 - Docket Report Page 2 of3 06/13/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 7/17/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/13/2003) 06/18/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 7/24/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/18/2003) 06/24/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 7/31/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/24/2003) 06/27/2003 3 Motion to Dismiss Case for failure to file the required documents Filed by Charles J DeHart, III (RE: related document(s)l) . (Garner, April) (Entered: 06/27/2003) 06/27/2003 4 Notice to PARTIES: (RE: related document(s)[3] ). Answers are due on: 7/17/2003. (Garner, April) (Entered: 06/27/2003) 07/16/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). TInS IS SUBJECT TO CHANGE. 8/21/2003 at 09:00 AM. (CA)(Etitered: 07/16/2003) 07/24/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 8/28/2003 at 09:00 AM. (CA) (Entered: 07/24/2003) 07/29/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 9/11/2003 at 09:00 AM. (CA) (Entered: 07/29/2003) 08/01/2003 .5. Order Granting Motion to Dismiss Case (RE: related document(s) [3] ). (NP) (Entered: 08/01/2003) 08/03/2003 Q BNC Certificate of Mailing. Service Date 08/03/2003. (Related Doc #.5.) (Admin.) (Entered: 08/04/2003) 08/11/2003 7 Final Report of Trustee in Dismissed Case Filed by Charles J DeHart, III . (NP) (Entered: 08/11/2003) https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?71 0566866893739- L _82_0-1 9/19/2003 I, I ~= .1 ~ " "'- ..",,, ,rSBC PAM - LNE - V2.2 - Docket Report Page 3 of3 I PACER Service Center I I Transaction Receipt I I 09119/2003 10:16:05 I Ip ACER Login: IIfp0039 IIClient Code: I !Description: IIDocket Report IICase Number: Ill:03-bk-03428-MDF I IBillable Pages: III IICost: 110.D7 I https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?71 0566866893739- L _82_0-1 9/19/2003 . ~~ "'-l'~'~.-~ -=-. ~~ ~ _~"'<i. .. Request for Military Status . Page 1 of 1 Department of Defense Manpower Data Center .. Military Status Report _ Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 SEP-19-200307:27:45 <Last Name First Middle Begin Date I Active Duty Status I Service/Agency GOURLEY Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks ofthe Department of Defense Manpower Data Center, the above is the current status ofthe Defendant( s), per the Information provided, as to all branches of the Military. P( Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization ofthe Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail tosscra.helpdesk@osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owalsscra.prc_Select 9/19/2003 - '"^ '<'., Request for Military Status . Page 1 of 1 Department of Defense Manpower Data Center _ Military Status Report .. Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 SEP-19-2003 12:37:53 <Last Name First Middle Begin Date I Active Duty Status I Service/Agency GOURLEY Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant( s), per the Information provided, as to all branches of the Military. pc Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization ofthe Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail tosscra.helpdesk@osd.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.milludpdri/owalsscra.prc_Select 9/19/2003 ,~~-. -' . ,"". . ~. ..,-<' ., I Request for Military Status . Page 1 of 1 Department of Defense Manpower Data Center .. Military Status Report _ Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 SEP-19-200312:39:15 <Last Name First Middle Begin Date Active Duty Service/Agency Status GOURLEY RICHARD E Only name was entered and there was only one hit based on the entry of the name. Without the Social Security Number, the DMDC cannot verify completely. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the Defendant( s), per the Information provided, as to all branches of the Military. P( Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization ofthe Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail tosscra.helpdesk@osd.pentaeon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owa/sscra.prc_Select 9/19/2003 c_ ,,', , , f , r -, FEDERMAN AND PHELAN BY: FRANKFEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 - ONE PENN CENTER PHILADELPHIA, PA 19103 215) 563-7000 ATTORNEY FOR PLAINTIFF 'c i i i I CUMBERLAND COUNTY I' I I I; 1'; \-i 'c PRINCIPAL RESIDENTIAL MORTGAGE, INC. vs. COURT OF COMMON PLEAS CNIL DIVISION JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348 i [:1 )::' ,;, I" VFRTFTrATTON , I , , I I I , i , I v !: I', Ihereby certify that a true and correct copy of the Notice of Sheriffs Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s) JUSTIN B. GOURLEY, RICHARD E. GOURLEY and DIANE M. GOURLEY on SRPTRMRRR 19, 1001 at 508 PORSHA TERRACE, CAMP HILL, PA 17011, in accordance with the Order of Court dated A PRTT. 10 1000. , . i , The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unsworn falsificaton to authorities. fJ~ FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF !~ rJ [:J Ii' l;! Ii ~ ~1 DATE: December 8, 2003 APR - ? "'iW.,\ '_u ~\ E'EDERMAN AND PHELAN BY: Lisa p.Blankenburg, Esq.' Atty. I_D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, pA 19102 (215)563-7000 PRINCIPAL RESIDENTIAL , MORTGAGE, INC. ATTORNEY FOR PLAINTIE'F Court of Common Pleas Civil Division vs. CUMBERLAND COWlty JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL AND NOW, this I() ORDER daYOf--1d.-rR\ L , 2000, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff'may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. , GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, P A 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotar'j's Office an Affidavit as to t,'le mailing. BY THE COURT: .15/ -t/rWi j, 1/11'1 <>/ J. ,-"~ . - . 7J!bO 3'101 'l611& 03QS&!Iba TO: JUST!N B. GOURLli;Y .508 I'ORSHA TERRACE CAMP HILL, PA 17011 ! I j I r SENDER: TEAM2 SPL I REFERENCE:JUSTIN.B. GOURLEY I I PS Form 3800 June 2000 ! RETURN Postage I RECEIPT Certified ~ I SERVICE ee : R~ Receipt Fee : i Rest~ Delivery Total_go & Fees I : US Postal Service POSTr..v\ ." I Receipt for I Certified Mail No Insurance Coverage ProvIded! Do Not Use for International'Mall --'~-,","-"--''''''-~--''-~''''--''''''''''-_._..''''''-.. "-.,.~".~,..,,,...._.....-'"..,.....--..~~~,,-....._......_-...-..- ,<- ~~~-w; I i I TO: I I I I I I ! I ,j i ! 71bD 3'm1 '16116 0305 6!155 DIAN.E M. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 SENDER: TEAM2 SPL REFERENCE: DIANE M. GOURLEY PS Form 3800 June 2000 RETURN Postoge RECEIPT SERVICE Certmed Fee Return Receipt Fee Restricted Delivery Total Postage & Fees i US Postal Service i i Receipt for ~~----~ - ,-~,'-- --~"_. 7lrbO 3'1Dlr 'Wt6 0305 '"76 TO: RlCB;AIID E. GOURLEY 508 PORSHA TERRACE . CAMP HILL, PA 17011 1 I SENDER: TEAM2SPL i REFERENCE: RICHARD F. GOURLEY i ! 1 RETURN RECEIPT SERVICE i i I I No Insurance Coverage Provided Do Not Use fo1 International Mall "'--__~_.._._____ ______ ._.____ .___~._ ._. __~._ _.__.~_._.__._~.______~~__r_______._'_____~._"__ US Postal Service Receipt for Certified Mail lilill~~-IilIi- ,~ _ r -. ~ '~~i~iiiii/;I""'''';''~e- ~j~!iJi(llW , - ~~... ~, M _0 (") 0 0 C <'.H ." ~: 0 ._- -05:' 1"" 2,~ -:'1'.1 rnrr' (, o"t"- :z: :t.. ~~~ :z: r,:.. (.r.j.~ "<_-'c kC :<:>- ?~:JJ ~C :s: '-0 ? :::2:1'11 5>~ 9 ~ 0 ?Q -<. ""j , - . . " ~ ~,~ :" '.2~ # , IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRINCIPAL RESIDENTIAL MORTGAGE, INC. ) CNIL ACTION ) vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY ) CNIL DNISION ) NO. 2000-348 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for PRINCIPAL RESIDENTIAL MORTGAGE, INC. hereby verify that on September 29, 2003 true and correct copies of the Notice of Sheriff s sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: February 3.2004 j)trJi/lZ ~)Un(}f/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '.' - cg~&~~ o g....<;l 2' _0 :....di 8 := ~ifS51e- :;;.~g[ II> ~ ....0 e 6.~.~. g.~. ~ E g, ~ g N3fA....o ...... _. v.::l .... !fg.~~e. C':g 08/l Ii a _. 0 tn. s:<<"t:l ::to g.'tl ~ Z.! ~ i g ~~. 2,o~gp.. 8 v:;'g e; g ~ fA ~ g e:. ill t->. s-....... 'ilb;l5~ . g B Po l'i S> ~ ~ [!t. @ ~. ~ 0 O3.g] R Ii- :. ~ S. [~~~ Hg:~ ~<<~- !l] B (i ~ g. !a~. S:"il~ .ggop.. g'"h ",.f:l 0 :-' -(i c. ~'!:l g ; 6 a:: s'" iil '" '" ::l . '" 6 . g a ~ ~. rn 8 g 5 Ii if _'_ o5.~[ o tn. V. <II ~"p. ;.~. g 8. -0 E b"< E::iil O"'d tt~'g~ ~tn'i~ g g s> [ (ll.. .~ '<0-; ~f ~ ~ :;;: "- ~, . z ..~ ,,~ ~" '"~ ~ ~ ~ " 5- ~ - '" - tv - - - o '0 ..., 00 '" Uo ... '" tv - ~""~.~~ t""' S' " 0>2: ....,""., {Il""6 ~ ~ ~ = '" ., """'= t\ "" ~O' g g ~. z ~~ "'~ ~g, o:? ~8 " . Cl ~ !P 8 ~ >< ()tJ~ ~~~~~~ 8e:~Znil ~=1g~G1! 6Q?;t""'J ~~~n! ~ ~ ~ ::; [J) 0 ~~~~~~! ;,. [J) 0 [J) l5: fi~E'%~ i n~H ~oS;:tn() [J) ,z Q ~ 0 ~~~~~ ~"~:t~w t""' b ~ ~ a 9tp:O~El ."" 0;,. ~ :J;: ~~~~~ 8 N...... Gj 0 t1 ~ ~ <: '" ~ 0 lil o IJj rn :i ~ ~ "tn ~!:Ii :;; v: ,>-l ~ , () ~ ~ [J) rn IJj J;; ~ ~ '" ..., ;,. :=: - ..., o ... '" ~ C:;" CD Z c: 3 cr CD ~ ~g;~gj E)-....}~trJ !~~~ Er'Tj() -P. g ~~ff~ 1-'::tf:+O ~a.tZl~ 0,< &:J;: "'COc:tli ~oC}l' ~~~~ .,J:::.. <: tZl ~ ~.agE .. 00 ..en" . " >-l _. .. ft " - .g i3 !l 0 ~ i ~.')! '!/ - .~R " f,rTij'\ , I '''' '0, I?J !~,J, :;: / ZJ I "\ i tJ1/ <;...-...",1 '~._ ',;'_?<:/....._~ "-.;"':/c( ,-~ '" ~ ig $~ !~ '" ~ i S< i:' Ii s: '" .<. i..-.UU( ~ <~ 1iII~~WO~ -""'" _lIIIiaIIi.i-..h< all , "" ,~ ~ ~ J<". ~, o c: "O~ mrr.. Z.+t -,., 05~ "". ~O <: J:;:O ~(-." s;;.c ~: u,- '""_'I - .N> =- = ..:- ...." M <::D I Ul ~ ~:it fl'I\iii :fig ~.::r1 0- Zfti ~ ..;0;: ~ CI> . -.:7 :x N .. ! Principal Residential Mortgage Inc. VS Justin B. Gourley, Richard E. Gourley, And Diane M. Gourley - ~~ " ,~",d "~_ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Frank Federman. Sheriff s Costs: Docketing Poundage Posting Handbills Advertising Mileage Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Law Library Prothonotary 30.00 16.07 15.00 15.00 32.33 15.00 40.00 20.00 316.55 309.43 29.32 In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-348 Civil Term 1.00 $ 839.70 paid by attorney 06/18/04 Sworn and subscribed to before me This .zIoM-dayof 9,., . 2004, A.D. GJA' ~ t2 ~ Prothonotary So Answers: rg.c::...-t:~ R. Thomas Kline, Sheriff B~AJ& Real E te Deputy uV /. CRqt.llfo ~. /0.2 3D'1 ~"c .~",.~,,-~ ..- -~-- . /1:, J r' PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). CIVIL DIVISION NO. 2000-348-CV AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,508 PORSHA TERRACE, CAMP HILL. PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, P A 17050 2. Name and address ofDefendant(s) in the judgment: Slime as aboye. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFT HOMEOWNERS ASSOCIATION CIO PMI, P.O. BOX 622 LEMOYNE, PA 17043 PROVIDENT NATIONAL BANK 295 MAIN STREET TIL TON, NH 03276 <;-~~~~ .",,-~, ....- --........ ~ "- , ~ 4: Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO 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. Sec. 4904 relating to unsworn falsification to authorities. September 19. 2003 DATE ~t1)\ ~ ~~)'t i'r\..fL~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~~;'!Ji;;;f,_ -"". ~~ -- ,~ * PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLN~DCOUNTY v. No. 2000-348-CV JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). September 19, 2003 TO: JUSTIN B. GOURLEY 1115 JERUSAlLEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, P A 17050 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT W4S NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 508 PORSHA TERRACE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on MARCH 3, 2004 at 10:00 a,m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $90.432.52 obtained by PRINCIPAL RESIDENTIAL MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P" Rule 3 129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: l. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 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. [,:~.-'''';1!!S ,~- ~~.-~ "'"= ,'~, ~~ , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice 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. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ;,;,)-v-:,~-~ ~ ,Co .,~ ~', ~-~ '- , , ~""-'-~ , ..l"LL THAT CERTAIN lot or piece of ground wir.h r.he improvements r.hereon erected, situate in the Borough of Wormleysburg, Cllmberland Count'!. Pennsylvania, bounded and described in accordance wich the Amended Final Subdivision Plan No. 1 entided "Foxcroft", prepared by Michael C. D'Angelo, R.S.. dated August 7, 1971, last revised on July 17, 1984 and recorded In the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as foUows: BEGINNING at a point at r.he northwestern corner of Lor No. K-4 set on the dividing line berween Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.R-O.A. /15. North 61 degrees ~9 minutes 47 seconds East, a distance of 24 feet (0 the dividing line betweell Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, Souch 28 degrees 10 minutes 13 Sel:Dnds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet (0 a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax. Parcel #47-18-1302-275 TITLE TO SAID PRElvlISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estare Fund 85-1, a PA limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. :;:;',J'>^,:uM ;f;;vg&P~\ , , ~-" "^, - ~~ , ~.... OfF!Cf Of r", SHERIff CUl-'8cP,' '\i"", CN~!IiY SEP 29 2 38 Pl~ '03 c (,- ~,~-, -, ;) ~-, ;'~ PENfo!~),(LYtd.jIA ~~r, _ c~~' ~~""";0lI'II'1:'-f~'''"",_~" ^-- "~""" ~~~" Mll11~IMIm""'" '0...._ _"__; -~i!!l! ". ... 'ife""6 "'''''Z 0:: ft1 ;;s . ~Q:::ct: cag~1 Q"''''' -< U) S> ::poq;- I' .' . . .. 11 ~el . . . 0) <Il ::i o ~~ ...... 0 8 u 0) .s i B;:; 000"'0 ~ur:/)t'- 0)- J3"OgJ<r: 4-< a 0 ~ o"'i:: o:S <1f ~..8~cr.: S~8] ou-u " '"~, - - - - - ",,=, - -::: - ": "":: :::: ~ ::; - .... ~ ~~ -<,-, ,. (Rule of Civil Procedure No. 236 - Revised) Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on June ~ .2000. ~y .d~ j?~A'~f15EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPlllA. PA 19102 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TIUS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT to COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ...~ -' , . , -- , ~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 . (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. 711 High Street Des Moines, IA 50392 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff VS. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley 508 Porsha Terrace Camp Hill, PA 17011 : NO. 2000-348 Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Justin B. Gourlev, Richard E. Gourlev and Diane M. Gourlev. Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 1/1/00 to 6/1/00 $88,070.20 $2,362.32 TOTAL $90,432.52 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE lIIEREBY ASSESSED AS INDICATED. a ~ DATE:.,.j,LA$ _:1.20:>0 II .(/)~~. ~ . . PRO PROTHY. **THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONsmUED TO BE AN ATIEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** " ~. > L "--'-, ~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL P~S:~~~~I~T MORTGAGE, INC. ~nrJS~ 0~ ~O~~0~ P~~AS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant(s) TO: JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17, 2000 THIS FI~I IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A. DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by actorney 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 enc:ered 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 CUMBERLAND COUNTY BAR ASSOClA TION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff - ~." .~ .1 - ~-- , ,. FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: RICHARD E. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 wi thin 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff . ~~-~- - " " FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: DIANE M. GOURLEY 50S PORSHA TERRAC~ CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANy INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be ~ntered 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff -~ I - ~ > ~ FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Common Pleas Civil Division vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY CUMBERLAND County NO. 2000-348-CIVIL ORDER AND NOW, this J () day of --1lf R', '- ,2000, upon consideration of Plaintiffs Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who "ill tile with the Prothonotary's Office an Affidavit as to t'le mailing. BY THE COURT: J5J ~M1 .;I. iJ)()) J. '-,-" ~:I--; -, '~ FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and chat on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Justin B. Gourley is over 18 years of age and resides at present whereabouts unknown. (c) that defendant Richard E. Gourley is over 18 years of age, and resides at present whereabouts unknown. (d) chat defendant Diane M. Gourley is over 18 years of age, and resides at present whereabouts unknown. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~ FRANK FEDERMAN Attorney for Plaintiff ~, . " t;,,',',", ,~ I "" .....Q ... Q:):La.lCJUJ <",ZQ:: a:::(I)-- l.I.Jl.I.JQQ.. >ct:ct:i:j :::;o~ Ll.Jo;>a:: oc:cCXW z:~oo :;:)<cu...o:: o " ;g i ~o ou .:: " .9 9 tiJ (") o S &~ ~8u:>i2 " ,,~ iJ];g~ t.+--.......oA-t o ~..d.1i . OJ,...., ~ <>~ '" iB~8i f'U~U ,. ~. ~ ~tE ~ p., p. .~ co ~ Cl~U ~ ,.,_c &1"- ---"-' "-'b - ~ ::::: - ~ ~ -:: - - ::C .: :: ....>: =E ....:;. ::= :: ""~l ~ .. (Rule of Civil Procedure No. 236 - Revised) Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendaut(s) Notice is given chat a Judgment in the above captioned matter has been entered against you on June ~ .2000. ~(lA..O . 2. 7f(7?~DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** " " FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, P A 19102 . (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. 711 High Street Des Moines, IA 50392 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley 508 Porsha Terrace Camp Hill, P A 1711111 : NO. 2000-348 Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Justin B. Gourlev. Richard E. Gourlev and Diane M. Gourlev. Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 1/1/00 to 6/1/00 TOTAL $88,070.20 $2.362.32 $90,432.52 I hereby certifY that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ':\~ DATE: _JL.A$ ~ ::2000 /s/ (l/)+J ..J ~__ I 'P~P~ "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU IIA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIIIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATrEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " .1 - I L .~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL P~ST~~N~InT MORTGAGE, INC. f'(jflP'T' 0~ C0!V!!V!0r-.1 ?~~_n_.s CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant(s) TO: JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: ~Y 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A. DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the dat:e 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 CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff - ,-- ~."' I .1 - ,"-,. . FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: RICHARD E. GOURLEY 508 PORSHA TERRACE CAME' HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Frank Federman, Esquire Attorney for Plaintiff - ~,. " ~ . ,_ t-o"," ~ , FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: DIANE M. GOURLEY 508 PORSHA TERRAC;e: CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 wi thin 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff I, , - FEDERMAN AND PHELAN BY: Lisa D. Blankenburq, Esq. Atty. I.D. #78020 - Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. Court of Common Pleas civil Division vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY CUMBERLAND County NO. 2000-348-CIVIL ORDER AND NOW, this / () day of --1tf J:l '\ l ,2000, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address. and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plairltiff's attorney, who \"ill tile with the Prothonotary's Office an Affidavit as to the mailing, BY THE COURT: ) s;/ ~Mt ;;{ if) /\) J. :1 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Justin B. Gourley is over 18 years of age and resides at present whereabouts unknown. ( c) that defendant Richard E. Gourley is over 18 years of age, and resides at present whereabouts unknown. (d) that defendant Diane M. Gourley is over 18 years of age, and resides at present whereabouts unknown. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ FRANK FEDERMAN Attorney for Plaintiff ~, - , =~ C~_;. ~k ~"__ I ,~ . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA} COUNTY OF CUMBERLAND) NO 00-348 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From JUSTIN B. GOURLEY, RICHARD E. GOURLEY AND DIANE M. GOURLEY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enj oined as above stated. Amount Due $90,432.52 L.L. Interest FROM 612/00 TO 3/3/04 (PER DIEM - $14.87) - $20,371.90 AND COSTS Arty's Comm % Due Prothy $1.00 Arty Paid $1917.74 Other Costs Plaintiff Paid Date: SEPTEl\>mER 25, 2003 CURTIS R. LONG (Seal) prothon04 e ~ .;ay: n ~ L . 'CfVLt:l.t.f Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIllA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 ~ili~Ml:\-5OI~"'"""""".''''''''_1tt~'U~'''''"'''''"~!!'~05k<tM"''':':''''\~'O'',"'^,;;':MI~t~"d,,-l;h"'k",~_~~l>""'~~. [" '-.'i~~~" ' -1iiI~~liill>r"- ,'~ " -" ~ -r . ~I Ii Real Estate Sale # 33 On November 18,2003 the sherifflevied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA Known and numbered as 508 Porsha Terrace, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 18,2003 ~ By: Real Estat Deputy ~.. ~ ;g li;;i V'IN't^lJ-SNiDd :" "l c:~ \ --\ ;"~ V ~ EG. ~\d LE Z GZ d:lS ,.".-' .)l'-~ ;,;'j'ljwno 111l,,,,j ,dO< ' , , '.:1.:10 JJI1l3l1S 3,,130 ,01 ~ II; ,~ . >.-" "I "- THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the 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 Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and publiShed in their regular daily and/or Sunday! Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. 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 Dau 'n in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #33 ................... ........... ...................................~......................... Notarial Seal T 81lY L. Russell, Notary P ie City Of Hanisburg, Dauphin My Commission Expires June 6, 2006 Member. f'ennsYlvanle Assocle1lon or NcteIteII commission expires June 6, 2006 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 309.43 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav 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. By.................................................................... " ". ,-~, "~ ESTATE SALE NO. 33 Writ No. 2000-348 Civil Principal Residential Mortgage, Inc. vs, Justin B. Gourley, Richard K Gourley and Diane M. Gourley Atty.: Frank Federman ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Bor- ough of Wormleysburg, Cumberland County, Pennsylvania. bounded and described in accordance with the Amended Final Subdivision Plan No. 1 entitled "Foxcroft", prepared by Michael C, D'Angelo. RS" dated August 7, 1971. last revised on July 17. 1984 and recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County in Plan Book 46. Page llO. as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said divid- ing line intersects with line of land designated as F.R.a.A. #5; thence along F,H.O.A #5, North 61 degrees 49 minutes 47 seconds East. a dis- tance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall. South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to Une of Lot No. J-6; thence along Lots Nos. J-6 and J-5. South 61 degrees 49 minutes 47 seconds West. a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West. a distance of 90 - feet to a point. the place of BEGIN- NING. BEING Lot No. K-4 on the above Plan and being known and num- bered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275. TITLE TO SAID PREMISES IS VESTED IN Richard E, Gourley and Diane M. Gourley. husband and wife, and Justin B. Gourley, Their son, single. as joint tenants with right of survivorship between par- ents and son by Deed from Scar- borough Real Estate Fund 85-1. a PA limited partnership dated 9/29/ 1997 and recorded 10/3/1997 in Deed Book 165 Page 697, . , -:~ ~, 1_. ,_c PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and . State aforesaid, being duly sworn, according to law, depos'es 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 ofthe said Cumberland Law Journal on the following dates, VlZ: Jj\~ARY 16,23,30,2004 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 statemr.nts as to time, place and character of publication are true. - SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004_ N SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 i I I -. '" ~'"'.. ". ~- "' ..1. ,,;~ -',j; nv.':d a 0 ~-. i:l 00 n '0 ;c rr ffi~ - r' - ~ _ c .0 . ~ ~ ; 0 ~"T'I~C:: ooCl)Z ,.,,:a>O "';IE"''''' ,..,,,,,,,,c: ><~:e< ~i!j I. n-no ll1 (j" H> :=:oS::n i!!.." cr' n CD ~ (!l CD " ~ I-l 0 '"t;jo"""H) >!1i g; st- ....... (tl p.. CD .....l(1l n "0 o~ 0 '"1 _" " 0 Wll1~st- (1)~O n6 Jg !1i (1) ~. ,~' , '~- (Rule of Civil Procedure No. 236 - Revised) Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) ^ Notice is given that a Judgment in the above captioned matter has been entered against you on June .2000. By.At'V1.D. 2~~'(t.r15EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PillLADELPlllA. PA 19102 (215) 563-7000 "TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** - , . - ~\ ~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 . (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. 711 High Street Des Moines, IA 511392 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley 508 Porsha Terrace Camp Hill, P A 17011 : NO. 2000-348 Civil Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Justin B. Gourlev, Richard E. Gourlev and Diane M. Gourlev. Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service chereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 1/1/00 to 6/1/00 $88,070.20 $2..362.32 TOTAL $90,432.52 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. (j~ ~1--- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE:, t. \r ;;; ;)~O /s;/(l1/27f.- ~ f2- I 'PRO PROT "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL P~S~~S~~I~I MORTGAGE, INC. ~nfTP"" rj'C" r0MI\Jf("'.'f\1 ~~~.7'i_.'3 CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant(s) TO: JUSTIN B. GOURLEY 508 PORSHA TERRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A. DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this 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 CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff .L. ~ .", >~ fEDERMAN AND PHELAN frank federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY fOR PLAINTIff PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: RICHARD E. GOURLEY 508 PORSHA TE:RRACE CAMP HILL, PA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED. A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by atcorney and file in writing with the court your defenses or object~ons 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 properc:y 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: CUwffiERLANDCOUNTY CUMBERLA."ID COUNTY BAR ASSOClA TION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ~ - ,.. ',--'e"i ( FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL RESIDENTIAL MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL TERM Defendant TO: DIANE M. GOURLEY 508 FORSHA TERRAC~ CAMP HILL, FA 17011 DATE OF NOTICE: MAY 17. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 wi thin 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ...- ~ . FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY CUMBERLAND County NO. 2000-348-CIVIL ORDER AND NOW, this I () day of --1lf r:l\ l ,2000, upon consideration of Plaintiff's Motion and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED chat Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address. and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who \\ill file with the Prothonotary's Office ill'1 Affidavit as to the mailing. BY THE COURT: JS) ~M1 j .1/,f)()/ J. ,-I, I , FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff Principal Residential Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Justin B. Gourley Richard E. Gourley Diane M. Gourley : NO. 2000-348 Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that che defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Justin B. Gourley is over 18 years of age and resides at present whereabouts unknown. (c) that defendant Richard E. Gourley is over 18 years of age, and resides at present whereabouts unknown. (d) that defendant Diane M. Gourley is over 18 years of age, and resides at present whereabouts unknown. This statement is made subject to che penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to auchorities. ~~~ FRANK FEDERMAN Attorney for Plaintiff < . _ j -~- .--, ,.-- ~ -" ;," , ~- , CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CITIMORTGAGE, INe., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, No. 2000-348-CIVIL v. JUSTIN B. GOURLEY RICHARD E, GOURLEY DIANE M. GOURLEY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $90,432.52 Interest from 6/2/00 to SEPTEMBER 7, 2005 (per diem -$14.87) $28,609.88 and Costs TOTAL $119,042.40 ~~fi.~r~ DANIEL G. SCHMIEG, ESQ One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ~iIll~_.iIj~~1~~~~~";"~"''''.'' "' - ~--~-, <" ,~" " = " ,"-~,"'>~,.~ -. === I/'ll/'ll/'l === r--r--r-- ........ .... <<< i:ldl. ~ g~g ~ ~ =:l=:l=:l 000000 UUU ~~~ === "",< UUU Z ~~~ o~ ~~ 0 .. ~~~ 00> ~ ~ . E-< <... O"U ~ [;0;1>< OO~~ ><~>< U ~~~ "'00 00 ~ " ~'F ~Z [;0;1 [;0;1 ~ ~~~ Zz U~" [;0;1~[;0;1 [;0;1 = .~ 0[;0;1 UO< ~~~ '" 1:1 [;0;1[;0;1[;0;1 "'" 0 ~~ ~~~ ~~ ~E-<" ~O~ 0-': OO~E-< '" 0,,0 ... .. . .... 000000 O~ ~ [;0;1 ~ <Ii " ." ~~ ~;, ;;; UZ U"O .. . [;0;1 . 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DESCRIPTION ALL THAT CERTAiN lot or pi~ce of ground with the improvements thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance wich the Amended Final Subdivision Plan No. I entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7,1971, last revised on July 17,1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.H.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall. Souch 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and 1-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Ta."{ Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a P A limited partnership dated 9/29/1997 and recorded 10/3/1997 in Deed Book 165 Page 697. Property: 508 PORSHA TERRACE CAMP HIILL, P A 17011 ,.... 'J~ UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN THE MA TIER OF: CHAPTER 13 ruSTIN B. GOURLEY Debtor CASE NO. 1-04-bk-01219 MOTION TO DISMISS ORDER AND NOW, at Harrisburg, Pennsylvania, in said district, upon consideration of the Trustee's Motion to Dismiss the case and Objection of Property Management, Inc. thereto, and after notice and hearing, it is hereby ORDERED that the above-captioned bankruptcy be and hereby is dismissed. BY THE COURT, ?2~~~~~ Date: March 11,2005 This electronic order is signed and filed on the same date. - . j APR- 7 20~ ~ FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 PRINCIPAL RESIDENTIAL MORTGAGE, INC. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. CUMBERLAND County JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY NO. 2000-348-CIVIL AND NOW, this I() ORDER day of ----11-r R'I l , 2000, upon consideration of Plaintiffs Motion and the Affidavit of Reasonable Investigation attached chereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JUSTIN B. GOURLEY, RICHARD E. GOURLEY, and DIANE M. GOURLEY, by mailing a true and correct copy of the C~mplaint by certified mail and regular mail to the defendant's last known address, and to the mortgaged premises located at 508 PORSHA TERRACE, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to t'Ie mailing. BY THE COURT: l5/-10rWi j. i /) /).J J. PHELAN HALLINAN AND SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 2000-348-CIVIL JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant o Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1Y~JjJ~ DANIEL G. SCHMIEG, QUIRE Attorney for Plaintiff iiI'" -"'~-IiIIa!.'~"~-""~' lIIl :.s. ,~. ""i!.Wit;lill;!ct:iil.....in~~il liIItillilIi~ ......... . ""~ , , ~ ' (') "" = 0 C = -n ~~ c.M "-alL :::lI: -l rn-,i! :>> :r:" 7,/ ,~~ -< m- :ZE'~ r -om en ,"E~ 0 ::nO -<.-.' 0' C:CJ -....0 -, ",. Xli ~~, .....- 0"" )';:0 - -~.(') C ill Om ~ -! C) ?l; '-, w -< ... . CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION .ruSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). NO.2000-348-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CITIMORTGAGE. INC.. SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .508 PORSHA TERRACE, CAMP HILL. P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PROVIDIAN NATIONAL BANK C/O PMI, P.O. BOX 662 LEMOYNE, PA 17043 295 MAIN STREET TILTON, NH 03276 FOXCROFT HOMEOWNERS ASSOC. j', , ~, ' ,~ ~ . . 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) Tenant/Occupant 508 PORSHA TERRACE CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 LAWRENCE G. FRANK 2023 NORTH SECOND STREET HARRISBURG, P A 17102 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. May 6. 2005 DATE fJ~Jlj~ DANIEL G. SCHMIEG, QUIRE Attorney for Plaintiff o -*'bl~_l_ 1~1iII~ ..""'".,"......, "'''''''iiiIiiIlo''--''''' "~~=< ~ A~_ illIiol:iDl ~o..dWil c" ",'. ..(- Ii!" .. < , ~ 0 N 0 = C = -n S-: c.n vl;:~ :JJ:: :r!:n :;I]~~L :,:~ -< me- ::;7r -. :rz:rn ~~~ 0 06 r-,..-. ~(~~~' ::::ili :l:>o ~L-t"l- :s: c::)__ ;-:;(0-':;, "_0 :t>c: <0 om ~ -I ....~ J> ".:<:? 0 CD \D --< ~ ",' - [ CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INe. Plaintiff, CUMBERLAND COUNTY No. 2000-348-CIVIL v. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). May 6, 2005 TO: JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY." Your house (real estate) at, 508 PORSHA TERRACE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 7, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$90,432.52 obtained by CITIMORTGAGE, INC.. SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 need 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. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ~. - f DESCRIPTION ALL THAT CERTAIN lot or pi(:ce of ground with the improvemeuts thereon erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended final Subdivision Plan No. I entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern corner of Lot No. K-4 set on the dividing line between Lots Nos. K-4 and K-3 where said dividing line intersects with line of land designated as F.R.O.A. #5; thence along F.R.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, Souch 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3; chence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. . BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband. and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1. a P A limited parmership dated 9/29/1997 and recorded 1013/1997 in Deed Book 165 Page 697. Property: 508 PORSHA TERRACE CAMP HILL, PA 17011 < ,,.. _II' ~' 'llill~~L -~- ~ '~"ri" 'w" .' -_",_o:..~. - "' (") c: ?: "'Cl..-;c: rnr';:! Z"':f_' ~fc ~c; beJ >c: z -';J -~ ,..., = = c.n z ::c o \ , :l:'" Z ~ ?i,~ -oe:3 5L c-;O .....,--'1 L-n r"'\-~' ~~O ,~"-m o -\ ?i; "< ...0 .. o o.,J;) 11 '"' ,J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL V ANlA) COUNTY OF CUMBERLAND) NO 00-348 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From JUSTIN B. GOURLEY, RICHARD E. GOURLEY, DIANE M. GOURLEY (I) 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 accouot ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is fouod in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $90,432.52 L.L. Interest FROM 6/2/00 TO 9/7/05 (PER DIEM - $14.87) - $28,609.88 AND COSTS Arty's Comm % Due Prothy $1.00 Arty Paid $2,772.44 Other Costs Plaintiff Paid Date: MAY 10, 2005 (Seal) CURTIS R. LONG :;,thZn~ o. f? ~/?/7AiA/ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQillRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 62205 liir ~""- ~ o ~ . -, ~~ "~' "~""'._."'., -' ...' , ~ -- " ~"~j ~ . I ,~ r PHELAN HALLINAN & SCHMIEG, LLP By: DANIEL SCHMIEG, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY No.: 2000-348-CNIL vs. JUSTIN B. GOURLEY RlCHARD E. GOURLEY AFFIDAVIT () ~~ ,1;c,;.. q;(f~ ----;;-- ~~:~!. ~ c:: :_~ ~ I hereby certify that a true and correct copy ofthe Notice of Sheriff Sale ii ~e a\jye .'J> c""": ;:= .,.. .......) captioncd matter was sent by regular mail and certified mail, return receipt request~, to~ -k 0') JUSTIN B. GOURLEY, RICHARD E. GOURLEY and DIANE M. GOURLEY on 5/16/05 at 508 PORSHA TERRACE, CAMP HILL, PA 17011, in accordance with the Order of Court dated 4/10/00. Thc undersigued understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. . fL~ESQ~~ Date: May 23.2005 ...., = = en () TI H-;t ;::;,-'1 , .!~ :9~ JJS' ~J.~ ~C) ;'=::;rn .._~ .::....-, "'~J :< -"1-. :~ -0< ...._iIliiIirliill ~-"'~- .~~~'"- '~~l~ " . ~~~ "~li.lII'n~ '" n~" -. ~~....,.......~ ~ .el'- '-_ ~ ... Ii&.! ... #- , "1.. ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA PRlNCIP AL RESIDENTIAL MORTGAGE, INC. ) CNIL ACTION ) vs. JUSTIN B. GOURLEY RICHARD E. GOURLEY ) CNIL DNISION ) NO. 2000-348 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, DANIEL G. SCHMIEG, ESQUIRE attorney for PRINCIPAL RESIDENTIAL MORTGAGE. INC. hereby verify that on 5/6/05 true and correct copies of the Notice of Sheriff s sale were Served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: August 4. 2005 DANIEL G SCHMIE0~ ------ Attorney for Plaintiff < . ., ~ "'" t .. ~ CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION .JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). NO. 2000-348-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTlAL MORTGAGE, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,508 PORSHA TERRACE, CAMP HILL, P A 17011 . I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTlN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, P A 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFT HOMEOWNERS ASSOC. CIO PMI, P.O. BOX 662 LEMOYNE, PA 17043 PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH03276 . ---~ 1,-, ..' , ... 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 LAWRENCE .G. FRANK 2023 NORTH SECOND STREET HARRISBURG, PA 17102 I veril}> that the statements made in this affidavit are true and correct to the best of m" !,'Ciso,'!}l knowledge or information and belief. I understand that false statements herein are made subj<Xl Ie' ,he penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. May 6. 2005 DATE <fY~ JlJ~ DANlEL G. SCHMIEG, QUIRE Attorney for Plaintiff "'-"......L.....~".'"ii-ul."""' - - - ' Lk 0'" . . - . :9.:~ t""' 0>2: ....,~., ~ " - :;;: - - - - '" 00 -.J ~ Vo .,. w N ~. ",s;-a . - Vo W N - 0 . Z " " " f;~ = .. ., ~~ ~..= ~. ~ ~ ~ '"' ~s. ;l. ~ ,'j' ~ '" Z <: 3 cr CD .., C v ~ C ~ '" .." ~ n v z "'-0'" ~;3 C v ~ g;~1i@ ~ ~ ~ 0 0 0 . Kg ~ n C/l a C/l C/l ~ ~ ~ . 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(1l g'_. /, ~:;I ~S' ~~9ft > .Q ~ ;:,'0,' ~~ A .~o~ ......-" Z' ,~~~ 0". 0 . ~-"' <> !='~ t~~ :> ~ PlTNPlBOWES Ei::g 0'0 . o. $ 03.600 c:.;("J'O'pj 02 1A 3::(ll~cr" ~ E;;.og,li' 0004300317 MA Y 06 2005 e. 8 ~ MAilED FROM ZIP CODE 19103 lIiIi' "., , ~ ~> G~ - '~'b/,j"'Jj;,j_,~~_",~""""",-' ~ ~-- ~'~ ..........'.~."-,- -" ~-~~~.,' j""'."I.....,"'" (} ~ Q. c g;; ~ ;f\ 0: ~ ~~ r/' 'Z':l:' Ir:> zr" I ~~ ~':E. uJ ,<C' ~ ;;C::H ~g %~ - - ~ ""I U1 ~ N , 'I , ~ - " ~='"<c..~ c_. 0' "' "= , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Citimortage Inc is the grantee the same having been sold to said grantee on the 7th day of Sept A.D., 2005, under and by virtue of a writ Execution issued on the 10th day ofMav, A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 348, at the suit ofCitimortgage Inc against Justin B GourleV,Richard E,Diane M is duly recorded in Sheriffs Deed Book No. 271, Page 1138. IN TESTIMONY WHEREOF, 14ereunto set my hand and seal of said office this -3 day of ,,~~ ,- >4 ~~ "7 ,. ~ Citimortgage InC., successor in interest By merger to Principal Residential Mortgage, Inc. VS Justin B. Gourley, Richard E. Gourley and Diane M. Gourley The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-348 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 13, 2005 at 5:48 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 Justin B. Gourley, Richard E. Gourley and Diane M. Gourley, located at 508 Porsha Terrace, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Justin B. Gourley, Richard E. Gourley and Diane M. Gourley, by regular mail to their last known address of 1115 Jerusalem Road, Mechanicsburg, P A 17055. These letters were mailed under the date of July 01,2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 07, 2005 at 10:00 o'clock A.M. He sold the same for the sum 'of$I.OO to Attorney Daniel Schmieg for Citimortgage, Inc. flkla First Nationwide Mortgage Corp. It being the highest bid and best price received for the same, Citimortgage, Inc. fi'k/a First Nationwide Mortgage Corp. of 5280 Corporate Drive, MSI011, Frederick, MD 21703, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$I,083.86. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge $30.00 21.25 15.00 15.00 30.00 10.00 1.00 12.00 6.13 15.00 40.00 .~~ -........- .... Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 449.00 356.78 18.20 25.00 39.50 $ 1,083.86 Sworn and subscribed to before me This II e: day of (J~ 2005, AD. ~~ Pr ot ., "-"-, so~~'~~~~~ R. Thomas Kline, Sheriff _ .1. .J;..vA- 3b . (fi) (,VV'-' /,'Iv Wi 3D f (2u... Ii; "5 J -''-- ~'--~,-, .' ." CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. CUMBERLAND COUNTY }', 1. COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). NO.2000-348-CIVIL AFFIDAVIT PURSUANT TO RULE 3]29 (Affidavit No. J) CITlMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC.. Plaintiff in the above action, by its attorney, DANIEL G. SCHMlEG, ESQUlRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,508 PORSHA TERRACE, CAMP . HILL, P A 17011 . L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JUSTIN B. GOURLEY ]115 JERUSALEM ROAD MECHANICSBURG, P A 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, P A 17050 DIANE M. GOURLEY ] 115 JERUSALEM ROAD MECHANICSBURG, P A 17050 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FOXCROFf HOMEOWNERS ASSOC. C/O PMI, P.O. BOX 662 LEMOYNE, PA 17043 PROVIDIAN NATIONAL BANK 295 MAIN STREET TILTON, NH 03276 -- - d ^ '~', . ,. 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 508 PORSHA TERRACE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 LAWRENCE G. FRANK 2023 NORTH SECOND STREET HARRISBURG, PA 17102 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. Sec. 4904 relating to unsworn falsification to authorities. Mav 6, 2005 DATE 'iY~ JlJ~ DANlEL G. SCHMIEG, QUIRE Attorney for Plaintiff - . ~;, i .' CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY No. 2000-348-CIVIL v. JUSTIN B. GOURLEY RICHARD E. GOURLEY DIANE M. GOURLEY Defendant(s). May 6, 2005 TO: JUSTIN B. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 RICHARD E. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 DIANE M. GOURLEY 1115 JERUSALEM ROAD MECHANICSBURG, PA 17050 '*THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TffiS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at . 508 PORSHA TERRACE. CAMP HILL. P A 17011. is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 7. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street,Carlisle, P A 17013, to enforce the court judgment of $90.432.52 obtained by CITIMORTGAGE. INC.. SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 need 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 SA VEYOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distdbution of the money bid for your house 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 distribution is wrong) are filed with the Shedff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 BEI"OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction ofthe plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. -- ~.. - -"~. ~ .J .__ J '. DESCRIPTION ALL THAT CERTAIN loe or pi~ce of ground wim me improvements thereoll erected, situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended Final Subdivision Plan No, I enritled "Foxcroft", prepared by Michael C D'Angelo, R.S., dated August 7, 1971, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page no, as follows: BEGINNING at a point at the northwestern comer of Lot No. K-4 set on the dividing line between Lots Nos. KA and K-3 where said dividing line intersects with line of land designated as F.H.O.A. #5; thence along F.H.O.A. #5, North 61 degrees 49 minutes 47 seconds East, a distance of 24 feet to me dividing line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minures 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West. a distance of 24 feet to the dividing line between Lots Nos. KA and K-3; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of 90 feet to a point, the place of BEGINNING. BEING Lot No. K-4 on the above Plan and being known and numbered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275 TITLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley, husband and wife, and Justin B. Gourley, Their son, single, as joint tenants with right of survivorship between parents and son by Deed from Scarborough Real Estate Fund 85-1, a PA lintited parmership dated 9/29/1997 and recorded 10/3fl997 in Deed Book 165 Page 697. Property: 50S PORSHA TERRACE CAMP HILL, P A 17011 . ,... - -- - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-348 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC., SUCCESSOR IN INTEREST BY MERGER TO PRINCIPAL RESIDENTIAL MORTGAGE, INC., Plaintiff (s) From JUSTIN B. GOURLEY, RICHARD E. GOURLEY, DIANE M. GOURLEY (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 $90,432.52 1.1. Interest FROM 6/2/00 TO 9/7/05 (pER DIEM - $14.87) - $28,609.88 AND COSTS Arty's Corum % Due Prothy $1.00 Arty Paid $2,772.44 Other Costs Plaintiff Paid Date: MAY 10, 2005 CURTIS R. LONG (Seal) ProthO:& 2 ~ ----.!ly: 0/1 P , ';/( 17/ r {./ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHlLADELPffiA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No, 62205 __~..L..-~ -~" mill'"' ~. 1Iiiii'"'-. ~ fllJ~~~' ="~". ~ ~~~ , -" . Real Estate Sale #40 On May 11, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA Known and numbered as 508 Porsha Terrace, Camp Hill, more fully described on Exhibit "A" Date: May 11,2005 B~~~~ Real Estate Deputy ~. ~ r.::::::i ~ liiri1 filed with this writ and by this reference incorporated herein. (\ ,( d 0 \ ^ ~\\ S~~I . . _ _ i " ' 'c' -, . "';' \ ''-:, ';--: '~.',: \ ; :,; ';jd "}\jJ'1\\U::',),~"I' ~:r.:-;;:;'I'"J -\(\ '-11\l~I'C: '('1! CIl) ".11_',,' , .;J.:J oj,,,, _.1.- 1.- <~ ~- 'd l.o-' .....~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County ofDanphin} ss ;.;d-- - t< Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005. 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 Miscel aneous Book "M", Volume 14, Page 317, PUBLICATION ~ ,.? COPY SALE #40 NOT Y PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertisiug Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 356.78 REAL ESTATE SALE NO. 40 Wrtt No. 2000-348 Civll Citimortgage Inc., successor in interest by merger to Principal Residential Mortgage. Inc. vs, Justin B. Gourley, Richard E. Gourley and Diane M. Gourley Atty.: Dantel Schmieg DESCRIPTION ALL TIIAT CERTAIN lot or piece of ground with the improvements thereon erected, situate in the Bor- ough ofWormieysburg, Cumberland County, Pennsylvania, bounded and described in accordance with the Amended F'lt1al Subdivision Plan No. 1 entitled "Foxcroft... prepared by Michael C. D'Angelo, R S., dated August 7, 1971, last revised on July 17. 1984 and recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County in Plan Book 46, Page 110, as follows: BEGINNING at a point at the northwestern comer of Lot No. K-4 set on the dividtiig line between Lots Nos. K-4 and K-3 where said divid- ing line intersects with line of land designated as F.H.O.A. #5; thence along F.H.OA #5, North 61 degrees 49 minutes 47 seconds East. a 415- tance 01 24 feet to the dividlng line between Lots Nos. K-4 and K-5; thence along said dividing line and passing through a partition wall, South 28 degrees 10 minutes 13 seconds East, a distance of 90 feet to line of Lot No. J-6; thence along Lots Nos. J-6 and J-5, South 61 degrees 49 minutes 47 seconds West, a distance of 24 feet to the dividing line between Lots Nos. K-4 and K-3: thence along said dividing line and passing through a partition wall. North 28 degrees 10 minutes 13 seconds West. a distance of 90 feet to a point, the place of BEGIN- NING, BEING Lot No. K-4 on the above Plan and being known and num- bered as 508 Porsha Terrace. Tax Parcel #47-18-1302-275. TrrLE TO SAID PREMISES IS VESTED IN Richard E. Gourley and Diane M. Gourley. husband and wife, and Justin B. Gourley. Their son. single. as joint tenants with right of survivorship between par- ents and son by Deed from Scar- borough Real Estate Fund 85-1, a PA limited partnership dated 9/29/ 1997 and recorded 10/3/1997 in Deed Book 165 Page 697, Property: 508 pmRSHA TER- RACE, CAMPHlu., ItA 17011, :! ;..," ~ ~ ~ '.. ,'" ~ ~_ I "_,I '. , , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on tile following dates, VIZ: July 15,22,29,2005 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. TO AND SUBSCRIBED before me this 29 day of Julv. 2005 NOTARIA SEAL LOIS E. SNYDER. Notary PubliG Cartisle BolO, Cumberland County My Commission Expires March 5. 2009 .