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Home My WebLink About00-00752 - J H ~ , ~g,,"- LAW OFFICES OF GREGORY JA V ARDIAN BY: GREGORY JA V ARDIAN, ESQUIRE ATTORNEY !.D. #55669 44 Second Street Pike, Suite 203 Southampton, PA 18966 (215) 942-9690 Attorney for Plaintiff CONSECO CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 Plaintiff COURT OF COMMON PLEAS TRIAL DIVISION CUMBERLAND COUNTY No. cYL;(X)- '7Sd-. Cuu..9 T01M vs. FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANlCSBURG, PA 17055 Defendant(s) COMPLAINT - CIVIL ACTION 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 this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense or objections to the claims set forth against you. You are wamed 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 NOTICE 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, P A 17013 717-249-3166 "'''''';-,,' ************************************************************************ NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ************************************************************************ I. This is an attempt to collect a debt and any information obtained will be used for the purpose. 2, Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3, If you notifY our offices in writing within thirty (30) days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. 4, If you notifY our offices in writing within thirty (30) days ofreceipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. "~~" ".~ ..........~ - ...li:Il!,,,, LAW OFFICES OF GREGORY JA V ARDIAN BY: GREGORY JA V ARDIAN ID# 55669 44SECONDSTREETP~ SUITE 203 SOUTHAMPTON, PA 18966 (215) 942-9690 Attorney for Plaintiff CONESCO FINANCE CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 :COURT OF COMMON PLEAS :CUMBERLAND COUNTY Plaintiff(s) VS. No. d-.D'C:f::)- '75Q. G.;;JITUt'1 FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Defendant(s) : COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE L Conesco Finance Consumer Discount Company, (hereinafter referred to as "Plaintiff') is an Institution, conducting business under the Laws of the Commonwealth of Pennsylvania and brings this action to foreclosure the mortgage between Frederic C. Jussen, III and Eva Jo Jussen, Mortgagor(s) (hereinafter referred to as "Defendant") and itself as Mortgagee. Said Mortgage was dated November II, 1998 and was recorded in the Office of the Recorder of Deeds and Mortgages in Cumberland County in Mortgage Book 1497, page 219. A copy of the Mortgage is attached and made a part hereof as Exhibit' A' . 2. The Mortgage is secured by Defendant(s) Note dated November II, 1998 in the amount of $111,600.07 payable to Plaintiff in monthly installments with an interest rate of 10.90%. ".." - '~-",,",; ! . 3, The land subject to the mortgage is: 160lThompsonLane, Mechanicsburg, PA 17055. 4, The defendant(s), Frederic C. Jussen, III and Eva Jo Jussen are the real owner(s) of the land subject to the mortgage and the Defendants' address is: 1601 Thompson Lane, Mechanicsburg, PA 17055. 5. The Mortgage is now in default due to the failure of the Defendant(s) to make payments as they become due and owing. The following amounts are due: Principal Balance: Interest to 1/11/2000 $111,380,55 $ 8,913.41 $ 1,411.41 $ 6,295.23 $ 5,569,03 Accum. Late charges Misc, charges Attorney Fee/costs TOTAL: $133,569.63 plus interest from 1/12/2000 at $33.54 per day, costs of suit and attorney fees. 6. In accordance with the provisions of the Act of January 30,1974, P.L. 13 No.6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose and Notice of Homeowners' Emergency Mortgage Assistance was sent to defendants October 26, 1999. The Defendant(s) have not cured the default. WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiffs favor and against the Defendant(s), in the sum of$133,569.63 together with the interest from 1/12/2000 at $33.54 per day, costs of suit and attorney fees. Law offices of Gregory Javardian -~ ~= ~,-~-~~_. ~J ~~ I -_r>kiL''''', . Rece1.ved: 9/22/99 6:11PM.; -> GREG .JAVARDIAN LAW OFFICE; Page EI SEP-22-1999 WED 02:48 PM FAX NO, P. 09 . ') . ~ . .....,.......J!~~..J:~,...;.~~1.. ...........!'!,.~h-~~~.cr.2!~rs........uu, ......,........,.,~y.~~.~!.........., co"," 1Ch,1 IIftMI ...............................Mi!!~.:me~!!!ffi.~nf1;...~~.9.'m~.c;..}m~s.~..r.,.W):!Y.l;y~n~.'....17.9.~!........m......n.n.. lPJapeny~ddn1..1 NOTE ~~~ . 9S10:--'i3. WI.N II 6'-O:i!i..~72-9 I. BORROWER'S PROMISE TO FA V In mum ror a I.... "'" 1 baw ....Iyed, 1 p....... OJ PIlJ U.S. $..U~.,~9.9_.,q9._..____.__........_. (rhls lIIllOWlL III called lrprildp.), p~ld 11lfereM:. 10 &be orderofdle Lender. The t..c.;Icl'h ,..~!.~.m.'..~~.'*~.~.~/..140l ~~~!I,~.l:,..~~~.P.\".'!Il;.fA!/....~.mM/..r.~...'!-!~!~...............................u...............u............................... I_.....ad ....1 die I.eo4e< may _ dlIs N..., 1110 Leoder or anyone wbo takd ...is Note by .....fer .ad who Is emicled 10 sec:ei.....,...... Udder this No.. is called Ihc 'N.... Holder,' .t. /l\!TBRIlST In...... will be c~ on 1lDpBid prim:ip>l uoIiI dta lIlIIlIDlOWII or priocipol.......... poid. I will fY i_ 11 a _Iy ..10 or .....~9.,,~R~..,.. 11.1_' wiU be cbargod bqilllli.,DB ............~.~!!I!'!1!lf...M~..!-oM.................... ' 'Ibe 111IO.... nle nquired by this _ 2 ill .... .... 1 will pay both betlne .... al\or .... de..... deocribed h1 SeodOD 6(8) or dlIs N..., ). 'AYMEN'I1l (A) SeWuIed ~ I will JIIY principal.... iDoeml by........ JlI1al- when sdledllled; G I wiD make: .......?-9.9...................., payallDII of $..~,.qA!s.:.7R.................u.u........n.... cadt on ~ .................~.fxh...........u................. of each .....~.~!!...., .., ..................... .., ... ....................,. .....,.................. ,.. ,................................. begiluUae 00. ....q~R~~.!..J.~,.o:.. lI:??........................ o I win m.... poym.... IS fallows: o I.lddilio. OJ Ihc pa,...... _n'be4 oIlovo. I will JIIY . 'bolloon poymenl' 01$ ...............................'... o. ................'........................ . TIle Nole Holder...w deli... 01 aIaIl OJ... notice prior 10 IlIIlIwi1y dw .... ball.... poym... is ~"". TIIiol101ic:e win ..... .... ball_ p&ymenl........IDd.... do.. ChlI h i. due. (11IMaturlly Dale a.d ..... of..,..- I wiD ..... III... po"...... .. ""......... _ I ..... pWIl11 01 .... p1ilIl:ipaI .... _ oad oa, other oJw,es desen'bed below dw I ma, owe _Ibis N..... My _loci poymenll wl11 be ...pllod OJ iDre.... _ priacipd. If. DB ""n.n!!~,,"'~I..~~~J...............nm................ 1...'11 _...._..this Nelle, I win JIIY Ihose 11IIOII"'" 10 fUD Olllbal dace. wlaiclt.ls called die lrmacw:icy.... . 1 will...... my lICheclulcd pI"......Il....9f.!".'1"n:,!l~..7.~,~R..~.,..!!Y.f!!!!!!..I,l.~"'...T.~m!\'.,..~..,~!i~.U.... ........................,.............................. .......,.,.....,. ... .., ....u.... ........., ... ... ...........,.., .......... or . a diffeJmt .looe if nquired by .... Note Holder. 4. BORROWER'S RIGHT TO_AY AND 'RIlPAYMENTPENALTY I bave .... rish! OJ ...... poym_ of priacipd 11 IllY lime ""fon: ....y ore due. A p&ymelll or pdDdpal 0IlI11s IlIIowu .. . "_ymeoL' WIleD 1_ a !r.'"~' I w1UtelldleNote Holder in wriIiog dIIlI... ~ 110. I!l 'wa'1l ~Y. ~=p:ulIY of ...!~.~~~..!!...}!~~!n'.~..~.5!!9...m:~.>>.I)R!..q...A9.f>>..!~n~....t.~M..Ant:-.'l8 ..~!n.~!..f.':'!i!..~.~..Rf.~~..!'!J..~b!u..:fJi..l1!.9})~!1f..~J.9.l!\.5h~.'A~'..R*..~})!..J.9Rn...........m........................ ...............un.............................................u.................................................. if I JIIepay Ibis Nab: iD lull. The N.... HoIdcr wiD "'" III or lID}' _ ... ........ .... ....... orprl...ipol.....1 owe """" rhl. NOlO, If I ..... . putiol pn:poymeal, Ill.... wiD be ... -"'10 .... du. dole or i. tile ...011.' of my lRIIllrhly paytIlCII< IUIlas Ihe N"", Holder ...... Ia wriIiIls 10 ..... c!lIqes. 5. LOAN CIIAIlGES 11 . law. w1dcIl oppIics 10 dlIs I.... oad wbIcb seullllliR\llm 10" -.... o. fiDally In/eIp''''''''''' ..... .... _ or olher '""" dtaqp:s eollc:c:&cll or ... .. eoIloo<ed In oolUlOl:lion with thio 1011I ......s \he .......11.... IllIIits. _ (i) lIlY such '""" cbarp sItaII "" __ by.... _ _ 10 ........ ........... 10 dI. petmillclllimlll IUIll (Ii) lIlY ..... allOlldy coIIcc"" ...... me: w1UclI 0IIl0eded petmi.....limits WIll"" ..1iuIded 10 me. 'Ibe NOIe Holder'may -.. !II ...... rhls ..- by reduchIa the prloclpoll owe uacIer dlIs N.... or by molmls . dirccc payment to.... 11 a.._ led..... priooipal, dJo redllOlion will be ....""'... parda1 prepoymeac. ,. BORROWER'S I'AILVIlE TO FAY AS REQCIIIUlP (A) LMe Ch.... For O.........1'oJmads Ir the Moo. Holder.... IIllI rcceivcol die filii 11IIO.... of lIlY 5CbedoIed paynlW by die... or ........~_~,......., -.ledu day1I after .... dore ic io _ 1 will pay a b'" dwgo OJ .... No'" Holder, 'Jbe ....... .r.... oIwgc wiD be .~.~..~~~,~..lIi ' . I...w)lOr tho......tJarae plOlOpdy IlUUmly once 011_ II.. paymonL 0 1. payme r f whJ:i::heve-r 18 gJ:elll'ter. (Bl Default Irl do IIllC pay .... f1IlIlIIIIO\IIll ol_lICh......ed pay..... DB IIlo cIaI.I.1s d.... I will "" in de/lIoll, (C) NoIIce of Dd'lluk Ir I_In cleW.. the Note Holder III&Y _ me. _ oodce ..lIillllmc: 11m. if I do DOl pay Ihe cweal.....;.....c by......... _. .... N"'" Holder may nqui.. me 10 pay I......II.'-Iy die 1UIl_ ofprioclpal wbiob IIu .... ...... plid and .n .... 101....1 ..... 1 0W\l OIl dint .......L 'I1>at cis.. ..... be Ill.... 30 dlIyo _ Ihe _ DB wIUdI .... ....... o. ddivered QT maitcd 10 InC. (0, No W...... By NoIe Holder EVCII if, ... .... wbe.o 1....10 dofllDl., .... M_ Holder does 001 nquin: me OJ pay lmmedintel1l. filII.. dose."'" _., .... N.... Holder will.1iI1 ba.. die r1Bhl OJ do an if 1.... i. _Oil" a Ialer lime. 00 ..,..,...t ofNole JIoId..... CCI ODd ~ If .... NOle Holder has requlled ... ... poy ~y i. fult IS cIncn'bed ."YO, lhe NOlO Holder ..111 baYO die ri8hI '0 "" pllid book by DR /Dr aI' of its ..... IDd _ In _.. dll. Now OJ .... .._ .... pIO\libIled by oppIleoble Ia... 'l'harc"""", inelll4e. for .....p.., 1<UO&IIbI. _yo' fees. MULTIPURPOSE FIXED RATE NOll IMULTlSTATE' - ,"'., .......s,.t......1floI....8I'.tIIIIII,M..,.,..,.,.......,.Imli'I. 11110:1 - .......iliilll".-.... -~~ ~- ~=...",.............. -~ ~ ._~''"'.......'r_ ' . Received: 9/22/99 6:11PM; -> GREG ~AVAROIAN LAW OFFICE; Page 10 SEP-22-1999 WED 02:49 PM FAX NO. p, 10 ,-. r- , " < 'f.GIVINGOJ'NO'I1CES . . '. u..... .ppli....l.taw "'I"i... a dilf_ .....ad, Uly IIlllioe dlal..... be Fien I. mcuudcr IbiI N.....m be ;n.... by cIcliv..ma it .r by ...ui.. it by lhsI .w. mail 10 me II .... PrapollY Add.... ._ .r II a diffmll1 add.... If I ..v. aile No4: Holder a DDIicc of my diItcrcat IIddrcsr. Any IIIl1icc Ihlll 101131 bo aMn 10 1hc: N... H.I..... ...lbia \II... will be ..... by pqili., it by fine claD IlIIillO lb. N... H.kIer Ir \h. .ddms SlIIOd i. See.... 3(1l) .. pase I .f Ibis N... or II. dirre- add",.. if I... sf..n a aodce of IbaI diffmnlldd_. t. OBLIGATIONS 01' PERSONS UNDER THlS NOTE If..... ........ po.... sips dIb N..., ..... _ Is lUUy awl pasoaoIly obIigllald 10 ...... 1111 of th. proolIlO$ made in Ibis N..o, I11010dil1ll dI. promise lO pay ....1\111 ....... owed, ADy pmoIl who is all....,,,,,,. SllIllIJ or...._ or thi. NOle i, .... obIip.... 10 do ..... thiOIl.. Aoy porson who likes OVer dIeoe ""Dilations. indudi.. Ihe obli....... .r . .........r. _ly or .......... of..... N.... i. al", obIi....., .. ...... III of lit. \l'OIl'ioco nuul. in do;' NolO, 'lbo NOIe Holder _y "'-'111 rish.. _this N'" .......,_....... ialividoalIy or ori....n .r........... Thls-..Ihar ooy _ .ru. may be n:q.l104 10 pay all orl\lo ........ owed 0_ dJis N.... ',WAlVE\lS IIIK1 I.., odIu- penon who his obJiaalioDS 1Inde1lhis NcHe waive Ihe rlgbl5 of pr--1tM_1 and..aodce of disllodot. '1'nIae_' m.... "'" n,ht to ... .... Nore H.lc1cr 10 demand payment.f........ due. 'N.d.. or diobollOt' -.s tbe rishllO R>q1U'" .... N"'" Holder I..... DOlloe eo _,....... dJat __ due baYO mil bo:oa poid. It. SEC1IREIl NOlE /a "'didoo 10 dJo pmll:C1ioao ...... eo .... Nato lIo1der _ ... N.... . !of...,.,., I>ccd .r'fnllR or 5a:urily Deed (.... 'SocurilY !1lIbUDICII1'. dllOd dte ..... do.. IS this N.... JlIDIectI tbe NOIe Hohler Iiam possible I..... Wlliob IDl&la ....t. it I .... IIDI bop lite pIVIDiICI whiell! .... io this NoIe. ThaI _y IIlSOUIIlCnI d....ibes _ aod _ whl' oondidona!may lie NqUiftd 10 IIIIke Imadialo _la IUII.f all ......- I.................. Note. Senne of eb_ .....ndUDI or. "'*'rlbed .. 101.....' Tnmfer or the Prapen, or . BOllOIIda\ ........ ... ............ Ir.1l or 1111..... of.... P_ .r ..y 1_ ill i. ia sold or ....._ (.r ir . bmoficiali_ ia _ Is <old or ......,OJrOd aod I_Is 110I . ....... ......0) 1Oidtoullmdor', prior wriIIca _, Leader "'Y. II i1s option, .....ire lmmcdio.. payotCIII in filII .r all lUAU _ by this Soc1IdIY _ H_. ..... Gpllao IhwII aor be ..._ by I,.eIlIIot if......la,.-.bibltc4 '" fc4oq\ law .. of\llc _.r this SenriIJ I............ If Leader ......... IIIls oplion, I.cIlIIor lIIIIIllliYO Bonawet IlOIic<o of "'"'orotion. '\'be nodoc: dtoIJ pnwldo . period of DOl I... ..... 30 "'Y" liom lb. _ .... 1IOIi.. is ddivcml or mailed wichin ..well B_ rallS. pay Ill..... _ '" ebis 5a:uri'1 InoIlUmeJlL IrBonawetlilils '" pay III......... plio< 10 lit. erpirodo. of ..1& period, LeIlcIcr may iavob IDY _ pcnaiIled by lIIi. S...,;ly InoUuJneaI wilboul funher_.r........, on_. 11, 1lA.1L00N PA \'MENT DrsCLOStlRE (Complete .... balloon ~ IIOIic:o below if lIti, NOlO provides I'or I baI..... pa,"'lllll Secdoa 3(10) DO pace I of this Hale.] '11IIS WAN IS PAYABlE It( fVlJ" .................................................................................................. ..................................................................................................rih.........................1 MIJS1" REPAY TIlE EN'I1IIE PlUNCIPA.L BALANCE OF 11IE LOAN A.ND llNPA.ID IN'l'EIlIlST TIII!N DUE, WIlICR MAY BE A LAROE PAYMENT. 11IELENIlER IS UND1lR NO OJILJGA'l1ON TO llEFIN'ANCE TIlE LOAN AT THAT TIIlIB.1 WILL, 1'lIIlJWrollE. BEIlEQUOI;ED TO MAIlE PAYMENT OUT OF 0'I1II!Jl. A.SSIt1S TRAT I MAY OWN. 0111 W1....UA VE TO FIND A LENDER, WRIC1JMA Y BE 'JIlE LIlNPF.R IlIA VE 'DDS LOAN WITII, WILJ.1NG TOLEI'iD ME TIlE MONEV.II' IIIJI'Il'IA.NCE THlS LOAN ATMATlIRITY, I MAY HAVE TO PAY SOMB 01l. ALL (iF 11m CLClSJNG COSTS NORMA.Ll.Y ASSOCIA.T8D WITH A NEW LOAN EVEN IF I O1ITAIN IUlFlNAN'CING FROM TIlE SAME LI!NDER. WITNIlSS mE HAND(S) AND SIlAL(S) Of TRB UNDERSIGNED. ~"J_~.,;".,.(;,J;t;:!:;.:.~....zt&..................... ..,..,,(s..J) Frederick C ~BBe I ~ww 'b-pV.-~I.'...........................................~ ............,'...'.....:.......................U.....U.........", ..,. ,.. O. .,.........(SaI) - {SIgn onli""'OIdy} .......~.'"'" ...C......ll ...........~fN ~I... ",.,.~",~J . Rece1ved: 8/22/99 6:12PM; ~J 'U"~ilI_, SEP-22-!999 WED 02:49 PH .-> GREG ~AVARDIAN LAW OFFICE; Page 11 FAX NO. p, !! r-'\ , ,-, i : MORTGAGE' DEED OF TRUST ASSIGNMENT 6902183729 For value received, GREEN TREE CONSUMER DISCOUNT COMPANY , a corporation organi;ted and existing under the laws of the State of Pennsylvania, hereby assigns to US BANK TRUST NATIONAL ASSOCIATION, its successors and assigns, all right. title, and Interest in and to III certain Mortgage I Deed Of Trust dated November 11, 1998, made by Frederick C. Jussen III and Eva Jo Jussen, his wife, as tenants by the entireties, as mortgegor(s), to GREEN TREE CONSUMER DISCOUNT COMPANY, as mortgagee, as filed In the offices of the County Recorder, county of Cumberland, State of PennsylvanIa, tDgether with the Note secured by such mortgage I deOd of trust on the followlng described property situated' in the above county and state, to Wit: Sea attached exhibit A for legal description. Dated this day of 11/23/98. GREEN TREE CONSUMER DISCOUNT COMPANY By: Stale of Arizona ) )sa County of Maricopa) As a Notary Public for the State of Arizona, I hereby celtify that Julie larson personally eam" before me on this date and acknowledged that she Is an Authorized Agent QREI!.N TRElE; CONSUMEll DISCOUNT COMPANY, aPcnnsylY8l\ia corporation, and that byaulhority duly given anrCI as the act of the corporation, the foregoing instrument was signed In Its name by her. Witness my hand and official seal dated 11123198. . SUSAN ANN PECE , ,',."," Seelpy PI.tbIe-,' , AtlzanO ~CoLln1y Mv~Elq:J/1'4lS Juno 6.2001 - ...' ~~.~ ' " I " -~ h....~~j , Rece1.ved: 9/22/99 6:08PM; -> GREG ~AVAROIAN LAW OFFICE; FAX NO. Page 2 SEP-22-1999 WED 02:45 PH P. 02 J9.J7J n r\ , _t , . C....IIlO.wooltll 01 l'oml5)'Inaia Spoce Ahove 'l'IIls tide For JleconIIac Do.. OPEN-END MORTGAGE Appli....~~ \ ~.,\'ft..3Na\ This Mortgage secures future advances . 1. DA~ ~ 'dARTIES. The dare of this Mongage (S~ty IdSlrUmCllt) is ...~'?~!':~~.7..,~~.'....t.~.~.~....... and /he paIlles, their ad resses and lax idemilicarion I1IIIllbers. if required, are as follows: MORTGAGOR: Frederick C Jussen III and Eva JO Jussen HIS WIPE AS TENANTS BY THE ENTIRETIES o If c:IIcclced, Rfer 10 Ihe allaellcd AddeDdum ilJl:OrpomlCd lluein, for additional MOrl88som. tbeir sigaalUleS aad ackDowled!lJllClIlS. LENDER: Green Tree Consumer Viscount Company 3401 Hartzdale Drive Suite 118 Camp~ill, Pennsylvania 11011 2. CONVEYANCE. For good aod ~uable eousickrarion, !be receipt 811d Sllffit:iCllC)/ of wbil:h is aclmowledsed. and lO IICClIre Ihe SI=red Debt (de/iae4 below) alI4 Mongagor's peri'onDaDce IIIIder Ibis secumy IJIStrumeDt. Mon,asor .g;aDtS.JprPiDs. c:onwys aad mortgages 10 LeDder Ibe foUowiag de&eribed pIUpcrty: -c::o .:;;: _ . z; ~ ~~l :\.. See Exhihit A oc:> ~ :,,, ,. .c::; ~:~!~ .....- 1- :.:: ;:~ W ~ ~~ -, c;:~ ~ ~ C')~l'~ o ;:::. <:::Q . I'"\) ~ ,~, !-2 ..... fn: . G.3 ,,< 0 :"tt c.o I tn ." n.e property is \ocated. in .. .u..~~...............~ .~..............-...~.....,.......... at ............................... ...~.................. ...~.... ._ . . (CcnIIIly) .' ." : . _-'_A;. 17055 .... ...........,..............-:.. o' ...........~...........~..~............ ... .~.............. .......................~~.........,. .~..... .---~l..T- ...',............1"........ (Addcoul (Cily) (7JP CM.) Togelher with all rights. easements, appurleDllllCes. lOyatlies, pdlleral dgIIts, oil and sas rights. all water aad r1parlaa rights. dird1es. aod waler srock aDd all e1istiDg and €utnrc improvetncnrs, ~. fixrures. aod rcpl_'IIS Ibat /DI.Y "', or at. any dme in the future, be pan of the real estate described above (all RferrecllO as 'Property"). 3. MAXIMUM OBLIfHt~~. The lOcal priacipal8lllOlll1l secured by this Security InscrWnea& at any one IUIlC slra1l JIO( exceed $ ...................~........:....................... . 'IbIs timilluion of lIIDOI1Dt does not iuclode iRlClest and otber Jees add charges validly made pursuanllO this Security I1lslrumeDt. Also, this timimlion does IlOtllpply 10 advaDces made lIIulct !be tcr.rnS of this SmIriJy IIlSllUlDeat 10 prom:l Len~' s scewilY 811d 10 perform any of the COVCdBlllS colllaiDed in this i!ecuiiIY l_bl. 4. SECURED DEBT AND 'Ji1JTtJRE AnV ANCES. The h:DIl 'Secured Debt' is defined as follows: A. Debt illCumd uDder the tenns of all ptomissory oore(s), colllllll:1(s). guaramy(s) or ollter evidl:_ of dl:bl described below aod all dleir ~lellSioDS, l'ClICwals. modilicatioos or subslituliollS. (When re.terendn, thll debr.s M~IW il is suggest~ rhat YOII/lIClude itemS 'IICh as OOrr_,' names. /tOM amounts, ilUerest rates. marwjty dates. eu:.) Note dated NO'llember 11, 1998, between Green Tree Consumer Discount Company an.!. rrederick C JUBBen III, Bva Jo ~saen. for $~~~.600.00. maturing November ~6. 2023. , PIINNSVLVllNlA . ~OR'l'O"Ql "01_ FNMA. FHLMC. _ OR VA usa .,... ......k.. tywI-. ...... 'Ie. Cl.... UN .,..004.74'U'1 IIftnn ...I-NTG....A '21''''' "Onl ID 11.11114 ~Qod497rAGE a19 .-..Jnt\ "-I" t..., til ~,~ -- ~-"''I''\i%~-Ri" Received: 9/22/99 6:06PM; -> GREG ~AVARDIAN LAW OFFICE; Page 3 FAX NO. P . 03 SEP-22-1999 WED 02:46 PH ,,-.., , ,"-'" . B. All fuNrc advances Iiom Lender 10 Mortgagor or OIhcr future obliganoos of Mortgagor to Lemler lIGdcr any prllmiSSOIY DOle, conuacl. summy. or olber evidetu:e of dcbt executed by Mortgagor in favor of Lender execaled aflcr this Seciurity IlISlT1UlIeIll whelhcr or nOI this SccurilY lnstnunent is specifically RferePCed. If _ Iban ODC persoll sigDS Ibis Security Instnmlenl, each Mortgagor agrees thaI Ibis Security IusltUlllelll wJ1l securc all fUture advllDl:es aad NlIlre obli8'ltions Ibat are giv$l1l0 or incurred by any ODC or DIOre Mortgagor, aT anyone or tIlOl'C Mortpgor and o\hers. A1Ili1ll1rc advaaces aDd olber furore obligadons are 5CCIIl'Cd by this Security JDSI/lllIIeDl even lbovgh all or part may IIOe Jet be advanced. All funue ad.'IIlIIlCCS aad olber NlIlre obligatious are secured as if made on Ihc date of Ibis Security lusll'OllDCtll. Nothlng ill this Securily l/ISllWIJenl shall cousdmte a commilmelll to malce addilional or future loans or ad.vantes in JUly amouPl. Any such commiltnCnl must be agreed 10 in a separate wrilillg. ' C. All obligations Mortgagor owes 10 Lender, which may later arisc, to the exleDl DOl plObibiled by law, illCludiog, butllOt limited to, liabilities for overdrafts reladll& to atIJ deposil 8CCOUDI agreellltDl between Mortgagor and Leudcr. O. All acldiliOlllll S11lDS advanced aad expenses iDwmod by l.ePder for iusuriog, plW'lVillg or otherwise plOfectiog Ihc Propeny a1Id ilS vahle aad any o!ber sums advlltlCed 8Dd expetISCS incum:d by Leoder 1IJIdcr Ihc terms of this Security Instrument. This Seeurity IDsll\ltDeDl will POl_ any olber debt if Lellder fails to give any required POtice of the righr. of rescissiOlQ. 5. PA \'MENTS. Mortpgor agreel that all paymentS UDder the Secured Debt will be paid when doe and !Ill JCCorcIaDce wiith the temJs of che ~ Debt alId Ibis SecurilY lasrrumcnl. 6'. WARRANT\' OF TITLE. Motlgagor wamats dlat Mortgagor is or will be lawfully seizecl of the estlle conveyed by this Seeurily IlISlTUmenr wi has Ibe righl to graDl, harpin. COIlVC)', sell, and mortgage the Property. Mongagor also _ thai the Property is \IlIe_bered. ClICept for etlC\IIIlbrBDCeS of ~ord. 1. PlUOll SECV1UTY INTERESTS. With regard to any other mortgage. deed of tnlSl. securily agreement or odm liell document that CRaled a prior secqrity I_t or em:umbIlltlCC 0.Il the Property, Mortgagor apees: A. To make all payments when due wi to perform or comply wilb all cove_. B. To pro.mptly deliver to Leader any DOIices that MOrl888or m:eives frOIII !be holder. C. Not to allow aay modilkatiotl OJ' exteJlSioa of. IIDf to requesl /lIlY fiI/lUe adVlUlCeS under allY DOte or lIBreemePr isecured by tbe Uen dOCumeDl widaoul LeIllIet's prior wnUCD. CO_Dl. I. Cl.AIMS AGAINST 'I1TlJi:. Monsagor will pay all raxes. asse55IIICI1lS, lieus, eDC1IIIIbrauccs. lease payDlClllS. ,mud ~, utilities, aad other daarges telatiog to 1hc Propen:y wilen 4lue. Lender may reqllire MORgagor to provide 10 LeIllIer copiIls of all notices that suc:\ 8IIIOUDts are due lUIli 1hc receiPIS evidtDcing Mortgagor's pa}'llletll. Mongagor will defend tide to the PlOpeny lIBainst lID)' claims that would impair the IiCll of this Security luslr1IlIleDI. Monpgor qrces to _ign to Lender. as requeS1ed by LealIer, any rights. claims or def_ Monpgor may have agaiusI p:lTties who supply labor or lDlIWIiaIs to _nWn or iaaprove the Property. ,. DUE ON SALE OR ENCUMBRANCE. Lender may. al ilS option, declaIc 1hc eDlire baIancc of 1hc Secuml Debt to be immedialely due lIIllI payable lJpOO the c:JelIIion of, or CODlI'lU:t for 1hc creatiO.ll of. 8IlY lien, enc1IDlbnm:e. tn\JISfer or salle of !be Property. This right is subjccllO the mtricdoasimposed by l'edelallaw (12 C.F.R.. 591), as appllc;able. This covellllllt sba\1 IUD with 1hc Property 8Dd shall remain ill eflCc:t IIIlIiI !be Secnml PebI is paid in IbII wi Ibis SecurilY IDSInIIlIBm is released. 10. PROPERTY CONDmON. ALTERATIONS AND INSPECTION. Mortgagor will!ceep the Properly 111 sood COJIdition and make all repails that luC: reasonably llI:ecssary. Mortgagor sballllOt commit or allow atIJ '\1l/8Ste.!mpaimuent, or c1cleriolration of the Prope<ty. Mortgagor will I<.eep the Property me of uoltious weeds aDd grasses. Mortgagor asrees dlat the IIl1tWIl of Ibe occupancy and \ISB will POI sllbSWllially cbanSe without Lender's prior wriuell CODSCUt, Mongagor willllOt permit ~ cbaDale in any Iiceuse. resuicdn covenam or easemenl without Lender's prior writtCD coasear. MOrtgagor wilt lIOlify l.cIIder of aD demlUllis, proceedings. clailllS and actions aga!USl Mongagor, aad of ar1)' loss or damage to tbe ProperlY. .).'4 ..... li/wleml. "",,!!h. ca.ud. NlN 1,-o~\'I1'2U'1 Porm Rl-t.IlTG-PA 11111nt.. !l~oki497 rAGE \220 ~ 6o.i~ .....-. ..~- -~"~. '. -. 1- ~'" liiI_"" Reee1.ved: 9/22/99 6:09PM; -> GREG ~AVARDIAN LAW OFFICE; Page 04, SEP-22-1999 WED 02:48 PH FAX NO, p, 04 ,-..,\ {'"", Lellder or Lender's agealS may, at Lender's option. enter !he I'ropeny at any reasonable lime for Ihe JllIlJlOse orinspeclill8l11e Propeny. Lellder s1rallllive Mortgagor notice at the lime of or bet'ow an illSpeCtiaa' specifyiag a reasonable putpOSe for lIIe inspeclion. Any inspcccion of lhe Propeny shall be elllirely for Lender's benefil and MDlIgagar will in no way rely on Lender's inspection. , 11, AUTIIORITY TO PERFORM. If Mortgagor fails 10 perEonn allY dllry or any of the covenanrs liOncaine<l in Ibis SecurilY IlIStnIlJIent, lender may. wilhout narice. perfonn or guse lhem to be performed, Mortgagor appoints lender as attonlCY in mllO silln Mangaccr's _ or pay any amount necessary for perfol1lWl<:e, Leodct's rigbt lO perform for MOllllagol' sball DDI ~reale an obliBarioR 10 perfonn, and Lender's lailure 10 pedonn willllOt preclude LeJlder from CMreislBs any of LeI/iller's other rig/liS IIl1der the law or this SccIIriry IllS_lit. 1f any COlIStIul:UOn 00 the I'ropeny is discolltiDUed or not carried ~In in a rellSOnable maoner, Lender may cake all steps necessBty CO proleCf lender's security i_1 in the Properly. im;j{udiag COlIIpletloll of the consll\lCtion. 12.. ASSIGNMENT OF LEASES AND RENTS, Monsagor inevocably grants. barpins. conveys and 1Il0ngqes to leDder as additiODal. security all the risht, 1i1Ie and interest in and 10 any and all eiliDnll or future leases. subleases. and any olber written or verbal asnemenlS for lite use ami occ:upaocy of any ponion of !he Propeny, ineludin,s any meJISiollS, rencWJJs, modific:atiollS or IiUb.sDmlious"of $11ch q_ms (all Rferred lO as "teases") aIld rem, issues and prolits (all referrecl to as "RePes'), Mortgagor will proalpdy provide Lender with crue lIIJd eo= copies of all edsdllS and fuluro Leases. MortBqor may collect. rec..lve, eojoy ami use lIIe Rents so 10llg as Mongagor is IIOt in default UDder /he lCn1lS of Ibis SllClIrlry Insuwnenr. . Monsagor qrecs rbatlbis assignmeot is hmnediareJy effeclive between !he panies to this Securiry Instrumeal and effccuve as to third panics on the recording of Ibis Security IllSrrument, and this assiglllDenl will retllaln effective umit !he ObJiptiI;pIS are satisfied, Mortgagor as*' dlat Lender is eml.lled to notify Mortgagor or Mortgagor's tellBDlS lO mala: paymeolS of RemIS due or lO become due direclly to l.elIder after 5lIch recordins. however Lellder agrees JIOt to notify MortgaBOr's _is util Mortgi\gOl' clcfaulrs and Lender notifies Mongagor of the default and demaIIds tbar Monsagor ami Moltllllllor's tell3lllS pay all Renrs due or to become due direcdy \0 Leader, On receiviag lIOlic:e of default. Monpgor win ewlone and deliWI' lO Lender any paymenr of Rents in Monga80r's possession and wUI rel:clve auy Rents in U1ISt for lender and willllllt cammil'lle !be Rents with any other lUnds. AJJ.y amounts collected will be applied as provided in Ibis Securiry InstrUmellt. Mortpgor \'I1UtlIIIlS /hat no default cxisl$ UDder the Leases or any applicable landlordltenanllaw. MoClJlll8Of also agIees lO mainrain and requtrc any tenant to ~OD1ply wilh lhe terIIIS of the Leases and applicable law. 13, LEASEHOLDS; CONDOMINIUMS; PLANNED 1Jl'IllT DEVELOPMENTS. Monsagor aarees to comply ,,~Ib the provisions 01 any lease if this Securlty InstrllDlClll is on a leasehold. If tbe Property iucludt:s a 1I11l1 ill a coadomiDlllm or a planDed 1l1li. develop_t, MortgagOr will ped'onn all of Mortgagor's dudes lI1Ider Ibe co_. by-lIlws. or IesuIa1ioos of !he eol!domlnium or pJ8IIIlOd 1IIIir clevel~ . - 14. DEFAULT. Mongqor wllt be ill default if any pany obligate<! on !he Secured Debl falls to maIce payment ""en due. Mongagor will be in default if a bIeaeh occ;urs under !he IeIJllS of Ibis Scc:wiry'1l1Stn1l11elll or any olber dOCllD1Cllt ez<<;DIed for /he pUJpoSe of aeating, securing or guarantying lbe Secured Debt. A good fallb belief by Lender lba1 Lellder at ~', dIlle is insecure with R$pCCtlO any person or CIlliry obliaated on !he Secued Debl or tbat the prospc~1 of any paymcm or *' value of the Propeny Is impaired shall also coDStitute an event of clcfault. 15. REMEDIES ON DEFA.'()LT. lD some insiances, federal and stale law will require LendCl' to provide ).{onsa8or wil:h notice of the right t<l cure or olller notices aad may establish time scJIedu1es for loreclosure attiOllS. Subje<:( to lhese limiu,tioas, if any, Lender may lIl:CeleOlc tile Secuml Debt and foreclose Ibis See1lriry Iasuwnent in a manner provided by law If Mortgagor is ill, demit. At Ibe opIitm of Lender, all or any pan at the aarml fees and cJwges. ACC1IIed ialere&t and principal sball become iDlroccli8.llOIy due and payable. afJet Sivillg ~ if required by law. upon the oa:urreacc 01 a default or anytime thereafter. In addition, Lemler shall be eIllided lO all !he remedies provided by law, the tCJIllS of the Secured Debt. this Securiry Instn\mCtll: aIld any relared documenrs. All remedies are di5tinct. cumulative ancIlIOl exclusive. and !he Leoda is entitled to all remedies provided at law or equity, whether or not eltpressly set fonh. The acceJlWlCC by Leoder or any S\IIJ1 b. paymePl or paniaJ pa:1JIItD< on the Secured Debl alier the ball111Ce is due or is accdetared or after foreclosure proceedilllls are filed shall DDt coDStilUle a waiver of Lender's right to require complete cute of UlY eJdsrinll default. By 1101 aereisiPg any re!'dOOy on Mortgagor':1 default. Lender does POI waive Leader's right 10 \aler consider Ihe evenl a default if it COPlitmes or happel1S again. .Bood4. 971'AGE ..221' d2(\ ..,,~ 018.<1 ..,........-......SI.CI.........N ,t..eoo-n7.Z3.U fonI!.Nl-MTQ.PA U/tlWU ~ 00 -.- _. ~.~ ,~.. bilo..:!lli.., Reoe.1.ved: 9/22/99 6:09PM; -> GREG ~AVAROIAN LAW OFFICE; Page 5 FAX NO, p, 05 SEP-22-1999 WED 02:47 PM I) r, , U;. EXPENSES; ADVANCES ON COVENANTS; A1TORNEYS' FEES; COLLECTION COSTS. Ellcept when prolliibiled by law, Mortgagor agrees to pay all of lender's expenses if Mortsagar breaches any covenam in this SecurilY IlISU\IIl1ent, Mongagor will also pay on demand any arooum illCllrred by Lender for imuring. iDspecling, preserving or oll1crwise prOle(:ting the ~openy and Lender's secuolY imeresl. These expenSes will bear Interest from !be date of die payment until paid in full at lite highest inlcrestlllte in effecl as provided in die terms of the S~'CUred Debt. Mangagor agrees to pay all co&l:l and expenses il\l:urre4 by Lender ill1 cOllecting, enforcing or procecting l.ellder's righlS and reatledles uDder Ibis Security lastl\lDlenl. This amount may ioclude. but is IIOtlimilCd to, attomeys' fees, court COSlS. and other legal ellpeuses. 'Ibis SecwilY lasuumem shall remain In effect unal released. Mongagor agrees to pay ror any recordation COsts of such re~. 11. ENVlRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section. (1) Enviromncnl3I Law means, withoutlimimuon. Ibe Comprehensive Ellvlromnenlal llesponse. CompeJlS8lion anc\ Uability Act (CERCLA, 42 U.S.C, 9601 et seq.). and all ol/ler federal. Slale alld local laws. resula!iollS, ordimnces, COUfl orders, allomey gc:acraI opiuiollS or illlelpJ'etive letters concerning the public heallh, safety, welfare. enviroJJIIICIII: or a hu:ardous subslalll:e; and (2) Huatdous Subs_ means U1'J tollic, radioactive or hbardOIlS matcrial, WOSlC, pollUllUIl or con/llJllillllllt which has cha13cterislics which reader Ibe substance c\aogeioIIS or polCndally I\aJIgerons 10 die public health, safl!llY, welfare or environment. The IeIIlI includes, widtout limilaUon, any substances defined as "hazardous material," 'lOxic subs/aJlces,' "buardous 'WlIS~' or 'huardou$ SUbsWlU' uoder any Envirollmelllal Law. MoltjJagor represents, WammlS bd agrees that: , A. ElIcept as previously disclosed and ackllowledged In writing 10 Lender. no Hazardous Substance II or will be Iocaled. stored or released on or In the Propeny. This restrietloll does lIOe apply to small quanlides of Hazardous SubstanellS /hac are generally recognilcd 10 be approprialC for the IIOnnal use and JDainIellallOe of me Property. B. Ellcept as previously cllsdosed and ackDowledged ill wrilinlllO Lemler, Mongagoc and every _ have been, _. and sball remalll in MI compliance widl any applicable EnvilOllllleDlal Law. C. Mongasor sball Immediately nmify LeDder if a release or lhreattned release of a Huardous SlIbs_ _ Oll, uader or about !he Propeny or !here is a violation of any EnvifOllllll:1Ua1 Law coacemiDg die PJoperty. III SIICh UI ev=r, MonP8or sballlaIrt all oeces5lll)' tcmecIlal acdoa ill accordance wilh bY EllYironmeolal Law. D. MOlfBaBOl sballlmmedialCly noril}t Lender ill wridn& as SOOn as Mongagor has _n ro believe !here is any pelliling or threalened invesripliOll. claim. or proeeediog ldaling ro !be release or tbreatenecl release of any Hazardous Subsl/lllCe or die vioIacioR of aay EsviroomemaJ uw. 18. CONDEMN A nON. MOrl/IBSor will give: LeIlder PlOIIIpt DOdce of any peIllIiDr or CIuea/e!Ied ~don, by private or pW~ emides to pu::base or llIIr:e any or 11I1 of die Properly IbrouIh coDde\>'''''dOll, "",1_... domain. or bY other meaas. MoIttsagor auIhorize.s Lellder to iDJezvene ill MonP8Qt'$ IIlIIDO m any of die above des4:ribed actions or claims. MOJtP8Ol ass'ips 10 Lender !he proeeeds of any awam or claim for damages colll1CCted with a coodemDation or other calcIDs of all or any pIIIt of die Propeny. Such proceeds sball be CIlIISiden:d paymems and will be appllcd as provided in dIb Security IDSuument. 'lhis assiJlllll10ut of proceeds is subjece 10 tbc terms of any prior IPOrtsage. deed of aust, securilY agreemelll or other lien dOClllllent, 19. INSVRANCE, Monsasor shall keep Property ill5\lle4 agaiost 105$ by fire, flood, lItelt and olher bazanIs and risks I'CllllIlIIably associated with Ibe ]>ropeny due 10 i" type and Iocarion. 'Ibis iDsurance sba11 be maimaioed m the lIIIIOWIllIand Cor !he periods thatl.et1der requires. The irlsurance canicr providiog !he iDSllfallile sball be ehoSCll by Mongagor subjecllD Lemler's .~proval, whiCh sball lI01 be PJIJ"lISOJIlIbly witbheld. If Monsasor WIs ro roal....... the coverage described above, Lender IIIaY. at Lender's option, obtain coverage to prolCCl Lender' $ rights is the Propert}' acearcliog to the tem1S of this SeellrilY IlISlJUment, All il\51lflllCC policies and renewals shall be al:CCpcable 10 Lender lI1ICI sball include a sllllldud 'lDongase clall5c' and. where applicable, "Joss payee clause.' MO{tJll8Of sbaII immedialCly 1IOlif'y l.elldet of C8III:e\IadUll orle1miamlion of !be ID!_. Lender shall have the righlto holclthe poUcies and rencwals. If Lender requires, Mortgagor sbaIl bmDecIiately Sive III Lender all receiplS of paid Pllllnlums and Il!laewal ooticco. Upon loss. Mongagor sball give immedialc IIOliee 10 the \IlsuraIlcl: carrier and Lender, Lender may lIIlIke proof of loss if not made immediately by Mongagor. ~ood497'AGE i222. ~ ~ (pas", 4"t iii =-<r '~. "" .... ..... SVIIWIUI. Iftc.. SI:. CleW. MN f1-.a~1tJ-a14tl Ilum f'l.oMT&.PA '~/l"'. - "~ ~ ~IIII_'" Received: 9/22/99 6:10PM; SEP-22-1999 ,WED 02:47 PM -> GREG JAVARDIAN LAW OFFICE; Page 6 FAX NO, p, 06 ,-; ;"'-\ U8less od1erwls1l aBreed in writing. all insurance proceeds shall be applied 10 die restotlltiOIl or repalr of tht Properly or Co /he Secured Deb., whed1eT or nOI chen due. at Lender's oplion. Any application of proceeds' to principal sba11 not extend or postpom: /he due dale of lIle scJteduled payment DOr change che amount of any paymenc, Any excess will be paid Co che 'Mortgagor. If the Property is acquired by Lemler. Mortgagor's right 10 any insurance policies and proceeds resulting ITom damage 10 che ~ before /he acquisition shall pass co Lender 10 che exlell/: of che Secured DeIK immediately before the acquisition. 20. ESCROW FOil TAXES AND INSURANCE. Unless orherwise provided in a separate agreement, Mongagor will 1101 be required 10 pay 10 Lellder funds for wtes and illSUl2llCe in escrow. 21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to Leader upon RqdeSC, any financial Sla_lIt or infonnanon Le\lder may deem reasonably o_SSlU)'. Mortgagor agrees 10 sigu, delivu, aad file any additional documerus or certillcatioDs chat Lcndec may consider n<<esSllty 10 perfeer. comirnre. and preselVe MortgrtgOl"s obIigaliOllS under chis Security IllSll1lDlem and Lender's lien statuS 011 die Property. 22. JOINT AM> INDIVIDUAL LIABILITYI CO-sIGNERS; SUCCESSORS AND ASSIGNS BOUND. All dudes UDder chis securil)l IllSllllllle.lJl are joim and individual. If Mortgagor sigm "is $eeurilY I05Il1llDePI but does DOt si,o all evidellCe of debl. MOrtgagor does StI only to motlllage Moft8lBCX'S interest in the Propcay 10 secure payment of the Securccl Debl aDd Mortgagor does DOt agree to be petSOllllly liable OIl che Sel:urccl Debl. If Ibis Sec:1Iril)l Instrumenl seewes a suannIY betwceIl Lender and MonsaBor, MongaJlbt agteeS 10 waive any rights tba1 may prevent LeDdeJ' from bridgiDg any action or clalrD agaiDH Morrgasor or 3JI]I patty imlelned llJlder the obIigatiol1. These righH may include. buc are DOt limited /D. uy anti-deficieocy or Oae-acliolllawS. Mongagor agleeS that Lellcler and any party to chis Security IDsll'lllllem may exle1ld, IIlIdify or malm any change ;q the lenns of this Securil)l [DStnllllem or 811)' tlYldem:e ,of debt wichoul Mortgagor's c:oasent, Sucl1 a change will IIOt release Monsagor liom die lClIDS of chis S-nty 11lSUIIIDeIII. The dudes aDd benefits of this StlCUrilY 105_ sball bind aDd beoelll the SlICCe5SoI$ aDd assips ofMonga&m' and LcmIer. 23. APPUCABLt LAW; SEVERABILlTYIINTERPRETATION. Tbis Securil)l \JIsInImeIlt is govem:d by lhe \a'WS of the judsdiction in wbich LeDdet Is located, excepl 10 the exteal Otherwise eqnired by the laws of the juris4ie1i0ll whttre the Propeny is located. 'Ibis Security Il15trument is CO/JIplele aDd fully iDtegr.lled. ThIs Security lJJsa\ImeDI may 1101 be a-.ded or modified by oral agreemenl. Auy .seclion 111 this Setwicy 1Ds1r\llDenl, 8I"'CJomo;nl.'l. or any agIte/lIeDlldated 10 the 5ecuretl Debt tbat conflicLV with applicable law will nollle effecdvc. unless thaI law l!ZpI'eSSIy or Impliedly pemdIs the variaIlODS by wrilteD a~ If any sec:doa of Ibis Securil)l Tosll'llllleDI t:aDDOt be enforced accordillllO ils _5, that section will be sevmd aud win 1101 affect the euforc:eabiUty of the remainder of this Securily Jasuumem. WbeDeva' used. !he s\npIlJr shaI1 include the plural _the plunlthe singular. The captiops and headings of the 5e1:lioJlS of this Security JII5lrUIJIeJlt ~ rot collVellience Ollly ware nollO be used 10 iDferpret or define the leI>D$ of Ibis Sec:urity JDsuumeDt. r_ is of die: _ ill this Secmity Inslr1llllellt. 4 .. 24, NOTICE. UlIIess ocherwise requited by law, 3l1Y IIOlice sba11 be given by delivering it or by maWng it by first class mail 10 the appl'OJlrialc p:uty's address on page 1 of d$ s-nl)l lDsInunem. or 10 any otber address desiglllled ill wrilillg. Nodcc 10 one monaagor will be deemed to lie IIOdcc 10 all mortgagors. 25. W AlVERS.ExcepllO the CXlelll probibill:d by law, Mongagcx waives auy right to appeal_em rellltillllto the Property. .loox1497NGi ~23 G,.... a..,..,....., --. ". C:l..... MN l1.aOO4.'...aU1~ hmI M-MTGoP" 12ftllO'" ~ ~~;;. .......-,~._~~., ~~ I -"""''"''''-',,", Received: 9/22/99 6:10PM; -> GREG ~AVAROIAN LAW OFFICE; Page 7 SEP-22~1999 WED 02:48 PM FAX NO. P. 07 ,..-., :. , :~\ " .2&. OTHER TERMS.lf cbeclccd. /he following are applicable to Ibis Security IIJSInuIlenI: tJ Line of Credit. Tbe SecIIIed Debl includes a lCVolviD8 line of e<edil provision. Allhough /he Secwed Debt may be reduced to nero balance. this Security IlISlIWIleJIt will remain in effect DDrU released. tJ Constl'lldlon Loan. Tbis Security Insttun\ClIl secures an obligation incwred for the CODSll\lCtion of an lmproVCll\C:Dl 011 !he Property. o Fixture Filin,. Mongagor granlS to LeacJec a security illlereSl in all goods IhaI MongasOf owns now or in the l'ul!lR and IIlaI are or will become filltures relatal to the Property. This Security IJlSlt\IIDent suf\icc.s as a fillllllCing statemcDl aad any carbon. photoglaphic or other reproducliop may be filed of recotd for purposes of Article 9 of the Upjform Commercial Code. o P\D'chase Money. Tbis Security los1l'u1liCDl secures advances by Lender used In whole or In part to acquire the Property. Al:cordiDSly. this Seturity IlISIIUIIIeDt. and the lien hereunder. is ami sbalI be CODSttued as a pwdIase lillOlie)' DIOrtgap with all of the rights. priori~es aod beuefilS thereof under the laws nf the CollllllOllWelllth of i'emlsylvaolia. o NOTICE TO BORROWER: THIS nOCllMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. o IUdenl. The coveD8Pls II1ld aa-melllS of eaeh of the riclers cbecl<ecl below are iJll:lllporated iDto aod suppl_Dl aod amcad the ICIDIS Of this Seturil}' 11ISU\IIllellC. {Check all applicable boxes] o Coodomlnium Rider 0 PlamJed unit Dlwelopmeot Rider 0 Other .........................................,......... o Additional Tenns. SIGNATURES: By signi... below. MongillO!. i_A;.., to be legally boulld hereby. agrees to die tenus aod covel1alllS collllaioecl. in this Securil}' JIlSUUIIIeDt and In allY altaehaletus. Mongagor also acknowledges n:ccipl of a copy of this SCCIIrity InsuumCIII OIl !be dale slllled on pase 1. .) ACKNOWLEDG&lENTl penns 1 va i f\, h_ \ Q COMM~fu.TH OF ..............y.......~...~............. COUNTY OF .~\l':'n!KL $:)~q~~::.. st.~ - On this. the .....t............... day of .Nl;w-'-....1Q,QJI....................... before me .....\..,,:J;;?~..w...~n-.:) "'6 ....... "". __. _-' -ni'''"IN'{; Dwtec.. Ill. Eva 30 Juto._ WCi "'""'"'rSiBJICd o..R.ier, pe'lIU'lI4oIly ~fOoU ................................................................ ...ou..................,.. ,..,.," u...................................... ..... ................... .....,..................... .... baWD to JIll: (or satisfaelonly proven) to be dIo paISOll(s) whose uame(s) is subspibed to the within iDsuumeDl. add aclmowIedged that !Il:fshe euwted !be same for !be 1I\Il'IlDSeS IheJdn con..i~ :1'/:... (OtIC) ~ood497 PAGE .224 "...,. 6 016/ _I . - ~.11I1:';"&l' Rec4&1.ved: 9/22/99 6:11PM; -> GREG ~AVAROIAN LAW OFFICE; Page e SEP-22-1999 WED 02:48 PM FAX NO, p, OB . .-.., (\ . , . , " EXHIBIT A Leaal Dedcr1ntioft% BRIBF LBGAL DBSCRIPTION: ALL THAT CERTAIN' PROPERTY SITUATED IN LOWER ALLEN TOWNSHIP. CIlMIlERLl\ND COUNTY AND COMMONWEALTII 01" PENNSYLVANIA BHING MORS FtlLLY DBSCRIBED IN DEEl! DArBD 09/12/1~77 RECORDED 09/15/1977 ~PEARXNG ~ONG THE LAND RECORDS OF THE CoUNTY AND STATE SET roR'l'H ABOVE IN DEBD BOOK VOLCME K-27 PAGB S59 parcel 10; 13-10-0258-064 . . ---:....... ."\. -\, . ~ood497PAG( .225 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE October 26, 1999 TO: FREDERICK C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 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 INFORMA nON 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY, This is an official notice that the mortgage on your home is in default and the lender intends to foreclose, Soecific information about the nature of the default is provided in the attached oages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This Notice exolains how the orogram works. To see ifHEMAP can helo, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITIUN 30 DAYS OF THE DATE OF THIS NOTICE, Take this Notice with you when you meet the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your Countv are listed at.the end of this Notice, If yOU have anY auestions. YOU may call thePennsylyania Housing Finance Agency toll free at 1-800- 342-2397, (Persons with imoaired hearing can call (717) 780-1869). This notice contains important legal information. If you haye any questions, representatiyes at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area, The local bar association may be able to help you find a lawyer. LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA, IS NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UN/fTRADUCCION INMEDIATAMENTE LLAMANDO'ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADA ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDA SAL V AR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA. I~~ " .... ;:l.l',_, -III:JIll>j..", STATEMENTS OF POLICY HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER CURRENT LENDERlSERVICER: FREDERICK C. JUSSEN, III & EVA JO JUSSEN 1601 THOMPSON LANE, MECHANICSBURG, PA 17055 6902183729 GREEN TREE CONSUMER DISCOUNT COMPANY GREEN TREE CONSUMER DISCOUN T COMPANY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MA Y BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR DEF AUL T HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of foreclosure on you mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -Ifvou meet with one of the consumer credit cOllDseling agencies listed at the end of this notice the lender mav NOT take action against you for thirty (30) davs after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submittin~' a complete application to the Pennsylvania Housing Firnince Agency, Your application MUST be filed or postmarked within thirty (30)) days of your face-to-face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. -""", AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified directly by the Pennsylvania Housing Agency of its decision on you application. NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEF AUL T (Bring it UP to date) NATURE OF THE DEF AUL T. The MORTGAGE debt held by the above lender on your property located at: 1601 THOMPSON LANE, MECHANICSBURG, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 5/16/99 thru 10/16/99 at $1,085,75 per month, Monthly Payments Plus Late Charges Accrued: NSF: Inspections: Other: (Suspense) TOTAL AMOUNT TO CURE DEFAULT $7,491.63 $0,00 $0.00 $0.00 ($0.00) $7,491.63 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A HOW TO CURE THE DEF AUL T- You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,491.63 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIlE THIRTY (30) DAY PERIOD. Pavrnent must be made either bv cashier's check. certified check or monev order made pavable and sent to: GREEN TREE CONSUMER DISCOUNT COMPANY, 7360 SO, KYRENE, TEMPEAZ 85283 ATIN: HAROLD E. WILLIAMS You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter, (Do not use ifnot applicable) N/A. IF YOU DO NOT CURE THE DEF AUL T-Ifyou do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iffull payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclosure upon vour mortgage properlY. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorney, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay thereasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00.' Any attorney's fees will be added to the amount to the lender, which may also include other reasonable costs. If YOU cure the default within the THIRTY (30) DAY period. vou will not be reauired to pay attornev's fees, OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. Ll~""'",~_ RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv time UP to one hour before the Sheriff's Sale, You mav do so bv paving the total amount then past due, plus any late or other charges then due, reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing bv the lender and bv perfonning any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted, EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale, Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER- GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 A TTN: HAROLD E. WILLIAMS TEL NO. 1.888-3 I 5-8733 EXT. 36239 EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You _ mayor XX may not (check one) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cost are paid prior to or at the sale that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF . TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUc1l' ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS A TIACHED, ~-~"'" Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) L-~;" -f':" ~.......~~g .....lmton Counties CammlSSlon F C . , 2138 LincaI;" S~to=llnIt'] A.c:::on (STEPl P. O. Box 1323 Wtlli:unsoo"" p' 1"-03 (5"0) 3 . - .." " . 2500Sd7 FA."{ (570) 322-2197 CCCS aOlol"".he3Stern P;\' 201 Basin St:'eet - Williams (570) 323~~t." 17703 FA."{ (570) 323~626 ' CLINTON COUNTY CCCS ofNorthe3Stern p." 1631 S Ather-..on S t - Suite 100 Sl::1te College, PA 15801 (814) 238-J568 F......"{ (814) 238-J569 COLlj'MBlA COtJ'r't'TY 31 W. Market St:'eet POB 1127 WUkes.Ba=. PA 18702 (570) 821-0837 or '800) 922.9537 F......'{ (570) 821-1785 ColI1Illisaion an Economics Opportunity of Luzerne Count:' 163 Amber Lane Wilkes-Batte. P.... 18702 (570) 826-0510 or (800) 822-0359 FA.'{ (570) 829-1665-CALL BEFORE F......'<:ING (570) 455-4994 HAZELTON FA.'{ (570) 455-5631-CALL BEFORE F......'<:ING (570) 836-4090 TUNKF_,\NNOCK CCCS ofNor--be3Stem Pennsvlvania 1400 Ahington E:tl!C',J,tive Park Suite 1 Clarks Summitt PA 18411 (570) 587-9163 or (800) 922.9537 F......'{ (570) 587-9134/9135 Booker T, Washington Center 1720 Halland Sl::'eet Erie, PA 16503 (814) 453-5744 FA.,,{(8141453-5749 Jahn F, K..nnedy Center, Ine. 2021 East 20th Sl::'eet ' Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CRAWFORD COtJ'r't'TY Greater Erie Communi!:"] ,o\l:,:;on Cotnmit'..ee 18 West 9th St:'eet Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Slienango Valley Urban League, Inc 601 Indiana Avenue Farrell. PA 16121 (4121981-5310 ' CCCS of Western Pennsylvania, Inc. 2000 Lingle.town Road Harrisburg, PA 17102 (7171541.1757 Urban League of :'tletropolitan Harrisburg N, 6th Sl::'eet Harrisb1.\rg, PA 17101 (7l71 234.5925 ' FA.'{ (717) 234.9459 Commwlity Action Comm of the Capital Region 1514 Denv Street Harrisburi, PA 17104 (717) 232-9757 FAX (717) 234-2227 , CUMBERI.A.~ COUNTY Financial COWlSeling Services of li'=klin 31 West 3rd Sl::'eet Wayne.bon>. PA 17268 (717) 762.3285 YWCA of Carlisle 301 G Street Carlisle, pA 17013 (7171243-3818 FA.,{(7171731,9589 Adams Caunty Housing Authori!:] 139-143 Carlisle St Gettysburg, P!\. 17325 (717) 334-1518 F......'{ (717) 334-8326 ..._u.....VI "....... 1"1, It I C"TtU """ "H'!. '-1", ...... .. ,..u~' 0:: 4nftt'l. - .1 '='b, VERIFICATION The undersigned hereby states that the statements made in the foregoing Pleadings are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. 4,4 cJJJJ..~ ~~ ~_~!ii~illit1!l!iI~!Bl!rn~~~ - -""""'" ~ ~Ii' -"""'"' JS tt: ~' ~ ~ -0 ~ {' ~ --- --- CJ\ co ~""" 1""- fft> -+:: 0'1 (J\ o v 0- f () S; <, -our n1n" ~f':' 0",1> ~,ts ~Q '"u PC Z =< " . "";: o c::; .." i~'''''' b:J t en ;':;:~J )~D , -:0 ~? ~ ( K", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 vs, FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG,'p A 17055 , COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2000-752 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due Interest from 4/24/00 to Date of Sale @ $22,52 per diem Subtotal (Costs to be added) $137,024.25 $ $ ~ "- ~'"'_&."", ! ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No, I, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning. ~ BEING Lot No, 2 on the Final Subdivision Plan for Glenn W, and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA BEING the same premises which Glenn W, Marquart and Jean C. Marquart, his wife, by Deed dated September 12,1977 and recorded September 15, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. "'''1l1frrIM""'< - r I' 9? ~ (J ~ ~ r w ....... k~ RJ -C' ~ + W ~ n ("--, ..- -" -""11i1i~iil14~~.ill~_ , ' '" -' ilI.~ ""_.""""~. ~~~ ~~ ~~-~ ~ 6<;l.. ;0..... D (). ~ -->.s ~ ..... ..... ~6' w~ ~ ~~ ...0 ~2 \.oV -- " r-6' r-Y') ...f::, () 0 gd~~8 0, c (; ~C) "\](), , I I I ~~ '" , , ::: ::: , , , , .::: , ~ , ~~ , - , ..::: - "'" "" - - - -- Y-J<- (') C ? -, -oc" "l1p'1 Z::r; zc Z?~f: kCJ ~r--, ..:'-\.-. ~8 ~ -< , ~ o N c:> n --< f UJ r' ~ F"l :!:] ,. ,~~b =~t~ ';:J(t) '-"',rn :0:; .". 5:J -< ::7: .~. '2 ;::) to . - I....... - ~.'iM..WL i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO CONSUMER DISCOUNT COMPANY, NO 00-752 Civil CIVIL ACTION - LAW Plaintiff (s) From FREDERIC C. JUSSEN, ill AND EVA JO JUSSEN, 1601 THOMPSON LANE, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $137,024.25 L.L. Interest FROM 4/24/00 TO DATE OF SALE @ $22.52 PER DIEM Ally's Comm % Due Prothy $1.00 Ally Paid $1492.40 Other Costs Plaintiff Paid Date: OCTOBER 9, 2002 CURTIS R. LONG (Seal) prothon~ [J~ <2Y: 0/)0"-" Yl/l/oz./ Deputy REQUESTING PARTY: Name GREGORY JA V ARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1ST FLOOR,SUITE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ill No. 55669 ,,"~ - _.~"'~ ''''':f.;""",",', OYiYCb UNITED STATES BANKRUPl'CY COURT , MIDDLE DISTRICT OF PENNSYLVANIA INRE: JUSSEN, FREDERIC C, ill CASE NO. 01.04788JJT-l CHAPTER 13 JUSSEN,EVAJO Debtor(s) NOTICE TO CREDITORS AND OTHER PARTIES IN INTEREST ~ Notice is hereby given that the Court has entered an Order dated AUGUST 22, 2002 DISMISSING the above-captioned case due to: TRUSTEE'S MOTION TO DISMISS CASE DATE: August 22, 2002 Clerk, U.S. Bankruptcy Court 228 WALNUT STREET P.O, BOX 908 HARRISBURG, PA 17108-0908 V AN-87 0151S3 -\ j,*,,, LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO, 55669 131 0 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, No,: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied () Vacant () COlDmerciaI () As a result of Complaint in Assumpsit (X) Act 91 complied with r IAN, ESQUIRE tiff - . ~~ ~ ~'.... ~~ > ....~'..~O'-',.,-!iI!OOi:~_4!R&ltlli l~ , I. ~11ili!1Itill"~' ~, .!::I ~. ......~ () C '"" ""(..1B~j mn: ~~:: (J)<",... ~(~ Z'::-:, "1~(;::: -L Z ~ "~~~<, C.::> 1'0 o n -4 I \D o 'Tl --i .!~ -r, -,....,rn ';;"0 ~V, -( -- -~-Yt ~~~~ 'J --i :>- :::0 -< 2;~ -'''' o => '0 . - -L_~~ -~MlIllillfol!!iil" , < CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No,: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICSBURG. PA 17055: 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C, JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 1601 THOMPSON LANE MECHANICSBURG, PA 17055 EVA JO JUSSEN 2, Name and address ofDefendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Lower Allen Township Authority 120 Limekiln Road New Cumberland, P A 17070 Lower Allen Township 1993 Hummel Avenue Camp Hill, PA 17011 ,~ ..J__-.,~"...".""'cl._ . . 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interel\t may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) T enantsJOccupants 1601 THOMPSON LANE ~CHANICSB~G,PAI7055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that fulse statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. October 4, 2002 iliihHf L~_-. ~.,J ~_ "~.~_. - '.~- "'L'''''''''~_j~~.;)~~=~' n -~IiiII"'.-'- - (') c: <: -o~, cpri1 "'- ;];_'1 Z, C0-.J> -<' . ~C_i .)>n Z:c )>C :2 ~ . ~ . ~, , . <::> l'0 o r.> ....., I (1) ~ ::;:1 .;;~ ~;~ s: 5J -< ,,". :::l: S? <:::> ~ ~ - lll;dil"_'~'_ . f LAW OFFICES OF GREGORY JA VARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM . FREDERIC C. JUSSEN, III EVA JO JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSB~G. PA 17055, is scheduled to be sold at Sheriffs Sale on MARCH 5. 2003 at 10:00 A.M., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the courtjudgrnent of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. 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 mnst pay, you may call: (2151 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) j~"""""""',"~- ~ ~~ - I. ""_t~~', . , 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) 942-9690. 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 ouly if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. . 4. If the amount due from the Buyer is not paid to the Sherifl: 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. 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 Sheriffwithin ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act innnediately after the sale. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ~...=-'" I "~t<!,,,~ " f ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned PIan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east IS 1.50 feet to a point at line oflands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west ISO feet to a point, the place of beginning. . BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 3 I, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977 and recorded September IS, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. ~.iIiM~fl:tt__U~~_Jld6~r ~ ~-'ir!iIl-3ll.Ji';iilH~'U~\<.."",~~!iIIII..::i. --~ ""': .1" '" LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2000-752 CIVIL TERM vs. FREDERIC C. JUSSEN, III EVA 10 JUSSEN 1601 THOMPSON LANE ~CHANICSBURG, PA 17055 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against FREDERIC C. JUSSEN, III and EV A JO JUSSEN, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As Set forth in Complaint Interest 1/12/00 to 4/24/00 $133,569.63 3.454.62 TOTAL $137,024.25 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. r Damages are hereby assessed as indicated. DATE: ilr~\ ~ oJ. " '2060 . /~ (]~/J~) 7<. ~ ~ 'P 0 PROTHY::::::Ji?i 0-- " ,.. ~ CONSECO CONSUMER DISCOUNT COMPANY In The Court of Common Pleas Plaintiff Cumberland County v. No. 2000-752 CV FREDERIC C, JUSSEN, III EVA JO JUSSEN Defendants TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN DATE OF NOTICE: 3/21/00 NOTICE, RULE 237.1 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 se forth against you. Unless you act Vvithin ten (10) days from the date of this notice, a judgme~t may be entered against you witl10uta hearing and you may lose your property or other important rights. You shouldta'ke thi;' notice to a lawyer at once. If you do not have a lawyer or cannot afford oIie, go to ,or telephoil.~ the following office to find out where you can get legal help. '.. Cumberland Bar Association La;wyer Reference. . '2 Liberty Av " Carlisle, PAl 7 (71 7) 249-3 I Gregory Javardian, Esquire . 44 Second Street Pike, Suite 101 Southampton,Pal8966 (215) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tomado la accion requiida de su parte en este caso. AI no tomar la accion debida dentro de un termino de diez (10) dias de esta notificacion, el tribunal podra, sin necesidad de compararecer usted en corte 0 escuchar prueba alguna, dictar sentencia en su contra, usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatemente si usted no tiene abogado, 0 si no tiene dinero suficiente para tal servicio, vaya en persona 0 llame por telpfono ala oficina, cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATIEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" J___, "-'''O~~i!ih _L'"e~.-lIiIliiIiIIrIiJ ~ .~~ ~~ ~ -'-~~.....~~ ""-"'jtiEil~ .~ '"-~~'~"'~IllJ!i'N d-J_ ~ ~ ,/ "" t. ~ \ '1q. ~ :.a 0 D 0 c .;.:::) - C> ::.'" '. ~ uf'~':- ~ ~ [:1H-': -"J -.-", ::::::: :-0 ~ -V ~5~-i 1',) ~ ~ .-J ~ kt~ At' 6'" Q; ~:;c; ',,' , -.,,- -: :.:J ~ ~~-:C' , ~ C) R ;L~ ~~ N \.=)'" . . -' =< ~v '--". f--"" :'1_' <' -< _S - ~- , 1-, Jl_IlII~" LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTlFICA TlON NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN VERIFICATION OF NON-MILITARY SERVICE GREGORY JA V ARDIAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) Defendant(s), FREDERIC C. JUSSEN, III and EVA 10 JUSSEN, 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) Defendant, FREDERIC C. JUSSEN, III, is over 18 years of age, and resides at 1601 THOMPSON LANE, MECHANICSBURG, PA 17055. (c) Defendant, EVA JO JUSSEN, is over 18 years of age, and resides at 1601 THOMPSON LANE, MECHANICSBURG, PA 17055. (d) Plaintiff, CONSECO CONSU~RDISCOUNT COMPANY, is an institution conducing business under the Laws of the Commonwealth of Pennsylvania with an address of7360 SO. KYRENE, TEMPE, AZ 85283. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. .. ni~'"'"~ I8__Jl """""'"ilIIIIIIIII!II!BII"'~ l!i!iiliil~-"" ~ .-"" , ".., ~II ~- ~,~ " ., ~ ~" ~ " .. 0 0 Cj C..:: Q -n <: -;'(:'" -r)fj v nl (i ~'--...J .c -Tl Z 'T' -".,' z: ~ N en ......; ~~~1 ~5 ~ ..~-" ~ C) ~-v --;-,. u N <~".';- rTl roo:.: u Z ~"t: -, :.) ~ -< <.)") --< . ~,' -~'~~' . ~.~ l&' ,,- - SHERIFF'S RETURN - REGULAR ~" \..1 _ CASE NO: 2000-00752 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT CO VS JUSSEN FREDERIC C III ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE JUSSEN FREDERIC C III was served upon the , at 0019:20 HOURS, on the 17th day of February, 2000 at 1601 THOMPSON LANE DEFENDANT MECHANICSBURG, PA 17055 FREDERIC C. JUSSEN, III by handing to 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 18.00 8.68 .00 10.00 .00 36.68 Sworn and Subscribed to before me this .:I. '1!!:- day of Y[;r;;:o"'" <AD _ J1A!tJtJI ~ ~ rothonotary . So Answers: ~~~~~~ R. Thomas Kline 02/22/2000 GREGORY JAVARDIAN By: of)A/7/7'd @~~. Deputy Sheriff .,_., -~~ - <"~-~_tlIi,., 1l .,i )..;f - SHERIFF'S RETURN - REGULAR CASE NO: 2000-00752 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT CO VS JUSSEN FREDERIC C III ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon JUSSEN EVA JO the DEFENDANT , at 0019:20 HOURS, on the 17th day of February 2000 at 1601 THOMPSON LANE MECHANICSBURG, PA 17055 by handing to AVE JO JUSSEN 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 So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~~~~~ R. Thomas Kline 02/22/2000 GREGORY JAVARDIAN Sworn and Subscribed to before By: ~d~~ Deputy S eriff a.v me this ..l"J ~ day of Y..(--Lu~"7 ,2nrU A.D. ~ Q IYL,";I~ 1!fVi' rothonotary , , ~ -~ "' '"~. IllilllIlIiltltl_~'-""i CONSECO CONSUMER DISCOUNT ,COM1\' ANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICS BURG. PA 17055: 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Lower Allen Township Authority 120 Limekiln Road New Cumberland, PAl 7070 Lower Allen Township 1993 Hummel Avenue CampHill,PA 1701I 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. <r_llflr','. ,. " 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification authorities. August 2,2001 ,."~., _. ~" I ~ . JL'-~ ~ ~'-~'lIili"ib~ t "f ", .~ ""1 .: " ~ 0 0 ., 5: "'" .~ "UOJ c: -J~ "T: mrn G"l ; !If'''''::: Z::r! I ~:gE3 zc,:: -.l (J)~", ~~ ~ej -0 ~C) ::JJ,: >8 5rn -~ .L .=> )> ~ co ~ ..~ ...~~-~~=._. ;&;J...re,1 LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 FREDERIC C. JUSSEN, 1lI 1601 THOMPSON LANE ~CHANICSB~G, PA 17055 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PAl 7013-3387 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSB~G, PA 17055 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Tenants/Occupants 1601 THOMPSON LANE ~CHANICSBURG, PA 17055 Dated: (p (1./& I sf ~ fr/ol GREG Y JA IAN, ESQUIRE Attorney for Plaintiff _"~O~_"ri'liiliUI_ --~ -" - "'-~~"-'''''~'I'''~ " ~~" ~ I L ___"""""'~",~"~,,"," __,H>I,-,'-"~~~,,,, .'0(,Jff/;~tA~~~~tii~f~' .' ,,'~,,"'.'- - -- . , . . . -/ --.-',. ,-.-- '. .' " ""'''':',': ,",,'., -. - .'..- ;,:*";;'~';';"-'J::~:';--.J:.~.f.~;"';';'<':;"~'~~;~;" "~'~..o.~..::.::,~"':.-~~ .' . ? opo.~+ b19~~0~'~~ SJ,3b~,p08 '.~"".. t\{/.~... ....~.'iJ:,'... ~l!i.. 1:11.....,..... .~..'... "'. ~,.;i~~ '1&:\LJf~n" , .1t!... Qli~ ....:; ....~,,'i....... . ,. 0 c.'.. "...... 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" a <n <n t:::l @ '" en I-i H n -',,\,";0 ,,,,,' - .~ dooO Clf:JJ':IJ :0:-- ~"~-~8-' ~-3 *' a (il_ffil~ll b>1i ~ 3.-~ ~, "_ 0 ~Q <<! 8'~- S" :J a ~ ~ ~ 0. ci" 0;' :::I CD ~ ',$,?~,-; .-' ,,-, -,," ,.;.,-;.',,::;' ,);~::.(.~:- -;~ -'i:-.'-" ~;\:,1.,', . ; ~ '> . .... " a <n <n '" t"' ~ H " o ~ o en tJ1J B~&r~)> 'l"~', ~cr<=t1ii':::!; '11 (j) m.... ~~ ><. * 0 c" 'llllll_lll f2: ....(1) 2.a--a;-Cl.Dl :O~S~Q'1ll3 ~ (I) i4,g ....0-0 Cb::' trill 3 fD::I: ~ -,Q.'~-~ CD 9~.... ::r m Illc. ~ lCi= 0,5 ~> :D!l ~o ~. a< o. iDe- 0.0 <" .- _0 ffi~ "-:'" "--;:' so o o D ";"'~fIIWj"'~~Ii1~}ffl.~r~'~~~"" l' ~ ~ ~"~ .;r<""".'~~""'l"'~'''' ~~. 0_ "',"'~.~~u_..~ Il!lIl ~,...",. .. _- ll!i ~_~~ May 25,2001 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): FREDERIC C. JUSSEN, III and EVA JO JUSSEN PLAINTIFF/SELLER: CONSECO CONSUMER DISCOUNT COMPANY DEFENDANT(S): FREDERIC C. JUSSEN, III and EVA JO JUSSEN PROPERTY: 1601 THOMPSON LANE ~CHANICSB~G, PA 17055 CUMBERLAND C.C.P. NO. 2000-752 CIVIL TERM The above captioned property is scheduled to be sold at Sheriffs Sale on SEPTEMBER 5. 200 I at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A I 7013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriff's Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule uuIess exceptions are filed thereto within 10 days after the filing ofthe schedule. ~ Gregory Javardian, Esquire Law Offices of Gregory Javardian 44 Second Street Pike, Suite 101 Southampton, PAl 8966 (215) 942-9690 ~ l" ~ ',- -;il . 1lt~~JlM1l!ij' .,;,,, . .'C'.' . __ lIWI~" -, ". '"oJ ~ , Ii " h , . I,! i 0 CJ 0 c: -'I ;;:: "" .-. "U(L' c: .:JJ f11rr, ::;") ',-- Z:1:i I ~~'~ tJ Zr;::: (J) c.. .-J ':',:::'1(? :::;L !;2C'; "'""(.1 .,__;:~ ....:..-l )>C- ::r.: ~)(~ Za "'-"',fl ::Pc: 0 ~ ~ .:;::> Z OJ ~ "" ~"ll"""M"'Jr~ ' - ~,,~ """"- , ~"' -*~""'--"""'_"~4.., Conseco Consumer Discount Company VS Frederic C. Jussen, III and Eva Jo Jussen In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-752 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Gregory Javardian. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 30.00 15.00 1.00 25.66 7.80 15.00 15.00 1.68 13.79 20.00 265.40 262.95 $703.28 paid by attorney ~~ This '78 day of A{);""~ L. , -. R. Thomas Kline, Sheriff 2001,AD.q'r'L 0 I'hJi, /~ BYCJorl Jndj Prothonotary Real E~ate Deputy Sworn and subscribed to before me ].0-0 C:...k- 3 'f 'ill (,. /2...... 119J~? - ,-.'llI~ ~,"'"' -~ "- ~ - .1 .. '~\i:;4J. .. ., CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVAJOJUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. ~CHANICSB~G. PA 17055: 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSB~G, PA 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSB~G, PA 17055 2. Name and address ofDefendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE ~CHANICSB~G, PA 17055 1601 THOMPSON LANE MECHANICSB~G,PA 17055 EVA JO JUSSEN 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. - .~" "~ > .~ ~."-" . , "'"'f!"""'"'~',- " . ' 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1601 THOMPSON LANE MECHANICSB~G, PA 17055 I verifY that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief I understand that fulse statements herein are subject to the penalties of 18 Pa. C.S.A 4904 relating to. unsworn falsification to authorities. May 25, 2001 - - - I_~ ~ ,1-, ~ln:,;'<- ~ ... LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA 10 JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, ill EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. ~CHANICSB~G. PA 17055, is scheduled to be sold at Sherifi's Sale on SEPTEMBER 5.2001 at 10:00 AM., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PAl 70 13, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS 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) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open th{, judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sall~ for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,1li~ " - ....llII, ... YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 ouly if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distnbution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distnbution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICJE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ..~, '--' , ~ ~ ~ ~ ~l,lli;Wl'", . - ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west ISO feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 3 I, Page 24. BEING known lIS 1601 Thompson Lane, Mechanicsburg, P A BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12,1977 and recorded September 15,1977, inDeed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. - ~~ . 'j, , ~'. ~ "-""'i1ih . WRIT C;>FEXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-752 CIVIL~: TERM CIVIL ACTION - LAW TO THE SHERIFF OF OJrnberland COUNTY: To satisfy the debt, interest and costs due Conseco Consumer Discount Canpany PLAINTIFF(S) from Frederic C. Jussen, III, and Eva Jo Jussen, 1601 'Ihanpson Lane, Mechanicsburg, PI\. 17055 DEFENDANT(S) (1) You are directed to levy upon the property ofthe defendant(s) and to sell !';pp T "'gAl T)p"rripr;nn (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from payinll any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise displlSing thereof; (3) If property of the defendant(s) notlevied upon an subject to 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 asa garnishee and is enjoined as above stated. Amount Due $137,024.25 from 4/24/00 to Date of Sale Interest @ $?? C;? J'Pr iHPm Atly's Comm % L.L. Due Prothy Other Costs $1.00 Atly Paid Plaintiff Paid $775.62 Date: Mev 31, 2001 Curtis R. Lonq Prothonotary, Civil Division 0u~p p ~~)- Dllpuly '-bv' REQUESTING PARTY: Name Gregory Javardian, Esq. A(ldress: 44 Second Street Pike.. Suite 101 Atlorney for: Telephone: Supreme Court ID No. Southampton, PA 18966 Plaintiff 215-942-9690 55669 L,~ " - :':"b~',-- c' "'"'"". "",. ., , ..J'h ~~~ --..... '....-~~- "-~- . ~ ~ """(j -"'- b' ~Jilii!iOl~ . - ~ .. ~:, REAL ESTATE S'i~E ~m JO C:'-'"l ~ &:::::::1 ese," ~ uil Jl.vrI.G. 5/).00 ( the sneriff levied upon the oerenaam[, Interest In the real property situated ~n J.f5/)..J(.A, f1f.CJM T~ Oumberland county. Pa.. known and numbered as: 1M> I Th~~ ~nd more fully described on Exhibit "A" med with this writ and by this reference Incorporated herein. oate:~I~ 5,~()O1 By: t~~ \1\ N'1 ^ l,i, SH ~3d '::', (' I . \\/8 10. ~\d Et \1 \ NOr UN n L ii \J," i ,.',i,nHIO HI\l3I1S 3111 :lOJ01~AO " -~- ,,~ ,~ ., ? , , , "" ~ ~- ~ - , ~~ '""'" '1_-' ~ ~ 1f'~ .. ,\ -'~'lt'~,~" THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable 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 I..IJ.g Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th. 1854, and September 18th. 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 24th and 31st day(s) of July and the 7th day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notie:e 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 behaif 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 recordeld in the office for the Recording of Deeds in and for said County of Dauphin ijMiSCellaneous Book "M", Volume 14, Page 317. 4 PUBLICATION . COpy S ALE #20 REAL ESTATE SALE No. 20 Writ No. 20lJO.752 Civil Term Conseco Consume_r Discount Co, vs . Frederic C, Jussen; III Eva Jo Jussen , , Ally: Gr~gory Javard,an OeSCRIPTION Notarial Seal Terry L. RuasoH. NotaIy Harrllilu'll, OIUjlhln MyCommIsslonExpl'OIJunu.20t2 NAY PUBLIC Member, Pennsylvania ASSOCla1Ion of ~'I.%mmission expires June 6, 2002 Sw CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUR1HOUSE CARLISLE, PA. 17013 ':"~{L that certain piece or parcel of land situate 'in ~" ,All n Township, Cumberland County, , ~~:;:Ylvan~a, morc' p~rticu\arly bounded a~d, ' described as follows: 'h r -, B'EGINNING at a poinL on the"nort em, me, 'l'. , ::~Thom son Lane widened as sho~n o~ the . ", ," . P, to' d Plan at the eastern lme of ;lieremafter men lOne " -'d L N," :~1Wt No.1 on said Plan; t~ence a~?n);~"9 ~~et 16 . ;-:1 north 13 degrees 18mmutescast .~ I "f ,':'--~' oint' orr line of lands noW or, f~rme~ y,: 0 ~ p. . K.. H. artrlee tbence along Said Hartzler ,>ll.enJamm -' " . t 15\;0 ;,}' nd utn 84 degrees 46 mmutes l;as. ,'" -::Ia s, so. r e of lands noW or formeriY1P[ :'.Jeettoapo_llltat 10,' lJ "'d 'Ellmaker-Iands, 'El1maker' thence alon", ,Sal "_;:S0~lh 13 degrees 18e~inl~~~~ ~t~:~~o~ee~~~e~ ::;JlO1nt on the nortl~ north 76 degrees 42 minute.s. ,,'thence by the laLtc, . - .he, place "ot, : west \50 feet' to a poml, ' . , : BEG~NNI1\GN "I on the final Subdivision" Plan BEING Lol _ o.~ C Mar um said Plan fo~ Glenn 'Vv~ ~ndi~eaSle 'Cum~rla~_d Counly ',bemg recore. B k"~(PalJe24 Recorder's OWee l~ :\an\60f Th~mp~on 'Lane, BEING known a~ ' Mechanic~burg, PA. ',h' h Glenn W BEING the same prefmse~ W IC his wife, 'b)' Marquart and Jean C. Marquart, " Deeddatcd 121477 and recorded September Scptembe~ 'cd Book K Va\. 27, Page 559, \ 5.1977. In De 'd "ranted alld Cumberland (F:o~dnt~-c ~~~~~~~;l, 11\ and Eva)o ~..c.onveY_'Unlrew .. . > . ...... 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 $ $ $ 261AS 1.fiO 262.~IS Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sundav Patriot-News, newspapers of genElral receipt of the aforesaid notice and publication costs and certifies that the same have By..................................................................... . ' REAL ESTATE SALE NO. 20 Writ No. 2000,752 Civil Conseco Consumer Discount Company vs. Frederic C, J1,lssen, III and Eva Jo Jussen Atty.: Gregory Javardian ALL that certain piece or parcel of land situate in Lower Allen Town- sWp, Cwnberland County, Pennsyl- vania, more particularly bounded and described as follows: BEGINNING at a point on the northem line of Thompson Lane, widened as shown on the hereinaf- ter mentioned Plan, at the eastem line of Lot No, 1 on said Plan; thence along said Lot No. I. north 13 de- grees 18 minutes east 273.29 feet 10 a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands. south 13 degrees 18 minutes west 294,55 feet to a point on the northem line of Thompson Lane; thence by the lat- ter. north 76 degrees 42 minutes west 150 feet to a point. the place of beginning. BEING Lot No.2 on the Final Sub, dMslon Plan for Glenn W. and Jean C. Marquart. said Plan being record, ed in the Cumberland COWIty Re- corder's Office in Plan Book 31. Page 24. BEING known as 1601 Thomp' son Lane, Mechanicsburg, PA BEING the same premises which Glenn W. Marquart and Jean C. Mar, quart. his wife. by Deed dated Sep' tember 12. 1977 and recorded Sep- tember 15. 1977. In Deed Book K. Vol. 27. Page 559. Cwnberland COWl- ty Records. granted and conveyed unto FredertG C. Jussen. ill and Eva Jo Jussen. his wife, . "- " IJ~" ~~ liilll'MlG-," ~ - ~. ,--. -- "'MHilil. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : 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, '\Vas 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, V1Z: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~A..Il ... R~Edltor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 , NOTAR~ ~. SNYDER, No!aryPubllc llu f'__~ Cumberland County 'J'I -...- Ellp/I8e March &, 2005 ~ . Ie, lIlillllillliW:V LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA 10 JUSSEN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certiJY that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exlnbit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 FREDERIC C. JUSSEN, III 1601 THOMPSON LANE ~CHANICSB~G,PA 17055 EVA JO JUSSEN 1601 THOMPSON LANE ~CHANICSB~G, PAl 7055 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Lower Allen Township Authority 120 Limekiln Road New Cumberland, PAl 7070 Dated: It) bJ- /d' J--- . , , Lower Allen Township 1993 Hununel Avenue ~ Hill, PA 17011 GRE. JAV~. Attorney for Plaintiff Tenants/Occupants 1601 THOMPSON LANE MECHANICSB~G, PA 17055 -"E~IIIlOIltI.lI"~IIiII~' ~ """'~~l"",_m,,",,__....-~J''''-~''L~-- ._'""~, _ ~~ _,~ ,~ -...--.... ,,- ......--. J O"F ..FI CI A l .~ a- o !'- .. ru o .0 o Postage $ Certified Fee Return Receipt Fee (Endorsement Req,ulred) ~cted Delt~ Fee (Endorsement Required) Total Postage &. Fees $ o ..D . '.::I'" Sen.tTQ . 0 ......_f_Im1jj:B1J;:.._G..._J..!l$..~~J'i.....U1..._........._____________...._. ru ......,."",wtO"THOMPSON LANE c or PO I3hJN1b. o CiiY.,~~E€-5BB'RG;--P.A---l.-'}f}5:5--""".-.-----"---"-""'.... !'- \' PS Form 3800, January 2001 See Reverse for InstructiOns ~ a- o !'-.. 'ru o o o postage $ CertIfied Fee Return Rebeipt Fee (Endorsement Required) ~DellveryFee (Endorsement Required) Tota'Postage a.... $ ';" o ..D .::r: BentTo. . o Eg~.L!!.~J.ill!!l.~]Al~_......_._________~_____...._~...._.__ ~ gm\.~MPSON LANE o ~A!Il.!il/;SJWRG;-.w."'l~55-.-'.''''._-'''-'''--'''' l"'" fSli~; II II a- .... ru IT' ~ IT' o !,-., O~FF:I.. CIAl _$ Oertifled Fee Relum Rec<lpt Fee ~ (Endorsement ReqUiml) 0__ 0e1!YelY Fee o (En-.mentReqilIred) _I_a.... $ , '- o ..D :r Sent 1b o ...............'!'Jll!ANTS/O!;.!<JJPANTS ___...____.._ ru ""."Apt~~Ol THOMPSON LANE o_<<~~~ -', " o .....-.--.....w=!h'.NH,SffilR{T,--.PA.-H'-655--.~...._--.- city, State, ZIP+}f !'- PS Fal In 3800, January 2001 See Reverse for lnstl uctlons ~llit_~,_H.w'_I" ) , _,J"'" ~ t~~~"""I~___~_"""',"",~"'~~ .~ '~J_..... ~ l.-.. -~, '_<oli.., . - l::GlmplStilterna1, 2,and S. Also complete nem 4 if R'jl\!rtcted Delive~ is desired.. . . Print your-name an,d address on the reverse so that we can return the card to you, - Attach this card to the back of the mall piece, or on the front If space permits. 1. Article Addressed to: 3, Service Type o Certlfled Mail D Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.Q,D, 4. Restricted DeUvery? (Extra Fee) IJ Agent IJ Addre.... I C. Date of Delivery 6, I I I , I IJ Yes IJ No ) FREDERIC: C. . JUSSEN, III 1601 THOMPSON LANE MECHANIGIlBURG, PA 17055 DYes I \ PS Form 3811. Augu'i.t2001 I 701120~bIl: ;[JQIJ2 71J91:1921;!b, -. ...: ": ~.' ' ,. . I 'I 1 ~ : I,' 10259s:.1l1-M-2509 r Domestic Return Receipt . COMPLETE 1 HIS SECTION ON DELIVERY A Signature, I_ Comptete.items 1, 2, .andS.Also complete' Item 4 II Restricted Delivery is desired.. ': . Print. your narne and address on the reverse I' so that we can return lhe card to you. _ Attach this card to the back of the mailpiece. . cr on the front if space permits. 11, 'Article Addressed to: I I i I I I J ) I x CJ.-.;. o Agent D Addressee B, Received by Printed Name) CN./S J' ...sse';.j D. Is delivery add~ different from Item 1? If YES, enter delivery address below: EVA JO JUSSEN 1601 THOMPSOl!kLANE MECHANICSBU~; PA 17055 3, Service Type o Certified Mail 0 Express Mail o Registered D Return Receipt for Merchandise IJ Insured Mall IJ C.O.D. 4, 8estrlcted Delivery? (Extra Fee) DYes .Ii. 7U[J2[J4b[J D[J021[J949233. 'I' , ;'. I PS Form 3811. Augu1ll2001 I I I Domestic Return Receipt 102595.Q1-M-2509 ~ SENDER: COMPLETE THiS SECTfON . . _ .complete Items " 2; and S. AlSo complet~ J item 4 if R~trlcted Delivery is desired. 1: · Print your name and address on the reverse I: so that we can return the card,to you. _ Attach this card to the back of the mailplece, I or on.the front if space permits. : 1, Article Addressed to: I TE~TS/OCCUPANTS 1601 THOMPSON LANE MECHANICSBURG, PA 17055 A. SIgnature I X /7/ IJ Agent ' ("',/1--- D Addressee 8, Received by Printed Name) C, Date of Dnlivery I u"i JvSSe:.J l)- ~ll I D, Is delivery address different from item 17 Cl Yes 1 If YES, enter delivery address below: Cl No 'I i I i j RE: JUSSEN $, Service Type Cl Certified Mall 0 Express Mail o Registered CJ Return Receipt for Merchllndise D Insured Mall D C,Q,D, 4, Restricted Delivery? (Extra Fee) DYes i 7[J[J2 [J46[J [JO[J2 7[J94 9219 r PS Fcrm 3811, August 2001 Domestic Return Receipt I 102595.Q'I-M-2509 " (f> 6' 3 Co> CD .... :-' "T1 <1> C" 2 " " '" o o '" "'tl " 'f;l ~ o ~ ~ !" :" !" z " ~ o " " ~ 1: ......1--';..., 0- ~~~ ~m .....,OG) 'en ~-ooo g~~:Bc;:; ;;0 c: '- C'>(D . C/))>r'T1;::J c:n -I <:: Cha. )> ~;o)>~ a "'LD~S;~ "" g. s:~;> z '"1::<=>03 C ....c: ~ ~ " "" ... ?' f> ~ ;-" ?' ..-.., -'0 i;;: O"Z ,<c "'~ ~!f ~Sl. "" .. ~ . t;'d Q![ ~'z ~c !l~ ,,~ 00 oo- ,.." ~.. o~ .. " ~ ~ ~~II~ t ~! r:;n 1: 000009 !l ~.~ 0 ~ "ll' iil8:;> Sl- 3 ~~ iil ~ ~ - ;i~O~~ :; . - or <1> :; ;l~H '" 0 a. -<! :t (\l -/ , ." ~~~ :s:: 0 S- o ~ j: ;;: 11bg 3 0 t- ~ onn ~~ ~ !1b 3 ;;: ~ngl . ~~I~ 3 . Q ." ~ . ~ ~ ~ = ~ 0 - f ~ ~ '" . c::: , 0 Q. :1 . ~ o I'" 0 S. ~ Z ~ :'I~ .- ~ iil I ~ ~ t; ~ Q ~ 0 1:-'''' DODD 0 I . I ~ ~ " :S" ; ~ , g;gj~ ~ ~ ~I ~ ." I f(I ~ ,g. ~ (J);;fJl;;o I '"z ;g~-.8 ::! ~ I ~ ~ . .... r t:j .iil 2l.32la it \ .... I ~,~ ~ .. a~i~ 0- I ; ~ HO N :' 'oi Hln I ~ , '" 'ti "2 0 ;- I en 0_ . -!!. I ~ Hln '" b' s,"S ~ !' , ~ o-,l po " 0 H "- ~ n -!!. ='" ~ o . III " a !!1: ! ~ " 3 " . " " ... 0 ~ o' ar .. " 0 ;:; . ~ a ~ '" 0 ... .. H CD z Od'~ ~ 2'< ~ ::! '" " ;'rn ~~~F x . O~Q.&a-lt~ . ,. ;;;~if~"m ~ --~ . cn@l tl-1Il a I>> "0 r,-\'. "J: 2 ~-~ I ~,o.. ~ CD .. . ffi~ .... . CD CD ~ .........'" " .0= ." CD '" ... , , 7Ji!l, ~ ...:J> ! :un I..iu' .c oS! "''' ~ ,. '1~i1~ c f~ \." :! oc ~o i " ~AiOJi <3" ,,- "c 3 .~ CD . :a . - 0 0 C " ::;;C11 f "'" 0<1> oil. i ~ C~ivery "0 ~......~ on *" Signa ure Corltirmatio d;l,(n ." , SpeC! I Handl hg ;1'''' CJ!,:I: . ctec Deliver It ;I':u .0 Retum Receip ":u $';:0 1'-'-9"""''''fl''''''':!I''~~--r-~ ,~ ,. ,.,..,~,. ~".~." ~" "- - '!I""r'~-"'r.JI';l'~"""I""'''''-"~''~~'' , ~.,~ ,JE>""""-~ , "'""___~"'" ,"-I .1lI>...."""'"',,, <, October 4, 2002 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): FREDERIC C. JUSSEN, ill and EVA JO JUSSEN CONSECO CONSUMER DISCOUNT COMPANY PLAINTIFF/SELLER: DEFENDANT(S): PROPERTY: FREDERIC C. JUSSEN, ill and EVA JO JUSSEN CUMBERLAND C.C.P. NO. 1601 THOMPSON LANE MECHANICSB~G, PA 17055 2000-752 CIVIL TERM The above captioned property is scheduled to be sold at Sheriffs Sale on MARCH 5. 2003 at 10:00 AM., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PAl 7013. Y 011 may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriff's Sale to protect your interest. A schedule of distnoution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distnoution will be made in accordance with the schedule uuIess .exceptions are filed thereto within 10 days after the filing of the schedule. Gr gory Javardian, Esquire Law Offices of Gregory Javardian 13 10 Industrial Boulevard 1st Floor, Suite 101 Southampton, PAl 8966 (215) 942-9690 .. ' ^~~ MUUUIliI '~11iIlil:o-----'~ , , .~.."~ ~- ,. " ~,,": Ii Ii I !'I I I I I I, II '~ 0 Cl c} c: t.o.l ~,,~., s: '- .' -0 OJ ):J!~ - rn'-:'i -..,.... Z:J:.: .,,-- zc N CD "'~_:;: ~t=j -0 i:c, .. J --".. L..(~ C;t CJ )>C :z :::.1 =< :D -.J -< ""._, L +~,....~~~ Conseco Consumer Discount Company VS Frederic C. Jussen and Eva Jo Jussen "~"' . ~ ~-. ~ "'.1, In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-752 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Gregory Javardian. Sheriff's Costs: Docketing Poundage Surcharge Law Library Prothonotary Mileage Certified Mail Levy Posting Handbills Advertising Postpone Sale Law Journal Patriot News Share of Bills 30.00 13.60 30.00 1.00 15.18 3.60 15.00 15.00 15.00 20.00 256.1 0 253.87 25.21 $ 693.56 paid by attorney 6/11/03 Sworn and subscribed to before me This If":: day of CJ,,~,-. 2003,A.Dq,f"-"() }y,Jjh,~~ Prothonotary So Answers: ~~~-<:#-., R. Thomas Kline, Shenff By~J~~ Real Est Deputy ,,0-\) "A 'l1\1..'1 V<.- 0 IJ q 7--' ~131 , ~~ ~---- i-. L- \t!lllll:.~" , CONSECO CONSUMER DISCOUNT J COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICSB~G. PA 17055: . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSB~G, PA 17055 EVA JO JUSSEN 1601 THOMPSON LANE ~CHANICSB~G, P A 17055 2. Name and address ofDefendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSB~G,PA 17055 1601 THOMPSON LANE MECHANICSB~G, PAl 7055 EVA JO JUSSEN 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 1993 Hununel Avenue Camp Hill, PA I70ll .,"0' - ~ ~ l.ill..dWi 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) . None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PAl 7013-0599 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1601 THOMPSON LANE ~CHANICSB~G, PA 17055 I verifY that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that fulse statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Octooor 4, 2002 .I /~j;, ~~--- =,f',\ ~:J ,~ (0l ~ 1 II I I I II ii, I,' i i) II II 'I il ;1 "11'-1 I 'iI'~ ~~ 1ll1l!'l'. _~~ IW.'I! . , " OfT ..-' ~IJ [jcr ~ F. ""RIFF ,'.''iTY '~! < < -, '_I ,_"-J,, " " n =u=u =ml = ~ inn] _1QlI!BlJ!,!,~~W~I!~>tWw-~~. _~~'~~. ~ .- " _. I.- ~illt""'; " LAW OFFICES OF GREGORY JA VARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM . FREDERIC C. JUSSEN, III EVA JO JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSB~G. PA 17055, is scheduled to be sold at Sheriffs Sale on MARCH 5. 2003 at 10:00 AM., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PAl 7013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT Tms 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: (2151 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,; . -..-"'_...~ " o , ~liil;;; , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sherifi's Sale is not stopped, your property will be sold to the highest bidder. Y oUi may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. . 4. If the amount due from the Buyer is not paid to the Sherifl: 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. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule uuIess exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 {;t'~~~ ~_. . ~< "~, " l-. ~ ,. ~~OIUL . ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 15 I .50 feet to a point at line of lands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west ISO feet to a point, the place of beginning. . BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 3 I, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, P A BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977 and recorded September 15, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. " . , ~~ -," Of:F~~"~ ~U:' Ocr 9 P,:.':- - ,1MI!lIl!!Ml!_~jll,!l!!!Ij;:\1r~WlI'~'W;:<I1:Ii1!~~ _~u 't.-- " j 2'.~ i! f'\!Ff ':,i-:-V I.l. , ~ ~O"<'-' ,U!]-"T' .1lIl.. ~..... - . -'-~. - -~ ~~, WRIT OF EXECUTION andlor ATTACHMENT .. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-752 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO CONSUMER DISCOUNT COMPANY, Plaintiff (0) From FREDERIC C. JUSSEN, ill AND EVA JO JUSSEN, 1601 THOMPSON LANE, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (o)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himiher that he/she has been added as a garnishee and is enjoined as above stated. , Amount Due $137,024.25 L.L. Interest FROM 4/24/00 TO DATE OF SALE @ $22.52 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $1492.40 Other Costs Plaintiff Paid Date: OCTOBER 9, 2002 CURTIS R. LONG (Seal) ProthA {} 71; ....Bv: '0"" 0 . /?.IU:U r Deputy REQUESTING PARTY: Name GREGORY JA V ARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1 ST FLOOR, SillTE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ill No. 55669 ~~~Ifii!;.j~'~~''iIiii!!'":l<i.i'li!&l~~IOO",lHI;j",~i;>J;M!d;''''''<IlL~"",s,''':C"''',i?''''''miX,'''.?I;o]j;:;W''',i'<.-~lM'~fi'""" did - 1lIIIII-'~ ~ ~ ~ . ""'_"'~'~~'O"- '. ~ i.:::~~:' lS2J c.:::------=-: [bf~ [UL., CL ~2) 1-".iN, .. .,i,('"'."''' "::I'':Ili'fj.-:->, .. Real Estate Sale # 2 On October 24, 2002 the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A, Known and numbered as 1601 Thompson Lane, Mechanicsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 24, 2002 By:cJClu-t~wq. ~~ ! i ,- :- d !1, J ('" 'L' C [ 1JO tLUi ~ = th!:b:. th!:b:. ~=i) :1\> ;:L10i " -" Il'-IlEAI. ESTATE SALE No. 2 g.:..wrllNo.~752 . : Civil Term _-:-- ~Co~Con8umer ~~- DJacount Co. ~~ va ~:-,-- Fred~rlc ~Ju.uen, III ~ ~..""d ~.~ ~va: 40 JU8een ~~. .lly;.tiresory Javardlan : M8CRIPTION ' _ -,thatwtain piece or pareel of land illUatc in ~QW'& Allen Tow!l~hjp, Cumberland County, -yhania, more particularly bounded and . as(onow~: 1N.NING at a point on the oorthern line of m~on Lane. widened a.s shown on the , after meutioncO Plan. at Ule eastern line of 1 an Wd Plan: lhcncc along said tat No. ;>; JlO1lh 13 ~ 18 minute~ east 27129 feet to mt on line of lands now or formerly of ujatilln K. HartzlerthcnC\l along said Hartzler !!antls! south -84- tkgrees 46 minme~ east 151.50 WAA.. a a -point a! line of lands now or formerly of. ~; thence along said Ellmaker lands. ~ 13 ~ees-Igminu!t$ WC-\t294.55 feel to-a "!fpolnt on the wrthern line of Thcmpsun Lane; ~ by the lalter, north 76 degree~ 42 minutes ~;; ~JjlL ftet to a point tbe plate of lNG. G Lot No, 2 on the Final Subdivision Plan ~.'~ W. lIl1d Jean C. Marquart, said Plan ~ t'l:cordeL in the Cumberland Count'! ~der~OfliceinPlanBook31,Page24. ' :::-WNo known as 1601 Thompson Lane, ':~shurg,PA,o~, ~. o.Inc same premises which Glenn W. ~ and Jean C, Marquart, IDS wlft. by ~~-So.lptember 12. 1977 and ra:(Irded ~lxr 15, 1977, in Deed BODk 1(, Vol. '27, ~. ~~ 5S9, Cumberland County Record~, granted ~ conveyed Ullto Frederic C. Jussen, ill and ~JiyaJpdu.ss_~,_bi~~~__ ~ i- ~ "~. ~-'- ...... .. ~~, i " THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 28th day(s) of January and the 4th and 11th day(s) of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorde,d in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #2 worn ~ n e T eny L. Russell, NotaJy Public City Of Harrtsbwg, Dauphin County My Commission Expires June 6, 2006 Member, Pennsylvania Association Of Notaries l My commission expires June 6, 2006 . CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 252.12 1.;'5 253.87 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of gen"ral circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By...,.,.............................................................. i'" X."., ~'II---~,.~ - """ i ~ ,; 'I Wlifu"", PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law J ournaI, 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, VIZ: JANUARY 31, FEBRUARY 7,14,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 NOTARIAl. LOIS E. SNYDER, I\Ict'il1Y Public CaIl!s!e 81:>;0, Culli~mbad O'..un!y My Corf.1liss!on Expll'llll Marcl15. 2005 lJBtI1llt1mr~~L ~_l<lr' I ~M~~t1iiili-'""",.g-M!hJe;;~~'l!IoIiI1i!liiHi 1fIiI...iJ~~- ,~'- REAL ESTATE SALE NO. 2 Writ No, 2000-752 Civil Conseco Consumer Discount Company vs. Frederic C. J ussen, III and Eva Jo Jussen Atty,: Gregory Javardian ALL that certain piece or parcel of land situate in Lower Allen Town- ship, Cumberland County, Pennsyl- vania. more particularly bounded and described as follows: BEGINNING at a poInt on the northern line of Thompson Lane, wi- dened as shown on the hereinafter mentioned Plan, at the eastem line of Lot No, 1 on said Plan; thence along said Lot No. 1, north 13 degrees 18 minutes east 273,29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 de- grees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker: thence along said Ellmaker lands, south 13 de- grees 18 minutes west 294,55 feet to a point on the northem line of Thompson Lane: thence by the lat- ter. north 76 degrees 42 minutes west 150 feet to a point. the place of beginning. BEING Lot No. 2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31. Page 24. BEING known as 1601 Thomp' son Lane. Mechanicsburg, PA. BEING the same premises which Glenn W, Marquart and Jean C. Marquart. his wife. by Deed dated September 12, 1977 and recorded September 15, 1977, in Deed Book K, Vol. 27. Page 559, Cumberland County Records. granted and con- veyed unto Frederic C, J ussen, III and Eva Jo Jussen, his wife, ~~NM'~'. _ _.~~ _" 'e^'. '..~,' ~ , '. .... ., :'( , . '" ,L " """,,, ."_' '0,',;"_,, "".,.1.,_ . '''"!IZC_ ..,. .. COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT COMPANY 7360 SO. KYRENE TEMPE, AZ 85283 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2000-752 CIVIL TERM vs. FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $137,024.25 Interest from 4/24/00 to Date of Sale @ $22.52 per diem Subtotal (Costs to be added) $ $ '-' j. :'.'h'_ " ~ ~ '~w..... "~~~.'. '"' """~'."""",.'",,' rcJ ~ .-'4. }..) ,- (J )..l 6'''J(I- ~7[ '<<9. 0 ..... ..... ... -l:;..o()(,.J-.. l...~ ~ ...... 0 II) fI) ~:-OCrt ~ ~ &- 6"'" &-~ . D DC~frt].J:.oO... 0 0 ..0 C ...... ~ () If'" C OCCC u"'\P--c:C \}C it- ~ - I I I ) I I I I \' , )..) ~ I ~ ~-V <:: - -... - - -i-f- -.. - - - - ~. ... - ... ::: - - - - - ... - . ... :::: ~ r..:J :b , .. .. .. ' .. . ... ..; '" ". ;-- .. - .... +- - Y-It:. kf -L.. ~ () r- [, .- ,_'""~ ~_ '~_,," ~^_, _~_'4.~" , . ., .",,, o ~,~ -rJ \~,\:) n"11i-, ~~;?~ ,~ ~ ;::: :;! <- ... g ~ ..r;.... -\ :r,;q'" ::r -r1 c:: rn r G") -0 m i3'I ~j~~ Q(') 6m ~j~ o ~ Ul " "~' "< , ~ ,1., l_ ~lR' I j ! ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, . Nmnsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 15 I .50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place ofbegiuning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12,1977 and recorded September 15,1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. BEING Parcel No. 13-10-0258-064. --., .- --. -b.~;"W WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO CONSUMER DISCOUNT COMPANY, NO 00-752 Civil CIVIL ACTION - LAW Plaintiff (s) From FREDERIC C. JUSSEN, III AND EVA JO JUSSEN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $137,024.25 L.L. Interest FROM 4/24/00 TO DATE OF SALE @ $22.52 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $2200.96 Other Costs Plaintiff Paid Date: AUGUST 12, 2004 CURTIS R. LONG (Seal) ProthO~ [J ~ '--By' 0.-...",. '/7/Te.r-- Deputy REQUESTING PARTY: Name GREGORY JA V ARDlAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SillTE 101 SOUTHAMPTON, PA 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 ~~ J ., J ,.-> . -' '~,l.." ~ '4; ~ .. IN THE UNITED STATES BANKRUPTCY CO~T FOR THE EASTERN DISTRICT OF PENNSYL VANIA INRE: Frederic C. Jussen Eve Jo Jussen Debtor(s) Chapter 13 Proceeding 03-00869 MDF Conseco Finance Consumer Discount Company FILED HARRISBURG PA Movant v. MAY 1 0 2004 Frederic C. Jussen Eve Jo Jussen Clerk, U.S. Bankruptcy Court Respondant ORDER . ~ AND NOW, this I () day of ~,2004, it is hereby ORDERED AND DECREED that the Automatic Stay be modified to permit Conseco Finance Consumer Discount Company to foreclose on the Debtor's property located at 160 I Thompson Lane, Mechanicsburg, PAl 7055 and obtain all other relief available under non-bankruptcy law. It is further ORDERED AND DECREED that should this Chapter 13 Proceeding be converted to a Chapter 7 the Automatic Stay will remain modified to permit, to Conseco Finance Consumer Discount Company and/or its successors and assigns to proceed with foreclosure on the property located at 1601 Thompson Lane, Mechanicsburg, PAl 7055 and obtain all other Relief available under the Non- Bankruptcy law. J " ^~' I -I::" '- ~.- -- '" L, -- N._ "~'.' '*! .' It is further ORDERED AND DECREED, that Bankruptcy Rule 4001 (a)(3) is not applicable and Movant is allowed to immediately proceed with foreclosure and all other relief available under the Non-Bankruptcy law. BY THE CO~T: III MARY D. FRANCE 1. Interested Parties: Gregory Javardian, Esquire Attorney for Conseco Finance Consumer Discount Company James M. Bach, Esquire Attorneys for Debtor(s) Charles J. DeHart, III, Esquire Trustee ., _' " ;,;, - " 'L_"_ :0"_ ",,_ ~ ~,,;" - ,,'--~ -, - .i.,/",r,- Id_, -,,;;',\0;'.,,-", > ~:,i: CONSECO CONSUMER DISCOUNT tOMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICSBURG. PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, PAl 7055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Lower Allen Tpwnship Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 1993 Hununel Avenue Camp Hill, PA 1701 I - ~,,' , "'-'-<<_ '-_'__1>~"'_,'_ -"~~ ',~I=" ;;,.;!r.,,', .Ill;: ~ 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1601 THOMPSON LANE MECHANICSBURG, PAl 7055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A 4904 relating to unsworn falsification to authorities. J ARDIAN, ESQUIRE intiff August 7, 2004 I, ,~ . ,,~:...i..~ij~i,i, " I , I I' I -,,,.,', , ",1 ,,,.,,,~"',",,. , [[1,._ ~" , .~.,' "";' ,.' ~ - . ,...,... '" , _'r ..,"~ <; n "" ~~~ C.Jo 0 ~ -n ~ -4 <= Iii {" nip -gm N 71J'Y 0 ::c> =10 - ''1~' 3: O:U ~?"O (jrn :;-~-t Cl ,l> .D (.)1 -< ~ ~ "-' '-<""," -,,', --"--'. - .,', ,-~, "c<,-,,,,.,,, _'~ :,_ , _ 'c_',' ,liJ'~"'-,; ,-~ "'-L.~ '~ "",,' LAW OFFICES OF GREGORY JA V ARDlAN By: GREGORY JAVARDIAN, ESQUIRE /DENTIFICA nON NO. 55669 1310 INDUSTRIAL BOULEVARD I ST FLOOR, SUITE 10] SOUTHAMPTON, PA18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certifY this Property is: () FHA () Tenant Occupied () Vacant () Commercial () As a result of Complaint in Assumpsit (X) Act 91 complied with -~............. ., ,.,"," , ;' .,',' ,.. , ,.,~ lilIi" J, ':;"" " ~ " -.. (") "'-> 0 (.":"'...) C = .." ~J~, .... :::-~ :II.." C:;l C~: !>,~, G~' rnp -om :DC) N (:)1 :::t~f.1 > -eL"i') :1': 0-"') :";:~n 0 .,",.\ ;p C) ...0 0'1 -< ;w ,';_,:",;~ ,.<&-_, ,;, -.' .-"h,..- "..<, -, - 1'_(" ~ '" ~'"_ , , I , I I I I I I I ! LA W OFFICES OF GREGORY JA V ARDlAN By: GREGORY JA V ARDlAN, ESQUIRE 'lDENTlFICA T10N NO. 55669 1310 INDUSTRIAL BOULEVARD I ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDEIUC C. JUSSEN, III EVA JO JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PAl 7055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSBURG, PA 17055, is scheduled to be sold at Sheriffs Sale on JANUARY 7. 2005 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PAl 70 13, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more charlce you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~'i" _ ',_,I _"-'C"" "'0'''..;(>"", ",-'- I"",,,~ ,~'_ ~ ""'; ., 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) 942-9690. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, P A 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 1"_' ,'.', , , ~ ' ' '-'"'' ^" ,"'" 1,'-, "'~~ ' ''''"" ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No.1 on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, nQrth 76 degrees 42 minutes west 150 feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977 and recorded September 15, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. BEING Parcel No. 13-10-0258-064. VV' , .., .' ~~ ' ,.-, <, ~ 0:- ,. ~ - -, ~ ., ".., p,"'" ("") ~.;; -:j i~c rnn:,',i ;..:: :'1.,' ~~ti ~ .-.,~ :?:~ ?"~:~ >'~ :':3 -, , '. <' ,..., "-"? = .c- ::I>> c: en 9. --i ffi;::: m =B9 (~C) :1:=n r')_ ~7(") (') rn ~ cn -< N > ::J::: o "'1 I -, '. '>'~.b:'<,-__"/,, ..;' " ,-.,.,.,'- " -,',,;1,,.;-,,';;-,-, ""'-'1 , LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 ] 3] 0 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (2 I 5) 942,9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA 10 JUSSEN AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, P A 17013-0599 Tenants/Occupants 1601 THOMPSON LANE MECHANICSBURG, PA 17055 FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, PA 17055 EVA 10 JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 , PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 1993 Hununel Avenue Camp Hill, PA 17011 Dated: If I ( / D If < .' , '~'i___-'" '- ~ ~', oj, (..0. _.'-"':"" -J- _,."~, - - ~-.." 7160 3901 9848 7415 8993 TO: Tenants/Occupants 1601 THOMPSON LANE MECHANICSBURG, PA 17055 SENDER: TEP REFERENCE: jussen, f. PS F 3800 J 2000 orm un. RETURN Postage .37 RECEIPT Certified Fee 2.30 SERVICE 1.75 Return Receipt Fee Restricted Delivery Total Postage & Fees 4.42 us Postal Service POSTMARK OR DATE Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail --.,- -- ---.-- 'I ~ "0 7160 3901 9848 7415 9013 :a m .,. m :a m z o !!I III m z c m :9 ~~~ n-O :I:>-ltn ~6~ ~~n n't3n '" "'. tJ:lO(:J !iilz", CH"'''' . ~tn >0 Z :> . - - - ..., - 6l '-" TO: EVA 10 JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 SENDER: TEP RETURN Postage .37 I RECEIPT Certified Fee 2.30 SERVICE Return Receipt Fee 1.75 ! Restricted Delivery ; Total Postage & Fees 4.42 us Postal Service POSTMARK OR DATE ! Receipt for I Certified Mail No Insurance Coverage Provided Do Not Use for International Mail _____u,_.._._ ...,.-. - , ~. " ~ ~ ~ '" ~ REFERENCE: jussen, f. 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I~~ [~ I ~~ - ~ ., - 0-' 0-,-. , ;',_' ~'.;,.,,'_' -,~ - Y';-"~'''' ,~<:_ _"" - 't;- November I, 2004 REVISED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): PLAINTIFF/SELLER: FREDERIC C. JUSSEN, III and EVA JO JUSSEN CONSECO CONSUMER DISCOUNT COMPANY DEFENDANT(S): FREDERIC C. JUSSEN, III and EVA JO JUSSEN PROPERTY: 1601 THOMPSON LANE ~CHANICSBURG, PA 17055 CUMBERLAND C.C.P. NO. 2000-752 CIVll.- TERM The above captioned property is scheduled to be sold at Sheriffs Sale on DECEMBER 8. 2004 at 10:00 AM., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA I 7013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriff's Sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ~';;;'7:,~. egory Javardian, Esquire Law Offices of Gregory Javardian 1310 Industrial Boulevard 1st Floor, Suite 101 Southampton, PA 18966 (215) 942-9690 ',",000_ ~ "0"_""",' . ~~ ,~ =1"D'1 r , ,~ '","." "~ ~~~~--. :. ..."... ,'-' ,,;"" '" ~C , 0 "-> = ~ c: c::) ~ -,,- "1'1 t:l} Z -I ~Tj f?:1 0 -r: ? '-'"-. <: rn:D ~?;; hi I :5y' c:: (5 U1 Qo )";: ~'" -0 :c:n --;."t ,J ::1:: ~i"'j ~;;:'C) )> .'. ':? om '-- Z -I :;I.. en ~ " 1..0 -<. , O~ ~ ~._--..- / ?l'-iLl_~',~, A~NDED RETURN Conseco Consumer Discount Company VS Frederic C. Jussen, III and Eva Jo Jussen In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-752 Civil Term Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2004 at 2:30 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Frederic C. Jussen, III and Eva Jo Jussen, by making known unto Frederic Jussen, personally and husband of Eva Jo Jussen, at 1601 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on November 02, 2004 at 6:50 o'clock PM, he served a true copy of the within Amended Notice of Sheriffs Sale, in the above entitled action, upon the within named defendants, to wit: Frederic C. Jussen, III and Eva Jo Jussen, by making known unto Frederic Jussen, personally and husband of Eva Jo Jussen, at 1601 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 18,2004 at 4:16 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Frederic C. Jussen and Eva Jo Jussen located at 1601 Thompson Lane, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Frederic C. Jussen, III and Eva Jo Jussen, by regular mail to their last known address of 1601 Thompson Lane, Mechanicsburg, PA 17055. These letters were mailed under the date of October 07, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 8, 2004 at 10:00 o'clock AM. He sold the same for the sum of$I.OO to Attorney Gregory Javardian for Green Tree Consumer Discount Company f/kla Conseco Consumer Discount Company f/kIa Green Tree Consumer Discount Company. It being the highest bid and best price received for the same, Green Tree Consumer Discount Company f/kla Conseco Consumer Discount Company f/k/a Green Tree Consumer Discount Company of 7360 South Kyrene Road, Tempe, AZ 85283, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $805.27. l"*~ -.....""'~ ,~ Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 15.59 15.00 15.00 30.00 10.00 $ 1.00 26.64 15.00 30.00 260.75 261.37 30.42 25.00 39.50 805.27 Sworn and subscribed to before me So ~ ~. 'I ~ 'l....t: -UJ Thisa=daYOfLLnA'j' - Q I . R. Thomas Kline, S. heriff 2005,AD. .,~._Q. ~~ ~~ r onotary BY Real Estate eputy Iiljl)JIlliiliilMi,', ~ ll1lt.y!L 3b- j.U1J C< t.jf3Q I rf.....-.jO'f/76 . - - -I , '. , ' ~ "l, , ~ lllIlliIIllII_", '. . . CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III . EV AJO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICS BURG. PA 17055: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, PAl 7055 EVA 10 JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA 10 JUSSEN 1601 THOMPSON LANE MECHANICSB~G, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Lower Allen Tpwnship Authority 120 Limekiln Road New Cumberland, PA 17070 Lower Allen Township 1993 Hununel Avenue Camp Hill, P A 17011 c '.-" < J - ..~; , , 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, P A 17013-0599 PA Department of Public Welfare Bureau of Child Support Enforcement Health and Welfare Building - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 . ~ -",,," , " '.li1l1", . , , ' . 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1601 THOMPSON LANE MECHANICSBURG, P A 17055 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. August 7, 2004 ARDlAN, ESQUIRE 'ntiff '"'" ',.. "c.' . . '-.. ,,,;;,..- "', j", . &[, LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN REVISED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSBURG. PAl 7055, is scheduled to be sold at Sheriffs Sale on DECEMBER 8. 2004 at 10:00 AM., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PAl 7013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TillS 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) 942-9690. ' 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 sak for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,~ -"'. ,.,c~ .-, L, ~ -8!llh 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) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ~,- ';~ ., ,.' -c,' ~ " " '~-~"I:,< 'illi;", ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west ISO feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977 and recorded September IS, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, ill and Eva Jo Jussen, his wife. BEING Parcel No. 13-10-0258-064. ~'lih LAW OFFICES OF GREGORY JA V ARDlAN By: GREGORY JAVARDlAN, ESQUIRE IDENTIF1CA nON NO. 55669 1310 INDUSTRIAL BOULEVARD 1ST FLOOR, SUITE 101 SOUTHAMPTON, PA 18966 (2] 5) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA 10 JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICS BURG. PA 17055, is scheduled to be sold at Sheriffs Sale on JANUARY 7.2005 at lO:OO A.M., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE 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\ 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the: judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chanlce you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) - -, 'y, -'," ~ 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) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe 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. This schedule will statle 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. 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ~~. ",,>;ii, ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No.1 on said Plan; thence along said Lot No.1, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line oflands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west ISO feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977 and recorded September IS, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. BEING Parcel No. 13-10-0258-064. --- -~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-752 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO CONSUMER DISCOUNT COMPANY, Plaintiff (s) From FREDERIC C. JUSSEN, III AND EVA JO JUSSEN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendantCs) not levied upon in the possession of GARNISHEECS) as follows: and to notify the gamisheeCs) that: Ca) an attachment has been issued; Cb) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendantCs) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him!her that he/she has been added as a garnishee and is enjoined as above stated. Amount Dne $137,024.25 L.L. Interest FROM 4/24/00 TO DATE OF SALE @ $22.52 PER DIEM Atty's Comm % Dne Prothy $1.00 Atty Paid $2200.96 Other Costs Plaintiff Paid Date: AUGUST 12, 2004 CURTIS R. LONG CSeal) prothon~ GJ,. 1'1.-... 87p--A..4-'''.../ Deputy REQUESTING PARTY: Name GREGORY JA V ARDIAN, ESQUIRE Address: 1310 INDUSTRIAL BOULEVARD 1sT FLOOR, SillTE 101 SOUTHAMPTON, P A 18966 Attorney for: PLAINTIFF Telephone: 215-942-9690 Supreme Court ID No. 55669 . "M~' , .;i' ", ;i 'I Ii " " !I I, " ii: ili ili Iii I!i I" Iii ,I, ii] i' Ii " Ii Ii iij Ii Iii Iii !'i il! 'I! :ii ,i! ,ii Iii 'I< i' " j; ., Ii !i Ii ';;"';"~~.~"I < ''''1M ~~''''''''''~' =~""!&iI!ljIi&tJi.ldill-'"~" -~. .'"'" ',- ~~~." "~ , ,"",",", Real Estate Sale #45 On September 03, 2004 the Sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A Known and numbered as 1601 Thompson Lane, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 03, 2004 By: JtHk~IIA i It/! Real Estat~ D;;~ ' "..' \' f\l ^SN H3d " ' ,'''' \1 i.'_.\ MII,j ..". ,! cf JU . L__ 1 ^ll'i!~V'; ,;,;\'J :JJlU3HS jl\~ ..10 ,..;,;iJjQ -~"'d @## ~~~ ---- -. REALESrATE sALe No. 4S :ii; e~~.Jt:.i~:752 " .; ,. CoIU$eCO Consumer ' ~ _ , ~- .Discount Company ~..:~~-':_-":' ,;::-;-Vs:- .: - .Frederic ~c. Jussen,lU and ~.__:.;"~"........EvatJoJussen ." . :",::-,Af!y; Gregory- ~aVardlan ',,"~~'_ ~''''~;;:i$''-~ ~,,:~ -i""","'<i=-"~- ....'. ,D~C~IPI10N ..:Ait~~~~~~~kwsituate in~-' A"CO T"'~" Cumlierl.ndCo ..~ .."""p, Wlly. ~_~ more particnlarly bounded and. OeSciit!eQasfollows:__ _, __ .-m .-. '/BEGJNNrNG atapolnt on-the.northeri1liIie of ~TIl~-~. widened, as. .shown on.the hqcimfter-- Plan. ~JIJe..-1ine of l.ot~o.l Q:Il~Plan;the:ncealongsaidLotNo, I, ~OI~t13 9~.gre~dg.minutes east273.2-9ieet to . lcpdiif imllDe of lands now or fonnetly of 'Benj_ K. Hartzler, llIence.a1ong said ll.1rraIer ~.~_46__""151.50 feeitoT~fiiffii1e~owo!1nrn,~lyof FllmUeJ, llIencealong said_ ""cis. south '13~1~_~~west2~55feettoapoint on 1he.~.lli1e_of'IhompsonLane; thence by the 1attex, n~ 76 ~_42minUU:s wesU50 . feet loa potm, die p1ace.ofBEGlNNlNG.. ___ BEING Lot No: 2 'oj{ the Pinal..o.SulxliviSion Plan fdr--GiEiQ-W;-.ndjean-C. Marqrnon. said PlM . bci1Jg . _ in the CumbaIawI Coinuy Reccrler'iOffi~TnF1ariBook31,Page24. ___ BEING -bloWn -~ _- 16m _ Thompson Lane, .Mechanicsborg,PA .BFJNG-the::same- - n_, : which _Glenn W. Marqnart mdJean c.;ru. wif. by Jl."j dared Sepremb<a-. 12.. 1977-and _ Bipteiiliei IS, 1977. in Jl."j Book K. Vol 27. Pa&e ~.Cumberland CoWlly Reoonla.grnnted andoonveyed untofredeDc c.J~ ill a,ndEva JoJllSSen,his.WifC:'u. _ llEll'IG1'iiiWlIlJ.:Ilto25l1-ll64. ~.. ~- , .). '<.~-' ." .' ,", ~ . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Connnonwea1th of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The 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 andlor Sunday/ Metro editions which appeared on the 19th and 26th day(s) of October and the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a reso1ntion 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 d for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. " COpy S ALE #45 PUBLICATION , , < CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs To THE PATRIOT-NEWS CO. For pnblishing the notice or publication attached hereto on the above stated dates 261.37 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. By......................................................,............. ~~~~ """',!!!liO!i[;L_' ' , , REAL ESTATE SALE NO. 45 Writ No. 2000-752 Civil Conseco Consumer Discount Company vs. Frederic C. Jussen, III and Eva Jo Jussen Att;y.: Gregory Javardian ALL that certain piece or parcel ofland situate iil Lower Allen Town- ship. Cumberland County, Pennsyl- vania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane. widened as shown on the hereinaf- ter mentioned - Plan, at the eastern !tne of Lot No.1 on sald Plan: thence along sald Lot No, 1. north 13 de- grees 18 mlnutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line onands now or formerly of Ellmaker; thence along sald Ellmaker lands. south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the . latter. north 76 degrees 42 minutes I west 150 feet to a point, the place of beginnlng.' BEING Lot No.2 on the Final Sub- dlvlslon Plan for Glenn W. and Jean C. Marquart, sald Plan being record- ed in the Cumberland County Re- corder's Office in Plan Book 31, Page 24. BEING known as 1601 Thomp- son Lane. Mechanicsburg, P A BEING the same premises which Glenn W. Marquart and Jean C. Mar- quart, his wife. by Deed dated Sep- tember 12, 1977 and recorded Sep- tember 15, 1977, in Deed Book K, Vol. 27, Page 559. Cumberland Coun- ty_ Records, granted and conveyed unto Frederic C, Jussen, III and Eva Jo Jussen, his wife. BEING Parcel No. 13-10-0258- 064. ''!i_.'_ ~ ';-I.,j'J . - ~,,,,o-,_ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VlZ: OCTOBER 8, 15,22,2004 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 22 day of OCTOBER 2004 L SEAL LOIS E. SNYDER, Notary Public Carlisle Bore, Cumberland County My Commission Expires March 5, 2005 I"'~'~~ ~. lililMliiIII ~~~-lI'W~ -~ '~ =~-'.....,~ .- ~ " ~ REAL ESTATE SALE NO. 45 Writ No. 2000-752 Civtl Conseco Consumer Discount Company vs. Frederic C, Jussen. III and Eva Jo Jussen Atty.: GregaI}' Javardian ALL that certain piece or parcel of land situate ii1 Lower Allen Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and descrtbed as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinaf- ter mentioned Plan. at the eastern line of Lot No, Ion said Plan: thence along said Lot No. I. north 13 de- grees 18 minutes east 273,29 feet to a point on line of lands now or formerly of Benjamin K, Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker: thence along said Ellmaker lands, south 13 degrees 18 minutes west 294,55 feet to a point on the northern line of Thompson Lane: thence by the latter. north 76 degrees 42 minutes west 150 feet to a point. the place of beginning. BEING Lot No.2 on the Final Sub- division Plan for Glenn W, and Jean C. Marquart, said Plan being record- ed in the Cumberland County Re- corder's Office in Plan Book 31. Page 24. BEING known as 1601 Thomp- son Lane. Mechanicsburg, PA. BEING the same premises which Glenn W, Marquart and Jean C, Mar- quart, his wife, by Deed dated Sep- tember 12. 1977 and recorded Sep- tember 15. 1977. in Deed Book K, Vol. 27, Page 559, Cumberland Coun- ty Records. granted and conveyed unto Frederic C, Jussen. III and Eva Jo Jussen. his wife, BEING Parcel No. 13-10-0258- 064. .. L,> .._,~ r~~ -~ - ..~-_-." ~- '-' -~-~<li'ii' \i._ I r JC umftL STATES BANKRUPTCY COURI'"' MIDDLE DISTRICT OF PENNSYLVANIA INRE FREDERIC C. JUSSEN m EVA JO JUSSEN CASE NO.: 1-00-03871 CHAPTER 13 Debtor(s) ORDER DISMISSING CASE At, Harrisburg, in said district, on the 121H day of FEBRUARY, 2001, Upon Motion ofDEBTOR and it having been determined that the case should be dismissed, itis ORDERED that the case of the above-named debtor(s} be and it hereby is dismissed and it is further ORDERED that the trustee hereby is discharged from further responsibility in this case, and it is further ORDERED that all pending adversary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are inunediately due and payable to the U.S. Bankruptcy Court. BY THE COURT: ~-- . -7'..... , ----.-- . 11 '-....-. t............ . I ~ (,,,.. )'Y .;;..r;,.;'. .,?-,~ ROBERIt- J. WOODSIDE. ',. CIllEF BANKRUPTCY JUDGE . 11.<] "......., ~.~~." ,J ,I ~~ > ~ .., , LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY CO~T OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA 10 JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 160 I THOMPSON LANE. ~CHANICSB~G. P A 17055. is scheduled to be sold at Sheriffs Sale on SEPTEMBER 5.2001 at 10:00 AM., in the Cumberland County Courthouse, I Courthouse Square, Carlisle, P A 17013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) '''''''''' -~ '""~- .lik.;;;ic" , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sherifl: 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. 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 distnbution is wrong) are filed with the Sheriff within ten (10) days. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW 1'0 FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ._ffi--- ^ ~"~~ " ,-- -..-~.,,~ , ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east IS 1.50 feet to a point at line of lands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12,1977 and recorded September 15,1977, inDeed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. _liItty-",-,..J~I'~~1ij~1EStd~$iI!_II.i:kI.~~'<ilJ2i!Mw~"_'_d..~ '" 1IiJ1iilI!1It ., """""""- - o C ":'. \:J[-';! S~ ~~- :-Zc- (j) - ~~ ?.:., -< C) .- 1 ::::. C,) i;? ,-... .,-,\ -']..--=- ~o =< (J"! . .~,~-"~,~~ . "'" , '" ," COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT COMPANY 7360 SO, KYRENE TEMPE, AZ 85283 COURT OF COMMON PLEAS /, CUMBERLAND COUNTY No,: 2000-752 CIVIL TERM vs, ---,' FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, P A 17055 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $137,024.25 Interest from 4/24/00 to Date of Sale @ $22.52 per diem $ $ Subtotal (Costs to be added) .!t4 j~ "=" "-~~ ~...."- - -' " i -W -Il!l~, ...... ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a pOint on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No.1 on said Plan; thence along said Lot No.1, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977, recorded September 15, 1977,in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto}.rederic C. Jussen, III and Eva Jo Jussen, his wife. ,- j ,--,'-~IihII~ ." -_- -. "-"'""~"~'~~~1iM1lrii!Wiril!i'lJlJl1!ho~<I!I<hJOO",""" ~~i!l'MlliI!:.m """" ~ .,.......' /. ., i I 1 ...... 2 0 0 \R lU -lq, 0 'Tl :~ -lQ. ~ ~ .... l\J "Pi if: ::It .-{ ...... :.0 ~ ..... f" ~co ~ Xl! . ~~ -< Pl.- ~ \) - ~ 0 r, g 6"- 8 c..> :"5' "It.. 0 c C "'0 C) '::)6 f I ;.::::0 :bo -;'-n ..c I I ~o ::u: P-'\,:!J ?'- ("::) ""'0 "'- -V ~g ~rl1 " 0 'f? 0 -- i1 l' 0 r 2: <;;.) s;! -- ... ... ... ... t =< ~ 6' , , ., . c..> ...... ~ ... ... ~ , "" ~ " . . ~,,- . LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY vs. FREDERIC C. JUSSEN, III EVA JO JUSSEN .. ,~..' ~.~ ~ " .\~ i:t:-" .,~ . . COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2000-752 CIVIL TERM CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certifY that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certifY this Property is: () FHA ( ) Tenant Occupied () Vacant ( ) Commercial ( ) As a result of Complaint in Assumpsit (X) Act 91 complied with ,~~.",..._",~.",.,,",,_._.__~~-, .I~'~~""""~""'" "'ll' . " ,., " " ~._-- tj Ij ...." () 0 0 Ii 0 ::r 'Tl :z:,. ::;.1 -< i'1i:!J ~~ (.,,) '+-r.;fl! ~e c :r:;9 c" "'" :::':;(j Jg ::.r: -r ::r e,:iJ \0 "":;;:? ~ - or (.,,) ~ (.) -< ~~~ ...~ ~ ""- ~ ""c ....:,' ... CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No,: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE. MECHANICSBURG. PA 17055: 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, P A 17055 2. Name and address of Defendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, PA 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. ",.."..... "~ .. ~.~. - .~ '-"-,.)f;'..i .. .,.. 4, Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) Beneficial Consumer Discount Company 4910 Carlisle Pike, Suite 104 Mechanicsburg, P A 17055 Plaintiff 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None, 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address carmot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N, Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) T enantslOccupants 1601 THOMPSON LANE MECHANICSBURG, PA 17055 I verifY that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa, C.S.A. 4904 relating to unsworn falsification to authorities, ('\RDIAN, ESQUIRE 'ntiff May 23, 2000 ~_lii~l;tUhm:riQl;lIIf~!1i;]I~l~~'illij"'lt1!H-&::'li;if~-" - ~lIiiIlI,W&IM"jjllir~~ " .", ~ ~ 0 0 0 'Tl ;}fro :x .-j :roo '," ~,!R -< i'-~;:: ~~ to.) -.'.,rTl 0 -"i;r, ., ,~ <~ J ;.::::0 :>> :..::1.::(' ~8 :J1: ..C -+I 0",- -~o >c 'f? orn ~ to.) ~ W -< '" .-"'11< ~ -'~,""__ .J ~~ Lj """!~~\c { LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOuNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C, JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSBURG, PA 17055, is scheduled to be sold at Sheriffs Sale on SEPTEMBER 6.2000 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, 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 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) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) __..i~"" "~" ~, 1_" I ~,' I YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You 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. 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. 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 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 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 ." ."h''''''_~''~'~- - .~ - - I, .;wl'-' I ALL that certain piece or parcel of land situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No. I on said Plan; thence along said Lot No.1, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of , Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA, BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977, recorded September 15, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. ~"~~~~i/,l,.'~~-""'-~'j""&~ Q1' ~ H'~liili;\!J.JI0'~,_"s;,'iWM%~':it,~~~ -, ' ~_.... ".....~""" (j E;: <!" !~".et,'~ III f!;) ;::;'';'". ;s:i!5 18 ~ !dr. \ o <::) :.Ii: ".. -< W C :l> ::I: If:? w w Q .. ~~'1 ;:r,;~ .1 ';id -r;rr,. ::;5 r-i .~{~ ---:r::u <-),_JI i3~ ~ -.;:, . 'F t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $137,024.25 Interest from 4/24/00 to Date of Sale @ $22.52 per diem Subtotal (Costs to be added) $ $ G A ,ESQUIRE >-1 ' ~~,,- . r ALL that certain piece or parcel ofland situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No.1 on said Plan; thence along said Lot No.1, north 13 degrees 18 minutes east 273.29 feet to a point on line of lands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151.50 feet to a point at line of lands now or formerly ofEllmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning. BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mecbanicsburg, P A. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12,1977 and recorded September 15,1977, inDeed Book K, VoL 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. .' , . . . ~~i'i~f;lfW\iliWli~Mt~~!l!il@.M~.Ji<.tfii"''WIi-'''''''''~OI~M.-=i -. -. " ^ , _llHIlI.~'ii:_&- Illim - ..w.'i , , ... ~ C ...... Cv ~ ~ ~ ..... .{)tr- ~ (.::) ...... eo., f'" r- f/? ~ . . o & :g 7 ~ f' ~ 0 () 8 r- g (v C' \) 0 ~ "'Il> fi' c::::'- ~ I \ \ I I I I . ......... ~ pr 2fT "'- " ~ .... :;~r" r..__: )oJ f' ... ... , ~ , {j):-- ..... ... ... ~ ~ t .... " , , , , ?W;~ .....:J ,. fj]- " -.. ~ ;:, ... , ~ , ., , , ^ " Pc ~ '" J~:? " Z :..,.j _c ~5.J -< (Jl -< .w"""","",,", 1.-- --",~ .. . ,CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1601 THOMPSON LANE, MECHANICSBURG. P A 17055: 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, PA 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG,PAI7055 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. " -..... ~ ~ . , " --', , r . ,,4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle,PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, P A 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 1601 THOMPSON LANE MECHANlCSBURG, P A 17055 I verifY that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of I 8 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. May 25, 2001 _illl(Ell~IlliiI~~~!!li;I!i'li~"'''''."''"' ~~~"ll&;~;!2~~"'~IlllHIII'. -~ _. -, ~" . .... " C::"< c:: ?,: -;:,:; n :1::--' [T\ CT' ".--,.. ~ ~ ..' . n ~7} ~~ ,-J j r::: L. <- " ~Z C) n )> - f;? ~,:::; C Z .~-,. =2 :n U1 -< "......." .....~.,-,..... - J, ., L!IJ>'I , '0.( .;. CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was tiled the following information concerning the real property located at 160 I THOMPSON LANE. MECHANICSBURG. PA 17055: 1. Name and address of Owner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. . ~ ...L:- ~- ~ i!h.-m" ~ 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Beneficial Consumer Discount Company 4910 Carlisle Pike, Suite 104 Mechanicsburg, P A 17055 Plaintiff 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, P A 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, PA 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TenantslOccupants 1601 THOMPSON LANE MECHANICSBURG, PA 17055 I verifY that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. ~IAN, ESQUIRE 'ntiff May 23, 2000 ~. I , ""'"'-, ..... LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE lDENTlFICA TION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 2000-752 CIVIL TERM FREDERIC C. JUSSEN, III EVA JO JUSSEN . NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: FREDERIC C. JUSSEN, III EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, P A 17055 Your house (real estate) at 1601 THOMPSON LANE. MECHANICSBURG. PA 17055, is. scheduled to be sold at Sheriffs Sale on SEPTEMBER 6. 2000 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A 17013, to enforce the court judgment of $137,024.25, obtained by CONSECO CONSUMER DISCOUNT COMPANY, 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: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (21:ll 942-9690. 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 g-ood 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 wilI have of stopping the sale. (See notice on page two on how to obtain an attorney.) . ,.,~ -~ J L ~ li!Iik . " YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690, 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 Gregory Javardian, Esquire at (215) 942-9690. 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. 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. 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 TIDS 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, P A 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 - ~~ 1-: -I." _< 'ill"" . .... ALL that certain piece or parcel of limd situate in Lower Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: . BEGINNING at a point on the northern line of Thompson Lane, widened as shown on the hereinafter mentioned Plan, at the eastern line of Lot No.1 on said Plan; thence along said Lot No. I, north 13 degrees 18 minutes east 273.29 feet to a point on line oflands now or formerly of Benjamin K. Hartzler; thence along said Hartzler lands, south 84 degrees 46 minutes east 151,50 feet to a point at line of lands now or formerly of Ellmaker; thence along said Ellmaker lands, south 13 degrees 18 minutes west 294.55 feet to a point on the northern line of Thompson Lane; thence by the latter, north 76 degrees 42 minutes west 150 feet to a point, the place of beginning, BEING Lot No.2 on the Final Subdivision Plan for Glenn W. and Jean C. Marquart, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 31, Page 24. BEING known as 1601 Thompson Lane, Mechanicsburg, PA. BEING the same premises which Glenn W. Marquart and Jean C. Marquart, his wife, by Deed dated September 12, 1977, recorded September 15, 1977, in Deed Book K, Vol. 27, Page 559, Cumberland County Records, granted and conveyed unto Frederic C. Jussen, III and Eva Jo Jussen, his wife. - . ~ -,~~,'-li WRIT OF, EXE~VTION and/pr ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-752 CIVIL i9~ Tenn CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Conseco Consumer Discount Company PLAINTIFF(S) from Frederic C. Jussen, III and Eva Jo Jussen, 1601 Thompson Lane, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ .\/iJ)I:: GARNISHEE(S) as follows: and lonotffy the garnishee(s) that: (a) an .'!\~PPli11en!-t1as been issued; (b) the garnishee(s) is/are enjoined from payin!~ 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 oHilecrereriOa~l11ffled'upCin an subject toattachmel'1tis fOlllldin!he.possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $137,024.25 from 4/l4/UU to date of sale Interest @ $?? ')1 pE'''' d;E'ill Ally's Comm Atty Paid Plaintiff Paid L.L. $.50 % Due Prothy Other Costs $1.00 $122.18 Date: May 30, 2000 REQUESTING PARTY: Name Gregory Javardian, Esq. Address: '44 Second Street Pike, Suite 101 Southampton, PA 18966 Attorney for: Plaintiff Telephone: 215-942-9690 Supreme Court ID No. 55669 ~~._'.....,=- ~~'~illW4oii~~~_d~ J __ ,,_ -~ ~. ~"'i REAL ESTATE SALE No. 31 \)f1~ d. ~ tile snentt levied upon the defendz.:-:'- Interest in the real property situated in ~ .., ~~'~A 4'rvP r Cumberland County, Pa., known and numbered as: J~dl ;tL..,;AA ......~ CVil ~Lta......u... Q'rf and more My :lescribed on Exhibit "A" filed with '~ this writ and by this reference incorporated herein. iiiil, oatef}_.1 ).rro &/: ~." jA.-IL ~~~~ 'rf! ',i'o' ,'.ll. c~ c.' ',1':1 d \' I" -1"_ ,/,...._,1,':'1 . !: - ~ : -, '--"--'''. [:0, ,.. 00 II ZE AUH A1Nnc~ .'JHOO ~~1~3HS 3,,1 JC ;~1;J:l0 I" ~ .. " Conseco Consumer Discount Company -vs- Frederic C. Jussen, III and Eva Jo Jussen In The Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-752 Civil liiIMIIIiI . iln., R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail Levy Postpone Sale Surcharge Share of Bills Law Journal Patriot News Sworn and subscribed to before me This # day of ~ 2000, A.D. ~ 0 n"d;;"/~, Pr th notary 30.00 12.49 15.00 15.00 .50 1.00 13.64 1.38 15.00 40.00 30.00 23.53 288.65 180.75 $ 636.94 Paid by atty 12/01100 So answers: R. Thomas Kline, Sheriff ByJt~_~ JM- Real Estate Deputy \.~ :;..U 30(" c.k 'I ~jO'l1J ,"""~ ~ . LAW OFFICES OF GREGORY JA V ARDIAN By: GREGORY JA V ARDIAN, ESQUIRE IDENTIFICATION NO, 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (2 I 5) 942-9690 CONSECO CONSUMER DISCOUNT COMPANY vs. FREDERIC C, JUSSEN, III EVA JO JUSSEN I JiM.' COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 2000-752 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certifY that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau 1 Courthouse Square Carlisle, P A 17013-3387 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, P A 17013-0599 TenantslOccupants 1601 THOMPSON LANE MECHANICSBURG, P A 17055 Dated: ~ - ~ -~ FREDERIC C. JUSSEN, III 1601 THOMPSON LANE MECHANICSBURG, P A 17055 EVA JO JUSSEN 1601 THOMPSON LANE MECHANICSBURG, P A 17055 Beneficial Consumer Discount Co. 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17055 ARDIAN, ESQUIRE aintiff . ML~~ ~"-~ ~ ~ " , Conseco Consumer Discount Company -vs- Frederic C. Jussen, III and Eva Jo Jussen In the Court of Common Pleas of Cumberland County, Pennsylvania Harold 1. Weary, Deputy Sheriff, who being duly sworn according to law, says on June 8, 2000 at 2:40 o'clock P.M. EDST, he served a true copy of real Estate Writ Notice and Description in the above entitled action upon one of the within named defendant to wit: Frederic C. Jussen III, by making known unto Eva Jo Jussen, wife at 1601 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Harold J. Weary Deputy Sheriff, who being duly sworn according to law, says on June 8, 2000 at 2:40 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice and Description in the above entitled action upon one of the wihtin named defendant to wit: Eva Jo Jussen, by makin gknown unto Eva Jo Jussen at 1601 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania, its contents ant the same time handing to her personally the said true and attested copies of the same. William Diehl, Deputy Sheirff, who being duly sworn according to law, says on July 12,2000 at 7:40 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Frederic Jussen and Eva Jo Jussen located at 1601 Thompson Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who b 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 within named defendant to wit: Frederic C. Jussen III by regular mail to 1601 Thompson Lane, Mechanicsburg, Pennsylvania. This letter was mailed under the date of July 13,2000 and never returned to the Sheriff s Office. 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 defendants to wit: Eva Jo Jussen by regular mail to 1601 Thompson Lane, Mechanicsburg, Pennsylvania. This letter was mailed nnder the date of July 13, and never returned to the Sheriff's Office. so~~ R. Thomas Kline, Sheriff ByJdL/~f ,/~K Real Estate Deputy t "-~"-. ~" I .. tr l'- o ~ ru ~ l'- ru l'- o o o o ru ru I'T1 tr tr o l'- Postage Certified Fee ~,,'0^i~ I://.~ ",*,'1\ {,:::'/ 1,,,, ~ --- \i' 00 ...J L (0 o ",-.:,,-, Cl) ,0> . :,,:i. )~ \) ","/cJ Return Receipt Fee (Endorsement Required) Restricted Delivery fee (Endorsement Required) Total Postage & Fees $ ., Name (Please Print Cle"f.'rlJU"~df mailer ___ m.__......m'._m....__:.,I:!re~<>lo/_Ja\<&rdian.._..m""nnhn__.mmnmnh Street, Apt. No.: or<<seto~d St. Pike Ste. 101 citY;-Siai~:-Z1P~-4-~Southampton;-F:-\...;.g9G6+----_.+----_._------~----"------ PS Form 3800, July 1999 See Reverse to _..-___r Ll1 Ll1 o ~ ru ~ l'- ru l'- o o o o ru ru m Postage Certified Fee Return Receipt Fee' (Endorsement Required) Restricted Delivery Fee (Endorsement Requill:ld) Total Postage & Fees $ Name (PI,sse Print Clearly) (To be completed by malls US? S '_mm'..m__..m..h__.._m..m..C___The-l.aw-OMces-ot-m_...'...____'m_n Street, Apt. 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City, State, ZIP+ 4 ,. < " aval'dHtu ,( "cnr'd C::t P"l PS Form 3800, July 1999 See Reverse fa - "tl 1l's: c '" " I. ." 0 . 0'" 0 " n <-<~ . . 6~ C3 3 ~ ". .. . ~c~ '" n ~ ClO 0 0 . ~ o~> ~ ~ ~ !l. a "0 ~ ..... ::0 Q e z-n(l) ",om s: t< I:Jj ~ C:JJ ~ ,. ~ H t'J . "0 - {1) ::0 " ~Om t< t< 3 ... nS: mm '" t'J ~ ~ ... I'" ClO . ~WC'l~ ..:J '" Z ~ on t1 d ",,,0 '0 . :TSiG -Izm . ~ " S:O 21 ~ 0 . ~ .:Ii . ~z -I 0 ~ -1-1- ..... 0 ~ o ....0 mm "Tl ",,- ..., Z ? .!l Ell j;0 0 1-3 '" e. s -I)> ..... ><: :;- r.i e: U) --f W ~-, , ~ a, ~m ~ ~r., " 1'0 c , . S:"Tl ~s: 0 SO JTf,.o, ;,,)> t< 0- "'1>- mr- ~ "'- 0'.,':.)\ zZ H <~~ r~ ~; (~)\ oQ :s:,c: -I !.n I:Jj '1l b 12:) : ,mVl.SOd . .. . . . ~ . m . . , ' . /-" : r" . "tl '" ." o 3 '" ClO ~ :-' s: ~ '" ClO '" ~ \l\ ~ o o g': 0" " :; x' - . . '" . . C::i" c'" . ::;'-'PS' ~ CD=iYil3 :10:1"'0 ........O'cn 0 " . ~ 'O. . n (") . ~ ~ 0 "' H " (") . " CI.l 3 to .. e: ~ ~ '-< 1t <> e: . CI.l . . I-cJ CI.l 1t > l:<l Z ~ ..... ...., 0 ..... '" ..... '" ..... "S:c :II ~~(n ~ < . ~ 6~ C3 CD me en a. "T1oo-l "T1 Om> a ::00.... 2 ~~ m C:JJ ~ ~gn ~~ m mm I~ ~n ",,,0 -Izm j:o 21 002 -I nlnl =n :u~O ")> :J-f ~m 1'0 S:"Tl ~s: ;,,)> ~? ",- zZ oQ -I :0(- ., - ,/" ') : ;OVJ.SOd . . , ; ~ 0 , .il_ !. ,_"t",': : r..~-- .~ ,- .-- - U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE useD FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: -~-. Ol(,- ',.", U!\~ 'l'het..1l>n... /<S>,,;~- . Eh"goty J: ~ otfS."( ,!Ul' ~ Second S a~ardian l-. .... "Q ",. t. P1J. .Q .c.ttI "'/FlT}] ''- 4,Jle 101 ~. mon p, . Om . <'1 lSWIG ;,9 One piece of ordinary mail addressed to: 'l'RNAN'l'C::: f()(,(,TTPAN'T'<::: 1601 THOMPSON LANE 11ECHKNIC5BURG, FA 17055 PS Form 3817, Mar. 1989 ERTIFICATE OF MAILING u.s. POSTAL SERVICE TIC ~ND INTERNATIONAL MAIL, DOES NOT MAY BE USED FNOS~~f~~S POSTMASTER PROVIOE FOR I Received From: The \AlW Offi.:':~ ..<\",:\ \:'_/ ' ~~~~f~~\S~;;o~~:lF!J~~' "}\ . 'I addressed to: \.\. -.. -._ ~. One piece of ordmary mal C AS S 1ST ANQ~S e,._", OF PUBLI "- DEPT. LV~ .j.j W~::;..t:l"lLN::;T~K UK P.O. BOX 599 17013-0599 CARLISLE, PA RE JUSSEN PS Form 3817. Mar. 1989 U.S. POSTAL SERVICE CERTIFICATE OF MAlLIN MAY BE USEO FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: ne;;;of , Gregory Javardian ,\ St'cond :st. ..PIke :ite. 101 '." One piece of ordinary mall addressed to: CUMBERLAND COUNTY DOMESTIC RELATIONS l.j ~. tlANUV~K SLK~~L CHARLISLE. PA 17013 ~e(,~.. /'<? \ _'-:'.._1 I(~;>.hl~ '-_ I I) '-.1 In\ \~C'\~ ij j;! Q lH '" ;:: ',/ 19-/ ~ ~ 1; l;!\,!1 m ., ...1f:1I11$.~""..~4-. ~I ~I m. PS Form 3817, Mar. 1989 0. . of,.!!/ . If.... ,",.;l- ~ #0 ~ "~, Ci<-' One piece of ordinary mail addressed to: fir .-,r_ " c, U,S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE POSTMASTER Received From: The Law Oflice9 or n--IJO~' Ja.'araiaR 44 Second St. Pike Ste. 101 /":.' " l\':'> (.J.I \,::( \)\ -5' "'fA 10 ,TTTSSEN 1601 THOMPSON LANE MEC~,IeSBURG, P~ 17955 PS Form 3817, Mar. 1989 do..... .if-,Il>3f,~'" ";',*,,,,)>" Thill I..AW Offices of Gregory Javardian U Rarnnd Rt Pike Ste. 10 j Sonthampton, PA lR~6G --: r~) r" . ~ U,S. POSTAL SERVICE CERTIFICATE 0 MAILING ...,.~ MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: '.\~~ One piece of ordinary mail addressed to: ._~.... l= BENEFICIAL CONSUMER DISCOUNT CO ~ 491u CAKLLbL~ ~LK~ ~ SUITE 104 ~ :;! MECHANICSBURG, PA 17055 ~ '" REi JUSSEN PS Form 3817, Mar. 1989 ...........1II........ It..... ~~~~~\W~~~tfit~>iI~~~"-,!;:",r<ik;,,_;;g,I".'ilii;~~ _. w......llllilOll. --.-. iiik. '.-- .~~~"..... 0 c, ~~ ~ c) "t;)CtJ :0- :::1 SPcg c: , G") :'-j1,2 65.~ I :::")n~ ~"'" ...... '?r 0 2'=:() ~ .,., ;~~ =tf ::;>8 :Jr: '-",,-- C ~ iSni ~ 0 ~ \0 -< -'I I i I I I . ..