Loading...
HomeMy WebLinkAbout00-02612 , - _."I~ ~-"' I. _~v. ~ FEDERMAN AND PHELAN By: F~FEDE~N,ESQU]RE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FORPLAmTIFF COURT OF COMMON PLEAS CIVIL DIVISION NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 Plaintiff TERM NO, aJ-,)IR/;) ~ v, CUMBERLAND COUNTY GARY R. STEmOUR, SR. BEVERLY JEAN STEmOUR 4236 CARLISLE ROAD GARDNERS, PA 17324 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE ..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 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #: 5020046 -~--,~ . ~'--~- 1. Plaintiff is NORWEST BANK OF MINNESOTA, NA AS TRUSTEE 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 2, The name(s) and last known address(es) of the Defendant(s) are: GARY R. STEINOUR, SR. BEVERLY JEAN STEINOUR 4236 CARLISLE ROAD GARDNERS,PA 17324 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3, On 10/30/96 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNION HOME EQUITY BANK, NA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1350, Page 531. By Assignment of Mortgage dated 3/16/98 the mortgage was assigned to FIRST UNION NATIONAL BANK which Assignment is recorded in Assignment of Mortgage Book No. 574, Page 902. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 1/4/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A" - " :-j 6. The following amounts are due on the mortgage: Principal Balance Interest 12/4/99 through 4/1/00 (Per Diem $38.99) Attorney's Fees Cumulative Late Charges 10/30/96 to 4/1/00 Cost of Suit and Title Search Subtotal $124,325.11 4,639,81 4,000,00 392,08 550,00 133,907,00 Escrow Credit Deficit Subtotal 0.00 0.00 0,00 TOTAL $133,907.00 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000,00, 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P,S, S 1680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10, The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i,) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum ot' $133,907,00, together with interest from 4/1/00 at the rate of$38.99 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /~:r~ F~FEDE~,ESQUIRE Attorney for Plaintiff ~ " ~' Ill!' I!il;,,~ ,'MA~~3I-00 15,34 FROM,FUMC B+C SERVICING IDdil1S85280B1 PAGE 1/4 tI!IS1 ,ltTNloN F'ItItUnion MGttgogo COIIlOrolion ""stOlllca Bo:c_l Ralolgtl, NOM Carollllo27m.soo, 1100 COIJIOrate eon... Drive Ralolgh, North Carolna276llT.$06i ~J:~...<~ 7'.fi.~' "--_ ~d~-.<.-O 02/S 5'- 6.- ,!Jo.~~;t r ,.o4-er-, /",111",1"11".1,1,1,,111"111,,,11.,,11.,,1.1..1.1..,1,1,1 GARYSTElNOUR BEVERLY STEINOUR 4236 CARLISLE RD GARDNERS" PA 17324 ./ 0310812000 RE: FUMC Loan Numbor Property Address Original Lender 0000005020046 4236 CARLISLE aD GARDHERS,l'A 17324 ACT 91 N()TICE TAKE ACTION TO SAVE YOUR H,OME FROM FORECLOSURE ThiS is liD official notie~ that the mOIllla2e on Y,9III' home;. in default and the lender into:Dds to foreclose. .ific information about the nature of 1h.! delault is urovided i1l the Iluached llllacs. Tholo HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (Hl;MAP) may be able to helll to sa~ yout home. This Notice exnlains how the1>ID!!raDl works. To see ;fHEMAP can hem_ you IIl1lSt MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TInS NOTICE. Take tbis Notice with vou when YOU meet tilt Counseling, A&.~. The name. adc!Jess and phone number of CoUSUl1lC1' Cr~dit Counselinn Anencie.. Set\lin!! yOut COUllIII aeg listed at the end of this Notice. !fvou have any questions. yoU may call1he P"""gylyania HOlISin!! Finan....Sf. Ag,encvtoU free a~ 1.800-342-2397. (Persons with ~aired hearinl! can call (717) 780.1&69), This Notic~ conrains important legal infonnatilm. If you hav~ any questiollS, representatiyes at the Consumer Credit Counseling Agency may b,} able to help explain it. You may also WaIll to CO!ltact an 8l1OnIey in YOut area. The local bar association may b~ able to help you find a !awyao. EXHIBIT A - -,~ "''-' M~R~~1-00 15,34 FROM,FUMC B+C SERVICING ID,SIS85280SI PAGE 2/4 LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECfA SU DERECHO A CONTINUAR VIVIENDO EN SO CASA. SI NO COMPRENDE EL CONTENlDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTB LLAMANDO ESTA AGENCIA (PENNSYL V ANlA HOUSiNG llINANCIl AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARlUBA. PUEDBS SER.ELEGIBLEPARA UN PRESTAMO PORELPROGRAMA Ll.AMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAI. PUEDB SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HlPOTECA. HOMEOWNER'S EMERGENCY l\IIORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELlGmLE FOR F'INANCIAL ASSISTANC:E WHICH CAN SAVE YOURHOMl FROM FORECLOSURE AND HELP YOU MAKlE FUTURE MORTCACE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (tHE "ACT"), YOU MAY BE ELlGffiLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTAN'CES BEYOND YOUR CONTROL. . lP YOU HA VB A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE .PA YMENTS, AND . IF YOU MEET OTHER. ELlGffiILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STA l! OF J'ORECLOSVRE-Uufkc the Act, you /Illl entided to a temporal)' sray of . foreclosure on YOUllllortgallil far thirty (30) days ftOlP the date ot this Notice. During that tinu: you JlJUSt arrange &Jld attend a face-tO-face meeting with lII1C of the consumer credit counseling agencies lined at the . end. oftbis Nolice. THIS MEETING MUST OCCUR WITHIN :!l!!LNEXT nO} DAYS. IF YOU DO NOT APPLY FOR EMERG:aNCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR. MORTGAGE UP TO DATE_ TIn! PART OP THIS NOTICE CALLr"o "HOW TO CURE YOUR MORTGAOEDEf'AULT" EXPLAINS HOW TO BRiNG YOUR MORTGAGE UP TO DATI!. CONSUMER CREDIT COUNSELING AGENCIEli:Ifyou 1!lCe'l with one of the cOllSumer credil coUnseling agl!llCies Iistlld alme end oftlti$ notice the lender may NOT 1llke action againsl YOIl for thiI1y (30) days after die dale oflbis meeting. The 11aIIICS. addresses and teleohone numbers of desimned COMWDer credit COlll1Selin~ allencies for tlte county in which the IlfOllertV is located are Set fonh at the :all! of this Notice. It is ollly necessary to schedule one face-to-face nleeting. Advise your leader mn"..ual~ of your imentioDS. APPLICATION FOR MORTGAGE ASSISTANCJo~ Your llltll:lgage is in a default for the reasollS 51:! fDrtb !arer in litis Notice (see followiJ1g pages far specific U1fOll:llaIion about the lIalure ofy01ll' c1efalllt) If . you have tried &Jld are uDabie 10 resolve this pIob1= widl die lencieJ, you have die right to apply for fiJlancial assistance from the Homeowner's EnlCfllency Mortgag~ Assistance Progr8lll. To do so, you 11l\1~1 fill oUI, sign aJld file a co:mpJeled Homeowner's Eme1l;ency Assistuu:<! ProBJll'D APplication with one IJf the dcsigDated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counse1ing agencies haYil applications for the progxam &Jld they will a.o;sist you in submitting a complete applicalion to the P<:DnSylvania HOllSing Finance Agellcy. Y 0111' application MUST be filed or posmwked within thirty (30) days of your face-to-face meeting, VOlJ MuST J'JLE YOUR APPLICATION PROMPTLY, D' YOU FAlL TO DO SO OR It YOU DO NOT FOLLOW THE OTHER TIME pERIODS SET FORTH IN THIS LETl'Ell, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION roB MORTGAGE ASSISTANCE WlILL BE DENIED. AGENCY ACTION-Available fimds for omergency mongagcl'lSsisu.nce are very limited. 'J'!2eY wi!! be disb1lned by the Agency 1UIdm' the eligibilil)' critllria tstablished by the Act. The PeDIlSY1V1lD18.llous~tg Finance Agenq has sixI)' (60) days to make a decision after it n'ceives your application. During !bat time, no forilClosllte proceedings will bil pursued ag,ril!st you if you have ='1 the time reql1iremcnts sel fordl EXHIBIT A " - " ~ ~ ~ -~~~ . --......-. MA~~3i-00 15,34 FROM,FUMC B+C SERVICING lD,8188528081 PAGE 3/4 above. You will be notified directly by the Pennsylvania Housins FiI1lIIlce Agency of its decision on yuur application. N ...". roU.... CDRJWm.Y """""""" BY .... PILING OF A PIlT1TION IN l BANKRUPTCY. THE FOLLOWING PART OF THIS NOnCE IS FOR-INFORMATION PtllU'OSE ONLY AND SHOULD NOT BE CONSIDEREO AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Wed bankruptcy YOll can still apply for Emergency Mortgage ..usistal1ce.) ROW TO CURE YOUR MORTGAGE DEFA!l1! (Brin~ it up to date\. NATURE OF THE DEFAULT. The MOR.TGAGE debt held by the above lender on your property loc:ared at: 4%36 CARLISLE RD, GARDNERS, PA 17324 IS SERIOUSLY IN DEl'AULTbc:caUSf': A. YOU HA VB NOT MADE MONTHLY MOR.TGAGE PA YlIolENTS for the following months and tbe following _ are now past due: Start/End: 01/04/2000 thmagb 03/0412000 at SI22!)57 per 1llOlllb. Total, AmountofPelinquent Payments Ih~ La"" Charg.es Propeny inspections and NSF check charges, if allY 01her charges accrued, if any LESS: Suspense (llDllpplied fUIlds) TOTAL AMOUNT OF DELINQUENCY 3681.71 342.90 15.00 24.00 0.00 4078.61 B. YOU HA VB FAILED TO TAKE THE FOLLOWING ACnONS (Do not use unot annlicabL!), IW. HOW TO CQJtE THE DEFAULT.You may cure 1hedefaulIwithin'lHlRTY (30) DAYS De the date of this JIOtice BY PAYING TIm TOTAL AMOUNT PA5.'T DUE TO THE LENDER, WHICH IS $ 4070.61, , PLUS ANY MORTGAGB PAYMENTS AND LATE CHAlRGES WHICH BECOME DUE DURING nlE nnRTY (30) DAY PERIOD. P9vmM1ts must be made either bv cashier's cheek. certified check o:lr , money ome:r ntad.l navable and sent Ill' Firat UDion Mortgage C::Orporatitul, AnenrioD: PaYl1leDt Processiag, 1100 Corporate Center Drive, lllIeigb, NC 17/i07,.s06li. IF YOU DO NOT CURE 'fH1!: DEFAULT.lfyou do not CUIe tbe default within 11lIRTY (30) DA Yflof the elate of this NotiU, the 1ender intends to exercise iIs rillhts to IlCcelerate the mortBaIle debt. The ="". that the entire outsWlding ba\aneeoflhis debt will be considered due immediately and YOl1 rmy lose th~ chaDce to pay the mortgage ill lIIOllthIy installments. If full payment or'the totlllllll1Outn past clue is Dot made within THIRTY (30) DAYS. the lender also intends to instruct its attorney to stan legal action to foreclo9U1'e noon your nlOrte:Sfle orODenv. IF THE MORTGAGE IS FORECLOSED UPON-The mortgage property will be sold by the Sherifflll pay otTthe mongage debt. If the lender refers your ease to its am:>me~ but you CllI'e the delinquency before the lender begins legal proceedings against YOll, you will still be required to pay the reasonable altomey's fees that were actUally incllrred, up ro SSO.OO. Howev':!', iflega! prOceedings are smrrecl agaiast you, you will bave to pay all re1SOIIable attOtney's fees actUally incurred by the lender even if they exceed $50.00. Any attomey's fees will be added to the amount to the lender, which _y also include other reasonable cOSts. lfvou cure the default within the THIRTY (301 DAY Deriod. you will DOt be re<lUire<!.!!! nav attomcv's fees. OTHF.1l LENDER REMl:nIES. The lender may also sue you personally for the unpaid priDcipal balallCe and all other sums due 1IIlder the mortgage, RIGllT TO C~ THE DEFAULT PRIOR TO SHERIFF'S SALE-Uyou have ~t cured the.defaal1 within the THlR.TY (30) PAY period and foreclosure proceedings have begun, vou snll have me neht Ig cure the default and nreven! the ~Ie at IlIlV am" lit> to ,one hour bt~ore the Sheriff's Sale. You mav do !~ bv oarinl! the IOtal 2mDUI1t then oast due.. nlus ldIY lare or other chanes thend~e_ reasoDa~le attOmev's ~ and COSts CODIIec:red with the foreclosure sale aud anv other eosts connected Wlth the Sheriff's Sale as.. sPecified in writin2 bv the lender and bv D~OIminl! anv other re~trire:men!S under the mortn..e. Curing EXH\B\T A , ~AR-31-00 15.35 FROM.FUMC B+C SERVICING ID.SISS52S081 your default in the manner set fonh in this uoti"e willl'estore Y0111' tDOI1gage to the same position as ifYOll had never defaul1:l:d. EA;P1 ,rl!~ POSSmLE SREJl:TIi'li"S SALE DATE-It is estimsted that me earliest dare 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 oftha actual date of the Sheriff's SILie will be sent to you before the sale. Of COUIk, the amount needed to cure the default wiU im;t"ue the longer you wait. You may fmd out at PlY time exactly wbat the required paymenl or actilm will be by cOlltlcting the lender. HOW TO CONTACT THE LENDER: FlI'St Unio.n Mortgage Corporation Attention: Payment Processing 1100 Corporate Center Dri've Raleigh, NC 17607-5066 Phelae: (800) '54-1350 I'll][: (919) 85%-7420. Contact: Edward Eary EFFECT OF SHERIFF'S SALE- You should realize mat a Shedff's Sa1co will .md your oMle!'Ship of !he lDOrtgaged property and your risht TO occupy ii, Ifyoll continue to live in the property after dIe Sheriff's Sale, a lawsuit to remove you and your fiu'nishings and other belongings could be started by the lender at any titne. ASSUMPTION OF MORTGAGE -You__may or_.may DOt (CHECK ONE) sell or lr8DSler your home to a buyer or t'llIIlSferee wbo will assume the mortgagll debt. provided that all the OU~lllDdiDt& payments, charge l1l1d al1omey's fees and COSt are paid prior to or at dIe sale and that the other requifemen~ of the mortgage are satisfied. YOU MAY ALSO HAVE THl!: RIGHT: . TO SELL TIm PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR,1'Q BORROW MONEY FROM ANOmBR. LENDING INSTl11JTION TO PAY OFF TIllS DBBT. . TO HAVE TInS DEFAULT CURED BY ANY THIRD PARTY ACl1NG ON YOUR. BEHALF. . TO HAVE THE MORTGAGE RESTORED TO 1liE SAMI~ POSmON AS IF NO DEFAULT HAl> OCCllRRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU NOT HAVE lHIS RIGHT TO CURE YOUR. DEFAULT MORE THAN 'IHREE TIMES no/ ANY CALENDAR YEAR.) . TO ASSERT THE NONEXlSl'ENCE OF A DEFAULT IN.'-NY FORECLOSURE PROCEEDING OR. ANY OTHER. LAWSUIT INSTITUI1ID UNDER THE MORTGAGB DOCUMENTS. . TO ASSERT ANY 01HER DEFENSE YOU BEI.JEVE YOU MAY HAVE TO SUCH ACTION BY 1HE LENDER . TO SBEK PROTECTION UNDER mE FEDERAL BANKRUPTCY LAW. CONSUMER. CREDIT COUNSELING AGENCIFS SERVDo/O YOUR. COUNTY IS ATl'ACHEl) Seat by Regular Mall, Certificate of Mailing (PS Form 3877) Sincerely. ~ SaINf Edward Eary DeliI1quency Control Mortgage Loan Servicing Grollp BLPAOl EXHIBIT A -'~. ~'- PAGE 4/4 .' - "liIo:.Ilm, I I I Penn$ylvania Housing Finance Aaency Homeowner's Emergency Mortgage Assis~nce Program Consumer Credit Counseling Agencies (Rev. 5/99) L'~-ll1' ~" p-'~ !l'~-.ll1"'n Count: Commission 1:' C eo, 2138 Li . or ommW:Ur"j .~:ion (STEP) nl:Oln ScreAf" .:." P. 0, Box 1328 -- (WiS~OH)"3":;!lOr:. PA 17703 . .6-0587 F."'''{ (570) 322-2197 ~~C~ of ~or-~'1e3Ster:! PA Wur a51.tl Stree, (5-0=) 3 !lOr:. PA 17703 j 2:3-6627 FA.,,{ (570) 32:3-0626 CLINTON COtJ"NTY CCCS of Nor-..lleaster:! P~ 16~1 S Atherton 5, . Swte 100 Sl::1te Collegt!, PA 15801 (814) 2:l8-J568 F.~"{(814)2:38-3569 COLtJMBIA COU1'O'TY CCCS ofNort.'1eastem Pennsvlvania 1400 Allington E:teC"~t:ve Park Suite 1 Clarks Sl1IIlll1itt PA 18411 (570) 587.9163 or (800) 922.9537 F.~"{ (570) 587-913-119135 31 W. Market Sl::'ee' POB 1127 WUkes-Barre. P.'\. 18702 (570) 821-0837 or (800) 922.9537 F...."{ (570) 821-1785 COIllIlli."ion on Economics Opportunity of Lw:eme Count;, 153 Amber Lane W:Ukes-Barre, PA 18702 (570) 825-0510 or (800) 822-0359 F.~"{ (570) 829-156S-<:ALL BEFORE FA.'GNG (570) 455-1994 HAZELTON F.~"{ (570) 455-5631-CALL BEFORE FA.'GNG (570) 836-1090 TUNKH.....""'NOCK Booker T. Washington Center 1720 Holland St::'ee, Erie, P.'" 16503 (814) 453-5744 FA."{ (814) 453-5749 John F, K..nnedy Center, Inc. 2021 East 20th St"""t Erie, PA 16510 (814) 898-0400 FAJC(814) 898-1243 CCCS of Wester:! PellIlSvlv311ia, Inc. 2000 !.i.ng!estown Road - Rar.:-'.sburg, P.'\. 17102 (717) 5'U-1757 Urb311 League ot:Yletropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 F."'''{ (7l7) 234-9459 Communi<-! _~::ion Comm of the Capital Region 1514 Der:'" St::-eet Harrisbu~, P.'\. 17104 (717) 232.9757 F.~,,{(717) 234-2227 CRAWFORD COtJ1'o'TY Greater Erie Communi<-! Ac::ion Com:mit"..ee 18 West 9th Street Erie, PA 16501 (814) 459-1581 FAX (814) 456-0161 Shenango Valley Urb311 League, Inc 501 Indiana Avenue Farrell. PA16121 (412) 981-5310 CUMBERLA..'lD COUNTY Financial COWlSeling Sernc.s of Fr:mkiin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, P.'\. 17013 (717) 243-3818 FA."{ (717) 731-9589 Adams Coun!:'! Housing Aut.'1ori!:'! 139-143 Carlisle St ~ttysburg, PA 17325 (717) 334-1518 F.~"{ (717) 334-8326 E)CHfB1T A PENNSYI.VANIA BUI.LET1N, VOL 29. NO. 23, JUNE 50 1999 " I s.c. . f . ALL that certa~n tract of 1and with the improvements thereon erected, situate in DicKinson Township, Cumberland County, . Pennsylvania, bOQnded and descr~bed as follows: BEGINNING at an iron pin in Pennsylvania Highway'Route No. 34 leading from Gettysburg to Carlisle; thence alon9 the center of said Road, North 3 1/2 degrees East 404 feet'to an iron pin;' thence by land new or formerly of B&:!lnjamin starn..r, 'south. 86 1/2 degrees West 138 feet to stones at therailroadi thence along said railroad, South 17 degrees West 409 feet to stones],thence by land now or formerly of C. U. Shambaugh, North 69 degrees East 295 feet to the place of '131~G:r:NN:r:NG. CONTA:I:NING' '2. acres and 2 perches. more or ~ess, and being improved with a.dwe~linq hause~ EXCEPT~NG approxi~ate~y 1 acre more or less .conveyed to Hermie. Taylor. by deed dated July 24', 3.958 and recoroeo in Deed Book 18-0, page 318; AND ALSO EXCEPTING approximately .40 acres mo~a or 1ess conveyed unto Elizabeth Myers, ~y dead dated May 2, 1953 and recorded in Deed Book 1~-H, page 201; which ~oth conveyc:r'nces were IOrroneous~y o:m..it:.tec3 from prior deed.s of oonveyances. :I:T BEING the same tract of 1ano which :r:ra K. Mentzer ano Faye G. Mentzer, his wife, by deed dated Apr.i1 17" 1982 "nd recorded in the Office of the Recorder or'Deeds 'of Cumberland County, Pennsylvania, in Deed Book. 29-T, pag'e 139, ,g'rantea and I;onveyed 'l).ntC"::l ne.ver~y- Jean AU9h1nbaugh, who now 'by '1narriaqe is j 0 i.ned by her fLUS band Gary n. Ste inou1.~ I Sr ~, Grantors Herein ~ AND the :::;,a i.d grantors herebY cove.nant and agree that 'they and each of them will wa~rant specia11y ~he property hereby conveyed. PREMISES: 4236 CARLISLE ROAD , . VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, 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. DATE: f/-;! Z& I {lJ ?~?~ J !~~I\i&lIIIfilIillOO~.'~iIIlMIlril~~lUi\lIlt!l~;i;!Ii~il""_,,,,,,,O'~'I'~"ci,M.01Wifil;!J:~'i>Ii ,~ l~ ~"J ~~ ~~ --- ~M ~~" ~<.'_~M_ "'l-,,__~_,_~,,~.1~ -~-,,~,,", -" - , ~,~- 'lfi;t~--~' . " o s~ -",;...'- i~~r .- !;.:~- ('0 )'-.- ~;:':~~::' " :::,; '-I -< S;-' "-.! '-J - . . ~ ~~) ,,-,' 7''1;0, --") ~- ,"\.) (:::, :2J \ '-,; SHERIFF'S RETURN - REGULAR CASE NO: 2000-02612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK OF MINNESOTA VS STEINOUR GARY R SR ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR GARY R SR the DEFENDANT , at 0013:03 HOURS, on the 3rd day of May , 2000 at 4236 CARLISLE ROAD GARDNERS, PA 17324 by handing to BEVERLY STEINOUR, (WIFE) 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 18.00 6.82 .00 10.00 .00 34.82 So ;;:M:-~~{ R. Thomas Kline me this ~ day of 05/04/2000 FEDE~ & ::~~ i'~~~. J~ ~~ Dep Sheriff Sworn and Subscribed to before '1k7:4~ A.D. i 'J;L- Q. 7J,wh / .~ thonotary I, ~~ ~ l . SHERIFF'S RETURN - REGULAR CASE NO: 2000-02612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORWEST BANK OF MINNESOTA VS STEINOUR GARY R SR ET AL CPL. TIMOTHY REITZ , 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 STEINOUR BEVERLY JEAN the DEFENDANT , at 0013:03 HOURS, on the 3rd day of May , 2000 at 4236 CARLISLE ROAD GARDNERS, PA 17324 by handing to BEVERLY STEINOUR a true and attested copy of COMPLAINT - MORT FORE together with NOITCE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Aft idavi t Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: r~~~t:~e R. Thomas Kline me this It!<%- day of 05/04/2000 FEDERMAN & PHELAN By, ;:~7~ De ty Sherif , , Sworn,','and Subscribed to before tn.a,/ d.it<rO A. D . ~<tc;r (l ~ A ~~ ~ othonotarY , --~ l' FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attomey for Plaintiff Norwest Bank of Minnesota, N.A. as Trustee 1100 Corporate Center Drive Raleigh, NC 27607 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION ~t.IJ.... : NO. OO~-CIVIL vs. Gary R. Steinour, Sr. Beverly Jean Steinour 41236 Carlisle Road Gardners, P A 17324 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against Gary R. Steinour. Sr. and Beverlv Jean Steinour, 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 4/1/00 to 6/7/00 $133,907.00 $2,690.31 $136,597.31 TOTAL I hereby certify that 0) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rille 237.1, copy attached. ~1-~ FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: ~() Is/(}HJ-h...)k- , PRO PROT "THIS FffiM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATfEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** . I' ". ,. .' ~; , FEDERMAN AND PHELAN 'Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF NORWEST BANK OF MINNESOTA, N.A., AS TRUSTEE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY ~1.1'J... NO. OO-~-CIVIL GARY R. STEINOUR, SR. BEVERLY JEAN STEINOUR Defendant(s) TO: GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, PA 17324 DATE OF NOTICE: MAY 24, 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have faii}J enter a written appearance personally or by attorney and fi ~taiting with the court your defenses or objections to the cl ' 7lPh against you. Unless you act within ten (10) days fro e of this notice, a Judgment may be entered against you witn 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 Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF NORWEST BANK OF MINNESOTA, N .A., AS TRUSTEE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY .21..'~ NO. 00 .<i!611S-CIVIL GARY R. STEINOUR, SR. BEVERLY JEAN STEINOUR Defendant TO: BEVERLY JEAN STEINOUR 4236 CARLISLE ROAD GARDNERS, PA PA DATE OF NOTICE: MAY 24. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMA FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRE NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO C 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 - 1IiIiIl;::',; , FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attomey for Plaintiff Norwest Bank of Minnesota, N.A. as Trustee : Cumberland COUNTY : Court of Common Pleas Plaintiff vs. : CIVIL DIVISION 2~1" : NO. OO~-CIVIL Gary R. Steinour, Sr. Beverly Jean Steinour Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Gary R. Steinour, Sr. is over 18 years of age and resides at 4236 Carlisle Road, Gardners, P A 17324. ( c) that defendant Beverly Jean Steinour is over 18 years of age, and resides at 4236 Carlisle Road, Gardners, P A 17324. This statement is made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. ~t~ Attorney for Plaintiff . ~ . (Rule of Civil Procedure No. 236 - Revised) Norwest Bank of Minnesota, N.A. as Trustee : Cumberland COUNTY : Court of Common Pleas Plaintiff vs. : CIVIL DIVISION : 3i~t- : NO. 00 -CIVIL Gary R. Steinour, Sr. Beverly Jean Steinour Defendant(s) Notice is fen that a Judgment in the above captioned matter has been entered against you on June .2000. . It' '41'J~ ~2 ~Arl...rDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attomey for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** . iJJlIl' ~""'-'~___~,~~Iiiliillll'~~kijiM~UW1",,"lfiiiWlljii_ ,,~~ '-'.Jj'. ~,".~~ ="111 ~ --0 . o o ~~~ ~ -C ~ G' ~ tj r--~ Fl' r--. ~ ~u ~ ~ tJ ~ ~". (") C <!" -0 (ii rpr~j ~_J_"_ ZC~ (f)" -<.~--_.,- r:: (5 ::2 ~;C) ~O C Z =< c::> o o ..,., ::;J f'h:n -ohl :DO ;:...) 1. -{C) I" -F",:!] "0 Bm M 35 -< <:- ~ '- z I Cl:) ...... :.x S' w (TJ l "c_~..""""""-,,,,~I " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P.3180-3183 NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE Plaintiff, v. No. 00-2612 GARY R. STEINOUR, SR. BEVERLY JEAN STIENOUR Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $136,558.32 Interest from 6/7/00 to 6/5/02 (per diem, 22.45) $15,400.70 and Costs TOTAL $151,959.02 1=~ 7~ FRAJ{KFEDE~,ESQtmRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attomey for Plaintiff Note: Please attach description of property.No. ,~ "~ ~ t"l... ~ >'Ij E 0 ~~ ~, ~..., ~ ~ " " P.- trI= '" t"l t:C trI ~~ [ '" ... trlc rIl ~;g <> ..., ~g ,j:o,,j:o, ~ ~~ t:C N N c> "l ~~ t:l!:l ... ... ~O 't:l 0\ 0\ 0 ~ t"lt"l S a:~ ><?:l ...,~ t"lo ~ ~~ " ~~ ""rIl ~~ g"'-l '<: trI..., '" 8' "llS < ~("l S ~~ 'f' ... ... .., ~ ..., ~s:: ""0 ~ rIlrll "d ~ 0 rIl~ trI'" ;~ t""t"" ~ ...,0 trI~ 0- S. " trItrI a. 5'''l ...~ ~ '" ~~ = trI Ii.?:l trI trio ~ ::ll .. ~ rIl ~~ ~ Orll 0 ~"d " ~~ ~?:l ..., rIlt"" po. t"l ~ ~ ? ><l'1 ~ t""> ~~ ..., ~ ... ~"-' 0 ~ ~ ~o "'''l ~~ > ~~ ~ rIl ~~ ........ ~~ ...... NN ,j:o,,j:o, f 'f,.~ _~~i",1Jl~~ _, "~_~ ...,...,..Dl, Rill f!!fj_~ti_!y,.,-"ep.',!j_""'i,c;.-""",,,,,;,:;,:'''<:'JiHcfitl'~'W'!J,!~;W;"",'irW!l'mli",;q11'.'i1''-''!;'i'!'lIF!lIWI'l'rw.r~JIlW.~ " ~- '. ,., ~"' ~~" (!Itil6jL 4._ DESCRIPTION / AJ:i THAT CERTAIN tract of land with the improvements thereon erected, Situate in Dickinson "township, Cumberland County, Pennsylvania, bounded and described as follows: / BEGINNING at an iron pin in Pennsylvania Highway Route No, 34 leading from Gettysburg to Carlisle; thence along the center of said Road, North 3-1/2 degrees East 404 feet to an iron pin: thence by land now or formerly of Benjamin Starner, South 88-1/2 degrees West 138 feet to stones at the railroad; thence along said railroad, South 17 degrees West 409 feet to stones; thence by land now or formerly of C. U, Shambaugh, North 89 degrees East 295 feer to the place of beginning, Containing 2 acres amI 2 perches, more or less, and being improved with a dwelling house, EXCEPTING approximately I acre more or le~s conveyed to Hermie Taylor, by Deed dared July 24, 1958 and recorded in Deed Book 18-9', page 3'18; and also excepring approximately .40 acres more or less conveyed unto Elizabeth Myers, by Deed dated May 2, 1953 and recorded in Deed Book 15-H, page 201; which both conveyances were erroneously omitted from prior deeds of conveyances, Tax Parcel # 08-42-3281-003 1~_lMiIll_~liI!IlI!iIlllllll~~~@iiaJi~llimiil&ID!llil~lIf~"'" - "~"' - .i.>."~ ... ~""', ~'" . ~ 1'".:J 1 -.... () ~ ~ ..... ~ "" 0 w ~ ...... w ...... c: 1\., 0 :-.. 6"- :-l:: ~ "tJ$: ..,~ "n "l 8 CJJ ........ ~ ~ d Q!n, rq ~ 8 "0 0 z-r., co ]] lU \) Z~' ll> ~- '" ~,0~ '-.) .fj I C> (1)= co ( ;::$2: }oJ t;9 I I I ~C) ::-:':;: ~~~' ~ 6)J I f?f2 )> ;r,;,. J..J z~, -- ~F~ :;;;6 - ---tJ ... ~ C5 -<:: ... ~ . 5:: ~ ... )0 .. ~ t-t? --j =< I'\) )>, . (J'l :0 ~ ... . , -< - -- '"' ~ ; ,- ~~ ....~~l ......1 -<=-. '. ......... NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GARY R. STEINOUR, SR. BEVERLY JEAN STIENOUR NO. 00-2612 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) NORWEST BANK OF MINNESOTA.. N.A. AS TRUSTEE, 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 .4236 CARLISLE ROAD. GARDNERS. PA 17324. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, PA 17324 JBEVERL Y JEAN STIENOUR 4236 CARLISLE ROAD GARDNERS, P A 17324 2. Name and address ofDefendant(s) in the judgment: GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, P A 17324 JBEVERL Y JEAN STIENOUR 4236 CARLISLE ROAD GARDNERS, P A 17324 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. . _~I' 0'-" ---," 0. , - ....... '" 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) HOUSEHOLD REALTY CORPORATION 25 GATEWAY DRIVE, SUITE 107 MECHANICSBURG, P A 17055 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4236 CARLISLE ROAD GARDNERS, PA 17324 ])omestic Relations of Cumberland County 13 North Hanover Street Can-lisle, P A 17013 Commonwealth of Pennsylvania ])epartment 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 unswom falsification to authorities. Februarv 20. 2002 DATE ~ AI )J/ F FEDE~,ESQUIRE Attomey for Plaintiff !~~IliUIiIIi!tlllJiilililoii!l~bll;iII!llli~Iii<<i!;>ii!'lld_"~idIl~~\...I~m".."'.o._~~,'i,,a!l~..~ < . ,"".",".",j ~~."-,. ~-~~~ - -, ~ ^ ~ .IW . ~........... ~ ,~ - _oj.. .. -,,,,,,,,,,,' "- ~ . - -~, - .~. 0 0 Cj c: !'-) ~ri ? .." ~::! -"OeD f"1 i';~'\ ;r: mr71 ct:J ZX1 ['0) --':, ,,--, Zr; '-(l'::;- en"", CO ~j~7 -=< L._ ~c ~:ill'> ~~~ti ~o ~. -0 <? ~.--n ;pc: ~ -? ..". ~ N :0 ()'1 "< ~~ 1IIlI_.1 "' -.j, FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION GARY R. STEINOUR, SR. BEVERLY JEAN STIENOUR NO. 00-2612 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) 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. W1\_ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '" :f!i~~IitllUl!llI~Ii!lliiiiilWijiiii.llii:il1~~llitl:iiilli.O<l<I'kl>IllH"'i\;W",;ti_~~rr;itl:tiI'I1!lli"~~ltlki ""'- ..'--' ""-~~'-"" il:I..-~ " ".___J..._".............. - "".~~ 0 0 0 C r<l -n s: -T'\ "'Ow r-q -\'"; rnrn cn z-n; N .-,jr; zS:; _'j:-;:~I en,," CP '~~~ --=<..:::. !;20 p ~O :J;': 5>2 S' 5rn -4 Z N yo =< (.11 ~ 'M~ _" J_~_..~ ~ .L "l, .' NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE CUMBERLAND COUNTY Plaintiff, No. 00-2612 v. GARY R. STEINOUR, SR., BEVERLY JEAN STIENOUR ' Defendant(s). February 20,2002 TO: GARY R. STEIN OUR, SR. 4236 CARLISLE ROAD GARDNERS, PA 17324 BEVERLY JEAN STIENOUR 4236 CARLISLE ROAD GARDNERS, PA 17324 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 4236 CARLISLE ROAD, GARDNERS, PA 17324, is scheduled to be sold at the Sheriff's Sale on JUNE 5, 2002 at 10:00 a,m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 136,558.32 obtained by NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered, You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 attomey.) - ~ ~ -~'~~~-~"'_l' , ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER IRIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 8I!:.L.M""b.&""-, " DESCRIPTION d THAT CERTAIN tract of land with the improvements thereon erected. Situate in Dickinson /TownshiP, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING :It an iron pin in Pennsylvani:l Highw:lY Route No, 34 leading from Gettysburg to Carlisle; thence along the center of said Road, North 3-1/2 degrees East 404 feet to :In iron pin: thence by land now or formerly of Benjamin Stamer, South 88-1/2 degrees West 138 feet 10 stones at the railroad; thence along said railroad, South 17 degrees West 409 feet 10 stones: thence by land now or formerly of C.D, Shambaugh, North 89 degrees East 295 feet to the place of beginning, Containing 2 acres and 2 perches, more or less, and being improved with a dwelling house, EXCEPTING approximately I acre more or less conveyed to Hermie Taylor, by Deed dated July 24, 1958 and recorded in Deed Book 18-0, page 318; and also excepting approximately AO acres more or less conveyed unto Elizabeth Myers, by Deed dated May 2, 1953 and recorded in Deed Book 15-H, page 201; which both conveyances were erroneously omiued from prior deeds of conveyances. Tax Parcel # 08-42-3281-003 ~~___liIlllllllitliiliIiiillllUi~It\i<i"')I<Jt<l$"lt~i~~"I~ ..~.I!!UII ~- . .n, ~-. ,_~ ", ._..=__ -- ... '" ,.""-" ~ , >,~L --> ~ ,I ~.......'" '" - .", ~~":r ~.. 0 C) Ci- C '" ... ::;:: .." "0 OJ r-q m[n CJ:! -:..;:': Z.A.' """ z~ f"-,) CO " <'j;::;: ~~:- , - '-0 .,:'i-\';::r:', ~ ::c-~ -~" ~~ 70 - ~C'" C5 ;t>,c Z; '" ~ =< :::1') Ul -< .'~ ~ " ~ . ,- '~' ""' ~""""""" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: NORWEST BANK OF MINNESOTA, NA, AS TRUSTEE ) ) CIVIL ACTION vs. GARY R. STEINOUR, SR. BEVERLY JEAN STEINOUR ) ) CIVIL DIVISION NO. 00-2612 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE hereby verify that on 2/27/02 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 2/27/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: April 29, 2002 ~"~~ER~~~6'UIRE Attorney for Plaintiff .. '. -""""'~ . ~ -, I I I I I I 1 '1 I . " ~ ~ ..eg = . 09tS909 '<1,1'" , ~'E-.!!2~ .. . .... 1;!;.1i1"lBd ~ ~B~ ~ ~ 0 O' I :~~fj~ 20.:2833 ~ 0.8 S:IE . &.A::,t.;:; U~'!~ ~~N ..~.?amlf~~~~, i:;;,"~ C~4< ..o!\. ""\" l'. ~'~~~, ~f~' ~ '" ,~" C> !:\;> 'I gh~!,-'I v~}: 1. j!0:IE \... 2~ ~ '! ~ ~ ',<>, ""- ~ '" '~ ~ j-g .."" iJJHd '0....\ 0 - ]058- M r- <i :5 - !le~s r- ..: ~ '~p~ - ~ ~ l;oo ..: ~^ - o.~ ~ g i!:>_' ~ '-""f- ~.r g ';; ~ ....l CO ~~i] '" '" t/l :g~H, ~ ~ U . 0. .- 'M~.5 e Z ~~~.s u ~ ~~~~:i !^ ",^ ~ u HI~I '" p;l r:3 ::s H~P ..: l:1'_ N (g ~ 1'0 0 ~~ 8. p..8 0 ~ '. 1; 8 ,~'~ ~ W ~ ~o.~" ! f- ~og.g~ ~ ;:;.; 5 o.:~... _ g~'O~~ M CI) ',:;I 0.... e VI :t: r- u.i I! '.::l's'~ 'l:l- - ~~:= s; g ~ ~ > " . M "O:t!.E/U- ~ ~ 1r = 0 ~3j ",' 0 cZ: ~ 'g . d II.> '~8 0 P '" ~ r:r. ~ ~.s1~~ - ~ \.I- :; ~ ~ ~ ::E ., ~ !;( 0 " 'S Ji 0 ~ Cl .~ 0: u fu '" I <'l ~ 0_ A 0 .".- z' ! - .. ~ ~ .B~ ::l 0 ,- = ~ ~ . "' .. '" " '" 6r1l~ ii ~ ~ i~ 'J:j .,g . 0 ~\', .. ,g S"8", .. a. " '" d' ~ tI). ~ ~ . ~ 0:: " ~ '" 0 "'"' !a Q).... IE M -- 0 0 ~..o :::1_ 00 '" . gj !:l 0_ ii '" ~ .... > - 6 ~. . ..o~~ '" ~ f- p..~~~ i! 0 -' I. . ~ ~ <i ~'iJ~~ .. w ~ ::i ....l a:: t lL) <: '" ~ ..: 0 B~ ~ iF~ ~. if ~ u ~ -' u~ ",. ~ u 0 0 ~o ~.E ~ ~ ~ :x: ~ - .. o ~ .. '" w I~ 00:; " ~ ~ CI)'" ~ ~ ~p,.""'''C 0 ::E ::J'" CI r-'" . 00 z ~ ~8-::= E 0 0 ~ 'iq . 0 u :x:!: ~ "'.<:: z -~ 1'", ~ .. rj .a E r:i "' z ;l '" .. 0 .... u z = ~ - = ~ .. .... Jl ... = '0 ... '" l() -~ 00> ;j '" <ll t", ","C li! <ll <ll = 5 ... <ll " - N '" 0 z-;;; 'Or;/') " .... '" '" r- oo a, - '" '" .... V> eo"'''' :::l - - - - - - as z<O 0.2 "'''' -- - . '"' "----~.. 1 I \ ..-' .-." 7160 3901 9844 7041 9160 TO: BEVERLY JEAN STIENOUR 4236 CARLISLE ROAD GARDNERS, P A 17324 SENDER: TEAM 5/HFD REFERENCE: STEINOUR, GARY PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service p Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for InternatIonal Mall -' .34 2,10 1.50 .3.20 1,14 .. 7160 3901 9844 7041 9153 TO: GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS,PA 17324 SENDER: TEAM 5/HFD REFERENCE: STEINOUR, GARY PS Form 3800 June 2000 RETURN RECEIPT SERVICE -'--", US Postal Service Receipt for Certified Mail No Insurance Coverage I'rovldecl 00 Not Use for International Mail .. ,34 2.10 1.50 3.20 7.14 "i.Ii;,~, ' I I , I I , ! I I i ! i ! I i ! 1 ) J i ,~~iIll.l~hiIllll!IIl~~~liM&iOilI;!ll!iiolliWH~5;;:m~lml'-;;;';;"j~lIii~ll>;~1iI...ill- -j! ,..,-.....,...'-'-~..'"'.~O'1IIIi ~l -.., o S; -o~;::, n)E~_ _..J.' ZC' ~3;~' ~.:: -::: c' ~~:) :J:>c:: 'Z :3 '. n t"'0 f'-'. '" o -,,-, s; "'c< I f") .<< .:.S; ,...! - l.:...._ ~~-'~'.' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Wells Fargo fi'k/a Norwest Bk of Minnesota is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2002, under and by virtue of a writ Execution issued on the 28th day of Februarv, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 2612, at the suit ofNorwest Bk of Minnesota. N A. Tr against Garv R Steinour Sr & Beverlv Jean is duly recorded in Sheriffs Deed Book No. 252, Page 3745 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this If!! day o~, A.D. 200<:" Recorder of Deeds ~=<:.l:'~ . -~'"" "~.~ 1.._...,. _~JOi'i Norwest Bank of Minnesota, N.A. As Trustee VS Gary R. Steinour, Sr. and Beverly Jean Steinour In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-2612 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 27, 2002 at 9:40 o'clock PM, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the withiJlnamed defendant, to wit: Gary R. Steinour, Sr., by making known unto Beverly Steinour, adult in charge, at 4 Dickinson School Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 27, 2002 at 9:40 o'clock PM, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Beverly Jean Steinour, by making known unto Beverly Steinour personally, at 4 Dickinson School Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly swom according to law, states that on April 4, 2002 at 1:58 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Gary R. Steinour, Sr. and Beverly Jean Steinour located at 4236 Carlisle Road, Gardners, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly swom according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Gary R. Steinour, Sr., by regular mail to his last known address of 4 Dickinson School Road, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriffs 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 marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Beverly Jean Steinour, by regular mail to her last known address of 4 Dickinson School Road, Carlisle, P A 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly swom according to law, says 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 June 5' 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Wells Fargo 1lk/a Norwest Bank of Minnesota, National Association, as Trustee for the Registered Holders from time to time for First Union Home Equity Trust 1997-1, Home Equity Loan Asset-Backed Certificates, Series 1997-1. It being the highest bid and best price received for the same, Wells Fargo 1lk/a Norwest Bank of Minnesota, National Association, as Trustee for the Registered Holders .-. . ~~ w_ '""",, I . lf~ lu"" from time to time for First Union Home Equity Trust 1997-1, Home Equity Loan Asset- Backed Certificates, Series 1997-1 of 1100 Corporate Center Drive, Raleigh, NC 27607, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of$704.60, it being costs. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Service Certified Mail Levy Surcharge Law Joumal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 13.82 15.00 15.00 30.00 10.00 .50 1.00 8.28 1.80 15.00 30.00 260.75 193.75 25.20 25.00 29.50 $704,60 paid by attomey 07/11102 Sworn and subscribed to before me S~)"7~ ~ r ~:;...~t:.r-'~~ R. Thomas Kline, Sheriff This .;Lv"" day of (,)"..", 1-' - 6 2002,A.D.~ O~.I,~ P ot onotary BY00~'-~j{h Real Esta eputy tiP~ vV 30' e'O 'jS 6k.. f7 ,//)i) ~ 1;(J't.~o "...~ -'. ~_~L"." . - " "~o<i": WRIT OF EXECUTJON andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-2612 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisf'y the debt, interest and costs due NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE Plaintiff(s) From GARY R. STEINOUR, SR. AND BEVERLY JEAN STIENOUR, 4236 CARLISLE ROAD, GARDNERS, P A 17324 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subj ect 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 $136,558.32 L.L. $;50 Interest FROM 617100 TO 6/5/02 (PER DIEM - 22.45) $15,400.70 AND COSTS Atty's Comm % Due Prothy $1.00 Ally Paid $113.85 Other Costs Plaintiff Paid Date: FEBRUARY 28, 2002 CURTIS R. LONG Prothonotary, Civil Division ~' 4do"r 0 . Q. 7rf/J/?A'r.J:VKr" REQUESTING PARTY: Name FRANK FEDERMAN, ESQIDRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ~~iili1~_!lmillh[liillll_~;!;~Mliij~xii!i"h!~'-<d,"'"lli~',""""", ,~"",""",,,,_,>,",~,",,)-.~;;,-ti.lI':iI>~i;n;il!"~~~"~"lr!ii50.1f~<<;l~~~O!le1_li>;!J&~!Ili~ , ~ ,~. ~ - o REAL ESTATE SALE No. c2.9 On March 8, 2002 the sherifflevied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, P A, known and numbered as 4236 Carlisle Road, Gardners and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 8, 2002 By: JcdL( Jvvtl.B. Real Estate Deputy \:' 1).1 '0'/. Oi I::' II \'. 01 j \ r'i ':' '\" ',<f:'i:.,](] iff, I:j n Zi S UUW Al~r!l,\. - j~no .:U1~31!S 'ii" j,j :J,,:;J,JO , ~. 'i....1 !: i (-) CUi] c;:;;] c;;::::::I <s=e> IniiJ " k - ~ ~ ....c....... -, - II NORWEST BANK OF MINNESOTA, N.A~ AS TRUSTEE CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GARY R. STEINOUR, SR. BEVERLY JEAN STIENOUR NO. 00-2612 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE, 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 conceming the real property located at ,4236 CARLISLE ROAD, GARDNERS, PA 17324. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address carmot be reasonably ascertained, please indicate) GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, PA 17324 BEVERLY JEAN STlENOUR 4236 CARLISLE ROAD GARDNERS, P A 17324 2. Name and address of Defendant(s) in the judgment: GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, PA 17324 BEVERLY JEAN STlENOUR 4236 CARLISLE ROAD GARDNERS, PA 17324 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 ......ll;i ~ 4, Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HOUSEHOLD REALTY CORJ'ORATION 25 GATEWAY DRIVE, SUITE 107 MECHANICSBURG, P A 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4236 CARLISLE ROAD GARDNERS, PA 17324 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Februarv 20.2002 DATE d A ~)/ F FEDERMAN, ESQUIRE Attorney for Plaintiff .....~ ~- ---iIiiI""""~"'''';'''; FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION GARY R. STEIN OUR, SR. BEVERLYJEANSTffiNOUR NO. 00-2612 Defendant( s l. CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) 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. j~ ~- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,.,~~. "' ~-~ , '- - " ~ .-~~'" NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE CUMBERLAND COUNTY Plaintiff, No. 00-2612 v. GARY R. STEINOUR, SR. BEVERLY JEAN STIENOUR Defendant(s). February 20,2002 TO: GARY R. STEINOUR, SR. 4236 CARLISLE ROAD GARDNERS, P A 17324 BEVERLY JEAN STIENOUR 4236 CARLISLE ROAD GARDNERS, PA 17324 **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 PROPER TY* * Your house (real estate) at, 4236 CARLISLE ROAD, GARDNERS, PA 17324, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 136,558.32 obtained by NORWEST BANK OF MINNESOTA, N.A. AS TRUSTEE (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.c.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments; late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. .,~_~____,_Y:9.umay_n~e.d_auattQrney_ tQassertso.uuightL'flleso_o.neL}'QQ.contactone,.the,mor.e_chance--.. -. . you will have of stopping the sale. (See notice on page two on how to obtain an attomey.) -- - , ':.s . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5, You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 24\9-3166 (800) 990-9108 . <, '~'tlllil!ii.." DESCRIPTION / ;yi THAT CERTAIN tract of land with the improvements thereon erected, Sirnate in Dickinson jfownship, Cumberland County, Pennsylvania, bounded and described as follows: ,I BEGINNING at an iron pin in Pennsylvania Highway Route No, 3.. leading from Gettysburg co Carlisle; thence along the center of said Road, North 3-1/2 degrees East -+04 feet co an iron pin: thence by land now or formerly of Benjamin Starner, South 88-112 degrees West 138 feet to stones at the railroad; thence along said railroad. South 17 degrees West -+09 feet co stones: thence by land now or formerly of CU, Shambaugh, North 89 degrees East 295 feet to the place of beginning, Containing 2 acres and 2 perches, more or less, and being improved with a dwelling house, EXCEPTING approximately I acre more or less conveyed to Hermie Taylor, by Deed dated July 24, 1958 and recorded in Deed Book 18-0, page 318; and also excepting approximately .40 acres more or less conveyed unto Elizabeth Myers, by Deed dated May 2, 1953 and recorded in Deed Book I5-H, page 201; which both conveyances were erroneously omirred from prior deeds of conveyances. Tax Parcel # 08-42-3281-003 .~ / . THE PATRIOT NEWS THE SUNDA Y PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler 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.Itle. 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 exactiy as printed and published in their regular daily and/or Sundayl Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advert[sing, 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 verily this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resoiution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscelianeous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #29 ~~...~.u..,..,.,...........................,.,...,. 02 AD. ~..... - ~ '. REAL ESTATE SALE No. 29 :- Writ No. 2000.2612 . Civil Term - ,-;;-NOMest Bank of 'MInnesota, N.A. as trustee vs aary R, Stelno"r, Sr, and Beverly Jean Stein our _ ~~tty: Frank Federman 'DESCRIl'TlON, , ALL THAT CERTAIN tract of -'and with the - lrnpmvements_.there.on _ erected, situate in Dickinson TOIVllShip, Cumberland County, Pennsyh'ania. bounded and described as foUow~: BEGINNIN"G at an iron pin in Penm.ylvania Highway Route No. 34 leading from Gettysburg to Carlisle;Jlience ilIong the center of said Road, North 3-112 degrees East 404 feet to an iron pin; . thence by land now or formerly of Benjamin .Starner,__S..Quth 88.[/2 degreesWe,:;t, 138 feet to stoneil ankrailroad; thence along said railroad, -::SOuUn1'aegrees west 409 feet to ~tones; thence by !and now' or fonnerly of C.D. Shambaugh, .,. . Nrnth 89 degrees East 295 reet to the pi", of, Publisher s Recetpt for Advertismg Cost beginning. Tontaining 2 acres and 2 perches, I.. . more-6rless,andoeiilgiriiproved'wun:i"dwelling ?, publisher of The Patrrot-News and The Sundav Patrrot-News, newspapers of general hous<,:'__' . 1 'ge receipt of the aforesaid notice and publication costs and certifies that the same have ~ EXCEP:'l1lrG- approximately 1 acre more or ess tonteyed to_Bermie Taylor, by .D~ dated July 24,-1958 -and recorded in Deed Book lS-O, page 318; and alsO excepting approximately AOams more or le.ss..coffi'eyed unto Elizabl;ih Myers, by Deed dale.o:::~ra"y 2, 1953. and recorded in Deed Book is-S;-page 201; which both conveyances were, erroIie.ously omitted from prior deeds of i cOffi'eyances:- 'Tax Parcel #lJ842-328HKJ3. . Notarial Seal Tetry L. RUSil;lI, Notal)' Pobllc Harrisburg. Daophln County My Commission Expires June 6,200 NOTARY PUBLIC Member, PennsyNania Assoolation ot Notaries ~ My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 192.00 1.75 193.75 By..,.........,...,...,...,.......,..............,.......,......",." ~ REAL ESTATE SALE NO. 29 Writ No, 2.000-2.612. Civil Norwest Bank of Minnesota. N.A. as trustee vs, Gary R. Steinour. Sr. and Beverly Jean Stienour Arty,: Frank Federman DESCRIPTlON ALL THAT CERTAIN tract of land with the improvements thereon erected. Situate in Dickinson Town- ship. Cumberland County, Pennsyl- vania. bounded and described as follows: BEGINNING at an iron pin in Pennsylvania Highway Route No. 34 leading from Gettysburg to Carlisle; thence along the center of said Road. North 3-1/2 degrees East 404 feet to an iron pin; thence by land now or formerly of Benjamin Starner. South 88-1/2 degrees West 138 feet to stones at the railroad; thence along said railroad. South 17 degrees West 409 feet to stones; thence -by land now or formerly of C, U, Shambaugh, North 89 degrees East 295 feet to the place of begin- ning. Containing 2 acres and 2 perches. more or less. and being improved with a dwelling house, EXCEPTING approximately I acre more or less conveyed to Her- mie Taylor, by Deed dated July 24, 1958 and recorded in Deed Book 18-0, page 318: and also excepting approximately .40 acres more or less conveyed unto Elizabeth Myers. by Deed dated May 2. 1953 and re- corded in Deed Book I5-H. page 20 I; which both conveyances were erroneously omitted from prior deeds of conveyances, Tax Parcel #08-42-3281-003, - ~" ~, 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 ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: APRIL 26, MAY 3, 10, 2002 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. ~ Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 NOT. LOIS E. SNYDER, NolalY PubI1c CarfisI8 Bolo. Cumbertand CounlY My CommissIOn EJpilIlS March 5. 2005 I," ~", , haii!.i , !i PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG, ESQUIRE IDENTIFICATION NO. 62205 ONE PENN CENTER AT SUBURBAN STATION PHILADELPHIA,PA 19103 (215) 563-7000 NORWEST BANK MINNESOTA, N.A., AS TRUSTEE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION v. PHS#:36514 GARY R. STEINOUR, SR. JEAN STEINOUR ( NO. 00-2612 CIVIL CUMBERLAND County PRAECIPE TO MARK JUDGMENT SATISFIED AND MARK THE ACTION DISCONTINUED AND ENDED WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly satisfy the Judgment, which ~~~red on or about 06/08/00 in the amount of $136,597.31, and mark the action disconJnued and ended, relative to the ~ instant matter. March 3, 2006 ,.< '~liiI~Ii_~~tiil~~nillll>>!i1,;iiliki!\"iI:$litii!.'dll;i;iiMJIj:'~""'"~_il!t~'"''''' ''"JiJi JlIIlU~l.l1!l~ 'JrtrlU>I].U~""JKL,>,_,,,,_~,,,_.~,,," __~,~~, _ " ~. iIf",,"h.'.).''''" ",_L~ di- ,~ ~ -,... ~. ",~,;.,,"""._, ,.,"<-....,: ,.,',"" ,., ~- ',,< C) "-.:> = 0 S =~ " ~.- a~ ~ -l :':;:," III ~ nl;:= "'IJm .;;'" cny C),.J_j ----.J.l__ .:r.~ :,'~~;~ CD ~?rl <"0 ::0 W -< '"