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HomeMy WebLinkAbout00-01033 ~'~~~~..~-- ~u",.~, ~"~ ~_' "~\..., FEDERMAN AND PHELAN By: FRAJ{KFEDERMAN,ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (7 1~) ~n,-7000 ATTORNEY FORPLAlliTWF COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION, F/KIA PIDI MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 TERM v. NO. -<000 - 10J,3 C,~J;'~ Plaintiff CUMBERLAND COUNTY JOHN W. SHEAFFER SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, P A 17241 Defendant( s) CTVTf. ACTTON - T,AW MORTGAGR 1I0RlI,Cf.OSTTRR NOTTCR **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment 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 TIDS PAPER TO YOUR LAWYER AT ONCE. W YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 9897661 r ~'"~"~ --",-,- """= ,I It<!'l~M, L Plaintiff is CENDANT MORTGAGE CORPORATION, FIKIA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2. The name(s) and last known addressees) of the Defendant(s) are: JOHN W. SHEAFFER SillRLEY M. SHEAFFER SOl STEELSTOWN ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/28/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1402, Page 833. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ~~~ . ~,- - ~ , --,. 6. The following amounts are due on the mortgage: Principal Balance Interest 9/1/99 through 2/1/00 (Per Diem $20.21) Attorney's Fees Cumulative Late Charges 8/28/97 to 2/1/00 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $98,385.64 2,485.83 4,000,00 252.45 .llQJlQ 105,673.92 0.00 1il.62 1il.62 $105,744.54 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not comeunder Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAlNTIFF demands an in rem Judgment against the Defendant(s) in the sum of $105,744.54, together with interest from 2/1/00 at the rate of $20.21 per diem to the date of Judgment, and otller costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. I. ~ ~=, "~ic :r-~ r~~ /r;::./ Fr:mk Fp.np.rm:m FRJV{KFEDE~N,ESQU]RE Attorney for Plaintiff - - ,'~ -'-' "' ~' J!&i> . < AI,r.. thnt certain lr'8ct or parcel orla.nd tog€:ther with the impro\lertl~lllS lhc:rcoll eonSl rueled or creCleu, situllte in North Newlon Township~ Cumberland C',)Ullly, Pell/lsylvllnia, more p~rtictl[arly bounded and described in accordance with a survey dated August 21. IlJc)7, by Eric. L. DifT'elll.u1ugh. prnfessional hwd Sllrveyor. as follows. to wi!; .BEGINNING at ll. point at the centerline of SR 4006 (Steels:town Road) ill an e:<istin!;l n1l.ccn (1 $) foot gravel CarOllane at lands now or formerly of Robert N, and Joanlll!l M. Zil1lmel'fJ1.Qn~ thence along lands now or formerly of Roben 'N. <lnd Joanne M. ZinUHCl'l1mn. Nt)["th eight (OS) deu-rees twenty-nine (29) minutes twenty (20) i'teconds E<lSl~ a dislance ot' two hundno;d thil'lcen and fifty-seven hundredth::! (213.57) reet to a point at rhe eastern edge of said fil1ccn ([ 5) fool g,l'o......eI farmlane~ thence continuing .along; lands now or formedy of Robert N, and Jo-annc \'Vt ~immennan. North eishty.seven (87) degrees forty-seven (47) minutes thirty-one (3]) seconds East. B. djstance of three hundred ninety-one and siMy.one hundredths (391.61) feet to a po;nt III landl:> noW or IOJ'lT\crly or Chester L, BUr'kett; thence alonp; said. lands now or tbnlH'~r1y of Chester L Bllrk~t[. South eight (08) degr'ees eight (08) minutes thirty-live (35) seconds West. a distflnce orlwO hundred fifly-tive and seventy..one hundredLhs (25S.71) feet to 1;\ point at centerline or ilrOI'cmef\!iofl(.!d SR 4006 (SleelstO'\Nll Road); then'cle along snid celllerlille. Nonh cigl1ty-eight PH~) uegrec.s Qlle (0 I) n,inule tifteen (l S) seconds West. a distance of olle hundred thirty-Jive and lievcnly-,!levcl1 (135.77) feeL \,0 it paint; thence along ~iltTle. North cighty-eight (8~)'cJcgrees Y..~l'O (00) minlJtcs lwellry.eight (28) seconds West, a distance aftwo hundred five nl1d thirty-livl.: hundredlhS (205.35) feel 10 a P9int; thence remaining in the bed oflhc said ::::R 4006 SteelSlown I'-Olld, North eight (08) degrees nny-one (5 I) n\inllle~ sevenleCII (17) secnl'd.s {;:<I$t, u diSlance or rom and ~ix.lY~!ievcn hundredths (4.67) feet to a point: thence F1long .same, ~or'th sev:nt):-seven~ (77) degrees twenty-four (24) ll\inutes twenty-three (23) second.s \.vC::it, it clistnncc of fOltY-l'ievl.:n und nny_tleven hundredths (47,~....;) feet to the poinT and place ofIU!;(;INNlNC. CONTAINING 2 AC:I'cs. 100 Perches, more Or' less. .' BEING the smne PI'Operty which Ray A. Halteman and Linda K. HalLen1an, husbgnd and wire, by deed dated July 01. 1986~ and recorded July 03, 1986, in Cumberland C(]U~llY Deed Book "Z", Yolui;ne 31, Page 933, granted and conveyed to Ray A, Halternan and LllIdn: K_ H::Ihel'nan~ husband and wife, Grantors herein_ AND the snfd Grantors covenant and agree that they will warrant .;peciaily [he- propt:;rty hereby eon"cyed. IN WITNESS WHEREOF'. said Grantors have hereLlnto set their hands and seals the day and yttB.r firsl above written_ PREMISES: 501 STEELSTOWN ROAD . ~ - , VERIFICATION MARC HINKLE hereby states that he is VICE PRESIDENT of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec, 4904 relating to unsworn falsification to authorities, frb.t7LIJ DATE: h)-13-0 CJ .1.:., (1"" ~~ ~ f' ~~ ~ FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 ~ 6q. n h~ o () "Cj 9 0 , ~~ ~ ----( , 0 C) 0 C c.=) -I"; "'Uf,~; -"1 rnrl'! ("'Or,,! ..'-- Z:l_' OJ 2:, C' T'~ (/:-! ,- .,. .~' ~ C::' 7:'",' .--'....,.. ":.,,- - ,~" ,,- C -". Z . ~ :--,~) -< (....; €) ..d ~~ <~ ~- '.""""1,) ~ ". SHERIFF'S RETURN - REGULAR CASE NO: 2000-01033 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS SHEAFFER JOHN W ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEAFFER JOHN W the DEFENDANT , at 0016:50 HOURS, on the 1st day of March , 2000 at 501 STEELSTOWN ROAD NEWVILLE, PA 17241 by handing to SHIRLEY SHEAFFER a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answ~ ~! ~ 1~ 18.00 8.68 .00 10.00 .00 36.68 R. Thomas Kline 03/02/2000 FEDERMAN & PHELAN Sworn and Subscribed to before me this :l <{ ~ day of By: C0<Um\ ~. ilL Deputy Sheriff ~ ~nril A.D. qf1~ c.. Iu .,'[,-/ .~ P othonotary . ~ "_~~~i,_. ~ I LJ ~ '~b!, .., .. "'.. SHERIFF'S RETURN - REGULAR CASE NO: 2000-01033 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS SHEAFFER JOHN W ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEAFFER SHIRLEY M the DEFENDANT at 0016:50 HOURS, on the 1st day of March 2000 at 501 STEELSTOWN ROAD NEWVILLE, PA 17241 by handing to SHIRLEY SHEAFFER 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 A;;~~l" 6.00 .00 .00 10.00 .00 16.00 R. Thomas Kline 03/02/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: \J<illYl\ ~. \kJL Deputy Sheriff me this .{,., J..<{ ~. day of '--7vL." J 'JA:L<ro-o A. D . ("\" ~ Q '-rvt./~ ~' '- f'p't;othonotary I d l~ ~~~ . lJ -- .', ......._~ 1- ..II:E!l" ( FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, FIKIA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 2000-1033 VS. JOHN W. SHEAFFER SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, P A 17241 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO mE PROTHONOTARY; Kindly enter judgment, in rem, in favor of the Plaintiff and against JOHN W. SHEAFFER and SHIRLEY M. SHEAFFER, 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 2/1/00 to 3/27/01 $105,744.54 $8,488.20 TOTAL $114,232.74 I hereby certifY that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ?N41- 'i~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - DAMAGES ARE HEREBY ASSESSED AS INDICATED. . ~ DATE: fYl:::!l'JrL .:let: UX) r (J-lfi*.J? PRO PRO **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUYfCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ...,f.H ~'~-_."" ---~ .~... .1 ~..~~~ " I- . l& , I , FEDERMAN AND PHELAN, L.L.P. F~ank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant(s) TO: JOHN W. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, PA 17241 DATE OF NOTICE: MARCH 12. 2001 f"" 1I.t; COPy THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff . "'"'..~~"'......,_ . O~ ___ ~~ "11 " ~ l~ ,,~~ ~" , FEDERMAN AND PHELAN F~ank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant fiLe' COpy TO: SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, FA 17241 DATE OF NOTICE: MARCH 12. 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ~,;'''''''" . - ,.~ 1- ~' .~, . FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, FIKIA PHH MORTGAGE SERVICES CORPORATION Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION vs. : NO. 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant JOHN W. SHEAFFER is over 18 years of age and resides at 501 STEELSTOWN ROAD, NEWVILLE, PA 17241. (c) that defendant SHIRLEY M. SHEAFFER is over 18 years of age, and resides at 501 STEELSTOWN ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to WlSWOm falsification to authorities. ?r~ 7..R~~ FRANK FEDERMAN Attorney for Plaintiff ~~ - .. (Rule of Civil Procedure No. 236 - Revised) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION Plaintiff : NO. 2000-1033 vs. JOHN W, SHEAFFER SHIRLEY M. SHEAFFER Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on MARCH;:)9 ,2001. ---.By Aa-,. {/ 2. ~D-u<JdI)EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TillS FffiM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** It..... .<', .' "''''IfIi.IliIlli''liIiiliIlili1i6i~:llIM~~J!''''' .~. ,:.'. .' ,"".; ~ ,~ ~ < ' """ Co' ~'"" ,. , i ~ . ~ i ~ ..fQ. C1 ,'-'" -..a --,...' c: . <" () ~f1~ r ....... \> m.. ~ "-' &.~~,', r-,~) , ':~3 \..D ....:} ~ ~" ':: ~i~j, ~ ~o j ~ ?G ;::" --I , ::i:.: -'~. -', 1 ;7' .f f~f'~ !U'~ '='0 C) Pc ~ 1 :?.: ~ =< ~" :::0 (D -< , '/ , I". 'k: !' i ,: ,. SALE DATE: SEPTEMBER 5. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW CENDANT MORTGAGE CORPORATION No.: 2000-1033 vs. JOHN W. SHEAFFER SHIRLEY M. SHEAFFER AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE 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: SOl STEELSTOWNROAD, NEWVILLE, PA 17241. As required by Pa. RC.P. 3129.2(a) Notice of Sale has been given in the manner required byPa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No, 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. , SQUIRE November 30, 2001 , .~ , - , I " . .. CUMBERLAND COUNTY CENDANT MORTGAGE CORPORATION No.: 2000-1033 vs, JOHN W. SHEAFFER SHIRLEY M. SHEAFFER SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.2) Plaintiff in the above action, by its attorney, Frank Federman, Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 501 STEELSTOWN ROAD, NEWVILLE, P A 17241: 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) 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) J ~ "'%0 . , CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAi'lD COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN W. SHEAFFER SHIRLEY M. SHEAFFER NO. 2000-1033 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 501 STEELSTOWN ROAD, NEWVILLE, P A 17241. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOHN W. SHEAFFER 501 STEELS TOWN ROAD NEWVILLE, PA 17241 SHIRLEY M. SHEAFFER 501 STEELS TOWN ROAD NEWVILLE, PA 17241 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~...... ~-""'~ -~ . ~,...._.. d .I","",~ - *' '" 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) REPUBLIC BANK D/B/A FLAGSHIP FUNDING 1400 66TH ST., N. RAI369 ST. PETERSBURG, FL 33710 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 501 STEELSTOWN ROAD NEWVILLE, PA 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties oflS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 1. 2001 DATE ~~ F~FEDE~,ESQUIRE Attorney for Plaintiff ~;i o ~ . - ~ z t:c "'3 'a" "'. a"~ ",g, C/> . " '" ~ "''' 3 ~ "0- o~ ~:a. .!!.,~ " ~ Z ~ 3 . o ~ '" g . :;E' 3~ ", "'0' g ~ ~. z . 0 "'3 ~a" ". o " ~ 0 - ~ 0" '"'r>(ii' "'0 n . . ~ - '" - ... - w N - - - o '" --.J '" '" 00 ,_. J'~:::.I I. ~_~4!.Q'JJl::::;.&nT::':;'; " '~.J""'-n t... "...~.,-:-~-~""'" ..--' ... /y...;...'...':,. 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I' '" ""..IliIIIf........."""~ aIlDil!ll;ll:im'~L,~,~ . .~"'"~, ~,"""" '~ '"..,;,.~" i .~ ,~-- ',"ii';'."" (") ~ "1J (l) mri-~ ;~~T' 21:"'" (n ~c:) :1> -.., Z~..I =u >'C Z =<! '. d' . -~ C) o " C:l rY1 C) , (..0 -n f~~ nl CJ ';~~ '=-1 )> -^~ -< ~ <:.n 01 ~ :;:1' t STATE OF PENNSYLVANIA, COUNTY Of CUMBERLAND } 55. Robert P Ziegler 1, ______________________________________________________________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sherifrs Deed in which ______n__n____ Cendant Mortgage Corp (FKA) PHH Mortgage Ser Corp . --_____~____________________________________________________________________________ ~thegrantee 5th the same having been sold to said grantee on the _______________n_________n______n____n_n__ day of December 2001 ________________________________________ A. Do, ; __no' under and by virtue of a wriL__________n_ 7th Execution 0 n__________________________________n___n___n ISSued on the _n____n__n_________n__n____n___ May 2001 , day of __________________________ Ao Do, ___n' out of the Court of Comman Pleas of said County as of Civil 2000 ____________________________n..__ ___ _______ ___ __ ______n_ ____n___________ n_____ Tenn, : . 1033 0 Cendant Mtg Corp (fka) PHH Mtg Ser Corp Number ______________, at the su.t of n______n_n_______n__n___________n_n______n_____________ John W Sheaffer & Shirley M ___________________________________against____________________________________________________ ~ 249 3090 duly recorded in Sherifrs Deed Book No. ___nn_____' Page ___n_______. IN TESTIMONY WHEIlEOF, I ha~unto set my hand and seal of said office this _LZ_____ day oL_ ~orpL_ Rec der of Deeds, Cumberland County. Cofarl!~I~, ~~1l2 My Commission E~pi'es t~e fust Monday . a . ,,-,," .~ ..~ ~ ~ I....... , ~'-b Cendants Mortgage Corporation, f/k/a PHH Mortgage Services Corporation VS John W. Sheaffer and Shirley M. Sheaffer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-1033 Civil Term Shannon Sunday, Deputy Sheriff, who being duly sworn according to law, states on May 25,2001 at 4:50 o'clock P.M., EDST, she served a true copy of the Real Estate Writ, Notice and Description in the above entitled action, upon one of the within named defendants, to wit: John W. Sheaffer, by making known unto Shirley Sheaffer at 54 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241, its contents and at the same time handing to her personally the said true and attested copies ofthe same. Shannon Sunday, Deputy Sheirff, who being duly sworn according to law, states on May 25,2001, at 4:50 o'clock P.M., EDST, she served a true copy of the Real Estate Writ, Notice and Description in the above entitled action, upon one of the within named defendants, to wit: Shirley M, Sheaffer, by making known unto Shirley Sheaffer at 54 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241, its contents and at the same time handing to her personally the said true and attested copies of the same. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states on July 1, 2001 at 2:48 o'clock P.M., EDST, he posted a copy ofthe Real Estate Writ, Notice, Poster and Description on the property of John W. Sheaffer and Shirley M. Sheaffer located at 501 Steelstown Road, Newville, Cumberland County, Pennsylvania 17241, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action by regular mail, to one of the within named defendants, to wit: Shirley M. Sheaffer, at her last known address of 501 Steelstown Road, Newville, PA 17241, This letter was mailed under the date of July 05, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action by regular mail, to one of the within named defendants, to wit: John W. Sheaffer, at his last known address of 501 Steelstown Road, Newville, PA 17241. This letter was mailed under the date ofJuly 05, 2001 and never retumed 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, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 5, 2001 at 10:00 o'clock A.M" EST. He sold the same for the sum of $ 1.00 to Attorney Frank Federman for Cendant Mortgage Corporation fi'k!a PHH Mortgage Services Corporation. It being the highest bid and best price received for the same, Cendant Mortgage Corporation fi'k!a PHH Mortgage Services Corporation of ,~!1i ............. . , , --' ll.l:l~ ~~illllb, 6000 Atrium Way, Mount Laurel, NJ 08054, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$I,104.74, it being costs. Sheriffs Costs: Docketing Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Out of County Dauphin County Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Poundage $30.00 15,00 15.00 30.00 10.00 .50 1.00 15.27 2.40 15.00 30.00 20.00 446.75 375.00 25.66 25.00 26.50 21.66 $1,104.74 Sworn and Subscribed to Before Me so~: ~ ~'1I_ :-,-~~ R. Thomas Kline, Sheriff This~Dayof JJ,,,~L. > 2001, AD. ~ofu~no:a n."Pn~. J/~ 'BY~6~~ Real state eputy ~o.ail euJu~ /.SO tk.. 3 '191.- ~ I jC/'1'fJ ,,,,,,,,,,, ~. " I , ~~ = ~~. ~-ii!,,;;,, , " , -~ " CENDANT MORTGAGE CORPORATION, FfKJA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN W. SHEAFFER SHIRLEY M. SHEAFFER NO. 2000-1033 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe forthe Writ of Execution was filed the Jollowing information concerning the real property located at 501 STEELSTOWN ROAD, NEWVILLE, P A 17241. L Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOHN W. SHEAFFER 50LSTEELSTOWN ROAD NEWVILLE, PA 17241 SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, PA 17241 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .J;..~~~' ^~"""-- ."~ . ~ . tit"", . . / f '"" 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) REPUBLIC BANK D/B/A FLAGSHIP FUNDING 1400 66TH ST., N. RA1369 ST. PETERSBURG, FL 33710 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 501 STEELS TOWN ROAD NEWVILLE, PA 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 1. 2001 DATE ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - '~ "-"''f:!; '. J' CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 2000-1033 v, JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant(s). May 1, 2001 TO: JOHN W. SHEAFFER SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, P A 17241 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBT AINEP WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 501 STEELSTOWN ROAD. NEWVILLE. P A 17241, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 5. 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION. F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property willi be relisted for the December 5.2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late chargl~s, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ~~~ _ M _ '- .1 l' liRill' '. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE, 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 (2 I 5) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sak This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 "-~ - ~'IiII_ ililti' \ , . DESCRIPTION .' ALL THAT CERTAIN tract or parcel of land together with the improvements thereon constructl~d or erected situate in North Newton Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey dated August 21, 1997, by Eric L. Diffenbaugh, professional land surveyor, as follows, to wit: BEGINNING at a point at the centerline of SR 4006 (Steelstown Road) in an existing fifteen (15) foot gravel fannlane at lands now or formerly of Robert N. and Joanne M. Zimmerman; thence along I ds now or formerly of Robert N. and Joanne M. Zimmerman, North eight (08) degrees twen -nine (29) minutes twenty (20) seconds East, a distance of two hundred thirteen and fifty- sev hundredths (213.57) feet to a point at the eastern edge of said fifteen (15) foot gravel fane; thence continuing along lands now or formerly of Robert N. and Joanne M. Zimmerman, orth eighty-seven (87) degrees forty-seven (47) minutes thirty-one (31) seconds East, a distance of ee hundred ninety-one and sixty-one hundredths (391.61) feet to a point at lands now or formerly of Chester L. Burkett; thence along said lands now or formerly of Chester L.Burkett, South eight (08) degrees eight (08) minutes thirty-five (35) seconds West, a distance of two hundred fifty-five and seventy-one hundredths (255.71) feet to a point at centerline of aforementioned SR 4006 (Steelstown Road); thence along said centerline, North eighty-eight (88) degrees one (01) minute fifteen (15) seconds West, a distance of one hundred thirty-five and seventy-seven (135.77) feet to a point; thence along same, North eighty-eight (88) degrees zero (00) minutes twenty-eight (28) seconds West, a distance of two hundred five and thirty-five hundredths (205.35) feet to a point; thence remaining in the bed of the said SR 4006 Steelstown Road, North eight (08) degrees fifty-one (51) minutes seven (17) seconds East, a distance of four and sixty-seven hundredths (4.67) feet to a point; thence along same, North seventy-seven (77) degrees twenty-four (24) minutes twenty-three (23) seconds West, a distance of forty-seven and fifty-seven hundredths (47.57) feet to the point and place of BEGINNING. CONTAINING 2 Acres, 100 Perches, more or less. TAX PARCEL #30-07-0485-027 RECORD OWNER // TITLE TO SAID PREMISES IS VESTED IN John W. Sheaffer~Shirley M. Sheaffer, husband and wife, by Deed from Ray A. Halteman and Linda K. Halteman, husband and wife, dated 8/28/97, recorded 9/2/97, in Deed Book 163, Page 841. .~. ~_J. ~ "..." , . -...~: . . ., ;,' ! ;/1 '''1';'':: wRniOll1;EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-1033 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF ",,...,'. CUMBERLAND COUNTY ..,:',. To satisfy the debt, interest and costs due _~endar:t Mortgage Corp., f jkja PHH Mo.~t';age Services Corp. PLAINTIFF(S) fmm John W. and Shirley M. Sheaffer, 501 Steelstown Rd., Newville PA 17241. DEFENDANT(S) Real estate located (1) You are directed to levy upon the property of fhe defendant(s) and to sell at 501 Steelstown Road, Newville PA 17241 (See attached legal description. ) (2) You are also directed to attach the property 0\ the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows and to notify fhe garnishee(s) that: (a) an aflachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt fa 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 tt!e defendant(s) npt levied upon an subject to attaphment is found in the possession of anyone Of her than a named garnishee, You are directed to notify him/her that he/she has been<ldded as 'a g'arnishee and is enjoined as abDve stated. $3,004.80 Due Prothy Other Costs $.50 $1.00 Amount Due $114,232.74 ($18.78 per diem) Interest 1ng/Ol - 9/5/01 . LL. Atty's Comm Atty Paid Plaintiff Paid % $124.68 Date: May 1, 2001 CURTIS R. LONG REOUESTING PARTY: ~. . ~_ ;1"};:=;" Deputy Name Frank Federman, Esq. O P C ter @ Suburban Station Address: ne enn en Philadelphia PA 19106 Attorney for: Plaintiff Telephone (215) 5637000 Supreme Court ID No. 12248 ~~\_r.w"="""'mI ,- " - 1~-iIl!i!!~'~": ~..M~>>l:'~~~i~~[~--"u'~"""" ",', i:~",","~ tl!iiililHllU:l ~"~ ~.~ "'"'>~~~" . . ' ,. ~ , ~ " REAL ES1":TE Si\LE Nu~., II . i .;11 ftl~ 'f, Jot::> J the snerift levied upon the oetenoali., Interest In the real property ~ituated in f/ I5l1:lt- (j~ ~ (lumberland County, Pa., known and numbered as: 5DI.Jilfl. fl ~1:1JW?t. f.d ~.f.MJvi.M..e and more fully described on Exhibit ,. A" tiled with this writ and by thls reference Incorporated taerein. ., ~1,~oOI 8YJt~~ Y\H'1I\1)St{.~3d -; -1 ,~- ~ .' "', ',', ,) \G, I\d ('Z ~ ~ ~~~ ", -;.. :'ayHl~ Ul\(\V. c' ',-3cM;\O Hlll:!\I'> ,ID _0 III "'='-~- ~~~~Tf~W,1J ,.' .~':"" .', 'Civlftenii .', ::=:.~. : ~:~~~~/~:~HH . - MortgaSi ServIces , COrporation '~~_~~~-~::.~W~~arter. ~r~, f~,.,...tthlrIey M. Sheaffer ~~l;~:o~~e;r'an '" ~k"'l!_f'L' " ..... ,.. ,',,' '1 _ .: r - I ~ :~T-ciRT.~1N (rXt:;.pa~~1 Oflf;~d '. . .Iler WIU! W..: imprm'cments thereon ~~d. Of C[t..'<;too"StlU.Jtc,_in N9rtI1 l\cwton ~'1'(iSumbcfJ;ind Counl~! Penns~lvanja, - . . Tarr~: bmmd~d and dc~cribcd in ~c.~'jth a )UfVC:)' dat<:d.Augurt_:l.1997. ~ET.::l: Dlffcnbaugh. prOrc~~ll)ilai land .' sun.t)or;a;;iollows;tov.it: . ~""NrnGal a POlllt a,1 the Cl:nt<.'rlinc of SR '4Q06 -(Skl:&tO"-""n~o.:.lm Ilea" 'cxi~tlng fifteen -~L .;.oot .gravel. -farml~nc. at Jamh no,,", or ~:~)' of - RollCrt K' - and Joanne M. ~IPIl,;i.JHo.\!~, thcl1!;~ ,along, lan,- (E now or form, crl,Y ~ K and JoAnne M. Zimmerman. North ~t .(08) degrccs twenty-nine (19) minllll.'~ :,~Il1}'-; Co) second!> Ea~t. a di~a"re of tM ~':)ftllfdreLlhi.lRC.O--'lod....fi[Ly-.',C\'cn' b,lllldrcdl11~ '-K(; : ~ {Ired tb a,:point'!,' Ilk ~tcrn cd.&l-' of'~h] -i" ," rrn-:f@l_'sravl.:'- t:JrlJllanc; Lh~nl'"C _ contin.uing :;long land\ now or formerly of Rol:ll'rt ,':~N. ana Joanne M. Zirnm<?fJ1Kl[l, Norm dgfuy. _~A'- '(87) ~e<:5_ fofty-~e\ICn - (47) mInutes ' ~~.~-(31T~m-=E;I'i> a'ilTsifrite'orw~ J '.. _ n roo nlnt;.ty-one . Ji}d S!xly~on..;: 11llWo1\.Xrt'h\ ,ri3S1.6!) feet Lo a point a! lands nov.' or rorm.;:rry -,01 t.:be~[cr L. Bu.rk~u; .tlICllC';: along 'iiid fJ.nd~ - nOW -or fomierfy of Ch..:,l<.:r L. Burku. Slluth '~_lOS) dq;r~<.:s dghftOH) minUl.;:~.thiny.Ii\<.: "=t;-J5f--!,l.'Cond\ ""hI, a 'uhtann: or two hundn:..l ; fifi}'.fhe <l~d se\'ent)~on<? hundredths (::5Pl 1 = fci;J.1o a point at centerline of afor~mentioned SR .4006--\S1.:chtown Road); thellce along l>aiJ ~inc,Northeil!.hLy-cight{8l':)d.;:srcesone ~...1PlJ minUl1.' fiftel.'li (15) Scc.6iiih West, a dhtance "C.OL one. .hundred thirty-fiw and se\'cnfi~sc\'en "=TIJ5:77) feet IOoa point: thenCt' along~. North ~-CfJ!ht~--eight IllS) ckgree~ zero (00) minut\.-.... ~jwen~ght QS) seconds Wl~t. a di~tancc of tv. 0 _nu.iifrca-mCand thirty-li\t: hundredths (105.35) :.~ poiilt: !hence' retnaiillng. in the bed orITl<)' ~~It:.CbjPWT! Road, North eight (Ol':) ~~s fifi)'-one (~T) minutc~ sCvCTftu:::n _(17) ~<bt,--<Ldistan~_offolir anJ~mY-~'\'l'n ~,. '.rtb~--1.t~7)ftXt to a ~i~t~ t~dlCcaTi'lng.~ . _' Noon St:\'enty-'>C\'\,'n r:rrJ degrees.twen\y. _ t:~~cs tWttiry~lhr~e C2Jl si."conds }:.~sTahce of (ortY-Sl'\'l::n and rift~"st:\'en ~--hundrcJlh~ P7.57) fQ:t to Ilk: pilin! and rl~ce or'- __Rffi]NNTNG. :.'1Xlt'tiAlt-.'JKG 2 r\crCS. ]0(} P~r;;hl:~. mure ("IT "'.lc~s. . ~ I H30~07--dl..~5-0!7,' ~- O\\~'ER: TfiiL' 10 Saki I"r\'ml~';~ i, ~ es ed in .John W. SheaffeT and Shirk)' M. ~ ~inu<;ffiiiiG':lOd ll.ife:bynu:JfromRay X. - ~,~,.__~ 3!1d.Lin,da--K: f!al,tcman. ,",U,',"', .and, ,and _ ~'.da~'8t$m. r~corQcd ~f!m. m_~\.-XI ~o;l,P~~S~~ _" ________ ,.",.. '.~.- . """.,. r -rn~0"; , .....", \... 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 taws 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 Th e 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 publi:shed 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 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 S? Company and subsequently duly recorde,d in :::,:::::'" · 0.00' " '"' ''':'==O~~;,"M'~n~~'='='mm COpy thO 21 day 0 gust 2001 A.D. Notarial Seal S ALE #11 Tiny L. Ruuetl, NoIBIy Hanl~ul1l, DB"",*, MyCo/llllllUlCflElI/lItNJu TARY PUBLIC Mln1,*, I'tt1nsyrvllllla ASIOClaIlon Of NOlIIIM .. 'J My commiSSion expires une 6, 2002 . CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PAc 17013 Statement of Advertising Costs To THE PATRtOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 373.150 1.150 375.100 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... -~ ---~ ~ REAL ESTAW SALE NO. 11 Writ No. 2000-1033 Civil CendlIDt Mortgage Corporation. f/k/ a PHH Mortgage Services Corporation vs. John W. Sheaffer and Shirley M. Sheaffer Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract or par- cel of land together with the im- provements thereon constructed or erected situate in North Newton Township. Cumberland County, Pennsylvania, more particularly bounded and described in accor- dance with a survey dated August 21, 1997. by Eric L. Diffenbaugh. professional land surveyor. as fol- lows. to wit: BEGINNING at a point at the centerline of SR 4006 (Steelstown Road) in an existing fIfteen (15) foot gravel f<M111lane at lands now or for- merly of Robert N. and Joanne M. Zimmerman; thence along lands now or formerly of Robert N. and Joanne M. Zinnnerman. North eight (08) de- grees twenty-nine (29) minutes twenty (20) seconds East. a distance of two htllldred thirleen and fifty- '. , .~ , _,','-",i'_'-',,,c~,..,,,c;,,,='<'<""'~""__'_ seve" bl1J1m<lredths (213.S7Jfeet" to , a p<>l'Ilt at the eas_et1geof said fifteen (15) foot gravel farmlane; thence continuing along lands now or formerly of Robert N. and Joanne M, Zimmerman. North eighty-seven (87) degrees forty-seven (47) min- , utes thirty-one (31) seconds East a : distance of three hundred ninety-- one and sixty-one hundredths (391- .61) feet to a point at lands now or i fonnerly_ of Chester L. Burkett; thence along said lands now or formerly of Chester L. Burkett. South eight (08) degrees eight (08) minutes thlriy- five (35) seconds West. a distance of two hundred fifty-five and sev- enty-one hundredths (255.71) feet to a point at centerline of aforemen~ tioned SR 4006 (Steelstown Road): thence along said centerline, North eighty-eight (88) degrees one 10 I) minute fifteen (I5) seconds West, a distance of one hundred thirty-five and seventy-seven (135,77) feet to a point; thence along same. North eighty-eight (88) degrees zero (00) minutes twenty-eight (28) seconds West. a distance of two hundred five and thirty-five hundredths [205.35) feet to a point; thence remaining in the bed of the said SR 4006 Steels- town Road.; North eight (08) degrees I fifty-one (51) minutes seven (17) sec- onds East. a distance of four and sixty-seven hundredths (4.67) feet to a point; thence along same. North seventy-seVen (77) degrees twenty- four (24) minutes twenty-three (23) seconds West, a distance of forty- seven and fifty-seven hundredths(47.57) feet to the point and place of BEGINNING. CONTAfNING 2 Acres, 100 Perches. more or less. TAX PARCEL #30-07-0485-027. RECORD OWNER TITLE TO SAlD PREMISES IS VESTED IN John W. Sheaffer and Shirley M. Sheaffer, husband and wife. by Deed from Ray A Halteman and Linda K. Halteman. husband and wife, dated 8/28/97, recorded ~~i~97. in Deed Book 163, Page ,-=,. "JL;;~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Joumal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, V1Z: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Joumal, 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. ~/~ "' Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 , NOTARIAl.' LOIS E. SNYDER, NoIaryPublIc CatI/tl8Bo1v. Cumberland County My CommiII8Ion ~ Man:h 5, 2005 -'. ," L_ " u. .. I PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION, F/K1A PHH MORTGAGE SERVICES CORPORATION Plaintiff, v. No. 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $114.232.74 j Interest from 03/29/01 TO 09/05/01 (per diem - $18.78) $3.004.80 and Costs TOTAL $117.237.54 ~~ F FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. iJ; en ?: 4: N Z ,.-- .. ::::>.~ we! - ()-- ~~-~~j ."...... C)~ .,,,,- ~~~:~ n... o?:i -<-......... r- 3~ =:l~-:-.; \ ccz >- UluJ c.o:~ .a: OJ D- c_- :.c ~ ~" l.L ::::> 0 0 (.) > >Tj "ll l"l l"l... ~. l"'l ~Z Po - ~ ~Z ~.., g.- (I) P.- ~t::I (I) if l"'l= '" >~ ~ ~ l"l ~~ "'" 00 "ll "ll""l Z(Il.... ~l"'l =.... =' ~g @ l"'lOO ""'0 l"l=3: ~-= c::> "'l ~~ '0 ~o 03:0 t::I~ .., ~ ~z ~ ~ ~o~ l"l""l ffi (I) I:""t-l~ (I) ~~ .... '< ~~ 00 '" O~~ 8 I:"" t-l, 8' 3:' -< ~"'l l"'lt"'oo .00 ~~~ Zl"l N ~ .... 00= ?' 0 . ~ = 't:I Sl ""I ""10 0 cr' "llol"'l a ~ 0 =l"'l .~ 3: 0 (I) >~> l"'ll;; "",C'll"l > '" ~ :;J a O''''l 0l"'l0 "ll~ ~ (I) ~. ~ l"'l >"'l Z~~ :;J i:il :;Jl"'l l"'lo (I) N:;cl"'l l~ l"'l~ ~O Zz p.. ;!:oi:':i Z"ll e; l"l i:':i ~~ 001:"" ~ ~tll ""I "'" l"'l"", <> ZUlOO 0 000 ~~ l"'lo= Z ~ ~~~ ""'''''1 > t=l':ll"'l I:""tll~ l"'l~3: . .." ~ooo ...~~ -!Z> ~il''''l "'O"'l ~~ .. , "" ~", "","l-' . , .,"' " ~'" , ~_. "r <_, _ 7~-r-', ".", V'-~"'f""'~~IIf!l'ij,~"~~ ."lIJll!l!!I!l!IiII.....,.,~ ~I -~... ~.- T _o<l;' .. DESCRIPTION ALL THAT CERTAIN tract or parcel of land together with the improvements thereon constructed or erected situate in North Newton Township, Cumberland County, Pennsylvania, more particularIy bounded and described in accordance with a survey dated August 21, 1997, by Eric L. Diffenbaugh, professional land surveyor, as follows, to wit; BEGINNING at a point at the centerline of SR 4006 (Steelstown Road) in an existing fifteen (15) foot gravel farmlane at lands now or formerly of Robert N. and Joanne M. Zimmerman; thence along I ds now or formerly of Robert N. and Joanne M. Zimmerman, North eight (08) degrees twent -nine (29) minutes twenty (20) seconds East, a distance of two hundred thirteen and fifty- sev hundredths (213.57) feet to a point at the eastern edge of said fifteen (15) foot gravel fa lane; thence continuing along lands now or formerly of Robert N. and Joanne M. Zimmerman, orth eighty-seven (87) degrees forty-seven (47) minutes thirty-one (31) seconds East, a distance of ee hundred ninety-one and sixty-one hundredths (391.61) feet to a point at lands now or formerly of Chester L.Burkett; thence along said lands now or formerly of Chester L. Burkett, South eight (08) degrees eight (08) minutes thirty-five (35) seconds West, a distance of two hundred fifty-five and seventy-one hundredths (255.71) feet to a point at centerline of aforementioned SR 4006 (Steelstown Road); thence along said centerline, North eighty-eight (88) degrees one (01) minute fifteen (15) seconds West, a distance of one hundred thirty-five and seventy-seven (135.77) feet to a point; thence along same, North eighty-eight (88) degrees zero (00) minutes twenty-eight (28) seconds West, a distance of two hundred five and thirty-five hundredths (205.35) feet to a point; thence remaining in the bed of the said SR 4006 Steelstown Road, North eight (08) degrees fifty-one (51) minutes seven (17) seconds East, a distance of four and sixty-seven hundredths (4,67) feet to a point; thence along same, North seventy-seven (77) degrees twenty-four (24) minutes twenty-three (23) seconds West, a distance of forty-seven and fifty-seven hundredths (47.57) feet to the point and place of BEGINNING. CONTAINING 2 Acres, 100 Perches, more or less. TAX PARCEL #30-07-0485-027 RECORD OWNER /' TITLE TO SAID PREMISES IS VESTED IN John W. Sheaffer~Shirley M. Sheaffer, husband and wife, by Deed from Ray A. Halteman and Linda K. Halteman, husband and wife, dated 8/28/97, recorded 9/2/97, in Deed Book 163, Page 841. "";"~~illI-'-' ihii.~iMl '- - ' ~i~~~i~ J;1ll'!li.iilUtIitll ' - . 1"',: :!ii@lliIllIlI,~ ('- ...--...... \' c:_..0 i s;:; " I~ I r--- I I \:~ . ~ I I I ........1 :{I J {~ ",,~\' R: ~> -.... - - ~ - Jv ~ t ~ u- ~ ~~ '" '" ~1 - '- \.j ~~ ~ ' I' V''' ....iiUllIIIIw ~ ~ ~,:i,,',' ~\ ~ % ~' '-.. ~~ 0\ SJ'\ ':. ~ ^~ " ~' o C ~r -0"" nl ("E~ _...,r, , ~::r,' 05~" -<"'~' f;20 ~> zO ..-0 )>c: Z ::;;! """ ~ ~" '. .. VfJ\) '".--" C:) o -('1 -- ~1. ~,. -< I -.J -n r-= -~~ cjm .O-j ?P Co< :~ -"'" "v <:)) - --I < I ~ ~ CENDANT MORTGAGE CORPORATION, F/KIA PHH , MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOHN W. SHEAFFER SHIRLEY M. SHEAFFER NO. 2000-1033 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION. F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attomey, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 501 STEELSTOWN ROAD. NEWVILLE. P A 17241. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOHN W. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, PA 17241 SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, PA 17241 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .ia[ .J.' - ~" . " - ~ik,; 1, , , j Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) , REPUBLIC BANK D/B/A FLAGSHIP FUNDING 1400 66TH ST., N. RA1369 ST. PETERSBURG, FL 33710 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knQwledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 501 STEELSTOWN ROAD NEWVILLE, P A 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Mav L 2001 DATE ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff lIi_~il1lI~m1iI;ti,iliiiilillll~iili]"fuill~~U@!J.;~~~~1!!1iiIIlIIiI ~ ~. .. ljjilll~~_--~'-~'. ~""""~~" ~~j ,",,- ~~H j '--,.1 , , (') 0 0 C -n :?: X -JOJ po " DJITt -< P z-e'l Ir:q __ .J-, . ZC: -t ',' C' (JJ <.-::;~ {),L, ~L ~, ~~'~ ~~ <:::~J -0 )::>C. -'"1" -~ -,~O z~ Or" --0 - :J>c.: .. ~ Z N ~ ":IJ CP -< . ... '--'^'"-~n J ~~~ FEDE~ANandPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION, F/KIA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION JOHN W. SHEAFFER SHIRLEY M. SHEAFFER NO. 2000-1033 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( X ) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unswom falsification to authorities. W FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - !iliMiliiliii~""" ~"~~~jl~J';M~m",;i;;lOO~~L"1'I:t..'ilJlll;~"iau;>"'''"''' Jl.. """""I<MI~~~ 'r.~__aU!LI "1iIiIi <.:L ~' 'iRSiil~ .............~ .. 0 C, 0 C <"" -n um :;;;; ~""3 OJn! z:;;. L~:X.l "",,' "T1r!.~ ZC I ::.39 (J)_,:' "-J -<:.? ~C) -r:, ~:::~C} -.";- -. j~" z<. ..,.. ;~:D pQ >-;7/,:-) L.- aiT' z s:;' :2 N (Xl :v -< ~~" ~- ...J-llWllIliI< - \tIr~", - , I ,. CENDANT MORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 2000-1033 v, JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Defendant(s). May I, 2001 TO: JOHN W. SHEAFFER SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, P A 17241 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 501 STEELSTOWN ROAD. NEWVILLE. PA 17241, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5. 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION.F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the December 5.2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late chargl:s, costs and reasonable attomey's fees due. To fmd out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. ...........,.""'" ~ - '0 - "- . '~'''-.Iill~< , , .. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. 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 Sheliff 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 within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the: Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act irtunediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT lfIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 11013 (717) 249-3166 (800) 990-9108 ,,,.. ~. -""" ~lilUj -~. r~ ,- ~- ~ ,:...' . ~ '-'IJ.. . N 1- ,. N-; I > DESCRIPTION ALL THAT CERTAIN tract or parcel of land together with the improvements thereon constructed or erected situate in North Newton Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey dated August 21, 1997, by Eric L. Diffenbaugh, professional land surveyor, as follows, to wit: BEGINNING at a point at the centerline of SR 4006 (Steelstown Road) in an existing fifteen (15) foot gravel farmlane at lands now or formerly of Robert N. and Joanne M. Zimmerman; thence along lands now or formerly of Robert N. and Joanne M. Zimmerman, North eight (08) degrees twen;l-nine (29) minutes twenty (20) seconds East, a distance of two hundred thirteen and fifty- ' sev n hundredths (213.57) feet to a point at the eastern edge of said fifteen (15) foot gravel fane; thence continuing along lands now or formerly of Robert N. and Joanne M. Zimmerman, orth eighty-seven (87) degrees forty-seven (47), minutes thirty cone (31) seconds East, a distance of ree hundred ninety-one and sLxty-one hundredths (391.61) feet toa point at lands now or formerly of Chester L. Burkett; thence along said lands now or formerly of Chester L. Burkett, South eight (08) degrees eight (08) minutes thirty-five (35) seconds West, a distance of two hundred fifty-five and seventy-one hundredths (255.71) feet to a point at centerline of aforementioned SR 4006 (Steelstown Road); thence along said centerline, North eighty-eight (88) degrees one (01) minute fifteen (15) seconds West, a distance of one hundred thirty-five and seventy-seven (135.77) feet to a point; thence along same, North eighty-eight (88) degrees zero (00) minutes twenty-eight (28) seconds West, a distance of two hundred five and thirty-five hundredths (205.35) feet to a point; thence remaining in the bed of the said SR 4006 Steelstown Road, North eight (08) degrees fifty-one (51) minutes seven (17) seconds East, a distance of four and sixty-seven hundredths (4.67) feet to a point; thence along same, North seventy-seven (77) degrees twenty-four (24) minutes twenty-three (23) seconds West, a distance of forty-seven and fifty-seven hundredths (47.57) feet to the point and place of BEGINNING. CONTAINING 2 Acres, 100 Perches, more or less. TAX PARCEL #30-07-0485-027 RECORD OWNER / TITLE TO SAID PREMISES IS VESTED IN John W. Sheaffer ~Shirley M. Sheaffer, husband and wife, by Deed from Ray A. Halteman and Linda K. Halteman, husband and wife, dated 8/28/97, recorded 9/2/97, in Deed Book 163, Page 841. litSaooiUl.;i.ii$.1 IIlI ,,-';'1....,Il<U~l:!!lIt:i5l:dllWi*:ll.~.~~-~ill~,~.'m.,J>J.;;J.,"liili~:j!- 1.-,*.: ,~ ~~~- ..-.;..... " "' C) c: ? -v CO rnfT) ~fI; S])'~~ r" roC: ~:--' c.......... ZLi --",0 )>c Z :< ~ ."1 , " t;) o -q :::.:1 ::Jl: )00, -< ":~?] ~::~ ;:..q ~,:j(:S ';'-'010, gq :::t> :::v -< I -.r -n N Co < . " .,"-; . .__'-:.ic ' .,. ~ c . , ~ ,-~ ,~- t:,-~; CEDANT MORTGAGE CORPORATION, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JOHN W. SHEAFFER SIDRLEY M. SHEAFFER: Defendants NO. 00-1033 CIVIL TERM ORDER OF COURT AND NOW, this 26th day ofJune, 2001, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff may obtain service of the Notice of Sale on the above-captioned Defendants, John W. Sheaffer and Shirley M. Sheaffer, by (I) mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendants' last known address and the mortgaged premises, (2) mailing a true and correct copy of the Notice by certified mail and regular mail to Defendants at 54 Mountain View Terrace, Newville, Pennsylvania, 17241, (3) publication once in the Cumberland Law Journal and in a newspaper of gen~ral circulation in Cumberland County, Pennsylvania, and (4) posting upon the mortgaged premises. BY THE COURT, Frank Federman, Esq. One Penn Center at Suburban, Station Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff .~ ~ ("..2.'7-0/ ~" f'~j!_00-'Oi':F)CE OF T fiY""D\OTf',RY 0, '1"'12''- (JJdi~_Q D;,~ 0. Ch i li (... .J...... (~U' cc',', ", "~U"fTV V fVJc;Ci\Lj"., I....-U i ~ I ! PENI'iSYl.W\NiA . , ~~-~ ~'''~~'_n, , .~ ~~ ~. - .,.,~..". ,J!!IIl!I!!I"!'''' ,~ , - _.l" .,', .l, ~~ .. ~I!:l[' 'J FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CNIL DNISION CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY vs. No.: 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER ORDER AND NOW, this _ day of ,2001, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), JOHN W. SHEAFFER and SHIRLEY M. SHEAFFER, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: ? J, J, ."",,,,,,,..1" ...~~ :, . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY vs. No.: 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service ofthe Notice of Sale by certified mail and regular mail to Defendant's last known address. 1--MMk ~J,6'AAM(}M. FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF ..'.'$1 " ~~~--~. i~ . ~-:!l-- ~{p. AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION N 0.2000-1 033 Type of Action - Notice of Sheriff's Sale DEFENDANT(S) JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Sale Date: SEPTEMBER 5, 2001 SERVE JOHN W. SHEAFFER AT 501 STEELS'UOWN ROAD NEWVILLE, PA 17241 SERVED Served and made known to , Defendant, on the day of ,200_, , o'clock _,m., at , Commonwealth at of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Cterk ofptace oflodging in which Defendant(s) reside(s). Agent Or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age_ Height _ Weight _ Race Sex Other I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and Sl'i1;.:bed be~s day of ,200_. Notary: eXHIBIT A By: NOT SERVED Oll the 9fL day of fJld-j Unknown , 200,1, at 8 ..;!.- 0 'clock ~.m, Defendant NOT FOUND because: ~ Vacant f I e~~K'C- .\... V K tv e ~ <?>tf, !vIoved No Answer Other: Notarial Seal Stacy L. Heefner, Notary Public Sworn tu and SUESC bed ~hambefSbUrg Boro~ Franklin County Q beth. d Y Commission ~xp"es Au 5,2 2 {2;t; el()reme IS ay '. ~ of --..ll1.v{ , 200 L Member, pennSYBIVyan.'a Asso tl f otaries vI Notary: CR. ~ J Attorne f, P a ( 0 " Frank Feder an, Esquire - I,D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, P A 19103 (215) 563-7000 - ",,~ "= - "-oj " -'10 'I", AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, FIKJA PHH MORTGAGE SERVICES CORPORATION N 0.2000-1033 Type of Action - Notice of Sheriff's Sale DEFENDANT(S) JOHN W. SHEAFFER SHIRLEY M. SHEAFFER Sale Date: SEPTEMBER 5, 2001 SERVE SHIRLEY M. SHEAFFER AT 501 STEELSTOWN ROAD NEWVILLE, PA 17241 SERVED Served and made known to . Defendant, on the day of ,200~ , o'clock _,m., at . Commonwealth at of PellnSytvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant( s) reside( s). Agent or person in charge ofDefendant(s!,s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age_ Height _ Weight _ Race Sex Other !, , a competent adult, being duly sworn according to law, depose and state that! personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of___,200_. Notary: EXHIBIT A By: q J-~ .', #\&-1 On the -"-f-"-- day of I NOT SERVED .200-1., at 9'.'f!O o'clock-f.m., Defendant NOT FOUND because: No Answer L Vacant t:f "-,-1,,."", L ~" -R. ~ ~ ~ C7~:. Moved Unknown Notarial Seal Stacy L Heefner, Notary Public Chambersburg Bora, Franklin County Sworn to and sUl1tbed My Commission Expires Aug. 5, 2002 , 'g before e this day Member, MnsY/VlIn/BASs 10 'Notaries ~~_ of ,zooL ~ Notary: .' f'f~' By: ' Attorne . 0 1 Frank Fede n, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Other: , , ,. ,-' .,;", . I., -~ ""<j?; j i\l\!) PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 2000-1033 Attorney Firm: TRACK STARS Case Number: Subject: JOHN W & SHIRLEY SHEAFFER A. KA: None Last Known Address: 501 STEELSTOWN ROAD NEWVILLE, PA 17241 Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says; 1. I am employed in the capacity of President for Players National Locator. 2, On 06/11/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: 175-40-9597 202-42-5243 B. EMPLOYMENT SEARCH: Unable to locate a good employer for John and Shirley. C. INQUIRY OF CREDITORS: The creditors indicated that John and Shirley are living at 501 Steelstown RQad, Newville, Pa. 17241 with no valid hQme phone number. One creditor stated JQhn is using an address of 54 MQuntain View Terrace, Newville, PA 17241. EXH\B\T "BII I' I Ii ! Ii Ii I' " i p t I: " ii ,'I INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The directQry assistance has no listing for John and Shirley Sheaffer. Contacted 717-249-6266 and spoke with a relative who confirmed John and Shirley Sheaffer are bQth living at the last knQwn address. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of June 7, 2001 the NatiQnal Change of Address (NCOA) has no change for JQhn and Shirley from last known address. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has JQhn and Shirley listed at last known address. OTHER INQUIRIES - A. DEATH RECORDS: As Qf June 7, 2001 the SQcial Security AdministratiQn has no death record Qn file for John Wand Shirley Sheaffer under their sQcial security numbers. , ,"", ,,-. " , ,.1,- B. PUBLIC LICENSES ( PILOT, REAL ESTATE, ETC. ): None Found C. COUNTY VOTER REGISTRATION; The Cumberland County Voters Registration Office has John and Shirley listed at last known address. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: John 03/49 Shirley 08/51 ~~'JO;~ARY~~;'EtAL~'~~~~'~l Kristine M SGOrt. Notary Pliblic J 81. LOlJlS,C,o"ur:,i,Y, ,;ta, it ',)1 M,' issouri My Com11i<J(,lc.n ['Xpi'82 91~12002 -......."P"'''''.."..~~,,^,"''.."/',.',...JJ._,--.,''',_.',rr~''''''~..''-,_ Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 EXHIBIT "B" l ""{(" FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY CENDANT MORTGAGE CORPORATION No,: 2000-1033 vs. JOHN W. SHEAFFER SHIRLEY M. SHEAFFER MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an , Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pac Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165,360 A.2d 603 (1976), An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the < ~. '!Iii;- whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service ofthe Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: CfA4hlk +akMlMA- FRANK FEDERMAN, ESQUIRE ATTORNEY FORPLAThITWF "-""'0 ,",1 VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pac C.S. Sec. 4904 relating to unsworn falsification to authorities. 1A/M1k ~ FRANK FEDE , ESQUIRE ATTORNEY FOR PLAlNTWF d,,",'""' ". --'="'1 FEDERMAN AND PHELAN By: FRAJ{KFEDERMAN,ESQlITRE IDENTIFICATION NO, 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY vs. No,: 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER CERTIFICATION OF SERVICE I, FRAJ{K FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on June 14,2001. JOHN W. SHEAFFER SHIRLEY M. SHEAFFER 501 STEELSTOWN ROAD NEWVILLE, P A 17241 1- ii/PHi( '1,Rdp~ FRAJ{K FEDERMAN, ESQlITRE Attorney for Plaintiff Date: June 14,2001 '-'-'-'"".",;-'." o C 5: -or:U ts:' ~t)- ]>,.-.., zV =L) orC Z; =< .".""-..2._'-..".-'-~~.hO;'." C') r'''' ~',,. 1") , ("1 ":::::1 -,'-, '-.' ~'.-;-:' ""' ',0 I ; ~,~;~ ~r~ :0 -< ",' , I '-~""l<i- ----.-- .---. ~ , . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUlRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. No.: 2000-1033 JOHN W. SHEAFFER SHIRLEY M. SHEAFFER AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to JOHN W. SHEAFFER and SHIRLEY M. SHEAFFER on 09/05/01 at 501 STEELS TOWN ROAD, NEWVILLE, P A 17241, in accordance with the Order of Court dated 06/26/01. I further certify that the mortgaged premises was posted by sheriff with the Notice of Sheriffs Sale on 08/11/01, in accordance with the Court's Order. The undersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. 9-;..~.II 9cJJ~A ~~"""', FRANK FEDERMAN, ESQUlRE Date: Seotember 6. 2001 . - . .' -~il%!ii,: l?a' CIJ:D::o " :D Ul 9 (') mm~ en m m 23' ::u :!!};l (} "n Z "" II~ CD c: ':!j~ 3 m c b" . i~ ::s. CD (/) m fll :D m !~~ II'" -. n 1 m ~ 1:1 ~~ - CD oti::Ofi~~ z -. ILl CD -. n ;l::;: ..a i~ a.. '9. 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'" '" c ~it .. - .. .... .. g ,., t'l ~ '" '"==~-" ..""""""',""..." , Law Offices FEDERMAN AND PHELAN, LLP Suite 1400 One Penn Center, at Suburban Station Philadelphia, PA 19103-1814 (215) 563-7000 Telecopier (215) 563-5534 Leo Magee Judgment Department Representing Lenders in Pennsylvania and New Jersey AUGUST 6, 2001 Via Federal Express fILE COpy William J. Mansfield, Inc. Legal Advertising Suite 507 985 Old Eagle School Road Wayne, PA 19087-1791 '606030747656 Re: CEDANT MORTGAGE CORPORATION vs. JOHN W. SHEAFFER and SHIRLEY SHEAFFER Dear Sir/Madam: Please publish the enclosed legal notice once in a newspaper of general circulation and once in the Cumberland Law Journal in Cumberland County. Also, if there is a specific paper in Cumberland County used for legal notices, please publish in that paper. Please note that publication must run no later than AUGUST 8, 2001. Please forward proof of publication and your invoice to my attention. Thank you for your attention to this matter. Very truly yours, Leo Magee for Federman and Phelan LEO 'j' Enclosure ' " ./ . William(~.J~t. Legal Advertising Suite 507 985 Old Eagle School Road Wayne, PA 19087-1791 .."'"~~ ..1.__- ~ ..~. _, ~ " ,~ --"""""'_lM",,' NOTICE'OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-1033 CIVIL TERM CEDANT MORTGAGE CORPORATION vs. JOHN W. SHEAFFER and SHIRLEY SHEAFFER NOTICE TO: JOHN and SHIRLEY SHEAFFER "NOTICE OF SHERIFF'S SALE OF REAL PROPERTY" TAKE NOTICE that the real estate located at 501 STEELS TOWN ROAD. NEWVILLE. PA 17241 is scheduled to be sold at Sheriffs Sale on SEPTEMBER 5. 2001 at 10:00 a.m., in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$1I4.232.74, obtained by CENDANT MORTGAGE CORPORATION, F/K/ A PHH MORTGAGE SERVICES CORPORATION (the mortgagee). Prop. Sit in N. Newton Township. Beg. At a pt in centerline of SR 4006 (Steelstown Rd.) Front: 183.34 ft. Depth: approx 236.97 ft. Back:391.61 ft. IRREG. SHAPED Being Premises: 501 STEELSTOWN ROAD Improvements consist of residential property. Sold as the property of JOHN W. SHEAFFER and SHIRLEY M. SHEAFFER TERMS OF SALE: The purchaser at sale must pay 10% of the amount of his /her bid on the day of sale; the remaining balance is to be paid no later than the Friday following the Sheriffs Sale. If complied with, a deed will be tendered by the Sheriff at the next available Court of Common Pleas for Cumberland County conveying to the purchaser all the right, title, interest and claim which the said defendant has in and to the said property at the time oflevying the same. If the above conditions are not complied with on the behalf of the purchaser, the property will again be offered for sale by the Sheriff within thirty days of the original sale. The said purchaser will be held liable for the deficiencies and additional cost of said sale. TAKE NOTICE that a Schedule of Distribution will be filed by the Sheriff on OCTOBER 5. 2001, distribution will be made in accordance with the schedule unless exceptions are filed. Frank Federman, Esquire Suite 1400, One Penn Center at Suburban Station Philadelphia, P A 19103 (215) 563-7000 Attorney for Plaintiff ,~""= . ~ ~-~~,<, I , AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, FIK/A PHH MORTGAGE SERVICES CORPORATION DEFENDANT(S) JOHN W. SHEAFFER SHIRLEY M. SHEAFFER No~OOO-I033 Type of Actio. . Notice of Sllerlff's Sale Sale Date: SEPTEMBER 5, 1001 SERVE JOHN W. SHEAFFER AT son S'tEELS'tOWN ROAD NEWVILLE. PA 1'7241 1ft""'I~"".' SERVED S....edlllldmadeknownto. '6~A1 _rl-it;-I4Ft=<:s=-~ . Defendant,oalhe II ~ day of A-Llh.<rT.2001, al 7: jf) . o'clock lPn.,.1 .ro (S'72%(S"J1lot,rnJ J(s~ N<.::>-W ilia 'L . Conunonweallh ofP_yl.lnla, in the maJUI.r describ.d bolow: Defadant penollAlIy serv.d. Adull family member WlIb whom Defendw(s) reside(s). llelallclllshlp 1. Adult in charse of Det'el>dant(s)'s residelwe who reNseclto give1llll\e or relationship, Mamcor/Clcrk of place o!lodging in which Deielldallt(.) rellido(I), Agant or peraoa in charse ofDefondam(s)'s of'lk. or usual p.... ofbuai4ess, 811 oflic.r of.aid Defondam(s)'s aompany. )( Other: p <J c-n,.'a) ~ptiOIl; Age_ Height_ WeIp_ Race_Sex_ Other 1. -J70k.2T A~, oA-SH . a competent adult, beU1i d1l1y IWom scaordiag to law. depolO and state that I peraoaallY~) I tnIe sod comat aopy of the Notice of Sheriff'. Sale ia the n:wmor IS sel forth herein, issued in the captioaed cue Oil tht date IISd at the sddrc1IlIldiaakod abov., Swam 10 ora:! Sllbscribed bef~it. ~I day , of ' lOO~. Nollt)';' <LI.laA(Q!(a:.Il>.~"^-' By: ~u~ NOT SERVED N TA LSEAl Susquehanna Ti:tl.' In Cou, nly ~mlea~q ___ ..::"':'~'!N . I1\t;i!OO4 . Otbor: .200-, at o'clock _,m, Defenda1lt NOT FOUND becauae: On AIlaw.r _ VIClDt S....m ID IDIl Sllbscribed btfore me lhi. _ day of . 200 _' NOCI:Y: By. AlterIaftt for I!lal.t:lff I'l'aBII. J'eG....... bqaln - LD. No. 1::48 0... Pd. C..ter SlIburbtm Sladoa, Sult, 1400 PlIlJadelpllll, PA 19103 (215) !63-1000 h.~:~ '" 0' ~1"\ _/11 - .' CEDANT MORTGAGE CORPORATION, Plaintiff IN THE COURT OF CO:MMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JOHN W. SHEAFFER SHIRLEY M. SHEAFFER: Defendants NO. 00-1033 CIVIL TERM ORDER OF COURT AND NOW, this 26th day ofJune, 2001, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court, it is ordered and directed that Plaintiff may obtain service of the Notice of Sale on the above-captioned Defendants, John W. Sheaffer and Shirley M. Sheaffer, by (I) mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendants' last known address and the mortgaged premises, (2) mailing a true and correct copy of the Notice by certified mail and regular mail to Defendants at S4 Mountain View Terrace, Newville, Pennsylvania, 17241, (3) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania, and (4) posting upon the mortgaged premises. BY THE COURT, ir kFederman, Esq. ne Penn Center at uburban Station Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff fRUE COpy FROM RECORD In j estimooy wooreof, I here unto set my hano ;,? the 5ef of said c~ at Carlisle. Pa. r hiS n r;::.y 01 .:lbb / . (iJ () :.t.. ~ , ,~:;;-- Prothonotary :if -~-' 4 ~'.-~ "~"",L'~'~~~il'illIii_ "'k.'. ~"---~,.'" ,., .. '" (") C, (") c: -/1 ;;:: 0') ;~q fD "Urn C"l film " Z::v -f']i'11 Zr;;: C> .:;t7C? 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