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HomeMy WebLinkAbout00-00681 STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, _u_h________hu______________________ _____u______u____u_u______uu____ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ______u______h Secretary of Housing & Urban Development . __________________._________________________________________________________________ m the grantee the same having been sold to said grantee on the ___~:~_________________________________________ day of Sept . 00 uu___u__u_______uu_u_________uu A. D., 119'-'uuu_, under and by virtue of a writ_u___________ Execution 16th _ ______u_ ______ __ _u ___ h___h__ ___ __ _ __ _u h _ _ issued on the u____ u___ _ u h u u _ u _ u u u _______ May xx2000 day of ____________,_u_u_u_u_ A. D., 19______, out of the Court of Cornman Pleas of said County as of Ci vi! ;>.cx2000 __________________.h__ ___ ___ _,. ______ _ u__u__ __ __u_h__ ___________ u u u____h _ Term, 111_ __ ____ 681 Countrywide Home Loans Inc Number u_u_________, at the suit of __u_____u__u_u________________________________,_____________ John A Morris II & Tammi E __________________~________________against------------________________________________________ is duly recorded in Sheriff's Deed Book No.2_3_~uu_u__, Page u!l_~~______. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ___(_~~_ day of ____~~____________ A. D.,l9-.i?--":-=- ~~~~~~-~in;~ Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires tlle first Mooda, of Jan. 2002 , Countrywide Home Loans, Inc. -vs- John A. Morris, III and Tammi E. Gettle In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-681 Civil Dawn L. Kell, Deputy Sheriff, who being dilly sworn according to law, says on May 19, 2000 at 7:43 o'clock P.M. EDST, She served a true copy of Real Estate Writ Notice r and Description in the above entitled action upon one of the within named defendants to wit: John A. MorrisIII, by handing to John A. Morris III at 311 Kerrsville Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Dawn L. Kell, Deputy Sheriff, who being dilly sworn according to law, says on May 25,2000 at 6:23 o'clock P.M. EDST she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Tammi E. Gettle, by makin gknown unto Tammi Gettle at 27 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. J. Michael Ickes, Deputy Sheriff who being dilly sworn according to law says on Jilly 13,2000 at 12:18 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of John A. Morris, III and Tammi E.Gettle located at 236 East Garfield Street, Shippensburg, Cumberland County Pennsylvania according to law. R. Thomas Kline, Sheriff, who being dilly 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 within named defendants to wit: John A. Morris III by regular mail to 311 Kerrsville Road, Carlisle, Pennsylvania. This letter was mailed under the date of Jilly 14, 2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff who being dilly 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 within named defendants to wit: Tammi E. Gettle by regular mail to 27 West Big Spring Avenue, Newville, Pennsylvania. This letter was mailed under the date 0 July 14, 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 Real Estate at public venue or out cry at Court House, Carlisle Cumberland County, Pennsylvania on September 6, 2000 at 10:00 o'clock A.M. EDST and sold the same to Attorney Leon P. Haller for $ 1'.00 to Secretary of Housing & Urban Development, His Successors & Assigns. It being the highest bid and best price quoted for the same Secretary of Housing & Urban Development, His Successors & Assigns of 100 Penn Square East 10th Floor Wanamaker Building, Philadelphia, Pa being the buyer in this execution paid to SheriffR. Thomas Kline the sum of$ 822.09 it being costs. Sheriff s Costs: Docketing Poundage Posting Bills 30.00 16.12 15.00 Advertising Acknowledging Deed Auctioneer Law Journal County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed Sworn and Subscribed To before Me Thisdll. 't'Day of (Jl~ 200, A.D.cttL. C2 ~. LPfrj o onotary 15.00 30.00 10.00 .50 1.00 24.18 1.91 15.00 30.00 270.05 288.30 23.53 25.00 26.50 $822.09 Pd By Atty 10/13/00 . ...'""f 4'",,' p.--:~~~: r ~i:...ke.:_ "'!>'?~P"< , ;'~"""Jfii ,6m~_. ,,,,t;(- .-,' , ",.' " " ,', R. Thomas Kline, Sheriff Byfct .-..: JJ..o;t;t: Real Estate Deputy ~ ~ l !JO lP~ \, 3D/~-1,., ue... "'0 /?-u.-. /D3 () , J ~ . '--., - . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under ReI No. 587. Rooroued Mau 16. 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: ThaI 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 knowiedge 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 Miscrous Book "M", VO:::~~~I::__-;---;-";;;;4__c;-;;;;-;y-;~_;;-:;:;; S ALE #22 Notarial Seal Terry L. Russell. Notary Public Hanisburg. Dauphin County My Commission Expires June 6. 2002 NO RY PUBLIC Member, PennsylVania ASSOCIation 01 N lefommission expires June 6, 2002 ? 1, 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 $ Probating same Notary Fee(s) $ Total $ 286.80 1.50 288.30 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 duly paid, THE PATRIOT-NEWS CO. By,.,.,.,.,.,.,.,.,.........,..........."."",.,.".,.""",",.,., ........ -_.--~ -:'I!EAL ESl'ATE'SALENo, 22 Writ No, :zooo.m CMlTerm CcuntrywldeHome Loans,lnc. vs JohnA.Morris III end Temtnl E, GeWe , Atty: JoseP~/'. Goldbeek, _ ,,_=-J:j~ON _.:.- *Ii nUT CE~'trN tract uf land with' .. ""'t',un;."~,,b ttire-on ere-cted. !>ituate at t!iifmtcrsection 'Of the ]\;orthea~t..:rl\' :.idt! of -,-iast-Garficld Street. Shippcn<;burg bOToush, ~d County, penn~)'l\'ania. bemg 'jtOre fulh. bounded and de~(ribcd according lOa'plan of sun'lj' by Carl D. Bert, R.5., datt'd '~~' ,mdb~ring dr.l\\'ing Ko. C~SB.i7.3, '5: . ~_ tEGt\1\1NG .11 J. roinl at a com"'T of ~ nark. 3t the interse<lion of the .liUrttreasterl)' side of Ridge Art:'nue and the :1:M'+1.P~t"'~r1P nf EJ~l Garfield Slrt't'l ~ ~ WI e; thence extending from ~id -_ ~ point along the Southeaster];' .,ide llfhst- Caifield 5trret. N.orth +l degrees 55 "l11im:ttes 00 Sf;'(onds usl, 40.00 feet to a punch ~inatt. in brick at a comer of Idnd 00\\ or ,-,Jm'mttly of Richard H. Oaris.: thence : ~ld:cndin~'-<llong .!>ame, South ~5 degrO;;cs {9 ~ seconds East. 85.00 f~t to an iron :~ rotn('T of land now or formerl)' of '_. Ie-R Bolan'!:>" Executor" thence ,_~g along !>attie, South +1 degrce:. 55 ~-oo scconds V\'est, .w.OO fct't to an iron '.fukd on the Norlhea..tem side of Ridge ~ (27.6-1 feel \ lde)"afore~aid; thence ~ along s.m"';',~rth {j degret'~ 49 '1iitfWIe.s ~ seconds \\~t. 85.00 fect to the first ::merrtkmed point and place ofBFGT~"NING. _ __,.BUNG known and numbered as 2.~ [obt ~-smppensburg, Cumberland County, pennsylvania. , ,5 , ;;' ~e ","^. REAL ESTATE SALE NO. 22 Wrtt No, 2000-681 Civ1l CountIywide Home Loans Inc. vs. Jalm A. Morris III and Tammi E, Gettle Atty,; Joseph A. Goldbeck, Jr. ALL TIlAT CERTAIN tract of land with the improvements thereon erect- ed, situate at the intersection of the Northeasterly side of East Garfield Street. Shippensburg Borough, Cum- berland County. Pennsylvania. being more fully bounded and descrtbed according to a plan of survey by Carl D, Bert. RS" dated July 1977, and bearing drawing No, C-SB-77-3, as follows: BEGINNING at a point at a comer of concrete walk, at the intersection of the Northeasterly side of Ridge Avenue and the Southeasterly side of East Garfield Street (33.20 feet wide); thence extending from said begin- ning point along the Southeasterly side of East Garfield Street, North 44 degrees 55 minutes 00 seconds East, 40.00 feet to a punch mark in brick at a comer ofland now or formerly of Richard H. Davis; thence extending along same. South 45 degrees 49 minutes 59 seconds East. 85.00 feet to an iron pin at a comer ofland now or formerly of MinnIe B. Bolan's Ex- ecutors; thence extending along same. South 44 degrees 55 m1nutes 00 seconds West, 40.00 feet to an iron pin located on the Northeastern side of Ridge Avenue [27,64 feet wide), aforesaid; thence extending along same. North 45 degrees 49 minutes 59 seconds West. 85.00 feet to the first mentioned point and place ofBEGlNNlNG. BEING known and numbered as 236 East Garfield. Shlppensburg. Cumberland County, Pennsylvania. ,'~ . . . I: ", PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATEOFPENNSYLVANIA : 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 ofthe said Cumberland Law Journal on the following dates, VlZ: JULY 28, AUGUST 4, 11,2000 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 statement. as to time, rlar~a]1c ;)haracter of publication are true. RO~Editor - SWORN TO AND SUBSCRIBED before me this 11 day of AUGUST. 2000 NOT'" l SEIIL LOIG E, SNYDER;......'1 ...... Corliol9loro, eu......-...ana,eo..my, p", My Commiaion ~MOi<~ 5.:Ibo' ~ - " 'f . - ," ,"-,. ,= GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. Term GETTLE (Mortgagor(s) and Record No. 2000-681 Owner(s) ) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the by its attorney, Joseph A. Goldbeck, Jr., Esquire, of the date the praecipe for the writ of execution following information concerning the real property above action, sets forth as was filed the located at: 236 E. Garfield Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or Reputed Owner(s): JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JOHN A. MORRIS III 311 Kerrsville Road ",-' -"" ;Ie", "<\1/'" l . Carlisle, PA 17013 TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY: ERTY & Mc dbeck, Jr., Plaintiff DATED: May 9, 2000 ,- ~ ~, " """ ,,"J' N"', , . f GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive IN THE COURT OF COMMON PLEAS Plano, TX 75024-3632 Plaintiff OF CUMBERLAND COUNTY vs. CIVIL ACTION - LAW JOHN A. MORRIS III AND TAMMI E. :ACTION OF MORTGAGE FORECLOSURE GETTLE (Mortgagor(s) and Record Owner (s) ) Term 236 E. Garfield Street No. 2000-681 Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 Your house at 236 E. Garfield Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $69,868.34 obtained by COUNTRYWIDE HOME LOANS INC. against you. 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 COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was '" ,-, "," '_0 .f'_ ".--_'"'1>, . ' 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 below 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 NOT 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, carlisle, PA (800) 990-9108 Legal Services Ine, B Irvine Row, Carlisle, PA 17013 (717) 243-9400 > ~. _h, ,'.o,j ._, _ j '..L__, " GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive IN THE COURT OF COMMON PLEAS PIano, TX 75024-3632 Plaintiff OF CUMBERLAND COUNTY vs. CIVIL ACTION - LAW JOHN A. MORRIS III AND TAMMI E. :ACTION OF MORTGAGE FORECLOSURE GETTLE (Mortgagor(s) and Record Owner(s)) Term 236 E. Garfield Street No. 2000-681 Shippensburg, PA 17257 , Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 Your house at 236 E. Garfield Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $69,868.34 obtained by COUNTRYWIDE HOME LOANS INC. against you. 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 COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was " -~. .~ ~. t. . ".'--, . 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 below on how to obtain an attorney) . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EV~N IF THE SHERIFF'S SALE DOES NOT 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (aoo) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 0..,'" ,_, _,',N .'_ -,-_ . " ALL THAT CERTAIN tract of land with the improvements thereon erected, situate at the intersection of the Northeasterly side of East Garfield Street, Shippensburg Borough, Cumberland County, Pennsylvania, being more fully bounded and described according to a plan of survey by Carl D. Bert, R,S., dated July 1977, and bearing drawing No. C-SB-77-3, as follows: BEGINNING at a point at a comer 'of concrete walk, at the intersection of the Northeasterly side of Ridge Avenue arid the Southeasterly side of East Garfield Street (33.20 feet wide); thence extending from said beginning point along the Southeasterly side of East Garfield Street, North 44 degrees 55 minutes 00 seconds East, 40.00 feet to a punch mark in brick at a comer of land now or formerly of Richard H. Davis; thence extending along same, South 45 degrees 49 minutes 59 seconds East, 85.00 feet to an iron pin at a comer of land now or formerly of Minnie B. Bolan's Executors; thence extending along same, South 44 degrees 55 minutes 00 seconds West, 40,00 feet to an iron pin located on the Northeastern side of Ridge Avenue (27.64 feet wide), aforesaid; thence extending along same, North 45 degrees 49 minutes 59 seconds West, 85.00 feet to the first mentioned point and place of BEGINNING. BEING known and numbered as 236 East Garfield, Shippensburg, Cumberland County, Pennsylvania, "" ,~', ,= ., " '~'('t . . , . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00-681 CIVIL 19X Tenn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Countrywide Home Loans, Inc. PLAINTIFF(S) from John A. Morris, III and Tammi E. Gettle (Mortgaror(s) and Record Owner(s), 236 E. Gi'lrfip1il ~trppt ~hipp"n"hl1rg. PA 17::>'17 DEFENDANT(S) (1) You are directed to levy upon the property of the detendant(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 " ,,: ,I-y:;~)i' ):'~:: 'N!',' ;11: ", .", M GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are'enjoinellfrom paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) notlevied upon an subjecllo attachment is found inthe 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, Atty's Comm Atty Paid Plainmf Paid % L.L. Due Prothy Other Costs $.50 $1.00 Amount Due $69.868.34 Intereffi from 7/1/99 to 5/9/00 at 8.750% $183.56 ~ Curtis R. Long Prothonotary, Civil Division ~f?~P J P 7pcYlfiA~{. / Deputy Date: May 16, 2000 REQUESTING PARTY: Name Joseph A. Goldbeck. Jr. . Esa. Suite 500 - The Bourse Bldg. Address: 111 C. IB6eflendeBee !'Iall Eaot Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No, 16132 I' -0''''-' '~-~''/iIiiiodIj.iIIlll __~~~~ ~"illiW '-~:MDl"'"""'~~~"' -~ 'q',.,;.,-2l - j' "~'"" ~'-L- ......... . "", ~" -, , '. ' .;1 . ' , REAt t:STATE SALE No. ~)- On I'M. ~ J 1. ")-r-ri) the sheriff levied upon the defendants interest In the real property situated In J 11/1"'. ~.A L] IJ,n.J"~ LP. , Cumberland County, Pa., known and numbered as: ~AI. E.N..~.~t.7ld J;'fJ? ,,11'1 and more fully described on Exhibit "An filed with <, ~'i~\ this writ and by this reference incorporated herein. \~~ ., ~ . ';;, ~4-Z;:\", '~;~~ ,<' ,..E;~ ~ c:;:;J GV\! ~ ~ nate:./YJI} ~ J?:J.nW ~.'~ :;)f . >,' ~~' 'J;;~ -' ~'" """, GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 -' The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive IN THE COURT OF COMMON PLEAS PIano, TX 75024-3632 Plaintiff OF CUMBERLAND COUNTY vs. JOHN A. MORRIS III AND TAMMI E. GETTLE: CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) (Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 236 E. Garfield Street Term Shippensburg, PA 17257 No. 2000-681 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2(c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale 7Jt by: ( ) Personal Service by the Sheriff's Office/ return attached) . was , . , ,~, (copy of ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriff's Office. Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached) . Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). Certified Mail & ordinary mail by Sheriff's Office (copy of return attached) . Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. ~ , ,f ._l' JII":I'.ii ...JcUoo"""'~~i.Lllilllii it , ,1., .",,^ - TO: P 1lI1"''' 1lI"3 If 113 TAMMI E" GETTLE 27 W.Big Sl3ring Avenue Newville, pA 17241 SENDER: GOLDBECK McCAFFERTY. McKEEVER. May 9, 2000 REFERENCE: MORRIS III,JOHN A. I CWD-DS72 9/ 6/00 -CUMBERLAND PS FORM 3600 EPTEMBER 1995 -go RETURN RECEIPT SERVICE CerlifledFee Retum Recalpt FIM Restricted Delivery Total Postage and Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use lor International Mail TO: P Ill" III IlIlf3 If 112 JOHN A. MORRIS III 311 Kerrsville Road CarliSle, PA 17013 SENDER: GOLDBECK MCCAFFERTY & McKEEVER. May 9, 2000 REFERENCE: MORRIS III,JOHN A. I CWD.0572 9/ 6/00 . CUMBERLAND PS FORM 3600 SEPTEMBER 1995 ""lag; CerlifledFee . RETURN RECEIPT SERVICE RelUrnRecalplFee --"""'" Total PosIage and Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail , ,:;" Countrywide Home Loans, Inc. -vs- John A. Morris, III and Tammi E. Gettle In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-681 Civil Dawn 1. Kell, Deputy Sheriff, who being duly sworn according to law, says on May 19, 2000 at 7:43 o'clock P.M. EDST, She served a true copy of Real Estate Writ Notice r and Description in the above entitled action upon one of the within named defendants to wit: John A. Morris III, by handing to John A. Morris III at 311 Kerrsville Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Dawn 1. Kell, Deputy Sheriff, who being duly sworn according to law, says on May 25,2000 at 6:23 o'clock P.M. EDST she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one ofthe within named defendants to wit: Tammi E. Gettle, by makin gknown unto Tammi Gettle at 27 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. 1. Michael Ickes, Deputy Sheriff who being du1y sworn according to law says on July 13,2000 at 12:18 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of John A. Morris, III and Tammi E.Gettle located at 236 East Garfield Street, Shippensburg, Cumberland County Pennsylvania according to law. R. Thomas Kline, Sheriff, who being du1y 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 within named defendants to wit: John A. Morris III by regular mail to 311 Kerrsville Road, Carlisle, Pennsylvania. TIlls letter was mailed under the date of Ju1y 14,2000 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff who being du1y 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 within named defendants to wit: Tannni E. Gettle by regular mail to 27 West Big Spring Avenue, Newville, Pennsylvania. TIlls letter was mailed under the date 0 July 14, 2000 and never returned to the Sheriff's Office. ' So anrv,? ~ -t:~/l:-J R. Thomas Kline, Sheriff By ~Ja7I Real Estate Deputy - , ' ~-- - -'., """,,,::", "',- ,'"-.1-,,, GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. Term GETTLE (Mortgagor(s) and Record No. 2000-681 Owner(s) ) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the by its attorney, Joseph A. Goldbeck, Jr., Esquire, of the date the praecipe for the writ of execution following information concerning the real property above action, sets forth as was filed the located at: 236 E. Garfield Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or Reputed Owner(s) : JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JOHN A. MORRIS III 311 Kerrsville Road ,~ ~ ~" ~, " '. - ,--, j, ;""'" , ' Carlisle, PA 17013 TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 9, 2000 ERTY & Mc dbeck, Jr., Plaintiff BY: ~, ~~U .,= ~~~ ." '~-"iiIIliliIiiIi i~!!I~"..M " -,- " "', ""k". " ,..' . ... -;....' =-",,j~"'~"' () C) 0 c <:::> .." ;;:: ):>0 ---j iilfg c::: ::r:t) G") m- Z::I) -0 hi ~'s;. .-J ~!70 -" " , {,-:., c',:: 1 \/' , ~-, , ," " GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor(s) and Record Owner(s) ) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) Term No. 2000-681 ORDER FOR JUDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS INC., and against JOHN A. MORRIS III and TAMMI E. GETTLE for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of SIXTY NINE THOUSAND EIGHT HUNDRED SIXTY EIGHT DOLLARS AND 34 C ($69,868.34) . I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is 6400 Legacy Drive, PIano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are JOHN A. MORRIS III, 311 Kerrsville Road, Carlisle, PA 17013; TAMMI E. GETTLE, 2 W. Big Spring Avenue, Newville, PA 1724 ; K McCAF RTY & Mc ER BY: Jo eph A. Goldbeck, Attorney for laintiff " " r ~ " ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal balance $ 61,020.43 Interest from 7/ 1/99 through 5/ 9/00 4,593.82 Attorney's Fee at 5% of principal balance 3,051.02 Late Charges 240.00 Costs of Suit and Title Search 560.00 $ 69,465.27 Escrow Balance Deficit 403.07 $ 69,868.34 Y & McKEEVE BY: oseph A. Gol beck, Jr. Attorney for Plaintiff AND NOW, this damages are assessed /t.,A day as above. of f'YZ;Lt ,2000 P~k.~ Ff-o Prothy . ~~~- '"-,-,,e, c" " <.'" ~' , ~ ,'<~ L',_, ," VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JOHN A. MORRIS III, is about unknown years of age, that Defendant's last known residence is 311 Kerrsville Road, Carlisle, PA 17013 and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: 4153411 - MORRIS III,JOHN A. - 'J", VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, TAMMI E. GETTLE, is about unknown years of age, that Defendant's last known residence is 27 W. Big Spring Avenue, Newville, PA 17241 and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: 4153411 - GETTLE,TAMMI E. ~;~ ! TO, TAMI E. GETTLE 311 Kerrsville Road Carlisle, PA 17013 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s) ) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TAMMI E. GETTLE 311 Kerrsville Road Carlisle, PA 17013 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JO:Jeph .A. (jotdteck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY, Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 " ~ " .-'" r' , , .-", ,'i,"" """"-'0_' L' TO: JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s)) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Isl JOd~f)h --.A. goldbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 , TO: JOHN A. MORRIS III 27 W. Spring Street Newville, PA 17241 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s) ) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: JOHN A. MORRIS III 27 W. Spring Street Newville, PA 17241 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ Jooeph -A. goldbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 - .~ ~"~ '""" ,",--- ~> - , " I "~, TO, TAMMI E. GETTLE 27 W. Spring Street Newville, PA 17241 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s) ) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant (s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TAMMI E. GETTLE 27 W. Spring Street Newville, PA 17241 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JOMph -A. (jotJbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY, Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 "'-, TO: TAMMI E. GETTLE 236 E. Garfield Street Shippensburg, PA 17257 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s)) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TAMMI E. GETTLE 236 E. Garfield Street Shippensburg, PA 17257 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ J03eph ~. (jotdbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 J,I_ ". ,-- -" '-, " ',"- -'Y'-". TO: JOHN A. MORRIS III 236 E. Garfield Street Shippensburg, PA 17257 COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor (s)) (Record Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 2000-681 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: JOHN A. MORRIS III 236 E. Garfield Street Shippensburg, PA 17257 DATE OF THIS NOTICE: March 23, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JO:j~fJh Ji. (lotdbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 . ,~ ~~'.....""""~.~ ,~ ~ _.,- <.~ _, v" ~~~""'.................."';,, , ,- n, ~," , . ~, , ~~~~ -. fi:- 0 J:.. ..0 --- () \'J ~ t v ~ t ~ f r-- --C: CJ ~ ~ ~ . , o c: <" -0[('; flirr ~~i ~2 Z ~ (;:) D o 'T) :.-:1 ~"':o ,1.\ -'"'~m /,0 {:.:).L --1(-' :r-n c.5"o ";;7 om ~ -< :J: ~\:.011 -< <n "'D :x :n UI ~ - ..^ .^ ^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff vs. JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor(s) and Record Owner (s) ) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) Term No. 2000-681 PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter Judgment in favor of Plaintiff and against JOHN A. MORRIS III and TAMMI E. GETTLE by default for want of an Answer. (X) Assess damages as follows: Debt $ 69.868.34 Interest 7/ 1/99 to 5/ 9/00 Total $ (Assessment of Damages attached) I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A py of the notice is attached. R.C.P. 237.1 A. Goldb ck, Jr. ney for Plaintiff I.D. #16132 AND NOW fYZs.t'isN I&, , ;;), DO () , Judgment is entered in favor of CO TRYWIDE HOME LOANS INC., and agalnst JOHN A. MORRIS III and TAMMI E. GETTLE by default for want of an Answer and damages assessed in the sum of SIXTY NINE THOUSAND EIGHT HUNDRED SIXTY EIGHT DOLLARS AND 34 CENTS ($69,868.34), as per the above certification. /s /(L,i:,n i2 4 Pr6thonotary - -~...- "-~'~ ~~" , ' ,,~" ~... .....-tllilii!lj -~ ~- ~ 0 c..-:;, 0 ~- 0 ''l ,-, ~ 3\: .-; VITI := i;-Pi~ ITlfT! -0: Z-' ~,1. ' :g-gj z:C~ Cf") (j),,::::: i,J<':J / " CC-? "0 "'""--n ~ 3:' <-:5:0 ,;;::-..".(') .70 ;::(=0 am )>c s;! Z Ul =< en ~ it;: ~- ~ , . ".~ ~. > PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. Term GETTLE (Mortgagor(s) and Record No. 2000-681 Owner(s)) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $ 69.868.34 Interest from 7/ 1/99 to 5/ 9/00 at 8.750% $ (Costs to be added) ",,~,;.""'" ~ liI!!I~r'f'{j:1li~'~-~""""" ~.""*~iiOO~~ 1fir.""'....OiL..i. , '"'- ". . . ! ~ 1-'00 'tl ootv:<Ji:':Ic, () H E ~wCll . 0 0 ~ I-'~ 1--'-0"\ () ~ ~ I-' f-'. ;J>c, 'd OGJZ Icl 'Uoort ~() 'd i:':I " i:':I f-j :<: ~. 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(1)() ~ i Z t' O"\i:':If--' ,..". -~ () t>;! suo. :to ooLQ H o,H rt' ~ lI.l - ~, , , !iilt~~llIil!IMtiIliif~.t~I'!'ir~~~":'~- -,- ~'m .~_''''''''''l~ "_. ,'" UI ' ~. r '~J , ALL THAT CERTAIN tract of land with the improvements thereon erected, situate at the intersection ofthe Northeasterly side of East Garfield Street, Shippensburg Borough, Cumberland County, Pennsylvania, being more fully bounded and described according to a plan of survey by Carl D. Bert, R.S., dated July 1977, and bearing drawing No. C-SB-77-3, as follows: BEGINNING at a point at a corner of concrete walk, at the intersection of the Northeasterly side of Ridge Avenue and the Southeasterly side of East Garfield Street (33.20 feet wide); thence extending from said beginning point along the Southeasterly side of East Garfield Street, North 44 degrees 55 minutes 00 seconds East, 40.00 feet to a punch mark in brick at a corner of land now or formerly of Richard H. Davis; thence extending along same, South 45 degrees 49 minutes 59 seconds East, 85.00 feet to an iron pin at a corner of land now or formerly of Minnie B. Bolan's Executors; thence extending along same, South 44 degrees 55 minutes 00 seconds West, 40.00 feet to an iron pin located on the Northeastern side of Ridge Avenue (27.64 feet wide), aforesaid; thence extending along same, North 45 degrees 49 minutes 59 seconds West, 85.00 feet to the first mentioned point and place of BEGINNING. BEING known and numbered as 236 East Garfield, Shippensburg, Cumberland County, Pennsylvania, IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 236 E. Garfield Street, Shippensburg, PA 17257 SOLD as the property of JOHN A, MORRIS III and TAMMI E. GETTLE TAX PARCEL #33-34-2413-026 ~ (j .......... 't JQ. "<J.. ~ ..c .\l; Cv ~ t.., .fQ.. CJ ~ ........ R.J ...!) tv ~ h c c::> 0 , "1 10 0 & ~ , , .;:""" '" "7J(,'>: :1: ...0 '" d 0 '6 ~ w ~ tv & "'nr:>-: ;:-'.;'lJO :-;:j ;;:ij ~L:n ~ C> ~ ~ ..t -< ;n;=..... ~ ..:t c;sc \Jh1 , I I I :;6' Q") "-Dc:? )::: {? I ()6 7-.J ~ P u <{;C) <J .,;:1..... " :::r; o:n 0 ~ F $0 iSh? - - ., c: - ~ - - ~ ~ .. - ~ - ;t; ::n ~ - ~ ,~ en - - ...... '"""' ...... '"' , , ,e " _,_n L _... .- ,-,', '4',_, __, d" -, GOLDBECK McCAFFERTY & McKEEVER Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW VB. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. Term GETTLE (Mortgagor(s) and Record No. 2000-681 Owner (s) ) 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is not subject to Act 91 of 1983 insofar as it is an FHA insured oan. I".." "-~~ " , '0" -i '."'.~~~ _~'''''''''_j..'''~'''~ ,~-'" ililil.llj~ ~... I, '..._.' - . l Q (.":) 0 ...~.. Cl -n u~~ :JI: --, IT?(r; :Do T 2,=:Q -< i'l~j~ 21... TriTt (j) t> en :oy -<~- L. ~~?o ~C '" -0 ~....-'-ri 20 :x 0::0 )>0 7~ C 2 :;; U1 ~ -< m . ~ ' ,_ 4 "." .,~ ~ r GOLDBECK McCAFfERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, FA 19106 215-627-1322 Attorney for plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. Term GETTLE (Mortgagor(s) and Record No. 2000-681 Owner(s)) 236 E. Garfield Street Shippensburg, FA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the by its attorney, Joseph A. Goldbeck, Jr., Esquire, of the date the praecipe for the writ of execution following information concerning the real property above action, sets forth as was filed the located at: 236 E. Garfield Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or Reputed Owner(s): JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 TAMMI E. GETTLE 27 w. Big Spring Avenue Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JOHN A. MORRIS III 311 Kerrsville Road ~"~-"" -' ~ . -. .ju",_ ", t-_, , , Carlisle, PA 17013 TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: May 9, 2000 ERTY & Mc dbeck, Jr., Plaintiff BY: :';d ~" ~"'--.h",":'_" ~. llil!lliiol~'~-" ..t::.iiiiIt_.....''-'',.---.....-- 0' ,', , 0 <.:;) 0 C Cl on ~ :x -4 v 0:; p. T n1rn -< iTl# Z::D :g~ zC 0'> (f)",,::_~ (~ // -~ r::O --0 :1::33 "- )>0 3: (::>0 ~c5 Zrn Pc: ~ Z (J1 ~ ~ 0'> r- ., , ~., ' , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive IN THE COURT OF COMMON PLEAS PIano, TX 75024-3632 Plaintiff OF CUMBERLAND COUNTY vs. CIVIL ACTION - LAW JOHN A. MORRIS III AND TAMMI E. :ACTION OF MORTGAGE FORECLOSURE GETTLE (Mortgagor(s) and Record Owner (s) ) Term 236 E. Garfield Street No. 2000-681 Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHN A. MORRIS III 311 Kerrsville Road Carlisle, PA 17013 Your house at 236 E. Garfield Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $69,868.34 obtained by COUNTRYWIDE HOME LOANS INC. against you. 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 COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was ~y j ;~; , 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 below 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 NOT 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. YOU may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. cu~erland County Bar Association 2 ~iberty Avenue, Carlisle, PA (800) 990-9108 Leqal Services Inc. 8 irvine Row, Carlisle, PA 17013 (717) 243-9400 ~" "" .__> ,'I o. " .,", , GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive IN THE COURT OF COMMON PLEAS PIano, TX 75024-3632 Plaintiff OF CUMBERLAND COUNTY vs. CIVIL ACTION - LAW JOHN A. MORRIS III AND TAMMI E. :ACTION OF MORTGAGE FORECLOSURE GETTLE (Mortgagor(s) and Record Owner (s) ) Term 236 E. Garfield Street No. 2000-681 Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: TAMMI E. GETTLE 27 W. Big Spring Avenue Newville, PA 17241 Your house at 236 E. Garfield Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff's Sale on September 6, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $69,868.34 obtained by COUNTRYWIDE HOME LOANS INC. against you. 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 COUNTRYWIDE HOME LOANS INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was - ~~ -~ . ~'" ", "ti;.. ',,____,_,1 "U ;; 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 below 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 NOT 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-94-00 iiIilJJilDU M."liil'Miv' ,~.~ , 1IDlli~t'"""",,-J.......,,, ,<"" ~' ""","~.", - ~ ~ 'J&tp - . (") 0 0 <;; C> -n :S. :x ::;:I -ace , j::ll;6! nlj'"ii -< Z::o ~~lm cQ~ Cl' ~bo ",; ; (,JO ~C] --0 :'l1-r-i ~Q ::El: ~~_:n ""-~ :::.;:=<-..1 ~ Pc Z (J1 ;l>' --1 ~ -<: 0'> , ;".~ - ...._~. 4"~ ~---~ " ~ '~~~ , SHERIFF'S RETURN - REGULAR CASE NO: 2000-00681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MORRIS JOHN A III ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MORRIS JOHN A III the DEFENDANT , at 0016:12 HOURS, on the 1st day of March 2000 at 311 KERRSVILLE ROAD CARLISLE, PA 17013 by handing to JOHN A. MORRISS, III a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So ;:~K~~ 18.00 4.34 .00 10.00 .00 32.34 R. Thomas Kline Sworn and Subscribed to before 03/02/2000 GOLDBECK, MCCAF~ERTY, MCKEEVER By: \J~ to VILl. Deputy Sheriff me thi s ;1.1 A.ol- day of ~ .1mJo A.D. C:t~~~p- Th ,iP. ) ~ Prothonotary' w~_ .-] SHERIFF'S RETURN - REGULAR CASE NO: 2000-00681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MORRIS JOHN A III ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GETTLE TAMMI E the DEFENDANT , at 0016:35 HOURS, on the 1st day of March , 2000 at 27 W. BIG SPRING AVE NEWVILLE, PA 17241 by handing to TAMMI GETTLE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 7.44 .00 10.00 .00 23.44 So .A.nsw:.;.; rs/: // ~~-r~i R. Thomas Kline me this .,}/4.l- day of 03/02/2000 GOLDBECK, MCCAFFERTY, MCKEEVER By: ~~\U1\\ t. VA Deputy Sheriff Sworn and Subscribed to before ~ :4'?rIJ A.D. qJf --0 """hr. uP, 0 /~trC Prothonotary -/ ..,~~ _.- " .~ -1- _ . t~_, , SHERIFF'S RETURN - REGULAR CASE NO: 2000-00681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MORRIS JOHN A III ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE-REI was served upon MORRIS JOHN A III the DEFENDANT , at 0016:12 HOURS, on the 1st day of March , 2000 at 311 KERRSVILLE ROAD CARLISLE, PA 17013 by handing to JOHN A. MORRIS, III a true and attested copy of COMPLAINT - MORT FORE-REI together with NOTICE (REINSTATED) and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.34 .00 10.00 .00 32.34 S;;i2~~~ R. Thomas Kline 03/02/2000 GOLDBECK, MCCAFFERTY, MCKEEVER Sworn and Subscribed to before By: \J~~. U Deputy Sheriff me this d-/~ day of ~ 2enrD A.D. ~~(J fhd~o ~ rothonotary , -'~._.~ .~ . " l<.~, SHERIFF'S RETURN - REGULAR . . CASE NO: 2000-00681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MORRIS JOHN A III ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE-REI was served upon GETTLE TAMMI E the DEFENDANT , at 0016:35 HOURS, on the 1st day of March , 2000 at 27 W BIG SPRING AVE NEWVILLE, PA 17241 by handing to TAMMI E. GETTLE a true and attested copy of COMPLAINT - MORT FORE-REI together with NOTICE (REINSTATED) and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 7.44 .00 10.00 .00 23.44 so;:;~~ R. Thomas Kline 03/02/2000 GOLDBECK, MCCAFFERTY, MCKEEVER Sworn and Subscribed to before By: ~~a.U Deputy Sheriff me this J..IA.A- day of ~A..-- .:Lovv A. D . ~L_fJ. 1ru;1"'r~ rothonotary . ~ ~~ -~-~-- .- ~ ~OLDBECK McCAFFERTY BY: Joseph A. Goldbeck, Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff & McKEEVER Jr. COUNTRYWIDE HOME LOANS INC. 6400 Legacy Drive PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN A. MORRIS III AND TAMMI E. GETTLE (Mortgagor(s) and Real Owner(s)) Term No.~ -It>~/ j;.J OIVIL ACTION: MORTGAGE FORECLOSURE 236 E. Garfield Street Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money 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 Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVlDO CON ESTA DEMANDA Y AVISO, PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: 81 USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PR08EGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVIClO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 :~ , COMPLAINT IN MORTGAGE FORECLOSURE .1_ 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 6400 Legacy Drive, PIano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are JOHN A. MORRIS III, 236 E. Garfield Street, Shippensburg, PA 17257 and TAMMI E. GETTLE, 236 E. Garfield Street, Shippensburg, PA 17257, who is/are the mortgagor (s) and real owner (s) of the mortgaged property hereinafter described. 3. On August 12, 1996, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORP., T/A CONSOLIDATED MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland county in Mortgage Book 1336, Page 164. By Assignment of Mortgage dated August 12, 1996, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 527, Page 845. These documents are matters of public record and a~e incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 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 August 1, 1999, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such paJrnents for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 7/ 1/99 through 1/31/00 at 8.750% Per diem interest rate at $14.63 Attorney's Fee at 5% of Principal Balance Late Charges 8/ 1/99- 1/31/00 Monthly late charge amount at $24.00 Costs of suit and Title Search Escrow Balance Credit Monthly Escrow amount $109.10 $ 61,020.43 3,145.45 3,051.02 144.00 560.00 $ 67,920.90 33.33 $ 67,887.57 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 based on work actually performed. 8. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $67,887.57, together with interest at the rate of $14.63, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. McKEEVER , Jr., Esq. ~, DEe 17 '99 12:22PM GOLDBECK MCCF'lFFffiTY (215)6277734 P.2/2 ..~ VERIFI6\iiioN I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the. best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 904 relating to unsworn falsification to authorities. 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