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Home My WebLink About00-00663 ""'~- . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (7 1~) ~nl-7000 ATTORNEY FOR PLAINTIFF COURTOFCO~ONPLEAS CIVIL DIVISION NORWEST MORTGAGE, INe. 5024 PARKWAY PLAZA BOULEY ARD CHARLOTTE, NC 28217 Plaintiff TERM NO. :21T1FD - l(.3 ~ I~ v. CUMBERLAND COUNTY JOSEPH R QUESENBERRY JOANNE L QUESENBERRY 403 EAST MAIN STREET SHIREMANSTOWN, PA 17011 Defendant( s) nYTl, AcnON - T,AW MORT~A~F, FORF.CT,OSTlRF. NOnCF. "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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT 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 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 YE 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 Loan #: 1743161 .-1 ~ ~ L Plaintiff is NORWEST MORTGAGE, INe 5024 P ARKW A Y PLAZA BOULEVARD CHARLOTTE, NC 28217 2. The name(s) and last known address(es) ofthe Defendant(s) are: JOSEPH R QUESENBERRY JOANNE L. QUESENBERRY 403 EAST MAIN STREET SHlREMANSTOWN, PA l7011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 9/14/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1165, Page 458, By Assignment of Mortgage dated 9/21/93 the mortgage was assigned to PRUDENTIAL HOME MORTGAGE COMPANY, INC. which Assignment is recorded in Assignment of Mortgage Book No. 454, Page 816, By Assignment of Mortgage recorded 8/14/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 501, Page 982, 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 9/1/99 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. 0\11 M'-'-_ . "'~~~~..' 6, The following amounts are due on the mortgage: Principal Balance Interest 8/1/99 through 1/1/00 (Per Diem $14.37) Attorney's Fees Cumulative Late Charges 9/14/93 to 1/1/00 Cost of Suit and Title Search Subtotal $73,88821 2,198,61 3,694,00 IIL72 lliJlQ 80,442.54 Escrow Credit Deficit Subtotal 0,00 1O.1i6 1O.1i6 TOTAL $80,47320 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $80,47320, together with interest from 1/1/00 at the rate of$14.37 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. ,~~c FRANK FEDE , ESQUIRE Attorney for Plaintiff I ALL THAT CERTAIN lot or tract of land situate in the Borough of Shirernanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a, point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast corner of the intersection of Main street and Catharine Street at the southeast corner of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly SO feet to a point; thence southwardly at right angles to said alley 150 feet to Main Street; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. ~l,JK ~ 3G '", 8'24 k~" -....... . VERIFICATION TIMOTHY O'BRIEN hereby states that he is ASSISTANT VICE PRESIDENT of NOR WEST MORTGAGE, INC. (NC) mortgage servicing agent for Plaintiff in this matter, that he 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 his knowledge, infonnation 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. TIMO ASST. DATE:*lno I. - ", . . , . 7 .... ~fJJ (;) .} ~ 0 ~ . r- I 10 r ~ 0 c - r' - .:;~". c' 9 ","<< -r "C",. . ~ rd'" -" ~ . &i ~ ..c; p; q\ "'I ~ ;o'C) ~ ~. '''1. $8 C CJ 2: ::< &:- t; ~ t ;r;;~ _.~~ -"- 'I ";1 :-iiiJI .~~[~'8 =:10 (j-ri ::,:0 Om ;;,"'! 55 -< (~ " 6"' ro . er, ?4. . ~ P ~R t CI ~ t r - - " ~ f - u:,~- ~ ""~-~~ ,~ , SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00663 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORWEST MORTGAGE INC VS QUESENBERRY JOSEPH B 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 QUESENBERRY JOSEPH 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 , QUESENBERRY JOSEPH B RETURN NOT FOUND AS PER ATTY 3/1/00. Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 18.00 8.06 5.00 lO.OO .00 4l.06 ~~ ~- R. Th~mas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this ;;J,JAA- day of ~ ~ A.D. ~J'O_)~ ~ Pr t onotary I -oj SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00663 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORWEST MORTGAGE INC VS QUESENBERRY JOSEPH B 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 QUESENBERRY JOANNE L 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 , QUESENBERRY JOANNE L RETURN NOT FOUND AS PER ATTY 3/l/00. Sheriff's Costs: Docketing NOT FOUND RETURN Affidavit Surcharge 6.00 5.00 .00 lO.OO .00 2l.00 s~ R. .h~as Klin~/ .. . Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this ~JM day of ~ d-o-uv A.D. n"..4'O"~ I~ ~J~tary -" " ~ ~~i<~.o~ - - >. . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (71 'i) 'ifil-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 Plaintiff TERM NO, cl-Inrr:J - (,.l.. ,:, ~ ,. ~ v, CUMBERLAND COUNTY JOSEPH B, QUESENBERRY JOANNE L QUESENBERRY 403 EAST MAIN STREET SHIREMANSTOWN, P A 170 II Defendant( s) CTVTT. ACTION - LAW MORTGAGF FORFCT.OSTTRF NOTTCF **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, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT 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 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 VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan#: 1743161 TRUE COPY FROM RECORD In Testimony whereof, I hire unto 98l my llano and tile seal of said Court at CaI1IsIe, PI. This tf ~ of,~ ~&VV. , ..J Q, .~ . 0 Prothonotary 1""""- " . . I , , 1. Plaintiff is NOR WEST MORTGAGE, INe. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 2. The name(s) and last known addressees) of the Defendant(s) are: JOSEPH B. QUESENBERRY JOANNEL.QUESENBERRY 403 EAST MAIN STREET SHlREMANSTOWN, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 9/14/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1165, Page 458. By Assignment of Mortgage dated 9/21/93 the mortgage was assigned to PRUDENTIAL HOME MORTGAGE COMPANY, INe. which Assignment is recorded in Assignment of Mortgage Book No. 454, Page 816, By Assignment of Mortgage recorded 8/14/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No, 50 I, Page 982. 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 9/1/99 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 . , 6, The following amounts are due on the mortgage: Principal Balance Interest 8/1/99 through 111100 (Per Diem $14.37) Attorney's Fees Cumulative Late Charges 9/14/93 to 1/1/00 Cost of Suit and Title Search Subtotal $73,888.21 2,198,61 3,694.00 111.72 .iiO.illl 80,44254 Escrow Credit Deficit Subtotal 0,00 1QJi6 1QJi6 TOTAL $80,47320 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $80,47320, together with interest from 111100 at the rate of$14.37 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. /~/ Frank Fp.np.mum FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff " j"-,~~ , ALL THAT CERTAIN lot or tract of land situate in the Borough of Shiremanstown, County of Cumberland and Sta.te of pennsylvania, more particularly bounded arid described as follows, to wit: BEGINNING at a point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast corner of the intersection of Main Street and Catharine Street at the southeast corner of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point;, thence southwardly at right angles to said alley 150 feet to Main Street; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. ~vJK~3G-- 8?4 ...... -...... ,- . , VERIFICATION TIMOTHY O'BRlEN hereby states that he is ASSISTANT VICE PRESIDENT of NORWEST MORTGAGE, INC. (NC) mortgage servicing agent for Plaintiff in this matter, that he 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 ofhis knowledge, infonnation 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. DATE:(;A~ IOU TIMO ASST. J , I i"'" ~ , ~~m " (0'fii=\lit;-F. 'n;F "T:~_: {:r.:l'~'~, ',~ '~.rE;~,i!:r:f ,~.'~f f Ell 4 ~ 1Q f:j~ 'urn PEi-'ll:--,' '..'i ,~:";', i ,,;.. ~~!N__ ijI:lIIl!"'1W"*",_,,w;f_'ji'",;<'7,-:;;,;Wt";;l~~fl~1~~m.!I!I!!!l ~I~ ~ --~~ ,. -~ ~~ ~~ -< "" ",-"l",_~_,,; . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 TWO PENN CEN-TER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? 1 'i) 'i11'1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 TERM Plaintiff v, NO. ;2 (Jlj<:) - (. (. ~ (2.;,u TLv- CUMBERLAND COUNTY JOSEPH B, QUESENBERRY JOANNE L. QUESENBERRY 403 EAST MAIN STREET SHIREMANSTOWN, P A 17011 Defendant( s) CTVTT, ACTION _ LA W MORTGAGF FORFCT,OSTlRF NOTTCF "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 REAFFffiMED, 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. ** 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, We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN ANO PHELA'" CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan#: 1743161 TRUE Copy FROM RECORD In T estimooy whGroof, I !llln, linl!) :>m my hand ilnd the seal at said ~lilsie. Pe. Th.IS ~ .ri""~. o2ewO . ,,::'b . # - 'f. Prottlonot2uy ~._~~ '. J ~ ilIloiiIlI~'~ l5lJoJl! ~""''' . L Plaintiff is NORWEST MORTGAGE, INC, 5024 PARK WAY PLAZA BOULEY ARD CHARLOTTE, NC 28217 2. The name(s) and last known addressees) of the Defendant(s) are: JOSEPH R QUESENBERRY JOANNE L QUESENBERRY 403 EAST MAIN STREET SHIREMANSTOWN, P A 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 9114/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1165, Page 458. By Assignment of Mortgage dated 9/21/93 the mortgage was assigned to PRUDENTIAL HOME MORTGAGE COMPANY, INC, which Assignment is recorded in Assignment of Mortgage Book No, 454, Page 816. By Assignment of Mortgage recorded 8/14/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No, 501, Page 982, 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 911/99 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, " ~how~ - ~\ ~ 6, The following amounts are due on the mortgage: Principal Balance Interest 8/1/99 through 1/1/00 (Per Diem $14.37) Attorney's Fees Cumulative Late Charges 9/14/93 to 1/1/00 Cost of Suit and Title Search Subtotal $73,888.21 2,198.61 3,694.00 111.72 5.5Jl.illl 80,442.54 Escrow Credit Deficit Subtotal 0,00 3illl!i 3illl!i TOTAL $80,473,20 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, WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $80,473.20, together with interest from 1/1/00 at the rate of$1437 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. /,,/ Fr::mk Fenerm~n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ , , ~" . ALL THAT CERTAIN lot or tract of land situate in the Borough of Shiremanstown, County of Cumberland and state of Pennsylvania, more particularly bounded arid described as follows, to wit: BEGINNING at a point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast corner of the intersection of Main Street and Catharine Street at the southeast corner of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point;, thence southwardly at right angles to said alley 150 feet to Main Street; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. """\3G .. "';'4 L'uu!\ ,\J 0 .. _...., """ -- ~ .' l:l!olrillltii,tili!;,e , VERIFICATION TIMOTHY O'BRIEN hereby states that he is ASSISTANT VICE PRESIDENT of NORWEST MORTGAGE, INC. (NC) mortgage servicing agent for Plaintiff in this matter, that he 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 his knowledge, infonnation and belief, The undersigned understands that this statement is made subject to the penaities of 18 Pa. c'S. Sec, 4904 relating to unsworn falsification to authorities, TIMO ASST. DATE:~ln() , , ji,!!) l'!I!!,_"'"""y"..11lt~....,,, ,...~"'''''' CfF:!t_r--._ 11~-r ~" '1,- .", '. ':""., - .;-}"l'-t,;:~::{~',:!flF ','-<." FEll Y Dr- , ~ L i'_ 4 10 Pil '00 , ,--;, , .. ~ ". j , Il~, ,.\~""~~~_.,' ~~,",;l.~~miI~~_. ~ " 1 , , 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 NORWEST MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JOSEPH P. QUESENBERRY JOANNE L. QUESENBERRY Cumberland County Defendants No. 2000-663-CIVIL TERM 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. ~~ ~/o~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: March 29, 2000 ",-, _~d .dirl~~' "lnUiIiiWAI- ~''IIiilII.lilliil!llll!U~. ~,~ - ~-.--~- j"- .. -.~liiI " ~t b S2 0 c ~ " s: '"," ---j -ocr' '-0 ::.-n rnrT\ :::v ,= Z'_'--' , _.~"]h1 ZI}:: if> -;'i'-,..-! Cf),..:,. .":::Jl--. -<.c_ ~~~ r::O ="" <:: 2;c! ::n:: ~u - orn >c - ~ z W :P' ::2 :D l'P -< J& ,. . ~~_;.c"", . . . , , $ D , "'. 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 \ NORWEST MORTGAGE, INC. Court of Common Pleas Civil Division vs. CUMBERLAND County JOSEPH B. QUESENBERRY JOANNE L. QUESENBERRY NO. 2000-663-CIVIL TERM ORDER AND NOW, this "'('" d f .. ay 0 m~ , 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), JOSEPH B. QUESENBERRY and JOANNE L. QUESENBERRY, 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 403 EAST MAIN STREET, SHIREMANSTOWN, PA 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 the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: Ii ~~~ , !-:-O:I~ , ,~ 'oe .' ,~^, , - ~ It .'v ., ~ FILEI}{)FFICE y .OF 1'1-:::: PI)0T', -!"WO"",AR" Y "-, - ',,' -"."" 00 "it~R 21 PH 4: 05 C'UI'\.'~;"~i,~t (} "'J'I\rrV 1.1....h.~, ,-,:..), '" l PENNSYLvANiA , -~~-- , , '....... ,'~""- ,,' ~- '-~~ ""'[; , ' 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 NORWEST MORTGAGE, INC. MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Court of Common Pleg~ Civil Division .t" ~~ ::tj'-' -''Z:1 '1\ CUMBERLAND County ;;I.,k; No. 2000-663-CIVIlgjliRM 'I ,,, Vs. JOSEPH B. QUESENBERRY JOANNE L. QUESENBERRY c ~i"1 'f,~ i: 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 403 EAST MAIN STREET, SHIREMANSTOWN, 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". I , ' ~ -; 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. Lisa ATTORNEY ~. burg, Esquire 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 NORWEST MORTGAGE, INC. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.2000-663-CIVIL TERM vs. JOSEPH B. QUESENBERRY JOANNE L. QUESENBERRY 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 Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gon7J'lle, 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." Anoption ofW"lker. 468 Pa. 165,360 A.2d 603 (1976), An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.FR 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'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(sl has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". - 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: enburg, Esquire r Plaintiff "-~ -L_ " . . MRR 08 2000 10:56 FR CUMBERLRND CO SHERIFF717 240 6397 TO 912155631581 . ~,I,j..L;.j."..l.j.:",. ..... .............""'.."". ............ _... ....-.- P.01/01 CASE NO: 2000-00663 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NORWEST MORTGAGE INC VS QUESENBERRY JOSEPH a R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent searoh and unable to locate ~ in his bailiwick. He therefore returns the COMPLAINT - MORT FORE / /NOTICE ;~I1'A , NOT FOUND I as to the within named DEFENDANT I QUESENBERRY JOSEPH B RETURN NOT FOUND AS PER ATTY 3/1/00. 18.00 8.06 5.00 10.00 .00 41.06 -..., Sheriff's Costs: Docketing service NOT FOUND RETURN Surcharge So County FEDERMAN & PHELAN 03/02/2000 Sworn and subscribed to before me this day of A.D. Prothonotary ** TOTRL PAGE.01 ** . MAR 08 2000 10:44 FR CUMBERLAND CO SHERIFF717 240 6397 TO 912155631581 SHERIFF'::; ,t.l.J::'!'U,t.lN - I~U'l r uu,""", P.01/01 CASE NO: 2000-00663 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ' NORWEST MOR'rGAGE INC VS QUESENBERRY JOSEPH a R. Thomas Kline. . ,Sheriff or Deputy Sheriff, who being duly sworn aooording to law. says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT QUESENBERRY JOANNE L but was unable to locate Her. in his bailiwick. He therefore returns the COMPLAINT - MORT FORE ~UiJ1"~ NOTICE , NOT FOUND , as to the within named DEFENDANT , QUESENBERRY ~OANNE L RETURN NOT FOUND AS PER ATTY 3/1/00. Sheriff's Costs: Dooketing NOT FOUND UTURN Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 So .. ,.:t'",,-:,~- ~,.....,.....-,.., . .~7 answe~,,") __ /.. ....._.-::-~,.,'.,,"""'., .~ .r .. ~~;~..;;;---'" . /' " ',;--.r ~ R. 'Thomas Kl ine - Sheriff of Cumberland County FEDERMAN & PHELAN 03/02/2000 Sworn and subsoribed to before me this day ,of A.D. prothonotary ** TnTAI PAGF.Rl ** ~" ~ -J- " ~,-:t- , PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 1743161 Attorney Firm: TRACK STARS Case Number: Subject: JOSEPH & JOANNE QUESENBERRY AKA: JOSEPH B QUESENBERRY, JOANNE L QUESENBERRY Last Known Address: 403 E. MAIN STREET SHIREMANSTOWN, PA 17011 Last Known Number: ( ) _ ~X/flqJrt Michael K Gross, being duly sworn according to law, deposes and says: 1, I am employed in the capacity of President for Players National Locator, 2, On 01/24/2000, I conducted an investigation into the whereabouts of the above named defendant(s), The results of my investigation are as follows: CREDIT INFORMATION- A SOCIAL SECURITY NUMBER: 211-34-8383 175-48-6982 B, EMPLOYMENT SEARCH: Unable to locate a good employer for Joseph. C, INQUIRY OF CREDITORS: The crediton; indicated that Joseph is living at 403 E Main Street, Shiremanstown, Pa. 17011 with no valid home phone number. Creditors confirmed that Joanne Quesenberry is deceased. INQUIRY OF TELEPHONE COMPANY - A DIRECTORY ASSISTANCE SEARCH: The directory assistance has no listing for Joseph and Joanne Quesenberry. Contacted 717-691-1852 and spoke with a relative who confirmed that Joseph is living at 403 E Main Street, Shiremanstown, Pa.17011. She also stated Joanne is deceased INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A NATIONAL ADDRESS UPDATE: As of January 20, 2000 the National Change of Address (NCOA) has no change for Joseph from last known address. MOTOR VEHICLE REGISTRATION- A MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Joseph listed at last known address. OTHER INQUIRIES- A DEATH RECORDS: As of January 20, 2000 the Social Security Administration has no death records on file for Joseph Quesenberry and or a.k.a.'s under his social security number. A death claim was filed for Joanne Quesenberry on March 11, 1996 under her social security number 175-48-6982. . =~ " ....... '\,~ \, ":""B, ,\~~" ... \...' PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC: ): None Found C, COUNTY VOTER REGISTRATION: The Voters Registration Office has Joseph listed at last known address. ADDITIONAL INFORMATION ON SUBJECT- A DATE OF BIRTH: Joseph 03/48 Joanne 05/59 ",.,- -2 c ~ - €tHl49Jf4 AFFIANT Michael K Gross "NOTARY SEAL" ~ Kristine M. scott., r':olary Public ~ SL Loui::; C::H.intv.Sj'~"-~f;!.Jf \;/1i32.ouri ~:,~~~~~.~~.::~~~_:~~,;,:~ '-,-p,.,--,~~ Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021 Phone: (314) 230-9922 Fax,' (314) 230-0558 V E R I F-I C'A T 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 8, 2000 enburg, Esquire r Plaintiff j' , . ---I ," -'" < , " . g 0 C> 0 'n "U~ ::J: :~:rl ". q;l rn :::0 I 1"""":';. _::0 ~~ ""'Of" (J'l l~~ -<-"'- !;20 -0 ~. ~8 :;rJ; .~~ :l>c r:? ~ w ~ '" !!"\. , FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff Norwest Mortgage, Inc. 5024 Parkway Plaza Boulevard Charlotte, NC 28217 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 2000-663 Civil Term Joseph B. Quesenberry Joanne L. Quesenberry 403 East Main Street Shiremanstown, P A 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Joseph B. Ouesenberry and Joanne L. Ouesenberry, 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 5/15/00 $80,473.20 $1,954.32 TOTAL $82,427.52 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. ~.w~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: (1? ay J lc., Jc)OO Is/ (2,,-;/;:;;.) 2. I PRO PROT **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TllAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** "'--- - ~~ -~~ ~ '"'~ - f - ~ . I ~d,- , 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 NORWEST MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS vs. CIVIL DIVISION JOSEPH B. QUESENBERRY JOANNE L. QUESENBERRY CUMBERLAND COUNTY NO. 2000-663-CIVIL TERM Defendant(s} TO: JOSEPH B. QUESENBERRY 403 EAST MAIN STREET SHI~STOWN, PA l7011 OAT]!: OF NOTICE: MAY 2. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMA'l'ION 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 CARUSLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ""~~~IM~ ~...........~~ "<.. ~--~ .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 NORWEST MORTGAGE, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JOSEPH B. QUESENBERRY JOANNE L. QUESENBERRY NO. 2000-663-CIVIL TERM Defendant TO: JOANNE L. QUESENBERRY 403 EAST MAIN STREET SHlREMANSTOWN, PA l70ll DATE OF NOTICE: MAY 2. 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, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff . ~, - ;ij;lJliIiollii,l,kj FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 JRNEY FOR PLAINTIFF /lfAR 2) 2000\ ~\ , '- NORWEST MORTGAGE, INC. Court of Common Pleas Ci vil Division vs. CUMBERLAND County J0SEPH B. QUESENBERRY JOANNE L. QUESENBERRY NO. 2000-663-CIVIL TERM ORDER AND NOW, this :J )St daYOf-4~,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), JOSEPH B. QUESENBERRY and JOANNE L. QUESENBERRY, 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 403 EAST MAIN STREET, SHlREMANSTOWN, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be BY THE COURT: IS/ /w.. j iML J. (i I I I I I i I I I done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. "".- ~~~ l .a~} . 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 Norwest Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Joseph B. Quesenberry Joanne L. Quesenberry : NO. 2000-663 Civil 'ferm 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 Joseph B. Quesenberry is over 18 years of age and resides at present whereabouts unknown. (c) that defendant Joanne L. Quesenberry is over 18 years of age, and resides at present whereabouts unknown. lbis statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~la- FRANK FEDERMAN Attorney for Plaintiff ,_.. . [ "be! . (Rule of Civil Procedure No. 236 - Revised) Norwest Mortgage, Inc. : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Joseph B. Quesenberry Joanne L. Quesenberry : NO. 2000-663 Civil Term Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on Mav 11..0 .2000. JO/>.< "P-7p07/?/f.' JDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SillTE 900 TWQ PENN CENTER PLAZA PHILADELPlllA. PA 19102 (215) 563-7000 **TIDS 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, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** iIIiIiIIIi "i!IiiiIII ..0...... 'th. . yoill;~1tim .,..~'~-.Q~iillil;lil~ ~ ~,'--"', ',I Ildiii;Iii . , C:J ~ t N .....Q 0 = 0 ~ c: 0 Tl j1:- 5 ?: 3': --; \"]0:1 :r~ ~1~~ mfn -.e -...m r z::::-; 66 Go -7~ -0 -V ~:!~:: 0't ~ ::~~rj CI1 S;:O v ,," ::!.l ~ ::I:: 00 ~ s- 28 Zm >J ~ t ):.--"c..:: J> \l.J' )J J z ;;- ~ ::< .z:- rt ~ ^ -~ ,-- ....J. , '" Norwest Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. No. 2000-663 Civil Term Joseph B. Quesenberry Joanne L. Quesenberry Defendant(s). May 24, 2000 TO: Joseph B. Quesenberry Joarme L. Quesenberry 403 East Main Street Shiremanstown, PA 17011 --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 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 403 East Main Street. Shiremanstown. P A 17011, is scheduled to be sold at the Sheriffs 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 Norwest Mortl!al!e. Inc. (the mortgagee) against you. If the 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 Sheriffs Sale, you must take immediate action: I. 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'_"",," <, ~-, ~ " " ~N~_~~_,""", -==. . -~- . , 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 00) 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT lIIA VE 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 0" ._ ___' ~M' , o b" ~, ~ '~ \ \ \ \ \ DESCRIPTION ALL THA T CERTAIN lot or tract of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast comer of the intersection of Main Street and Catherine Street at the southeast corner of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point; thence southwardly at right angles to said alley 150 feet to Main; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. TAX PARCEL #37-23-0555-298 TITLE TO SAID PREMISES IS VESTED IN Joseph B. Quesenberry and JoAnne L. Quesenberry, his wife, by Deed from Rosemary Robusto, single person, Isabella Robusto, single person and Delia Robusto, single person, dated 9/14/93, recorded 9/21/93, in Deed Book N-36, Page 824. _..b.~ _ill'. ilIiliilllI~~IIIiIiriwI~~~~[l~,ru.1&ciOl\'i.'",*,,1i!>_',M!,i"'!.!l'i!ilotliw,~'" '-.. ~ , - n--,,~~i' .........1 ~ ,~~~ ~. . f~ 0 0 0 -r, :x '-I .~ ",. a~-n -< to "'P -om ~e 0 86 i~ ~ g~ ::J: - .. 0 ~ c -< 'r ,;-~. ~~ ~~ " I FEDE~NandPHELAN By: F~FEDE~ Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF Norwest Mortgage, Inc. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION Josepb B. Quesenberry Joanne L. Quesenberry NO. 2000-663 Civil Term 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. ~~ ~~Al.AA ____ F K FEDE , ESQUIRE Attorney for Pia' tiff ~." ,_.l'~'~~~~M]:!~i1il!-~&..i>i'I\iili'_l;.;;Mi!.IKiMilr"' ...,~,~~" " 'iI .-~ --,-,-"...;,- li;-i .~ c:> 0 c:> -n :x :.:;J I ".. ,,";'--r'i -< ''fIF .~ {;;t) ~gx c:> (.... ,.<:. 3,( . .0' .." 6-r, . ::n ;f} :x ~O - am - .~ ~ c:> c:> "< ~ FEDERMAN AND PffEI.AN BY: FR1"NK .FEDERMAN .~. IDENTIHCATION NO. 12248 ATTORNEY FOR PI~l\INTIFF SUITE 900 - TWO PENN CENTER PLAZA PHILJIJ:lF;LPHIA, PA 19102 (215) 563--7000 Curril::",rland County Norwest Mortgagel Inc$ vs... Court of Comm.Ol1 Pleas aos(-::pb H5Quesenberry \Jcianne L ~ Q'tH?:sertt)e:rry " Civil Division ,j ; ., -~ vl!? ,j,' YEHI.EJC;ATIQt! I hel':eby c8.!::'t:i.fy that a true and. cor:!::"ect COP}' of' tJ~u::: t-.Jotice of Sherif:E f s Sall;~ in the a,bove c~':lptioned matter W'C),E:; sent by regul,a,r mail and c<",rtified mail, return receipt: requested, to the follo\,iing person (5) J'oseph B. Ques.elll>'?:rry and .."Joanne Ii,. Quesen.bE~.rr;{ on May 26, 2{}(jO at 403 E,~-st M:;3."iIi '--"Street Sh.LremanstO!l"/fl, Pa 17011 in ac:coT.'d.,;.1!1ce vlt th the Order. of (,~ourt dat(;:~df Nal~ch 21 f 2000_ .. i thdt t.his st;{i.te_mE:~nt .us ma,ciE:? c. S.. s.4 9tr4,\ re 1 d. t ing ..__.to(:.:;..... uns\I',ro t' n .."-'- . "'- "\ f 1_ \ I I ,//<;;/~:~.,,1...lr ..<::<ic~l:?C',"--,. y-.-... / ,f". I"n~'l.'.l.( "'El'i':'-RM";.1 . ..t'. .. r~~ 'I , .c c>_}t;. _-_hI. . 'I'he unde.rsigTled, un.d~-r~~a.nd,s SUb]9Ct to th.(;:~ p!:~na..ltl.es of 18 PA. falsificaton to authorities. /,." DATE: J'u:ne 9, 2000 r....------.-"-.....--."':.--'-.--;:-.....-~.-..:-----m-..:_!"~----".......-..... , IU rn <0 I "7''')'''', i~ .~ 3 tr ;"~' " , ;:r ""' o- r.>. ",',llii:;", f-lL.TUfiN -. }" RECEiP't. $ER'J!CE 'M::irr;,(r::fH~y~~tJf.~(Ir '.: ':': '::'-:':::,:' : -', . ~;f.'fmFI~i:' F\i(;: ,. C-lE'I1.If'.N ~1E,:c.:w'r '.\~")TN...PC;I'(~;E /Jill t'tt~l: OOf'f;)flilmi;Ff , <t.. 'ie,.':' ._........;j;._.......>,;;-.........------.--._'"._~....".:;.._.." POSTIlAA.~ OR 1m ";'-':-]:'::::',.. PE.~,,:1.>~ - C,'\. ~.\ ..,..(.~~ m :....... :~.~.r..& . '" S?- --:: '.-' ,crw, ,if Y~}.- ~~ .~3t10..", Receipt for Certified Mail /2 w .. o -, , '"'" >'" ZW ,"0: ~2 o.~ 120: ttffi ",0: ,",,- ~O' 1:!'"" ",=< ...~ : -a; u '"'" Iii!' ., '" ~ o .. l! m rn ,cO Cl ,-1 .tr ::r l'- IT" Q. ..'_.~ ~..-. ~-- ".-- JOSIlPB B. QUESEm"l1!lilRY ~3,J:IlST)W]l~: . ~~A1101i Di1l11~' ..'",'... ......._..'.,.'..-.... 1-'",",'..--.:-- ! PS FORM 3HO(l US Posta! Service ,', m.;Tl.!RN nE(;(lFT - - - - _: . R-I: Slr>,ii:11~("t1l:::W'\,'E""~ ' \~l-::fnnH, f'f.X t t\nUl1N m,['.rJPT -~'..-" " ' ~~i:.R\~CE .'Jb;i\0i<t)S'r,o.;~E ;.No__rk-~.s: ,,-:~\::~:',:::.~:,:.~":I'..:':'.-~;': ;)..0 .' 1~'7N~T~:.,b~::~t~~'''~.!"...,~..:. Jo.AmIR L.Q~DE't ltO,ISAS'lM1;N1mJr,r SllIIfJ'.tUlS'l'OloiX.,,,,UOU '0 WI \<;.. "- !'..--"~, ".-., 'j'''' -F:i;FORrA~l8QO-- U~P()st~-;.;-~--'-'--ReceijJtfOr- Certified Mail I:! 1 w , :5 1 cd q) ~ >'" ffi~\ u.ct o"i \3%" l-~I ~t-l €r:~l ~~? ~~L ~~\ . u.~t '" I ~ i: a:: I' ~ I ;j i { '". .__......__".._.-'".__...._~~_..._...,,__'~.-,_......-..___ '"._.._.~ :_.___~.__., ____ __~_. ~ .. h _,. _.__ .~ -..- ... -.. ""-- - ~,..-. -~~ FEDERl.IAN AND PHELAN BY: Lisa D. Blankenbu:cg, Esq.. Attv. I.D. *78020 . 5te: gOO/Two pennCente:c Plaza Philadelphia, FA 19102 J.gJJ;) 563-7000 NORWEST MORTGAGE, INC. ')HNEY . FOR PLP.IN'rIFF MAR 2 1 2DDO\ .. ................ ...~S' .- Court of Common Pleas Civil Division vs. CU!1BEHLAND County JaSEPH B. QUESENBF;RRY JOANNE: L. QUESENBEEIRY TERM . ... ORnER . AND NOW, this ,.;} )S~ . day Of~fl.l.{jL~ 2000, upon consideration of Plaintiffs Motion and me..Affid,lvit of Reasonahle Investigation attadled thereto, it is hereby ORDERED that Plaintiff may obtain seryi<;e.ofth~Complailltontheab()ve captioned Defend<ll1t(s}, JOSEl'H B. QUESENBERRY and .JOANN.E L. QUESENBERRY, by mailing a true and correct copy ofthe Complaint by certified mail and regular mail. to the defendmlt's 1<1.:;1 , - ,-.:.._'........:.."-,-.-'--...--, -,',. .'. . - "-' " . . . - . . known address, and to the mortgaged premises lOCated at403 EAST J\iLUN STREET, SIfIRE"'L<\NSTO\VN,PA liOn Service of the aiorementioned mailings is effective upon the date of mtliting and is to be done by Plaintiffs attorney, who \vill :file with the Prothonotary's Office an Amdavlt a.~ to t.lje mailing, BY THE COURT: ~;I. i,^-^) _ J, __~ ,,, J.,....o~lUfii~~litiIlII:iaIt"'"'~. ~~" jfJUl~iOIUj~'~r '1 .i.l tr'll" -. - ~ . -, ,'".;~.",~'" '.~ " ev_ ~~ ~~, '&Ii'" ,/ , 0 CJ () C c.:> ;;;: "n U D.~' '- n1 r-- n-~ ::E ~ :c: ;-;"1 ~ Z C- c, Cf) ,', 'LJ ~ ~et . .- , ~r -0 ~::) >':c -T- (, ::r: ";--c~ ..e:...c"" ~~f~ )> 3 (.0 c: Z '~.-" ~~'j --I c- P -<; c.:! ;:0 -< ~'" ~ .. ~~ " . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Norwest Mortgage, Inc. Cumberland County Plaintiff, v. No. 2000-663 Civil Term Joseph B. Quesenberry Joanne L. Quesenberry Defeudant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $82.427.52 ,/ Interest from 5/15/00 - 9/6/00 $1.544.70 and Costs (per diem - $13.55) $83.972.22 TOTAL FED TW PENN CEN SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. ~ I , I I I I Ir~ .. ~ "'!j "'Ii ~.... ~. ~ ;~ - p,. " @ p,. '" l"'1 l"'1= ;; ~ ~ g:l~ .... j~ ~... :z 'l~ga~~ c:o ~o (1) ~ ... (,H tt:I c:o "'J ~ ~ ~ ",,"'''l'''1'" ~o ==og el~ ,.., III '" '" 'CI ~ =- ... ""aa~=- a:::e '" ~>-3 (1) (1) ~ '" .... ~ C2~=~~ ~~ r!= ~ 00 S;g.~tO tOtO -< c:o ~~ - ,. .., 'D ~ " :E ~. = ~ >-3 = = .... '" == '" '" '" IJQ >-30 'D g"~J= oo~ ~ 0 '" '" III ~~ 'D '" '" IJQ > ",c:o~;ig. o"'J == == ~'" ~ l"'1 =-=- !:l ,,= '" '" '" '" .... l"'10 <ftl-04......''''t ~~ " " 1:1 g.(j'" ~ ~~ !" ~~ . == s ~ 00 "'Ii 6.... (j ts~ ~ >-3 .... <> 00.1>.... 0 ~~ == =-=c:o ~ .,. (H ~ ~ l"'1 == ...."'J El ~ == > '" '" ~ ... t"' '" a::' S'~tO :E ~. = == == '" '" rJj ~ "'Ii~== >'"=- '" '" ......." ~ ~ .... .... j ~ """""W~""~~,"_~I!II':~nf_~ . ,.~ , ~lIII!lt _~, 'l15!:,i!!J!lIm:ll~!>!"1"~j8'"-",,.-'j;;:'f<i"'''~''"~'''I'''~~1'l~~~~'"",,W:<<l!"'!4ilI,~T,jI~~:~j~!!;lilJlI~1' ~~. " '" ~, '. - -' I. . \ \ \ \ \ \ DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast comer of the intersection of Main Street and Catherine Street at the southeast comer of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point; thence southwardly at right angles to said alley 150 feet to Main; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. TAX PARCEL #37-23-0555-298 TITLE TO SAID PREMISES IS VESTED IN Joseph B. Quesenberry and JoAnne L. Quesenberry, his wife, by Deed from Rosemary Robusto, single person, Isabella Robusto, single person and Delia Robusto, single person, dated 9/14/93, recorded 9/21/93, in Deed Book N-36, Page 824. ~iIiMl~~~j - ~"< .~O -__,r..<"liillr<l,,;J~>ili;jHill~~!llIl'fl r~ "'J 'll \J.; '" '" " \ ~~ \ '...w."",~". ~", ~~ "L ~ ~.. o o :s:: 3'" -< b) o " . ,~ 0,: -n ---l :J:-n -f:]")F: ~9 :..'? -0 ::c;;;.t :s:: 0-:- N ~~ .. ,;:;..t- ~ ~ ~ ~ 1 t: --- \ ("l ~\~ ~ :-- ~ -.!:: ~ "- ~ ~ :'- :-0 !'\ ~\ c::. <::. ~ ct E;' .. ~ r ~: , ~' " FeDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102 (71 'i) 'ifi~- 7000 NORWEST MORTGAGE, INC. Attorney for Plaintiff : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. JOSEPH B. QUESENBERRY JOANNE 1. QUESENBERRY : CUMBERLAND COUNTY Defendant(s) : NO. 2000-663-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT RV MATT, PTJRSTTANT TO COTJRT ORnF.R 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 JOSEPH B. QUESENBERRY and JOANNE L. QUESENBERRY at 403 EAST MAIN STREET, SIllREMANSTOWN, P A 17011 on A PRTT, 10,2000, in accordance with the Order of Court dated MARCH 21, 2000. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S, 94904 relating to unsworn falsification to authorities, Date: April W 7000 .-;::;-~ ::;.-~ FRANK FEDERMAN,ESQUIRE Attorney for Plaintiff . ".," .~"". ~>=<<~, '~-~lmfjilli1~~ffiil~kit.llll!i ~~ ."'""' 'J;.."Juij - ,;......"'...., ~,," .., O,,"~~_ "'" . ~". ]li ,.', .,,-, I ,,<'. ~ ~~j ~- , n 0 C) c: 0 -T1 ?~ ~ uC;::-7 -r; ~ ri'JrTi 00 ;/.:::;:-J In / , -~"'iCJ ~~', .,. . ",1 ~~:'j C) -u -'1' ~ ,...~. ~T1 ~ , -a.. '~~f~ ro':;: r::' > ~:... L_ ::::, ""'- N );> ::z ::0 .-J -< ;:; ".--- '\ . Norwest Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Joseph B. Quesenberry Joanne L. Quesenberry CIVIL DIVISION NO. 2000-663 Civil Term Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Norwest 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 403 East Main Street. Shiremanstown. P A 17011. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Joseph B. Quesenberry 403 East Main Street Shiremanstown, P A 17011 Present Whereabouts Unknown Joanne L. Quesenberry 403 East Main Street Shiremanstown, 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 ~....~"'...~_.- -~ '" ~'< . " 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 403 East Main Street Shiremanstown, 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 24. 2000 DATE :;t~~Q~~ Attorney for PI tiff ~jjfll;i!I~- l",^j"_ilI~IlI!I>I~M_i~i.I"WAA%~ill'""l"'ii>;"',i&:'I&li\l!lii!i-,,,,,,,,~"""'III"' , , m ~ ,__ ~ , ~ . , , ~ ~ ,.-< 1iIlll~ ~"""W~ "~~-, <" ~ ,- ~ It ~t5 ~/;) ~8 ~ ~ , , ~_ L .0 l f g :"I: )0>, -: Co.> <:::> ~ i\; .. en '0 !:i? :~ ._-1:. l"11iI1 i5.$ft;3 ~~ (!5f'n 35 .... 'l: ~ " , .., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORWEST MORTGAGE, INC. Plaintiff CIVIL DIVISION vs. No, 2000-663 CIVIL TERM JOSEPH B. QUESENBERRY JOANNEL.QUESENBERRY Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for NORWEST MORTGAGE, INC" hereby verify that on MAY 26, 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 MAY 26.2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto, Date: AUQust 10, 2000 -. . .. o>Z , "'10." "0"" t'" We-a ~r ~ 5' :: ftl l'll 10. ~ " 0_ - - - ~ - - 0 .. ~ ~ ~ z v. "" w - 0 '"' 00 -.J '" V. "" W N - ., - Cc 10. :<: 5 o C" 1- Q.o C"~ '< 0 ",'" 1> 0 = ,r Q. 0 " .;:. z 'I' 0 5 C" "',"""l ~ =.~l"l =-00 ;>;l"" il1:l C"l"'= "'..'"" '" ..'- "'..'- Z Q,,,,l"l o 0 .. .. " 3.[ ~ >"'0 ==l"l = =0 ==0 = -6"=::: 19~::: -"'z - "'> ;;"'''' 3 ".= ~ Z " 0 ~ "l"l> l"lz l"l~1ci 0 ;.;" C"l > Q.O _"tol tol>z tol >z .., = 3 - .. Z -C" ~ "''""'" :::"''"" ::: ~tol :::"'= it ",=Ilo "00 r:-=,"" >'""- > ~'""== Q. >1> o ~ tol - :::r' 11 ~ 0 ~ Z:::O Z ., '" - .., . = C"l o~ ",>C"l '" >.0 '" :::,0 ~ ~~== "'~" ,""=:e oR Sg ~ > tol ,""_C"l '"" -e -;-~ n 0 OZ;a 0 Ztol OZtol '" ="r:- o ~ "'or:- ii t-.)p> ~ cl<:> ~"'> ~ "'''' ~"'''' Z'""z ?- '""tol Z'""tol J'. "'Z "'tol'"" - " "Z . ;J Z ~ 5. "'"S ",tol'"" '" tol== '" == - . Q. .. :-1 ",Z >tol > toltol >toltol "0 '"' is '""'" ...'"" ... '""l:j ...'""l:j ? = "0 -.J -.J <= cl -< 0 m"O tol"'l = = -< SI 3 ~ ... ... ... '0- ~ tolC"l ... ... ... g -3 '""e ~ el ~ > ::: Q. o " 5;- -.~ == ~ "0 ~ tol ~ ~ 19 z 3 ~ 0 0 = .., ;>;l C"l 0 n 0 0 <' e 5' Z "" '"" -< ~ ~ l _ . -:';;;:::~~~.~. . - 1'1 0 I :: "r."'JiJ ~ ~".,w ,1'" ;, _ u 1lr.1'~' . _:~ (,.'", .... >I- ~. ~:~ ~'(-~v . .... . '0 ~ .........- '-:::) .~ : ~~mSnd s" !. .........O'/'~CIt\Jo;'f. -~ '~-.~...... : ~-,,~'\(~~. ~i :.e::::~ d' :<: = "" o I ." R ~d -} .~,.~,.,/ ~"- ,.~"- '. .SENDER: . Check box at right if you require Restricted Delivery. . ~n.t your. name and a.ctdffiss on the reverse of trns form so that we can retUr'n this card ~yeu.>..,., .. . Att;:lch this form to the lront of the mailpiece, or on the back if space does not permit. . The Return Receipt will show to whom the article was delivered and the date delivered. r also wish to receive the following services (for an extra fe o Restricted Delivery 3. Article Addressed to: Consult postmaster for fee. 4a, Article Number P 974 910 832 jt>s~';pn 11. GUU.m.l'J':lIRY 403 E..~.T l'iAL-: S'l'Rl'.lrt ShlRE1'"iANS1'OI.'~A 1701 1 4b. Service T&pe )( CERTIFIED , Received By: (Print Name) 7. D!lte of Delivery re: (Addressee or Agent) -.-..L.-. M 3811~cember 1994 b . Domestic Return Receipt -~~';-_:.-~..:ji- -_.,-~ SENDER: , ,:~:.-.;,: , . Check boX at right if yoll'feql,liR!I'Restricted DelIVery. . Print your name and address on the reverse of this form so that we can retUm this card to you.]" " ~ . . Attach this form to the front 6f the- mailpiece, or on the back if space does not permit. . The Return Receipt wlll show to whom the article was delivered and the date delivered. I also wish to receive the following services (for an extra fef o Restricted Delivery 3. Article Addressed to: Consult postmaster for fee, 4a, Article Number P 974 910 833 JOA._ L;.. QllESEIIlU!1lB'l 403 l".Aft.,MAIJi S1'lli:Jo:T 5lfl!{lil"~"'. PI. 11011 4b, Service Type )( CERTIFIED 5, Received By: (Print Name) 7, Date of Delivery c> - tf1) 8, Addressee's Address ure: (Addressee or Agent) PS RM 3811, December 1994 Mol:> Domestic Return Receipt ~= " ... 1- - - ---- , , POSTAGE rr1 rr1 '" RETURN RECEIPT SERVICE CERTIFIED FEE + RETURN RECEIPT ,. ;J.t9 ,{.. ',- , ~~",'" RESTRICTEDDELlVERV Cl .-'l IT" SENT TO: TOTAL POSTAGE AND FEES NO INSURAN E COVERAGE PROVIDED - NOT FOR INTERNATIONAL MAIL seEOnteRSllIE Receipt for Certified Mail .~--=-....=:....:=-:'...:::::=.====- -.::=:::::...::::::::::::..:::::=..- -==: -=::::..-:.:=:::::::~ ...=:::----==-~-:-==-==-~--==-- ...==--==- .. -.- , , , POSTAGE POSTMARK OR DATE RETURN RECEIPT ~ RESTRICTEDDELlVERY SERVICE J CERTIFIED FEE + RETURN RECEIPT TOTAL POSTAGE AND FEES :~O ~-;E.j't SENT TO: NO 1~:w..RANCE COVf~IM>~OVIDED- ,{"c::-- /" """'(,~ NOT FO~S~~tg~AA~~r.AL MAIL ~~)~ JQSE1}h l)... <,(l;1::SEX}~ERRY '6 .. J lJ " <,<:, ',0 ;.OJ .EAST EAIN STRs,n ~ -'>; ,"- ......'G'y/ Stili" ~~A_;;.s:O-~.naSAI~A liGli. ~l:IOI.V DM K . =r r- IT" c.. Jo;....zrNE :.... ;~lfESZ~~BEP,.R'.;: 403 SAS': ;,~n~ STi'U'~f::T 5E:_RE:-'.<.ot-\r,:~r~c'i"Vrn, ?A l1Cl1 OV1AK PS FORM 3800 US Postal Service ru rr1 '" .-'l IT" =r r- IT" c.. PS FORM 3800 US Postal Service Receipt for Certified Mail iilOO'" ~...~iti_~D!ii!jo-"""'iII P' W1WZiil.~~I""""" ,," -~ ~ 0 0 0 C 0 s::: ., """ ;:RGJ c: --j n rn :r.-n Z:n G') rl1p ZC" ~"'1rn (/J "" cr, 67 -<"CO' r;::i5 -0 ~.j(.J P ;;"l: =+i ZO ~ 0;)0 pO c '-::! om z W > ~ (;:l :0 -< ~ - , ~" lo '" '~: l 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 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. JOSEPH B. QUESENBERRY and JOANNE L. QUESENBERRY at: 403 EAST MAIN STREET SHIREMANSTOWN, PA 17011 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. kenburg, Esquire r Plaintiff Date: March 8, 2000 ~ N ~ ~ :: S~ ~~,.,.' ~ .~ :t: 0.... Q'?;S; 15 tf>52 bi: - ffi~ ~~l~l ~ ~. """ u..::t: :s:: to- g ~L. 0 - - " . ' . t,-, MAR 21 2000 '\ . , ~ -,-~- _ "." "'-^-~~- _I" . , , i I' ii " I:' i , , 1:] , , 'I ; ~ I I'i ,';, ~: I , , 1;1 i'l ii, I 1:1 ;'1 'I :1 " H II II j;,! ,:.1 ':i i,l , Li II 1'1 il 11 " il , 1 STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _______________~ ~_______________ ______________________________________ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which _hh_h__h____ ______~_0_~we9~J1t~-Inc----------------------------------__________________________ ~ the grantee the same having been sold to said grantee on the _________!!j:.!L______________UU___h_hhh___ day of ______8<>p-Eembe-l"h_hh__h____________ A. D., l~*we&-, under and by virtne of a WriLh__h__hh_ ______E=urJ.o,,,______________h_hh___h_h__ issned on the _,;){}Eft__h_h_h_____________________ May .J<x2000 . day of __________hhh_hh__h_ A. D., l~______" out of the Court of Cornman Pleas of saId County as of ______~j_~!!__________________ ,_____________________________________________c____ 1renn, ~OO!l_ Number ---643--------, at the suit of --NtlTWes-t--tIts--fne--------h--------------------------------- ___________ __ ___ __ ___ _____ _____ ____ againsL_...I.o.s e.ph._B_-Ques.e.n.be.r-l"_y._~,J.ga;me.-l----- ____ ___ is duly recorded in Sherifrs Deed Book No. h_h_22.'i__' Page _h_1>9.4____. IN 1rES1rIMONY WHEREOF, I have hereunto set my hand and seal of said office th~ _gt..~_ day of __~_________ A. D., i90.!?_~ -~~~~n;~ Recorder of llteds, Cumberland County, Ca~isle, PA My ComIllJSSIOIl Expires llte first Monday of Jan. 2002 < ~ . ~ ~ ,',J~ ~ . ",' Norwest Mortgage, Inc. -vs- Joseph B. Quesenberry Joanne L Quensenberry In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-663 Civil Shannon E. Sunday, Deputy Sheriff, who being duly sworn according to law, says on Julyll, 2000 a5 3:24 o'clock P.M. EDST, she posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of Joseph Quesenberry and Joanne Quesenberry located at 403 East Main Street, Shiremanstown, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says 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 one of the wihtin named defendant to wit: Joseph Quensenberry by regular mail to his last known address 403 East Main Street, Shiremanstown, Pennsylvania. This letter was mailed under the date of July 12, 2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheirff, who being duly sworn according to law, says on he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheirff mailed a notice of the pendency of the action to one of the within named defendants to wit: Joanne L Quensenberry by regular mail to her last known address 403 East Main Street, Shiremanstown, Pennsylvania, This letter was mailed under the date of July 12,2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on September 6, 2000 at 10:00 A.M.EDST and sold the same to Attorney Dale Shughart, JR for the sum of$ LOO for Wells Fargo Home Mortgage, Inc., F/KIA Norwest Mortgage, Inc. It being the highest bid and best price quoted for the same Wells Fargo Home Mortgage, Inc., F/KIA Norwest Mortgage, Inc. being the buyer in this Execution paid to SheriffR. Thomas Kline the sum of$ 770.35 it being costs. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Certified Mail Mileage Levy Surcharge Law Joumal Patriot News 30.00 14.91 15.00 15.00 30.00 10.00 .50 1.00 3.29 7.44 15.00 30.00 288.65 234.53 .. Share of Bills Distribution of Proceeds Sheriff's Deed 23.53 25.00 26.50 $ 770.35 Pd by Arty 9/21/00 So answers; r~~ This -$I!::- Day of (Qe.t:;;:L. _ ~- g If'Tli'omas Kline, Sheriff 2000, A.D ";t' 0 )'tdh), UJ,df--- .. ~ . )~ 14 Prot 0 otary By n...I A eal Estate Deputy Sworn and Subscribed To Before Me . ~ "k ~ ~~ eN 30\.~ tjQ.,J9~'1 v ~J(?ZO\<f ,_....,~,~.. Ii..... ~!f; \ , Norwest Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS . Joseph B. Qnesenberry Joanne L. Qnesenberry CIVIL DIVISION NO. 2000-663 Civil Term Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) Norwest Morte:ae: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 403 East Main Street. Shiremanstown, 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.) Joseph B. Quesenberry 403 East Main Street Shiremanstown, PA 17011 Present Whereabouts Unknown Joanne L. Quesenberry 403 East Main Street Shiremanstown, 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 ,. -.. ''',=",-, ~. " , .b;;&;' '\ r 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 403 East Main Street Shiremanstown, PA 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. Mav 24. 2000 DATE " '"~ - ~ "", .\ Norwest Mortgage, Inc. CUMBERLAND COUNTY Plaintiff, v. No. 2000-663 Civil Term Joseph B. Quesenberry Joanne L. Quesenberry Defendant(s). May 24, 2000 TO: Joseph B. Quesenberry Joanne 1. Quesenberry 403 East Main Street Shiremanstown, 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 403 East Main Street. Shiremanstown. 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 Norwest Mortl!al!e. Inc. (the mortgagee) against you. If the 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 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. '-- ...............,~~ ....=..,".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 ifthe buyer pays the Sheriff the full amount due in the sale. To fmd 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. i' 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. Ii 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. i ,:,.1 I ,': i'l :i " H " 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. i-;' 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. :i n i; ;i CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ''l - ~""'~ ;<".,.,. . \ " \ \ ; \ \ \ DESCRlPI'ION ALL THAT CERTAIN lot or tract of land situate in the Borough of Shiremanstown, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of East Main Street, said point being 400 feet eastward from the northeast corner of Main and High Streets, being 50 feet eastward from the northeast corner of the intersection of Main Street and Catherine Street at the southeast corner of lot now or late of Ray E. Wolf; thence northwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to the southern line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point; thence southwardly at right angles to said alley 150 feet to Main; thence westwardly along Main Street 50 feet to the place of BEGINNING. HAVING thereon erected a brick dwelling house and garage, known and numbered as 403 East Main Street. TAX PARCEL #37-23-0555-298 TITLE TO SAID PREMISES IS VESTED IN Joseph B. Quesenberry and JoAnne L. Quesenberry, his wife, by Deed from Rosemary Robusto, single person, Isabella Robusto, single person and Delia Robusto, single person, dated 9/14/93, recorded 9/21/93, in Deed Book N-36, Page 824, ~j -_.J _I .- ~" . WRIT OF EXECUTION and/or A IT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cunberland NO, 2000-663 CIVILlUI ~ CIVIL ACTION - LAW COUNTY: To satisfy the debt, interest and costs due Norwest Mortgage. Inc. PLAINTIFF(S) from Jose.ph B. Ollp.Sp.nhP.rry .lonnnp. T.. Ollp."p.nhprry 40, F.""t M"in Strf!P.t. Shiremanstown. Pa. 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See attached legal description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: , i ! " i I I I I I i and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property olthe defendant(s) not levied upon an subjectto attachment is found inthe possession of anyone other than a named garnishee. you are directed to notffy him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $82,427 . 52 L.L. Interest from 5/15LOO-9/06/00 (per diem-$13.55) P Interest 1.544.70 and Costs Due rothy Atty's Comm % Other Costs Atty Paid 1 14 Oli Plaintill Paid $0.50 1 nn Date: May 30. 2000 Curtis R. Lonq Prothonotary, Civil Division (f,-. 0 h..dJ;, , by: Deputy REQUESTING PARTY: Name Frank Federman, Esauire Address: Two Penn Center Plaza Suite 900 Philadelphia, Pa. 19102 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 12248 "'f/"'w.o:..~O,t..lt"''''liIljJ!~~'~_' >"'~ "-~""~,,,,",;!;1Jil~Hil!'-~"' ^- ..rIl~"'IiIIii~~;,l;ll~ """'~,..."~~~ _..~ ~ . REAL ESTATE. SALE. No. ~s \.Ill ~ I, "Wt-O the sheriff levied upon the deiendantb interest in the real property situated in J;/~', ',- .~ L--'~A~ Cumberland County, Pa., known and numbered as: <9h oS /:4 ,..: )l::,f ~/~ and more ft!li~escribed on Exhibit "An filed with this writ and by this reference incorporated herein. By: llr__, JL7L ~~~ '1ate:9.b!-<Q ~J 2rrz> . ,. , 1,,_1 i' >, . cc E r,r ll-nJ ue i'~f'1 Alt-;!;,: ;/.:lnc;;~- 11'J ";);:0 . 1 S ~ II::::J ~ INlJ ,! ! I REAL ESTATE SALE NO. 25 Writ No. 2000-663 Civil Norwest Mortgage, Inc, vs, Joseph B. Quesenberry and JoAnne L. Quesenbeny Atty.: Frank Federman DESCRIPTION ALL TIfAT CERTAIN lot or tract of land situate in the Borough of Shire- manstown, CounlyofCumberland and State of Pennsylvania. more particu- I larly bounded and described as fol- lows, to wit: BEGINNING at a potut on the north side of East Main Street, said point being 400 feet eastward from the northeast comer of Main and High Streets, being 50 feet eastward from the northeast comer of the in- tersection of Main Street and Cather- ine Street at the southeast comer of lot now or late of Ray E. Wolf; thence nortbwardly at right angles to Main Street by land now or late of Ray E. Wolf, 150 feet to tbe soutbem line of a proposed 14 feet wide alley; thence along the southern side of said alley eastwardly 50 feet to a point; thence soutbwardly at right angles to said alley 150 feet to Main; tbence west. wanlly along Main Street 50 feet to tbe place of BEGlNNING, HAVING thereon erected a brick dwelling house and garage. known and numbered as 403 East Main Street. TAX PARCEL #37-23-0555-298. TITLE TO SAID PREMISES IS VES1ED IN Joseph B. Quesenbeny and JoAnne L Quesenbeny. his wlfe. by Deed from Rosemary Robusto. single person, Isabella Robusto. sin- gle person and Della Robusto. single person, dated 9/14/93. recorded 9/21/93. in Deed Book N-36, Page 824, - ~~, , -~ .{-- >i "-"'- ~~^- ,~ " o^_' ';"""',",-'; PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, 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: JULY 28, AUGUST 4, 11,2000 Mfiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he isnot 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. SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 NO AL LOIS E. SNYDER. Notary PublIc CartWe Boro, Cumb.rtcincl County, PA My CommlPion bpi.... _h 5, 2001 , ~ !t!;AL..!'S.. w:J;SALE No. 25 -\.' "'!riWo>200G-663 ~~:. .~~"r~:e,fne. -~ - "VI ~ -J1l'8Ph B, Quesenberry ~ --~~-;.~neLQuesel1berry , .:~." -. )'U;t;F. rank Federman ~' ~C-;.i)JESCRIPT10N ~ THAT CERTAlN lot or. trdct oll.1nd Ell.: m U1~ Borough of Slnr~manstown, ::~ - tv of Cumberland imd Stab.' of ~nsi'r.-.:mia, more rarticularlv bounded and ~ed~fullows.to\fH; , ~'~1NING at a point on the north side ~ - ('1::.1. Milin Sb'~t. )<lid point bdng .roo f..d ~\'.Jl'd m thf.' norlheJ~t cotner of Main . igh &reel-.. being 50 feel ea::.h',ard from .north~t comer oi the lntersedion (If ~tr~l_,lnd Catherme Strt'et at the ~~l corner of lot rtow or tate of Ra\' E. ~- . _ _' Utence northwardly at right angl(!s to ~Uiin.stredb)' land now or laIc of Ray L ~\olt~ ,~ie~t w.1ht: southern line of a pro~t'd 14 ~t '.ride .lJ1eF thrnw along lhe southern sid\' ~ alter cJs/ward!}' 51) feel to a pmnt; ,;:ntciu:-.,,5QuUw:ardlv J.t right J.nglt's to said Cii:/E' ISO feel to ""'bin; tnencl' WL'5l-w,udh' ~,\;~:G.St(~el 50 ft,~t !o the poo of ~ aroNG ther<,on IOrclfed J brick dw~mtl~ ~~ _..md sarage, known and numbercJ a~ ~~tMa1llStrecJ. -< .--- ~;w;rNii:a#37-23.o555.29S. it!- .' ~. TO SAID PREMISES IS VESTI:O IN :::- osepJl. _ it Que.enbcny and JoAnnE' L. =- u.esenb~rr"'" his wife, by De!'d from - R. .osental). tob~lO, single per~on. Isabella ~oblg;to,. single person .1nd Ddia Robust. ~=dated9IW93,rCcordl'd 9l21l93. E'""~;~~~~~f, -"Y'_.. ! _~________<..-::...::;_::."",:_ '____<.'_ _ ___ __ .-c,-__' - ~_o " ,_ I -<L\il\~"' , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderHct No. 587. HDDmued Mau 16.1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Accounts Receivables Manager 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 and Metro editions/issues which appeared on the 1 st, 8th and 15th day(s) of August 2000, 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 compan~~ subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscell, us Book "M", vo;:: ~~'::~I: ~ ____________________~~------------------------ COpy Sworn to and subscribed before me . 30th day 0 ugu 00 A,D, SALE #25 Notarial Seal Terry L. Russell, Notary Pu . Hanlsburg, Dauphin Cou MyCommissionExpiresJuneli,2002 NO RY PUBLIC Member, Pennsylvania Associaf 6iQIWI1ission expires June 6, 2002 " 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) $ T~~ $ 233,03 1,50 234.53 Publisher's Receipt for Advertising Cost THE PATRIOT.NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duiy paid. THE PATRIOT-NEWS CO. By...,.,.,.,.,.,.,.,.,.,."""...,......,.,.",."".,.,.,.,.,.....,.