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HomeMy WebLinkAbout00-02757 1 :.., - u '~_" ~ ",; CUMBERLAND COUNTY KEYSTONE FINANCIAL MORTGAGE CORPORATION No.: 00-2757 vs, THOMAS E. PATTERSON,II CORINNA R. BAILEY SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.2) Plaintiff in the above action, bY' its attorney, 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 <<jlremises>>, <<jlremisescsz>>: 3. N allle 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) Pheasant Run Condo. Assoc. PO Box 233 Carlisle, PA 17013 American General CDC 6 S. Hanover Street Carlisle, PA 17013 4. Nallle and address of last recorded holder of every mortgage of record: N allle Last Known Address (if address cannot be reasonably ascertained, please indicate) ~il - " ~ 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) None. 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, ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff May 4,2001 ill~ilimll:!ta~~~.<l!Il8i!~~\~I";"&b;-~__1l<it~~~1 , ~ -~ " ~ ~~~.- UJI 'liiililll' (") C :;''''' (::)r';:'; [Df::': ~~;:.- i~; ~,:;:;c.; -s;:; .<.~~ --; -< """'"- c, -- ;::~~ --" ;-\.) tIi ::E "'- ~ CJ 25i~1 Si ~J."] -< t\) -:..,,) <;0 -';:1 ~. .( ,~~ /4 .'~ -' :. ~ " "- '" .. .-....... KEYSTONE FINANCIAL MORTGAGE CORPORHION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION THOMAS E, PATTERSON, II CORINNA R. BAILEY NO, 00-2757 Defendant(s), AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No.1) KEYSTONE FINANCIAL MORTGAGE 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.at1402 BRADLEY DRIVE. AlKJA 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE. PA 17013. I. Name and address of Owner(s) or reputed Owner(s): NAME LAST K1"'iOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS E. PATTERSON, II 1402 BRADLEY DRIVE, AJKJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 CORINNA R. BAILEY 1402 BRADLEY DRIVE, AlKJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 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 so ld: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None -,,~ . I -< .. --.. ~ Namearrd address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Members 1 st Federal Credit Union 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 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 so indicale.) 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 indicale.) 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 1402 BRADLEY DRIVE, A/K1A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 Pheasant Run Properties 1824 Sterretts Gap Avenue Carlisle, PA 17013-1249 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. ~~%~ FRANK FEDERNIAN, ESQUIRE Attorney for Plaintiff Februarv 22. 200 I DATE 1~m.liIllI~IIII!IlHMII~lil;jai!ilriiil~~!~II!iIi1i!~,.;iAg;"'1"'1>''''i'.';;''-'',u,dlillfu"'~~~~IWTV~I-.i:'- .,~ <. _., .J_ ,.......,.~. ~'~~..~d..im1 '-'- ~ . o c- jp'i~ <.-"!' - ~iC: <('~' 2~(-,:' c- :? ---i -, ':.) ':0 "-~ "- ) . \ ~. , <::> - ~--:; -';"J "-;1.,... 5:~~:; -:: i\) (I; ""t) ~:r:: r\.) >ii" 'c ~~ SALE DATE: JUNE 6. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KEYSTONE FINANCIAL MORTGAGE CORPORATION No.: 00-2757 vs. THOMAS E. PATTERSON, II CORINNA R BAILEY AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. RoC.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: 1402 BRADLEY DRIVE. AlK/A 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE. PA 17013. As required by Pa. RC.P. 3129.2(a) Notice of Sale has been given in the marmer required by Pa. R.C.P. 3129.2(c) on each of the persons or parties nanled, 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 ofthe notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stanlped by the U.S. Postal Service is attached for each notice. ~~~- "- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - May 4, 2001 1~$imtt'1lb1I~~0i~l!iiilli'~I~~iJ&lIWJl~~l\t:ill,M,-#.,,,",~_~.ll,lll"I~MA:i li$liilf.cwW"- iIiIlOQJIII,,"" . ~,J to. '.o~ ..""__.~ (") ~ -pP" Pltl':.: Z~: Zf.- (I) _.....,- i~ Fe: ~ =2 o '-~',l -< ,~~) .....' " () ;..L:; '-I~ ~~~ ~ d"n ::< r:~ :.,j ...J ,~ .....iIll ,... \2~ ~ .. , -- DATE: 02/22/01 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) THOMAS E. PATTERSON, II CORINNA R. BAILEY PROPERTY: 1402 BRADLEY DRIVE, AlKlA 1402 BR...\DLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on JUNE 6. ~, at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street. Carlisle. PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH -.- - N :::'.c;l I ~ fir _ ~z VI ..c H "," ~il, ~ ~ ~;;l ~s ~. Z I!.c ag. .". ~~s. 0"" ~ ~~.. ~ l~ ~Oj~ '-'~ (\ i . """' 0 ~ . ". .. ~ 1:1::::""';;1 88&"'''' . . ~ ~ 2' ~ls~;: ~ ~. . . - . 5.-.3' [.. "'3 =..'2 ~ a e,; g' Q'>:;-t::;' 9., ;.r~~[ a.-.8~ li S'~'O S;n" :t."d rD iii' a ~~ g~.Q o r;. (') i:I.o 5. ;;<..~8. o _. ~ 0. 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""'".... --, LL (") ~ -a I:'i~ ~f r ~- #Eg ~ $] ,~ 1IIIiiiIl-"" 0:' ::'0 CO . ,.--, ",-,-' ~~ ::t: .';;;> .,,< i'",) C/, -- '. ::.:: - , .:5 -< ii~ "~" --'=~"'- \ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R-C.P.3180-3183 KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Pll1intiff, v. No, 00-2757 THOMAS E, PATTERSON, II CORINNA R. BAILEY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $35.543.19 .' Interest from 96/20/00-12/06/00 $986.96 and Costs (per diem - $5184) $36.530.15 TOTAL .' ~ Note: Please attach description of property, No. ~~' ~'~~1lllldlIlIfIIi1lii;J~1IiM~~~flIMi~OO~~~.JtI~ili..:Ij[liil.">'<": .' ~"~J .........,.; "" -.,,,"-"'"' I r' , .... .... <"l < ... ... > ~. f;olf;ol ~~ ~~ "> ~f;ol ~S ;!~ O~ UN = ...;:$ .".... =.... O~ f;ol ~ '"< =~ "';> ~ ... r:i~ ... Eo-< Z ~ ... B o . ...:l", ~ Z> ~~<"l .0 ~~ ~'E' Q) 0 Of;ol f;ol;!.... ~ ci Of;ol :;;:Z "'...:l f;ol = ...~f :;;:~ &1< ., ~ 3~ ... 0 ... .... ., :;;: . Oc:l <>< Q) 0 O~ ...~ .. ~f;ol~ .0 0 ~~ ... l. ~ 0 U~ U~ ,,; ~i o.i...:l . 8 N ~O .. ~< ",~e3 Ef ~O ., "Z .... ...u ~~ f;olZ ~~ ~~i!l Q) Q) "';! ONsa g. Eo-< ~~ ...0 Ot: p. f;olU ~O ... 0 =:=< Q) ~< ", 'Z f;ol6 ...;:!;u ~ 8sa ou 0 =: ~ ... ~f;ol ... ... U 00 '" ~ ., E-<~ > ~ Q) ~ Q) ~ Z~ - "'u ~ ~ '~~ _ '.1- ." ", DESCRIPTION ALL THAT CERTAIN unit designated as No. C-2, being a unit in Pheasant Run Estates, a Condominium, located in North Middleton Township, Cumberland County, Pennsylvania, which unit is located on the Third Floor, Building I, as designated in the Declaration of Condominium recorded September 24, 1980 in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Book 258, Page 6, et seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record 312, Page 776, et seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, page 783 et seq., togemer with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in me hereinafter named. Recorder's Office in Miscellaneous Record Book 258, page 25 et seq., and togemer with plan recorded ih the herein muned Recorder"s Office in Plan Book 38, Page 112. " TOGETHER with all right, title and interest, being a .0059524% interest in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration' Plans. ...- UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in me Declaration of Condominium, Code of Regulations and Declaration Plans. Tax Parcel #29-17-1583-0 15B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd, his wife dated 2/14/1995 recorded 2/22/1995 in Record Book 118 Page 861. ;it1~il!ij~it.1lill!i~e!M~~J~lj"~I~~j~I1ijl;l~;~>\liiBl<i\~Rdu!i~R~n'"~'~Iiit~- - ~~~ "~" "~L..>J..--,-, - ,,,',,,~ ~. , 1~ ..... ,,() a 6'- t~ ~ d - ....... ...0 .ca -- . ..... Oi r o () (-rY .... '" w~ ::-.. ."> ..... 0 c C. ",Pfl ~ :s 'f.-I (") C ? "1:',",' n1r~" Z-j-' -:;:..i-.:': Us'p ~6 :i>~ 2....; >() c Z ::2 ~ ~~...... . "l f' 11 0 ~ () t' C () C I I I I ... '" ~ ~ ... ...... . ... .. .... .... .... .. <-"-",1 , I . c::.. CJ """ (0 "J CO' - -: -~~! :::',..!... :r:r,c. ~',< -,>. .'~; '::.:::t; &;'" ->c.:: ;'=---,r-j ,_J :c-i 3:i -< dilJr' -~b ~" '\ KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION THOMAS E. PATTERSON, II CORINNA R. BAILEY NO, 00-2757 Defendant(s), AFFIDA VIr PURSUANT TO RULE 3129 (Affidavit No. I) KEYSTONE FINANCIAL MORTGAGE 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 1402 BRADLEY DRIVE. AIKIA 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE, PA 17013. I. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS E. PATTERSON, II 1402 BRADLEY DRIVE, AIKIA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 CORINNA R. BAILEY 1402 BRADLEY DRIVE, AIKIA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 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 - ~ ~~ -. - ~ il~lu ... 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Members 1st Federal 5000 Louise Drive, P.O. Box 40 Credit Union Mechanicsburg, PA 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 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 1402 BRADLEY DRIVE, A/KJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE,P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Pheasant Run Properties 1824 Sterretts Gap Avenue Carlisle, PA 17013-1249 I veriry 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. August 23. 2000 DATE , ESQUIRE j~!~i.i.:aliIDtiijl)j:li_,j{i":t!;''i.'i'_'b--0<_-i.",~,'."""j,1bi,;j,',l.;,;!_ill,',l&''(\'';"''''''_',W''UJ:-,j''-''''':;''-'''~'8'!ii&,,,j'iffi,;';w'iii!<~~f~>&,:--- ",,;;;oj ,'.. ,~ ~'" -~,- 1M ""'~i ,.." 0 Co C Co ~ -Os... :0. rn[r , ""' ~Fij G~) (/) '7-; N j=$?: en ~C' );:,. ~ ~,.-, :z:0 -""~ _.h 5>0 - c - 2:': :<f r.- '" .-----. -~"'~~ - - 'IIll~*,-,,'-1 FEDE~andPHELAN By: FRANK FEDE~ Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION THOMAS E, PATTERSON, II CORINNA R. BAILEY NO, 00-2757 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant ( X ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C,S. Section 4904 relating to unsworn falsification to authorities. ~~&.~~ F F DE AN, ESQUIRE ) Attorney for Plaintiff 11.~~~!I~:ruijf>ti;'h.",.;r<hg;Lj-fi:!,~Wj2Jii,,'-:d"'<"';;"~,f!;.~:K.~:!'_"''''--'''1''-;'J',~';,k.~,jfl:'_1,.-;;;.-!,.,~,''t-~l$j~!:~~l\Na~;~''~BM,,,,,,,,,,.~iillk~ "=~ }f- ,: ;t\, '~ ~- Wl~~JM.~...~'~''''' o c <- elfie, Ir' !:==c p: ~..c; ""-c-' :t>' C :z ~ C.) r~~ ~ ;::..... ,S; ...,"" J"'...,) 0:' :1:"" .....,.,0. ~' ~~ -< .,",'= ',I..., \. KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No, 00-2757 v, THOMAS E, PATTERSON, II CORINNA R. BAILEY Defendant(s), August 23, 2000 TO: THOMAS E, PATTERSON, II CORINNA R. BAILEY 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB 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 1402 BRADLEY DRIVE. AIKIA 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE. P A 17013, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by KEYSTONE FINANCIAL MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the March 7, 2001 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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 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, " -" ....-~ ~" - , 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 (215) 563-7000. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ", "--...~ .....- . " DESCRIPTION ALL THAT CERTAIN unit designated as No. C-2, being a unit in Pheasant Run Estates, a Condominium, located in North Middleton Township, Cumberland County, Pennsylvania, which unit is located on the Third Floor, Building I, as designated in the Declaration of Condominium recorded September 24, 1980 in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Book 258, Page 6, et seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record 312, Page 776, et seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, page 783 et seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, page 25 et seq., and together with plan recorded in the herein named Recorder's Office in Plan Book 38, Page 112. TOGETHER with all right, title and interest, being a .0059524% interest in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd, his wife dated 2/14/1995 recorded 2/22/1995 in Record Book 118 Page 861. , , I I I I I \ I I I I I I I I I I I I I I UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plans. Tax Parcel #29-17-1583-015B ~'t-' , ~ . ~-, SHERIFF'S RETURN - REGULAR CASE NO: 2000-02757 P COMMONWEALTH OF PENNSYLVANIA; COUNTY OF CUMBERLAND KEYSTONE FINANCIAL MORT CORP VS PATTERSON THOMAS E II ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PATTERSON THOMAS E II the DEFENDANT , at 0014:15 HOURS, on the 19th day of May , 2000 at 1402 BRADLEY DRIVE UNIT A-314 CARLISLE, PA 17013 by handing to CORRINA R. BAILEY 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 18.00 3.10 .00 10.00 .00 31.10 SO;~~A~~~ R. Thomas Kline OS/23/2000 FEDERMAN & PHELAN Sworn and Subscribed to before BY~JA)~ Deputy She f me this J...- day of qu<.P-..- d..mrO A.D, q~ {(, Ihdlh~,~ rothonotary ~" .... '\ ~ '} SHERIFF'S RETURN - REGULAR i" j'-i Ii " i CASE NO: 2000-02757 P !,'j I,,! COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KEYSTONE FINANCIAL MORT CORP VS i] '-1 PATTERSON THOMAS E II ET AL :' 'I GERALD WORTHINGTON , Sheriff or Deputy Sheriff of " i,l I ~ 1;1 I:i i Cumberland County, Pensylvania, who being duly sworn according to law, U ;1 says, the within COMPLAINT - MORT FORE was served upon :.1 ii BAILEY CORINNA R the ~. : DEFENDANT , at 0014:15 HOURS, on the 19th day of May , 2000 '! at 1402 BRADLEY DRIVE UNIT A-314 ;.1 n CARLISLE, PA 17013 by handing to Ii '"I CORRINA R, BAILEY l'i ! a true and attested copy of COMPLAINT - MORT FORE together with -'J i ,I l'1 I ::i ,I , " i !:I !:I I , fi fj I " " NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 ,00 10.00 ,00 16,00 So Answers: , ~/4 ~fJ?~,,<:~~ R. Thomas Kline OS/23/2000 FEDERMAN & PHELAN Sworn and Subscribed to before me this /.-.r day of By: ~~~ Deputy Sh . ff cl.tJ-oD A . D , {2~ P othonotary ..Ii "'. - . , FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, P A 19102 (215) 563-7000 KEYSTONE FINANCIAL MORTGAGE CORPORATION 2270 ERIN COURT LANCASTER, PA 17601 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DMSION VS. : NO. 00-2757 THOMAS E. PATTERSON, II CORINNA R. BAll.EY 1402 BRADLEY DRIVE A/KJA 1402 BRADLEY DRIVE, UNIT A-314, CARLISLE, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAlLURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against THOMAS E. PATTERSON, II and CORINNA R. BAILEY, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 4/11\)0 TO 6/20/00 TOTAL $34,966.47 $576.72 $35,543.19 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. 1~ 7-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: (,- rA./- 0--0 (JU/\M~ I? / ~ tu. PRO PROTU U'~ "TIllS FIRM IS A DEBT COLLECTOR ATrEMPTING TO COLLECf A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIiAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. .;>l -"'-. -,"~.., - ._,--- . ..~ ,~'" \; FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Perlrl Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY THOMAS E, PATTERSON, II CORINNA R. BAILEY NO. 00-2757-CIVIL TERM Defendant(s) TO: THOMAS E. PATTERSON, II 1402 BRADLEY DRIVE, A/K/A 1402 BRADLEY DRIVE UNIT A-314 CARLISLE, PA 17013 DATE OF NOTICE: JUNE 9. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against youA'lobYa hearing and you may lose your property or other impo " You should take this notice to a lawyer at once. If 0 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, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff -f" - . ~~" ~'~~K._". - " . ." ~ -..,! ~ 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 KEYSTONE FINANCIAL MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY THOMAS E. PATTERSON, II CORINNA R. BAILEY NO, 00-2757-CIVIL TERM Defendant TO: CORINNA R. BAILEY 1402 BRADLEY DRIVE, A/K/A 1402 BRADLEY DRIVE UNIT A-314 CARLISLE, PA 17013 DATE OF NOTICE: JUNE 9, 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telep~ne the following office to find out where you can get legal helPrJLE COpy CUMBERLAND COUNTY CUMBERLAND COUN:rY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for plaintiff .~ 'I ...iII. I, -:" ,~~ M"~. ..... FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Peno Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff KEYSTONE FINANCIAL MORTGAGE CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-2757 THOMAS E. PATTERSON, II CORINNA R. BAILEY 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 THOMAS E. PATTERSON, II is over 18 years of age and resides at 1402 BRADLEY DRIVE, AlK!A 1402 BRADLEY DRIVE, UNIT A-314, CARLISLE, P A 17013. (c) that defendant CORINNA R. BAILEY is over 18 years of age, and resides at 1402 BRADLEY DRIVE, AlK!A 1402 BRADLEY DRIVE, UNIT A-314, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ?~?~ FRANK FEDERMAN Attorney for Plaintiff .. .. L ~~" " (Rule of Civil Procedure No. 236 - Revised) KEYSTONE FINANCIAL MORTGAGE CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-2757 THOMAS E. PATTERSON, II CORINNA R. BAILEY Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JUNE /J../ ,2000. BY~ r1 ~DEPmY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPlllA. 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 THIS 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, ** i~l~niIil!IIIIl~:lHijd;iU'"l!I!.!;;'~;';';,,~~!:!l!r.w!,\~4i!""";""'tjJr,"'lk';)"_"~H_'-""r:iU'I~-'til<"'h'1l"">t'!!!ii;.:g:l!id!l~"';i;,'",~1Iilii;;j,"~~'~ '0 ~o$ji", ~-""-"'~'l~' '@ ~ ~ '"" ~ "'" n " \:::::> r::: ~ ~ ~ '-J ~ rc$ ~ .-Sl... ...... I ~ ~ ~ ~ (") c <- -nf~:' fl1r- -7:,' ~~:_: -<~ ~c: .1.-".--. <---71 -' L-;".. $c: 7' ~ ..~~ 'c:-') c:.} "'-' :)':::" :,n (;:) .~ ~~': " . I I ':_J 5~~ _U -< () iT) , ~ "^-",.~=--""'- .........1 L . ~- - ...1tq,;, . FEDERMAN AND PHELAN By; FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL MORTGAGE CORPORATION 2270 ERIN COURT LANCASTER, PA 17601 ATTORNEY FORPLAINTITF COURT OF COMMON PLEAS CIVIL DIVISION TERM v. NO. 06 - ,;('7S'( GU\'L '-r~ Plaintiff CUMBERLAND COUNTY THOMAS E. PATTERSON, II CORINNA R. BAILEY 1402 BRADLEY DRIVE, A/K/A 1402 BRADLEY DRIVE UNIT A-314 CARLISLE, P A 17013 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS FIRM 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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IT 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, P A 17013 (717) 249-3166 Loan #: 54411 ,~ - -' -~ ~~ ~ ~ ~"'-' 1. Plaintiff is KEYSTONE FINANCIAL MORTGAGE CORPORATION 2270 ERIN COURT LANCASTER, PA 17601 2. The name(s) and last known address (es) of the Defendant(s) are; THOMAS E. PATTERSON, IT CORINNA R. BAILEY 1402 BRADLEY DRIVE, A/KJA 1402 BRADLEY DRIVE UNIT A-314 CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 2/17/95 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. 1252, Page 267. 4. The premises subj ect 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 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." - ---,,~_--~I - ~"'- '-~'*"'~,- , , 6. The following amounts are due on the mortgage: Principal Balance Interest 9/1199 through 4/1100 (Per Diem $7.12) Attomey's Fees Cumulative Late Charges 2/17/95 to 4/1100 Cost of Suit and Title Search Subtotal $31,517.23 1,516.56 1,000.00 74.16 550.00 34,657.95 Escrow Credit Deficit Subtotal 0.00 308.52 308.52 TOTAL $ 34,966.47 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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 9. 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, PLAlNTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 34,966.47, together with interest from 4/1/00 at the rate of $7.12 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. /s~ederman FRAJ{KFEDE~,ESQU]RE Attorney for Plaintiff j""-' .,,-~ -- ~'> - -'~_"'~1 2270 Erin Court P. O. Box 7748 Lancaster, PA 17604-7748 K<:y'stone Financial Mortgage ~ corporatio~ 1-800-KEY-8131 (747) 399-6498 FAX (717) 397-2834 December 10,1999 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOM'E FROM FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose, Saecific infonnation about the nature of the default is provided in the attached paaes, The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to help save your home. This notice explains how the prOQram works, To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THI:DATE OF THIS NOTICE. Take this Notice with you when yOU meet with the CounselinG Aaencv, The name. address and phone number of Consumer Credit Counselina Aaencies servina your Countv are listed at the end of this .Notice. If yOU have anv Questions. voumav call the Pennsvlvania Housina Finance AQencv toll free at 1-800-342-2397, (Persons with impaired hearina can call (7171 780-18691. This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA, SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA, PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(SI: Thomas E. Patterson, II & Corinna R. Bailey PROPERTY ADDRESS: 1402 Bradley Drive, Carlisle, PA 17013 LOAN ACCOUNT NUMBER: 54411 ORIGINAL LENDER: Keystone Financial Mortgage Corporation CURRENT LENDERlSERVICER: Keystone Financial Mortgage Corporation EXHIBIT A 1 >~""",it""- " .--~ ~= -~ "L , ~ ''''~''''~~.''i . HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS . IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGILIBILlTY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY, TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 1301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAUL TO, EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and teleohone numbers of desianated consumer credit counselina aaencies for the countv in which the DroDertv is located are set forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within (30) days of your face-to-face meeting. yOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO 00 SO OR IF YOU DO NOT FOllOW THE OTHER TIME PERI0i5SSET FORTH IN THIS lETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE Will BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you If you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOllOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COllECT THE DEBT. (If you have filed bankruptcy you can stili apply for Emergency Mortgage Assistance.) EXHIBIT A 2 ''''-~I<ki!Il<-.~ ..Iiili """".' . " , HOW TO CURE YOUR MORTGAGE DEFAULT JBrina it UD to date}. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located a~ 1402 Bradley Drive, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $382.83 for the months of October 1999, November 1999 and $384.68 for the month of December 1999. LATE CHARGES AND OTHER CHARGES: $24.72 TOTAL AMOUNT PAST DUE: $1,175.06 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,175.06, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check, certified check or money order made Dayable and sent to: Keystone Financial Mortgage Corporation 2270 Erin Court P. O. Box 7748 Lancaster, PA 17604-7748 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, The lender intends to exercise its riahts to accelerate the mortaaae debt. This means that the entire outstanding balance ofthis debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments, If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose UDon your mortaaaed DroDertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If yOU cure the default within the THIRTY /30\ DAY Deriod, YOU will not be reauired to Dav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the richt to cure the default and orevent the sale at any time uo to one hour before the Sheriff's Sale, You may do so bY oaYina the total amount then oast due, olus any late or other charaes then due, reasonable attomev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as soecified in writina bY the lender and bY oerfonninc any other reauirements under the mortaaae, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSiBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sales of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender, EXHIBiT A 3 ",l.=,,,=_"~~ _='""'="~ ~w ,.~,~, , HOW TO CONTACT THE LENDER: " Name of Lender: Keystone Financial Mortgage Corporation Address: 2270 Erin Court, P. 0, Box 7748, Lancaster, PA 17604 Phone Number: (717) 399-7082 or (800) 760-1257 Fax Number: (717) 399-7099 Contact Person: Denise Lowrie EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor ..x.. may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER, TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, fl~~ Rebecca Boston Default Manager EXHIBIT A 4 ,i '~" iI~'- ~'.~I",~ ~ J - 2870 ~~ . . -~,~",,",' STATEMENTS OF POLICY CCCS of West em PA 219-A College Park Plaza Johnstown, PA 15904 (814) 539-6335 Lycoming-Clinton Counties . Commission For Community Action (STEP) 2138 Lincoln Street P. O. Box 1328 Williamsport, PA 17703 (570) 326-0587 FAX (570) 322-2197 CCCS ofNortheastem PA 201 Basin Street Williamsport, PA 17703 (570) 323-6627 FAX (570) 323-6626 CLINTON COUNTY CCCS of Northeastem PA 1631 S Atherton St Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 !-, COLUMBIA COUNTY CCCS of Northeastem Pennsylvania 1400 Abington Executive Park Suite 1 Clarka Summitt PA 18411 (570) 587.9163 or (800) 922.9537 FAX (570) 587-9134/9135 31 W. Market Street POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-166s-:.cALL BEFORE FAXING (570) 455-4994 HAZELTON FAX (570) 455-5631...:..cA1.L BEFORE FAiaNG (570) 836-4090 TUNKHANNOCK Booker T, Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX (814) 453-5749 John F, Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CCCS of We stem Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 234-2227 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 3n! Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 EXHIBIT A PENNSYLVANIA BULLETIN, VOL. 29, NO, 23, JUNE 5, 1999 -- ~~~~ - PENNSYL VANIA HOUSING FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Loan Program Payments General Information (717) 780-3940 Correspondence 2101 North Front Street General Information 1-800-342-2397 2101 North Front Street P.O. Box 15206 TDD # For Hearing Impaired (717) 780-1869 P.O. Box 15530 Harrisburg. PA 17105-5206 FAX # (717) 780-3995 Harrisburg. PA 17105-5530 , 3/20/2000 KEYSTONE FINANCIAL MORTGAGE 2270 ERIN COURT PO BOX 77 48 LANCASTER, PA. 17604 SUBJECT, S-U.LfI \ THOMAS E PATTERSON II 1402 BRADLEY DR A 314 CARLISLE, PA. 17013 Your application for a HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE LOAN has been DENIED pU~suant to Act 91 of 1983, 35 P.S. Section 168.401-C et seq. and/or Agency Guidelines 12 PA Code Section 31.201 et seq. for the following reasons' DELETED IN LENDER'S COPY You may be entitled to an appeal hearing if you disagree with our decision. We must receive a written request for a hearing within 15 days of the postmark date of this letter. (Appeal requests must be in writing; a verbal request is not acceptable). The hearing may be conducted by a telephone conference call; therefore, you must include your telephone number. Requests for hearings must state the reason(s) that a hearing is requested and must be sent first class, registered or certified mail to: Chief Counsel - Hearing Request, PHFA/HEMAP, 2101 North Front Street, P.O. Box 15628, Harrisbu~g, Pennsylvania, 17105-5628. The Agency will attempt to schedule the hearing within thirty (30) days after the request is received. When sending your appeal, please be sure to print your name legibly and include your social security number. You have a right to be represented by an attorney in connection with your appeal. If you cannot afford an attorney you may be eligible for Legal Services representation, You can contact a Legal Services representative through the following toll free number, 1-800-732-3545. Please be aware that scheduling an appeal hearing does not necessarily stay foreclosure proceedings. DISCLOSURE OF USE OF INFORMATION OBTAINED FROM OUTSIDE SOURCE, 1. Disclosure inapplicable. The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided that the applicant has the capacity to enter into a binding contract); because all or part of the applicant' s income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal Agency that adminis~ers compliance with this law concerning this creditor is the Federal Trade Commiss~on, Equal Credit Opportunity, Washington, D.C. The Pennsylvania Housing Finance Agency EXHIBiT A ,c " .. ... ~" c . ~~ " "" ALL that certain unit designated as No. C-2, being a unit in Pheasant Run Estates, a condominium, located in North Middleton Township, Cumberland County, Pennsylva~ia, which unit is located on the Third Floor, Building I, as designated in the Declaration of Condominium recorded September 24, 1980 in the Office of the Recorder of Deeds for Cy,mberland County in MiscellaneoLls Book 250, Page G, et seq. { Clnd which'Declaration waG amended by Ainentlm.ent dated Novelnber 14, 1985~ and iecorded December 23, 1985, itl the hereinafter Inentioned Recorder1s Office in Miscellaneous Record Soak 312, Page 776, et seq., and was further amended by Amendment dat.ed November 14, 1985{ and recorded December 23, 1985, in the hereinafter mentioned Recorderrs Office in MiscellaneoLls Record Book 312, Page 783 et seq., togethe" with a Code of Regulat.ions for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1900, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, page 25 et seq., and together wittl plans recorded in the hereinafter named Recorderls Office in Plan Book 38, page 112. TOGET!IER with all right, title and interest, being a .0059524% interest in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. UNDER and subject to all agreements, conditions, easements and restrictio~s of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plans. BEING known and numbered as Unit A-3l4, 1402 Bradley D"ive, Carlisle, Pennsylvania 17013. BEING the same premises which Carlisle Apartments Limited Partnership I a limited partnership acting herein as Metlanca Inc., a gene"al pa"tne" by deed dated November 1 1980 and ' recorded in the Office of the Recorde" of Deeds in and fa" Cumbe"land County in Dee~ Book 29-F~ ~age.74, ~ranted and conveyed to Sean M. Dowd. Mar]orl.e W. Dowd ]ol.ns ~n th~s conveyance to' ..' - extinguish any right, title or inte"est she may have to said property by reason of marriage to Sean M. Dowd. THE grantee, for and on behalf of the Grantee and their heirs personal representatives, successors and assigns, by the ' acceptance of this Deed covenants and agrees to pay for such charges for the maintenance of, repairs to, replacement of and expenses in connection with the common elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania, as amended, and further covenants and ag"ees that the Unit conveyed by this Deed shall be subject to a charge for all amounts so assessed and that, except insofa" as Sections 705 and 706 of said Unit P"operty Act may relieve a subsequent unit owner of liability for prior unpaid assessments this covenants shall run with and bind the land or unit hereby'.' conveyed and all subsequent owneFs thereof. " . ~~~ , - , ~ ~ rei" ': ; ii ;'1 :J I. .' :.1 I::: VERIFICATION ROBIN YOHE hereby states that he/she is VICE PRESIDENT of KEYSTONE FINANCIAL MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/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 his /her knowledge, information and belief. The undersigned understands that this statement is made subject 10 the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. <-!?aL fj~ DATE; .5"':;<-00 1~_ItiIIiWi~~~">l"",~~m~,lIJWlI~illiillli1it!;1,j~~~=-"<J_-~._'~>"""I...~~ - "_-~ ~ ~ :.' ,!..-." ~., 'C ~, ''''-''- . . . -. 1ft ~ t ~ ~ 0 (::t ~ ~ 0 c C) 8 'v" <'" :r; G 8 ""'OeD .-1 :u- -l.'- ..CJ ~ rnnl ..... f11.fll 0 2:.n ZC;::: I -'~-Jm I/) U~d..;. .j;;'" :00 -<....~ 06 ~ .lJ ~ ~c; -,..; 1:J ;I> ~-' ... -J :> ;-s:i:l )J p:: zO ::r zO t: -..n '2 )>c om "t z '" ~ =< '0 -< - -f.-' AFFIDAVIT OF SERVICE PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.00-2757 DEFENDANT(S) THOMAS E, PATTERSON, II CORINNA R. BAILEY Type of Action - Notice of Sheriff's Sale SERVE AT 1402 BRADLEY DRIVE, A/K/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Sale Date: DECEMBER 6, 2000 SERVED Servedandmadeknownto 1tOIM~5 If 1 f;).*~SotJ :JI;Defendant, on the at~o'c1ockf.m.,at J'fo~ 6~h''( YJc..-. UN'~ 1>-.-)14-. of Pennsylvania, in the manner described below: \o..~ C:~\., dayof Seftew .200~ G~(l..bk fA I . Commonwealth Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant( s)' s residence who refused to give name orrelationship. ).\ . "\'^. "" c.,,'f.\' <, \ <- Manager/Clerk of place of lodging in which Defendanl(s) reside( s). \ W\;:': ~ \ " Agent or person in charge ofDefendant(s)'s office or usual place of business. f.)'~\\ --( w\<\: I' anofficerofsaidDefendant(s)'scoljlpany. G' . R, <)/1.,. vI-> ~ Other: .~...c 5 ...' . 5 5;>.\'<. W3"> :;let..- ~'<.~ \0 '~IIOt:->",,'-\'i \ ~\M"'$, f[. a:' (:((50"""_ _" \'l-e..~ ~~ J os I 0;;1.. ft.. fJo c:, t3-SS'e5 -1_ Description: Age..3Q. Heighl 6.5 Weight~ce WI" Sex F Other sit<....'., \..A. 13'o,,~ \,","f- I, C'\a.({...rJc<<. L. c.'Oolt \7 . 'J/t , a compelent adult, being duly sworn according 10 law, depose and state that I sonallyhanded a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth rein, issued in the cap' ed case n e date and at the address indicated above. ;J Notarial Seal Stacy l. Heefner, Notary Public Sworn to and stW~fribed Chambersburg Bora, Franklin (;ounty be~;'b~; ~ day My Commission Expires Aug. 5. 2002 f 200 A. ember, Pennsylvania Association of Notaries ~o : 8N' (r~ By: NOT SERVED On tbe ___ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed belbre me this _ day of ,200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D, No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102 (215) 563-7000 ~IdMii:' '0 -.iri _ill!MIiIIIIII_~lil;:!imfJ;~I~_~iilj!ill~i!!lll;i.iu;Ullililiii;'. ~m!!Bi""-' ~"'~'-""iaUIiL "," '. ' ",..," , ....."".: " "- C> 0 ~ ~ 0 en -, ,.,J "'OU) r"1 +;:!J 9lgj """ . '-r- 2~ N ~;~~8 ~~: N ,;;.-,~ JQ ,.,~!. . '20 ..-0 ~l- . ?-):JJ :F>O :;J!: '::c,() 20 - ?::,fTI )>c: .. ~ 2 U1 ~ ::<! r ~ ~~~ ~~ nll ~_. , AFFIDAVIT OF SERVICE PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No,00-2757 DEFENDANT(S) THOMAS E, PATTERSON, II CORINNA R. BAILEY Type of Action - Notice of Sheriff's Sale SERVE AT 1402 BRADLEY DRIVE, A/KIA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Sale Date: DECEMBER 6, 2000 1:, l' ~o , al . , 0 clock +-.m., at /40;). SERVED ~. (bJ., \1:.'1, Defendant, on the t3~"'.l\ltf ~f-. t>",\~ ~~3''4-. C tf-t.. day of ,'it~ ,~~o~ CC)~ \ ~ ~ \ ~, fA, Commonweallh , ~i I ,,I i-ij :.:i Served and made known 10 Co ~ i t-J 1\1 <;:l " , of Pennsylvania, in the manner described below; X Defendanl 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 ofIodging 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. 'i' ,'I i Iii !'I i:: hi '11 Other; _"' JIo" _ J.I \'il-Sse:; Descriplion: Age .J 0 Height LJ' Weight / ;'S Race W,^ Sex L Other ~';.O 5 l... .cz I ..1 <l \k it ::11'''''';5''' ~ r.J 0", \ I, <:Ialt et.J"... L, C~fI.:\'f .~a competent adult, being duly sworn according to law, depose and state that I personally handed a true and corr~ct copy of the Nolice of Sheriff's Sale in the manner as set forth herein, issued in the C(1faf d case~n dale and at the address mdlcated above. Nolanal Saal (!bee vf . Stacy L. Heefner, Notary.publiC Sworn to and s~Cribed Chambarsburg Bora. Franklin County b . d My Commission Expires Aug. 5, 2002 e~:l:. t: ;U ay 'n ~o~.t.r ~~~ Mamber.Pe~~~YlvamaAssoclatlonotNota as l) U 0' NOT SERVED Moved Unknown No Answer Vacanl "I Ii Iii II I .I 'I :1 , ;1 I I I " " II " 'I I I I I I , I 0ume /~ay of ,200_, at o'ciock _.m., pefendant NOT FOUND because: Oti,er: Swom to and subscribed before me this _ day of ,200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I,D. No, 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 ~1I1.jl--~~ ,< h/iljBi$!;,~,~allj..f"~ """'~"--""""'-'Ju:li:>lJl'J;iiJi~'Jill'i" ~.....A - Ji",",~_ .....". " ,',~ '~' .' c ~ . g 0 Q, 0 s:: en --,1 -oc.<l 1"'1 :L---r<< mg; -0 111;:2:;: 2' N '""lhj 21:; N "~c.: ~.-;; ,~, i ":.,.~{ (J: ,<C) '"'0 .....,--r'l ~:D iO ;:x ~.~O C:1 am c: --1 .,," :.n ~ ~ - '< ~ _~r-__ oc..J ...."'--, . .... . ~ .......... ' Keystone Financial Mortgage Corporation -vs- Thomas E. Patterson, II, Corina RBailey ~ ,~.. , 'K '1; In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-2757 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed, Sheriffs Costs: Docketing Poundage Posting Bills Levy Certified Mail Mileage Surcharge Law Library County Postpone Sale Share of bills 30.00 2.77 15.00 15,00 .64 3.10 30.00 .50 1.00 20.00 23.15 $ 141.16 pd by arty 10/09/00 Sworn and Subscribed To Before Me This 1/ te:.. Day of m~ /'_.'.'--"\ 2000, A.D. ~tLQ. .~ I~' Pro onotary S~~ R Thomas Kline, Sheriff BYV.u ..J.t,14 Real Estate Deputy \,&0 t.J..z. 3bD:?D i0.v /o}.J/~ - :IlIilb......... 1-- # ; \. ~ KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION THOMAS E, PATTERSON, II CORINNA R. BAILEY NO, 00-2757 Defendant(s), AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) KEYSTONE FINANCIAL MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, setsfortli as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 1402 BRADLEY DRIVE, A/KJA 1402 BRADLEY DRIVE, UNIT A..314. CARLISLE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS E. PATTERSON,n 1402 BRADLEY DRIVE, A/KJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 CORINNA R. BAILEY 1402 BRADLEY DRIVE, A/KJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 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 Ii'-. "- , ,-~ "t" ~ ; " .. 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Members 1st Federal 5000 Louise Drive, P.O. Box 40 Credit Union 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 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 1402 BRADLEY DRIVE, AlKJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Pheasant Run Properties 1824 Sterretts Gap Avenue Carlisle, PA 17013-1249 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. August 23. 2000 DATE .1'; , I . " .". , , ,- KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No, 00-2757 v. THOMAS E, PATTERSON, II CORINNA R. BAILEY Defendant(s). August 23,2000 TO: THOMAS E. PATTERSON, IT CORINNA R, BAILEY 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 ""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 1402 BRADLEY DRIVE. AlK/A 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE. PA 17013, is scheduled to be sold at the Sheriff's Sale on DECEMBER 6. 2000 at 10:00 a.m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by KEYSTONE FINANCIAL MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the March 7, 2001 Sheriff s 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: 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. "'..""'."".""''11 '" ~ , ~L .- ....I~ ".~ <. , 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,) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd 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 fmd out if this has happened, you may call (717) 240-6390, 4. !fthe 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 '--.'~- - ',--' "" , "-"''''~- -~ - ~. ~" ~~,1~*, . ,/ , ., DESCRIPTION ALL THAT CERTAIN unit designated as No. C-2, being a unit in Pheasant Run Estates, a Condominium, located in North Middleton Township, Cumberland County, Pennsylvania, which unit is located on the Third Floor. Building I, as designated in the Declaration of Condominium recorded September 24, 1980 in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Book 258, Page 6, et seq., and which Declaration was amended by Amendment dated November 1+, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record 312, Page 776, et seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, page 783 et seq., together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and recorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, page 25 et seq., and together with plan recorded in the herein named Recorder's Office in Plan Book 38, Page 112. TOGETHER with all right, title and interest, being a .0059524% interest in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plans. Tax Parcel #29-17-1583-015B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd, his wife dated 2/1+11995 recorded 2/22/1995 in Record Book 118 Page 861. /~ - ~ ~~~~ :b , , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-2757 Civil_ Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Keystone Financial Mortgage Corporation PLAINTIFF(S) from Thomas E. Patterson, II, Corinna R. Bailey, 1402 Bradley Drive, A/K/A 1402 Bradley Drive, Unit A-314, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description (2) You are alsbjdi~lecfI8)'atl'a'c~'th~"~~~perty of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: '" .,)H~ and to notrry the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthedefendant(s) not levied upon an subjectto attachment is found inthe possession of anyone other than a named garnishee, you are directed to notrry him/her that he/she has been added as agarnishee and is enjoined as above stated. % L.L. Due Prothy Other Costs $.50 $1.00 Amount Due $35,543.19 from 6/20/00-12/06/00 - $986.96 Interest per dien ($5.84) My's Comm My Paid Plaintfff Paid $119.10 Date: August 28, 2000 Curtis R. Long Prothonotary, Civil Division 4f2-? ,,- 2.. 77;C17~.J Deputy ,,---by: REQUESTING PARTY: Name Frank Federman, Esq. Address: TWo Penn Center Plaza, Suite 900 Philadelphia, PA 19102 Attorney for:Plaintiff Telephone: 215-563-7000 Supreme Court 10 No. 12248 iII~~'I'.'."'~"QaJIiiildi!ll~~Ulll;ll~~~__.'.if''''Ii-..i~.gw-",","~dM"- " " .!Illiii '"""",,~",,,"','>lh - "It l"If"' -"' - ~:[;:F\lj !C'(~:i"!~,4r~i~~' '~,'~~~i ': ~..-,. "~:~_:_ \' 1J,~a...~~L LbtJbH'"htJ it ~~tl~L~~ ~"tl0c ... . I ~ On ~ 3 I, ?-rrrV the sheriff levied upon the defendants interest in the real property situated in,41/7'>~~//iL~</, Cumberland County, Pa., knowr ,nrll1umbered as: J<.j/)2, A....JtJ't)tZ_~A-3i'l a i e4. f. and more [I,{, on Exhibit "A" filed with ~ c=;;:i1 c:;::::2 G=e> UVil this writ and by this reference l')ate:rZ'(<'.I,....~I?/ ~) ncorporated herein. "'1'; \-I I ,,'.. , C' , i ., ~J ,.l ~~ ;': -'f i \ j _--': '-; I",: ':""J ~~ re, , ~c n' nc. 90H ,Lu ._ 6_1 L' lJ~ V UkH. .,.,n0 ;j'!II!~H~":.,,,I, ,1.!i~~g , .,~~- - '"" ",","', .t!'il~~:!!'.i!f1.' . . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 P~ELPfDj\,Pi\ 19103-1814 (71 'i) 'ifi1-7000 ATTORNEY FORPLAlNTWF COURT OF COMMON PLEAS CNIL DMSION KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.: 00-2757 vs. THOMAS E. PATTERSON, II CORINNA R. BAILEY AFFIDAVTT 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 THOMAS E. PATTERSON, II and CORlNNAR. BAILEY on April 17,2001 at 1402 BRADLEYDRNE, A/K/A 1402 BRADLEYDRNE, UNIT A-314, CARLISLE, PA 17013, in accordance with the Order of Court dated April 11,2001 . The undersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unswom falsification to authorities. '~nm1 ~~~ ~FEDERMAN,ESQUIRE Date: April 70. 7001 ....., ~r ~ 0- _ ~ t u, ~. 3 o .,. 0.0 .,." '<8, on o " 0. ~ "'..., ::.:, ~~ rr, '. a.t ~ ~g. ~ OC~ -., ,0 ..., 0:;: t>l :i~' ::.:, g ~ ~ o .< ~ m.. ~ 3 0 ,.. ""~ ~ ~ ~ ~ o ~ o 0 -:' .. , ~ Z . ~ o - ~ o ;;' 3' '" ~ ~ ~ ..., - .." - o 'D 00 - N - w );~;y~'~:r~ {-l- Po?\'.;; 'J \ )> F . ~,~ .:...:; ~, ~: ,,> .?\/d1I~t.t-- -w - -.l '" OJ< (" .." w "~ ~ N ("l o ... 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PATT~RSON 1402 BRADLEY ::JRIVE, AlKlA 1402 BRADLEY DRIVE, lJ.NIT A-314 CARLISIE, PA 170:j TO: SENDER: LEO REFERENCE: SALES PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Rec"eipt for" Certified Mail No Insurance Coverage Provide~ Do Not Use for International Mall CORINNA R. BAILEY 1402 BRADLEY DRIVE, A/KIA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 SENDER: LEO REFERENCE: SALES .34 1.50 1.90 0.00 ,74 PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees -" .-tl".-~ . ,r~:-."''II r!!-~~ . "r~'j"~) ~~_: ."~i <-. ~ US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use lor Jnternatlonal Mail ~ ~ ;- ~ '""""'~)1l::,1 .. FEDERMAN AND PHELAN By: FRAJiKFEDERMAN,ESQlmRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (71~) ~h1-7000 ATTORNEY FOR PLAINTIFF C01JRT OF COMMON PLEAS CIVIL DIVISION KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.: 00-2757 !. ftr!O!RMAN AND .. ... ATTORNEY flU:~' PLEASE RETURN vs. THOMAS E, PATTERSON, II CORINNA R. BAILEY AFFIDAVTT 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 THOMAS E, PATTERSON, II and CORINNA R. BAILEY on April 17,2001 at 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNlT A-314, CARLISLE, PA 17013, in accordance with the Order of Court dated A prilll, 2001 . 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 au~~orities. ~lv(\1 ~tLM1'tfLY1 ~FEDERMAN,ESQlmRE Date: April 70. 7001 JlEDERMANAtfl) PHe., AmtRNEY F.lE eopy PLEASE RETURN i~l~ilitiU~~jllW\i:>>"a",~J:\)~;~I~'1.l.,1&I~Ii1llilii~~i~<lli'liJio;lr"~~H,,;;"{,',M~~dJi'~:.rn~,"'" ,,',- " ,.,,1" , ~,. hi~~_- ; ~. "- ~",.! . ;;; t~ ;",- - ~', .,\' , ~ .,. J ~_ ,,~._.. ~ ~, ~;f_!jJIil!llJ\mliIi~ll>tiM_'<Illl!:'MII!lI -JjLiJ "'4 '- - '. ~ - (") <:::> C () ? .";'"f "'Om 1>0 ffiTn -"J ~~;.! ~~} ::u rtl~ r>~ N --om W "]6 :;::0 C) i8 -0 --f ::JI: =c-,-; Qil5 ~ w om " - :;;! \.0 ::0 -< o~ . ~ 1';__ ~w,.;.,. ~, ,.~tR!.-~-: < ,'1 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.c'P.3180-3183 KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v, No, 00-2757 THOMAS E. PATTERSON, II CORINNA R. BAILEY I1efendant(s), TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $35.543.19 Interest from 06/20/00 - 06/06/0 I $2.049.84 and Costs (per diem - $5,84) $37.593.03 TOTAL ~~ FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. 1402.. i3m.ttI-el.( 1Jy: {,iflA .4 - 3/4- (!.a..r{iiJlc... FA I7IJ/j -- ......,~~MM!t~~~~1!I!l!<1~~~,ibi!li'imi~d_'1 ';',,;... " 1I."""~~""'~~ri;" ....-~;..'-- .., - 10.. ~.~ ,~,..~" r. .... ..,...,. .... .... ..., ..., << E-<E-< .... .... ZZ ~~ ~~~s ....QQ~ ~~~< !:l:1 roil roil=- ........ . ~~~; Zi:Qi:Q~ ;!.......... 000 U;:!;;:!;U ",,;:$ Z o~ ~ 0 =~~ 00;> .... <.... E-< roiI~ .... ~ :i'~ .... S:OO ~ . 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DESCRIPTION ALL THAT CERTAIN unit designated as No. C-2, being a unit in Pheasant Run Estates, a Condominium, located in North Middleton Township, Cumberland County, Pennsylvania. which unit is located on the Third Floor, Building I, as designated in the Declaration of Condominium recorded September 24, 1980 in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Book 258, Page 6, et seq., and which Declaration was amended by Amendment dated November 14, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record 312, Page 776, et seq., and was further amended by Amendment dated November 14, 1985, and recorded December 23, 1985. in the hereinafter mentioned Recorder's Office in Miscellaneous Record Book 312, page 783 et seq.. together with a Code of Regulations for Pheasant Run Condominium Association dated September 17, 1980, and fecorded September 24, 1980, in the hereinafter named Recorder's Office in Miscellaneous Record Book 258, page 25 et seq., and together with plan recorded in the herein named Recorder's Office in Plan Book 38, Page 112. TOGETHER with all right, title and interest, being a .0059524% interest in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plans. Tax Parcel #29-17-1583-015B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd, his wife dated 2/14/1995 recorded 2/22/1995 in Record Book 118 Page 861. i_. ~~, ~..~~ ,- ~~ ~ ~ } " " _JiIliIiI _. ~ 1; D N -k~_' -~. . -""~~ild;~;"'~ifmf!l!i,;ililll '","Ow ~ -... 'g _', "I . ~. '"~, , . '.' d'''d_~", ~"'''''i 9-:> -:r )-.J \-;! ~ J ..........<-.>> .......... -t-".J~G.I -t::--. _ _"- ~ _ _, ~ <:'>1 ~). . _' Qi C :-. <>5o\:> - % '" "" ~ ~ . '"" n ~ ~?~t :f:: j-Cl c/:." _}:. ~ ~, ~~2 ~ .. .. ". C:~) '. " 1 (;(~ .bC; r""J 0'" II Ii " i I Ii II ii 'i Ii I i I I ~ . ~ ;c~"""""",m - , ~ _' -<~ ~ . L , , " "".:j,. ..4 -. KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v, CIVIL DIVISION THOMAS E. PATTERSON, II CORINNA R. BAILEY NO, 00-2757 Defendant(s), AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) KEYSTONE FINANCIAL MORTGAGE 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 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314, CARLISLE, FA 17013. I. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address canoot be reasonably ascertained, please so indicate.) THOMAS E. PATTERSON, II 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 CORINNA R. BAILEY 1402 BRADLEY DRIVE, ArKfA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address canoot 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 canoot be reasonably ascertained, please so indicate.) None ~-" '-~~~ = " ,~ -.-, ""i ~, 4. Nanle and address ofthe last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Members 1st Federal Credit Union 5000 Louise Drive P.O. Box 40 Mechanicsburg, P A 17055 5. N anle 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. Nanle 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/Occlllpant 1402 BRADLEY DRIVE, AlKlA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 Pheasant Run Properties 1824 Sterretts Gap Avenue Carlisle, PA 17013-1249 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. February 22.2001 DATE ~~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff iillMiiJ'> "~.'" """'"'''''.".'< ".~ '", .", , 1J1d1~ilmIi!t:lC:'1l,fi,,(M#~i<i~,jjriMC ~". ,~ " I. -~".~ -~,~ >.~ .i.:;,;;;.,..~' L.'<~_". Lii.~'-""'~'~~"~ """~B C) (~:: -rlt;~ gJL; "--;-." (:~:~.~ ~;t_, 10 f3 -7 <~ .~ ,- -< (;-, 'Ij r~ c_-~ . ~." f'c) ...l , I ~iItOIbilllilali:!~;. r) , '..., InJ...... 'JSJ f INRE: '\ \J l:ho~nas Eugene Patterson, II . ) Comma Renee Patterson Debtor(s) UNITED STATES BANKRUPTCY COURT FOR THE MlDDLE DISTRICT OF PENNSYLVANIA Mil" v, <15 () C) Cj J)- Chapter No.7 cf ,~ F f\,' (G) IJ '-j:.,+ Bankruptcy ~O~::354~~:~'~rg;:~I') fi~:~"'" 1: ,,-::':C:':C;-\ \ \ \ Ute 'I"' L' \ \ " .----_..----~., -. Keystone Financial Mortgage Corporation Movant Thomas ~:ugenePatterson, II Curinna Renee Pattersoll Respondant (s) C\" \ " e\<,'., -. ...".,..- ~..::.~-_... AND NOW, this 13m QRQER " day of ~ , 2000, upon consideration of the Motion for Relief and Motion for Default of Movant, Keystone Financial Mortgage Corporation, it is hereby ORDERED that the Order for Relief be entered by default with respect to premises at 1402 Bradley Drive, Carlisle, P A 170] 3 a/k/a 1402 Bradley Drive, A-314, Carlisle, PA 17013 to allow the Movant to foreclose on its mortgage, which mortgage was recorded in Cumberland County, in Mortgage Book 1252, Page 267, to allow the Movant to foreclose on its mortgage, and allow the purchase of said premises at Sheriff's sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. By the Court: Is} f\oilenj. 'i,;,..;,;,;,..,j Robert 1. Woodside, Bankruptcy Judge ce: Judith T. Romano, Esquire One Penn Center at Suburban Station t617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 Thomas S. Diehl, Esquire 401 East Louther Street Carlisle, PA 17013 Leon P. Haller, Esquire (Trustee) 1719 North Front Street Harrisburg, PA 17102 Thomas Eugene Patterson, II Corinna Renee Patterson 1402 Bradley Drive A-314 Carlisle, PA 17013 ~j-';', '11lClIiIlifIIlI !!II - " ~'" -li;;~w~niDWl!lllYlllf~~iJ.~""~"ld'iiWit!jllil1.!!\;)I>iIi_;lLiIl_ ~,,~~' - I ~_?_~ .<=~"" , ~~Mlll~t' ...:~~"" - ~- ~ . -- .'. ~ CJ C" d3 /~!:. ~,,;::r -'/ ,-. (15 \- ~~;: ;~~ -' . ~7' '. ':;,-''''" ",::0",- /-" -.,_1 -"(' - o ~ _ -'=" ("f"' ~'--'! C) '--J C", ;....,J ~ -'~' ~ - " '., ~'" ' ^' .~-I FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Snburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION THOMAS E, PATTERSON, II CORINNA R. BAILEY NO, 00-2757 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 unsworn falsification to authorities. ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff li_!:Ml .......1Iid'~~~~~lliBi~!Hir~"'~LO"'~"""",:,{~t""01,,~~Al~ , . ~"', , It ~il:kIiIl"-"'" ~"~In" , ..&l1mJ c <;;; <:.. ;fIr ~;: ~t~ '7 >~~~ C::'I :r: :.:-, '.~ C'. ----;:'1 '-"-,:J :,'?: ()i -",. .... ~. II" 'j"" ... I KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No, 00-2757 v, THOMAS E, PATTERSON, II CORINNA R, BAILEY Defendant(s), February 22,2001 TO: THOMAS E. PATTERSON, II CORINNA R. BAILEY 1402 BRADLEY DRNE, NK/A 1402 BRADLEY DRNE, UNIT A-314 CARLISLE, P A 17013 **THIS FIlUvl IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORi\1ATION 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 1402 BRADLEY DRIVE, NK/A 1402 BRADLEY DRIVE. UNIT A-314. CARLISLE. PA 17013, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 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 KEYSTONE FINANCIAL MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 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 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. ,r"-~- ~- ~ _L .~ ., '_.'. It , 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 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. 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, PA 17013 (717) 249-3166 (800) 990-9108 ~ . " - ~~-. -. - "",'~" DESCRIPTION A.LL TH.-\ T CERTA.I)f unit designated as )fo. C-2. being a unit in Pheasant Run Estates, a Condominium. located in )forth :Vliddleton Township, Cumberland County, Pennsylvania, which unit is loc:lted on the Third Floor, Building I, as designated in the Declaration of Condominium recorded September 2-+, 1980 in the Office of the Recorder of Deeds for Cumberland County in Miscellaneous Book 258. Page 6. et seq.. and which Declaration was amended by Amendment dateLi November 1-+, 1985, and recorded December 23, 1985. in the hereinafter mentioned Recorder's Offic:: in :Vliscelbneous Record 312. Page 776. et seq.. and was further amended by .-\mendment dated )fovember 1-1-, 1985, and recorded December 23, 1985, in the hereinafter mentioned Recorder's Office in :-"liscellaneous Record Book 312, page iS3 et seq.. togerher wirh a Code of Reguiarions for Pheasam Run Condominium ,-\ssociation dated Seprember 17, 1980. and recorded Seprember 2-+. 1980. in rhe hereinafter named Recorder's Office in :Vliscellaneous Record Book 253. page 25 et seq., and together with plan recorded in (he herein named Recorder's Office in Plan Book 38. Page 112. TOGETHER with all right. title and imeresr. being a .005952-1-~-; imerest in and to the Common Elements as more fully set forth in [he aforesaid Declaration of Condominium and Declaration Plans. CNDER .-\)iD SCBJECT to all agreements. conditions, e:lsements and restrictions of record and [0 [he provisions, easements, covemnts amI resrrictions as contained in the Declar:ltion of Condominium. Code of Regulations :lnd Declaration Plans. Tax Parcel 429-17-1583-0 15B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd, his wife dated 2/141l995 recorded 2/22/1995 in Record Book 118 Page 861. i~III~Wl.~~&;ll;i,~~~I~~i!I!!~,,,,..;,'tII"""~~~U.lM' ".~'MUiiIIl~ r:r ~, . "~..;" ."~""'-= h.,,,,,,_,,,,,,,,,,,,",, ~ ,~ "~", ~. d IT! ,', ("(l_' .:;..- ~: [~~ r-.. ~;-, ( S:~~ <- --i -< ~ ,---, r'",) (7) - ~ , f STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _____________________________________________________'________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ________________ __~~~_e_~~!_p_~~~~3_~~_~~_~~~~J?_~_~~_~~:~~_~~~~______________________________________ ~ the grantee the same having been sold to said grantee on the _____________<1.l;,h_______________________________ day of ___..!J;1!l_~________________________________ A, D., ; 200L___, under and by virtue of a wriL_____________ Execution , ____________________________ -_________ -__ _______ ISSued on the ___ --_C>.th.______ __ ______ ____ __ _______ f March A D 2001 , . day 0 __________________________ .., _____, out of the Court of Cornman Pleas of saId County as of Civil ------------------------------..-- --- ------- n_ -- -- ----_ ___________________ ______ _ Tenn, i 000.---- Number ___~Z~L______, at the suit of ___~:.~~:~':~_!!_':~:~_a_~_~~_':.~~~.?_:_~.?_r:.~______________________ --_____________________________ __ __ against- _.:rJ!Q!!1.!tS__~_fJ!.1;t~.F_f!.Q!LJ)~._~__f.~! !~~~_~_.A l!!}_~:t_ is duly recorded in Sheriff's Deed Book N!>. ____2.41-____, Page __'n!fL_____. IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office th~ ____i3:.Lf.__ day of ____________~----------- A. D., ;J.-D_~L ----'f4.~--~~-'khI--~ Ilecordcr of Deeds Retonler of Deeds, Cumberland County, Cartisle, PA My Commission Expires the First Monday of Jan. 2002 . .u . ~ , -." ~-; , I Keystone Financial Mortgage Corporation VS Thomas E. Patterson,II and Corinna R. Bailey In the Court of Common Pleas Cumberland Connty, Pennsylvania No. 2000-2757 Civil Shannon Sunday, Deputy Sheriff, who being duly sworn according to law, says on April 17, 2001 at 6:10 o'clock P.M. EDST, she posted a copy of Real Estate Writ Notice Poster and Description on the property of Thomas E. Patterson II and Corimla R. Bailey located at 1402 Bradley Drive Unit A-314 Carlisle, Cumberland County, Pennsylvania, according to law. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on April18, 2001 at 3:10 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Thomas E, Patterson, II, by making known unto Larry Dale Flora, adult in charge, at 211 Red Tank Road Boiling Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 3:10 o'clock PM EDST, he served a true copy of Real Estate Writ. Notice Poster and Description in the above entitled action upon one of the within muned defendants to wit: Corinna R. Bailey, by making known unto Larry Dale Flora, adult in charge, at 211 Red Tank Road Boiling Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants to wit: Thomas E. Patterson by regular mail to his last known address, 211 Red Tank Rd. Boiling Springs, P A. This letter was mailed under the date of April 19, 200 I and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants to wit: Corimla R. Bailey by regular mail to her last known address, 211 Red Tank Rd, Boiling Springs, PA. This letter was mailed under the date of April 19, 2001 and never returned to the Sheriff's Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock A.M" EDST. He sold the same for the sum of $40,000,00 to Attorney Dale Shughart for Federal National Mortgage Association, it being the highest bid and the best price received for the same, Federal National Mortgage Association of 1900 Market St., Suite 800, Philadelphia, PA 19103, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of$I,848.12, it being sheriff s costs. Sworn and subscribed to before me This ~o ..j;-day of G4 2001, A.D. ~ (l '1-VI,pi,^",(~ Pro otary Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer County Mileage Certified Mail Levy Surcharge Legal Search Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed ~" ~ -'re 30.00 800.00 15.00 15.00 30.00 10.00 1.00 7.44 1.39 15.00 30.00 200.00 353,75 262.95 25,09 25.00 26.50 $1848.12 Paid by Attorney Frank Federman 7-06-01 ~ ~ ~~. ,;y-.-n-~""<< -r-- r~ ~ - . ~:lliomas Kline, Sheriff .... By ~ JVYI~ih Deputy Sheriff aI-'~ J6.uV G ' j,Q1l -1 .,7- ",It'>) If''l11 ~~II ,-.... ~...... ..' "- ~" """-'i:-.! i to SCHEDULE OF DISTRIBUTION SALE NO. 14 Writ No. 2000-2757 Civil Keystone Financial Mortgage Corporation VS Thomas E. Patterson, II Corinna R. Bailey 1402 Bradley Drive, a/k/a 1402 Bradley Drive, Unit A-314 Carlisle, PA 17013 Sale Date - June 6, 2001 Buyer - Federal National Mortgage Association Bid Price - $40,000,00 Real Debt Interest from 6/20/00 - 6/06/0 I (per diem - $5.84) Writ Costs Total DISTRIBUTION Total Collected Sheriff's Costs Legal Search Total Refund of Advance Costs Date Filed - July 6, 2001 $35,543.19 2,049.84 272.76 $37,865.79 $ 1,848.12 1,648.12 200.00 $ 0.00 $1000.00 ~~s~s: ;--- ~..'. -I: ~ r ~ c..(I R. Thomas Kline, Sheriff BY-flO~ J~'Vu<C~ R al Estate Deputy ~"'l~ -...... - I -~ '. . .JI TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WmCH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 14 Held Wednesday, June 6, 2001 Date: June 6, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive, Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer, Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below, JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2001, and recorded , 2001, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Sean M. Down MaIjorie W. Dowd, his wife by Deed dated February 14, 1995, recorded February 22,1995 in the Office of the Recorder of Deeds in and for Cumberland County in Carlisle, Pennsylvania in Deed Book 118, Page 861 granted and conveyed to Thomas E, Pheterson, II and Corinna R. Bailey, OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attomey acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3, Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose, 4. Payment of State and local Real Estate Transfer Taxes, if required. 5, Public and private rights in the roadbed of 74 foot roadway known as Bradley Drive and adjacent parking area, 6. Conditions, covenants, easements and restrictions shown on or set forth on in the Declaration of Condominium for Pheasant Run Condominium dated September 17, 1980 and recorded September 24, 1980 in Miscellaneous Record Book 258, Page 6, as amended by amendment dated November 14, 1985, recorded December 23, 1985 in Miscellaneous Record Book 312, Page 776 and as further amended by amendment dated November 14, 1985 recorded December 23, 1985 in Miscellaneous Record Book 312, Page 783, and as further amended by amendment dated October 20, 1999 and recorded December 20, 1999 in Miscellaneous Record Book 633, Page 1006 and as shown on the --....... _I" ~ jf. , Plans recorded in Plan Book 29, Page 7 and Plan Book 38, Page 112, 7. Building and use conditions, easements and restrictions as set forth in the code of regulations for Pheasant Run Condominium Association dated September 17, 1980 and recorded September 24, 1980 in Miscellaneous Record Book 258, Page 25, 8. Mortgage in the amount of $33,000.00 given by Thomas E, Pheterson II and Corinna R. Bailey to Keystone Financial Mortgage Corporation dated February 17, 2000 and recorded February 22, 2000 in Mortgage Book 1252, Page 267. Complaint in Mortgage Foreclosure filed by Keystone Financial Mortgage Corporation as Plaintiff against Thomas E. Pheterson, II and Corinna R. Bailey in the Office of the Prothonatary of Cumberland County to file no, 2000-2757. Judgment entered June 21, 2000 in the amount of $35,543.19. 9. Mortgage in the amount of $10,000,00 securing future advances given by Thomas E. Pheterson, II and Corinna R. Bailey now by marriage, Corinna R. Pheterson to Members First Federal Credit Union dated March 21, 1998 and recorded March 26, 1998 in Mortgage Book 1440, Page 681. 10. Mortgage in the amount of $14,000.00 given by Thomas E. Pheterson, II and Corinna R. Bailey, now by marriage Corinna R. Pheterson to Members First Federal Credit Union dated March 21, 1998 recorded March 26, 1998 in Mortgage Book 1440, Page 683. 11. Judgment in the amount of $2,06.85 entered by American General Consumer Discount Company as Plaintiff against Thomas E, Pheterson, II as Defendant on July 6, 2000, 12. Judgment in the amount of $260.57 entered by Pheasant Run Condominium Association as Plaintiff against Thomas E. Pheterson, II as Defendant on August 23, 2000. 13, Rights granted by Metlanco, Inc. to United Telephone Company of Pennsylvania for buried facilities by instrument dated April 6, 1973 recorded June 29, 1973 in Miscellaneous Record Book 204, Page 703. 14, Rights granted by Metlanco, Inc. to United Telephone Company of Pennsylvania for buried facilities by instrument dated December 13, 1976 and recorded July 18, 1977 in Miscellaneous Record Book 229, Page 638. 15. Rights granted by Carlisle Apartments, Limited Partnership to United telephone Company of Pennsylvania by instrument dated December 13, 1976 recorded July 18, 1977 in Miscellaneous Record Book 229, Page 649, 16. Satisfactory evidence to be produced that proper notice was given to the holders of al liens and encumbrances intended to be divested by subject Sheriff Sale. 17, Real estate taxes accruing on and after July 1,2001, not yet due and payable, It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal . 'ct Cou t.'" -L1 Robert G. Frey, Agent Note: This Title Report shall not be valid or until countersigned by an authorized signato - -, ,,; , . REAL ESTATE SALE NO, 14 Writ No. 2000-2757 Clvtl Keystone Financial Mortgage Corporation vs. Thomas E. Patterson. II and . Corinna. R Bailey Atty.: Frank Federman DESCRIPTION ALL TIiAT CERTAIN unit desig- nated as No. C-2. being a unit in Pheasant Run Estates, a Condo- minium. located in North Middleton Township, Cumberland County, Pennsylvania, wbtch unit is located on the Third Floor. Building I, as designated in the Declaration of Condominium recorded September 24, 1980 In the Office of the Re- corder of Deeds for Cumberland County in Miscellaneous Book 258. Page 6, et seq.. and which Declara- tion was amended by Amendment dated November 14, 1985, and re- corded December 23. 1985, in the hereinafter mentioned Recorder's Office in Miscellaneous Record 312, Page 776, et seq.. and was further amended by Amendment dated No- vember 14, 1985, and recorded De- cember 23, 1985. In the hereinaf- ter mentioned Recorder's Office in Miscellaneous Record Book 312. page 783 et seq.. together with a Code ofReguIatlons for Pheasant Run Con- dom1n1um Association dated Septem- ber 17, 1980, and recorded Septem- ber 24, 1980. in the hereinafter named Recorder's Office in Miscel- laneous Record Book 258. page 25 et seq., and together with plan re- corded in the herein named Record- er's Office In Plan Book 38, Page 112. TOGETHER wtth all right, title and Interest, being a .0059524% interest in and to the Common Ele- ments as more fully set forth -in the aforesaid Declaration of Condo- minium and Declaration Plans. UNDER AND SUBJECT to all agreements. conditions, easements and restrictions of record and to the provisions, easements. covenants and restrictions as contained in the Declaration of Condominium. Code of Regulations and Declaration Plans. T"'!' Parcel #29-17-1583-015B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd. his wife dated 2/14/1995 recorded 2/22/1995 In Record Book 118 Page 861. ;j%>lf.' "'~ . t . =~=. =. _ " ti:~1 -',. .-', ""j," .... ., KEYSTONE FINAi\iCIAL MORTGAGE CORPORATION CUMBERLAND COI'NTY Plaintiff, COURT OF CO:VIMON PLEAS v. CIVIL DlVISIO:\' THOMAS E. PATTERSON, II CORINNA R. BAILEY NO. 00-2757 Defendant(s). AFFlDA VIT PURSUANT TO RULE 3129 (Affidavit :-Jo. I) KEYSTONE FINANCIAL MORTGAGE 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 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 , CARLISLE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): NAl'vlE LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) THOMAS E. PATTERSON, II 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 CORINNA R. BAILEY 1402 BR.ADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 2. Name and address of Defendant(s) in the judgment: NA.JvIE LAST KJ'iOWN ADDRESS (If address carmot 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 ltt. ~'~;c; , 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KJ'iO\VN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Members 1st Federal Credit Union 5000 Louise Drive P.O. Box 40 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 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 KJ'iOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1402 BRADLEY DRIVE, A/KIA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 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 Pheasant Run Properties 1824 Sterretts Gap Avenue Carlisle, PA 17013-1249 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledae 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. ;%~A-fI!(rtVL-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Febmarv 22.2001 DATE ~........ '- ~~ .~~ -, , ~ . . . . ~" , , . , . "KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No. 00-2757 v. THOMAS E. PATTERSON, II CORINNA R. BAILEY Defendant(s). Febmary 22,2001 TO: THOMAS E. PATTERSON, II CORINNA R. BAILEY 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 **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 BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 , CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on JUNE 6,2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by KEYSTONE FINANCIAL MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5,2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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. " ~~- . . - 'iIi; ~-----~"'~,".-'~ I , . You may need an attorney to assert your rights. Th,e sooner you contact one, the more chance 'ou will have of stopping t11e 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 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 S,lle will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, youlllay 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 filll 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, PA 17013 (717) 249-3166 (800) 990-9108 ,~ ' " ,,~ - . - ! ,; '" DESCRIPTION ALL TK~ T CERT.~I~ unit designated as ~o. C-2. being 3. unit in Phe3.sant Run Estates, a Condominium. 10c3.ted in ~onh :VliddleEOn Township, Cumberland County. Pennsylvania. which unit is \oc:lted on the Third Floor. Building I. as designated in the Declaration of Condominium recorded September 2-+, \980 in the Office of the Recordet of Deeds for Cumberland County in :VIisceU::meous Book 258. P3.ge 6. et seq.. and which Declaration was amended by Amendmem dated ~o\ember 1-+. 1985. and recorded December 23. 1985. in the hereinafter mentioned Recorder's Office in \liscellaneous Record 3[2. P3.ge 776. et seq.. and was funher amended by .\rnendmem dated ~ovember 1-1.. 1985. and recorded December 23. 1985. in the hereinafter mentiorred Recorder's Office in ';Iiscellaneous Record Book 3l2, page 783 et seq.. tOgether with 3. Code of Regulations for Pheasant Run Condominium .\ssociation dated September 17. 1980. and recorded September 2-+. 1980. in the hereinati:er named Recorder's Office in \liscellaneous Re'~ord Book 258. page 25 et seq.. and EOgether with plan recorded in rheherein named Recorder's Office in Plan Book 38. P3.ge 112. TOGETHER with all right. title 3.nd interes!. being 3. .005952-!:: interesr in 3.nd to the Common Elements as more fully set fonh in [he aforesaid Declaration of Condominium and Dec!:J.r:ltIon Plans. CNDER -\:-JD SCBJECT EO 3.11 3.!!reemenrs. condirions. easements and restrictions of record 3.nd EO . - the provisions, easements. covenanrs 3.TILl restrictions as ~onrained in the Declaration of Condominium, Code of Regulations 3.nd Declar3.tiorr Plans. Tax P~rce! 429-l7 -1583-0 15B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Corinna R. Bailey by Deed from Sean :VL Dowd 3.nd \[arjorie w. Dowd. his wife dated 2/1-!il995 recorded 2/2211995 in Record Book 118 P~ge 86!. - - - " ~ d'. _ - ...~+~I .' . . . '.. ., WFU19~i'rilI.lT~?N and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA). .... ,1. NO. 00-2757 CIVIL fe{ TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF rllmhPrl F!nil COUNTY: To satisfy the debt, interest and costs due Kpy",tnnp Finnn"ial Mnrtgage PLAINTIFF(S) from Thanas E. Patterson, II Corinna R. Bailey 1402 Bradley Drive Unit A-314 Carlisle, Pa. 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: I and to notWy thegarnishee(s) that: (a) an allachment has been issued; (b) the garnishee(s) is/are enjoIned from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof: (3) If property oflhe defendant(s) not levied upon an subjecllo attachment is found in the possession of anyone other than a named garnishee, you are directed to notny hirn/herthat he/she has been added as agamishee and is enjoined as above stated. L.L. Due Prothy 1 00 Other Costs Amount Due 515.543.19 From 6j20jOO-6j06j01(per diem-$5,84) Interest 7. n4Q Rd AllY's Comm % Atty Paid Plaintiff Paid 272.76 Date: March 6, 2001 Curtis R. Long Prothonotary, Civil Division by: Y'r 0, ""rru.f.l ,~ Deputy REQUESTING PARTY: Name Frank FedeITIlan Esquire . d One Penn Center at Suburban Station Ad ress: S'lit€l pnn . Philadelphia, Pa 1910] Allorneyfor: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 ~iM .,:_""_'d.....;,_'. " -.< -,i',;...,;,. ffl"M 'If --- ''"J~oi-!f.'"~~;~j~ ~ !/Ml1.......... ~,' -""J" '1 " ROt E.SJATE.~SALE N~. ft' , Uf:I t1Yl ~ ~; tJ 0 0 I the sheriff levied upon the detenoai Interest In the real property situated in-"'?"..,.;/14;~'4,--r"!-'f1 C1Jmbetland County, Pa., !/.. tAa~ and mor,. . T" Exhibit "A" tilfX!'j$i ) ~ ~ ,.~ O~ o"""w--.rv ",;l. ~"" """ ~ .-no ~~ \'.7....{ ,...... .~~ c)rn .... ",.,0 Cfl->::;, ...o~ .;::s;.~ 41 ....11. c? ~ ;...-' nr!numberedas:NIJ~ ~~ thiS writ and by this re1;c '''':l.te:Cv11D~1.5?, 1ldCJl 'lereln. t n~~ , - -;;::.D ~ tl ..~~:r ~~ ('" (f' L\",' "'P" rc -;t=.. -- 7. . m. ~~I\llft!!o.lI ' ilf- l!~7~. - ~-~~~. 's_one mandal-- ~ ~ ',,,,!<1s'lli'.gl>CO'l1. _ ~ ~":-' ~::'--~~mi-ie-:~~on, rr- -=-==- --.- "-~,"-_.torinna R. Bm!~Y ~~.~~,l'At1y: f~Jl~ F~_d~rm~iJ ~~i\~!~~~n.;;;c..,...'-',...., ~U TIi-\T aRTAT\uruTdcslgnatedJ~ \:0, (-2,--< ~;,._~~.."~-.u_njt. in. ..Ph~ol.~a:rll .Run" h~l~' a_ . .,",""",.IQ"t",LllL':;"rl!l._\li<l<l,~,",,. ~... in., cum..b~.rran'J.-COu."nty;-.Pc-nn5d"Jn._ia, '- ~~~~~~~~~i~ ~~IJW~~~~~~'~ - ~dmrijnru.m ..r\>(.ord~d.l serte.m. b,.t Z~,1980 in " g', n ,R=",QUk"h.iN, - J)' ~1_~tkc.01~nco~Joo~ ~SB, __ "'-dncf-ii,-nlcli- O'i::d,iraoon- lIdS - Jl'~Gl,""9'1\~~'U~ J2~Q..~~ .~~ , ' l'ml.!:a.: ~"",if.Ll .,.In.... " 3L:,.]a"~7Asl,j~Jl1~-=r , . ':tl.. '1m';<!I)1."'! .<!at\!ll, . 1.1.%5.. <nh"Qrd,~Q"."l<J lJ" . 1 N~in._~r_LjenljQ. \:!elLR~cgr.jcr}..~, ',~cilJaJlco~ ~c:cord )Jpox. ~ pJgti " 6" '~h.~r_~iili ~r.Qg.Q..ofJl~.ttLC@>~ .:. :_~~-~~~,~~-~: .2:LJ9]lJ1;lo ..sgtgjp~~LDaP..i~d_~ c~ ijDfi ! ' s ~t:.~QJP--?09k " ? "~_ ~'LAn_j9gl'l er _ II ith r1;,ln . , , _' am~g RrcoC:'s6Qilic,; ~";-112. - r1ilJ~.JR[uoalnwIT~ : 'M!11 SmJn@__.. ~'_'_ _~_ .__ '_ .QJ'~,d.." '"..,(:9i1<!,mW!llll..J,l!., '..11,09'; ~~'~SUrStl31ECfio~~(w~~~""nt~. .. .,.'~m,'.U!.>,ln' r~W1W~"'''' . - 0- '.c promions cJitm~cl1fb covc!:l~n.~ apd _ '4 m fh,lJ.:.~ of, Jl.! > :2f':'E.l:guwhons .1Ild ': jJ' l2 , , .'\ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 24th day(s) of April and the 1 st and 8th day(s) of May 2001. That neither he nor said Company Is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in :,:,~:~:~:,"g 01 Do~, '0 OM ''''.'C,":O'~5&O['=O"'',"'.~mm COpy Sworn to and s' . 21st d of M 2001 A.D. S ALE #14 Nolana! Seal Teny L. Russell. Notary Pu . Hamsburg. Deuphln Coun My Commlsslon Expires June 6. N TARY PUBLIC Member, PennsylVenia Association of ~i~~mmission 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 $ 261.45 1.50 262.95 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.................................................................... ~,i ------"'-4-."::'::;:' I I I Ii ,I "i REAL ESTA'llE, SALE N6. 14 Wrtt No. 2000-2757 Civil Keystone Financial Mortgage Corporation '11 ',I ]1 ,I j;! II II II :1 II II 11 II :1 I' II , I vs. Thomas E. Patterson. II and Corinna R. Bailey Atiy.: Frank Federman DESCRIPTION ALL TIiAT CERTAIN unit deSig- nated as No. C-2, being a unit in Pheasant Run Estates, a Condo- minium, located in North Middleton Township," Cumberland County, Pennsylvania, which unit is located on the Third Floor, Building I. as designated in the Declaration of Condominium recorded September 24. 1980 In the Office of the Re- corder of Deeds for Cumberland County In Miscellaneous Book 258. Page 6, et seq.. and which Declara- tion was amended by Am,endment dated November 14. 1985. and re- corded December 23, 1985, in the hereinafter mentioned Recorder's OffIce in Miscellaneous Record 312, Page 776, et seq.. and was further amended by Amendment dated No- vember 14, 1985, and recorded De- cember 23, 1985, in the hereinaf- ter mentioned Recorder's Office in Miscellaneous Record Book 312, page 783 et seq., together with a Code i of Regulations -for Pheasant Run Con- domlnlumAssoclatian dated Septem- ber 17, 1980, and recorded Septem- ber 24, 1980, in the hereinafter named Recorder's Office in Miscel- laneous Record Book 258. page 25 et seq.. and together with plan re- corded in the herein named Record- er's Office In Plan Book 38. Page 112. TOGETHER with all right. title and interest, being a .0059524% interest in and to the Conunon Ele- ments as more fully set forth in the aforesaid Declaration of Condo- minium and Declaration Plans. UNDER AND SUBJECT to all agreements, conditions, easements and restrictions of record and to the provisions, easements, covenants and restrictions as contained in the Declaration of Condominium, Code of Regulations and Declaration Plans. Tax Parcel #29-17-1583-015B TITLE TO SAID PREMISES IS VESTED IN Thomas E. Patterson II and Cortnna R. Bailey by Deed from Sean M. Dowd and Marjorie W. Dowd. his wife dated 2/14/1995 recorded 2/22/1995 In Record Book 118 Page 861. . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, VIZ: APRIL 27, MAY 4,11, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~"Edil"" SWORN TO AND SUBSCRIBED before me this 11 day of MAY, 2001 . N. .. . . .~E;SNYDE~P1lbIIc ... . CIiIIiiIe,IIonl. . Co\IIi\Y . MyColilli IIllan ElqliresMarchS; 2005 . " .i . , , 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 KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.: 00-2757 vs. THOMAS E. PATTERSON, II CORINNA R. BAILEY ORDER AND NOW, this (/" day of 11-.,,," , ,2000, upon consideration of Plaintiffs 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), THOMAS E. PATTERSON, II and CORINNA R. BAILEY, 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 Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: ( -1 tJJ- y .~ f' -~ 0' l,-cSr i\-\r~ , f'nP U:i ~;f \' -I ,(--'C I ",\,,'1\( :"L]' ., r:' o r;"i '-, ; .):.). . "C' !'.n'U1iSI\I """,1 \\l-:'-I~\i ," ',' , I...)~, 1\1 I I \,;wl'pE~4NS'{[V'!\\'lii~ - "~,..,.~ . ."..." ~ , . I " ,~ ~"~~~~!l11:'ll~o ...~. , >~ ~..,. ~_,~liIIII!Pl!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 KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.: 00-2757 vs. THOMAS E. PATTERSON, II CORINNA R. BAILEY 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. 1~1~ FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF .,~ "!..--.-~-:}: , " - ":- - ."--~ ~ '"=1ii';,'; ---- ~ AFFIDAVIT OF SERVICE PLAINTIFF KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLk'm COUNTY No.00-2757 DEFENDANT(S} THOMAS E. PATTERSON, II CORINNA R. BAILEY Type of Action - Notice of Sheriffs Sale SERVE AT 1402 BRADLEY DRIVE, A/K/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Sale Date: JIJ~E 6, 2001 SERVED Served and made known to , Defendant, on the day of ,200_, at , o'clock _.m., at , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) residers). 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 1 personally handed a true and correct copy ofthe 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: By: NOT SERVED On the \~"''c\ day of XY\lN' J.r, ,200.1., at a,,'.\":, o'clock\L'm., Defendant NOT FOUND because: Vacant +0 t?o'o ''w.a s: ,...w.~ ' PFI dIU..... <tl.......+ 8 ""'_~s ~o ~ Moved Unknown No Answer Other: Sworn to and subscribed before me this .IJ!:!::. day of /Y),qplA ,200 L Not3ry~iO~ Attornev for Plaintiff Frank Federman, Esquire -1.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 BY:~~{),LJ~ Notarial Saal Samara D. Barnhart, Notary Public Green Twp., Franklin COunty My CommissIOn Expires Oct. 9. 2004 Mamber, PennsylvaniaAssociatlcnclNolarles E){HlB\T A m -- AFFIDA VlT OF SERVICE PLAINTIFF KEYSTONE FINAi'lCIAL MORTGAGE CORPORATION CUMBERLAi'lD COUNTY No.00-2757 DEFENDANT(S) THOMAS E. PATTERSON, II CORINNA R. BAILEY Type of Action - i'iotice of Sheriff's Sale SERVE AT 1402 BRADLEY DRIVE, AlKJA 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, PA 17013 Sale Date: JUNE 6, 2001 SERVED Served and made known to , Defendant, on the day of ,200_, ai , o'clock _.m., at , Corrmionwealrh of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) residers). 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 of Defendant(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 Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. S worn to and subscribed before me this _ day of . 200_. Notary: By: NOT SERVED Onthe \(1"'''''' dayof ~c.>v-- , 200..L. at ). '"C; o'clock L.m., Defendant l'I'OT FOUND because: -K- Moved Unknown No Answer Vacant ~ \~l>" \'''''''<6 Sp.tl'w-~~, PA ~ttl'-' cu...n+ 8 1M ~%S "'-~ Other: Sworn to and subs,,&bed bdore me this ~ day of /}1lJRcH . 200 L Notary~~ Attornev for ptaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Snburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 By:'toJL>0, W~ Notanal Seal Barbara D. Barnhart, Notary Public Green lWp., Franklin COunty My CommissIOn expires Oct. 9, 2004 Member, f'ennsy\vsnlaAssoclstlonofNolaJtes EXHIBIT A " - 1- .- , , ~~ EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Federman & Phelan Subject: Thomas E. Patterson, II Corinna R. Bailey Property Address: 1402 Bradley Drive a/k1a 1402 Bradley Drive Unit A Carlisle, P A 17013 Last Known Address: 1402 Bradley Drive Carlisle, P A 17013. Current Address: . 1402 Bradley Drive Carlisle, PA 17013-1261 Last Known Number: non-published George H. Lewis, III, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of researcher forEKL DATA, INC. 2. On March 26, 2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: 1. Credit Information A. Social Security Number 1. Thomas E. Patterson, II: 203-58-6639 2. Corinna IL Bailey: 196-62-6194 B. Employment Search: Could not locate any information for the above Darned subjects at this time. C. Inquiry of Creditors: The creditors indicated that Thomas E. Patterson, II and Corinna R. Bailey both reside at1402 BradleyDrive, Carlisle, PA 17013-1261. II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has Thomas Patterson listed with an address of 1402 Bradley Drive, Carliste, PA 17013-1261. The phone number is non-publisbed. HI. Inquiry of Neighbors Could not locate any neighbors for the above named subjects at this time. IV. Inquiry of Past Office A. National Address Update: As of March 26, 2001 the National Change of Address has no forwarding record for Thomas E. Patterson, II and Corinna R. Bailey listed at 1402 Bradley Drive, Carlisle, PA 17013-1261. EXHiBIT "8" -. ~ ~ .iSli""~"""":_.j .- ~ ,"i__' EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION V. Inquiry ofDMV The Pennsylvania Department of Motor Vehicles has Thomas E. Patterson, II and Corinna R. BaUey listed at 1402 Bradley Drive, Carlisle, PA 17013.1261. VI. Other Inquiries A. Death Records: As of March 26, 2001 the Soeial Secnrity Death Index has no death record on file for Thomas E. Patterson, II under his social security number Dor is there a record for Corinna R. Bailey under her social security number. B. Public Licenses None found c. County Voter Registration: The county does not bave Thomas E. Patterson, II or Corinna R. Bailey listed as registered voters with an address. of 1402 BradleyDrive, Carlisle, PA 17013-1261. .D. A.K.A.: Thomas E. Patterson - Corinna R. Patterson E. D.G.B.: Thomas E. Patterson, II: 12-05-74 Corinna R. BaUey: 05-02-74 F. Miscellaneous Information None t George H Lewis ill Subscribed and sworn before me on Ma,ch 26, 200 L ~~~ Notary Public Notarial Seal Ellen K.lawls, Notary Public lower Merlon lWp., Monlg6mery County My COmmission Expires Feb. 24, 2003 EKL DATA, INC. 13 66 Brookline Boulevard 13 Havertowu, PA 19083 Tel.: 1-888-829-576813 Fax: 610-446-277913 email: ekl-data@home.com tiXH\B\T "8" _,._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 KEYSTONE FINANCIAL MORTGAGE CORPORATION No.: 00-2757 vs. THOMAS E. PATTERSON, II CORlNNA R. BAILEY MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service carmot 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 carmot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." 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 Inforrnation 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 " "'f;~ 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: -r ruvJ , jJ J QJ1nYrny FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF , - .l.J;j 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 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ,YIlm1l1~, FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF " .. J~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 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION KEYSTONE FINANCIAL MORTGAGE CORPORATION CUMBERLAND COUNTY No.: CORINNA R. BAILEY vs. THOMAS E. PATTERSON, II CORINNA R. BAILEY CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy ofthe Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on AprilS, 2001. THOMAS E. PATTERSON, II CORINNA R. BAILEY 1402 BRADLEY DRIVE, AlK/A 1402 BRADLEY DRIVE, UNIT A-314 CARLISLE, P A 17013 danJ 1~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: AprilS, 2001 t; ~~pj " ,., -~ 0:1 FEDERMAN AND PHELAN, L,L.P. By: DANIEL G. SCHMIEG, ESQUIRE IDENTIFICATION NO. 62205 ONE PENN CENTER AT SUBURBAN STATION PHILADELPHIA, PA 19103 (215) 563-7000 KEYSTONE FINANICAL MORTGAGE CORPORATION ATTORNEY FOR PLAINTWF COURT OF COMMON PLEAS CIVIL DIVISION v. THOMAS E. PATTERSON II CORRINA R. BAILEY NO. 00-2757-CIV TERM CUMBERLAND COUNTY PRAECIPE TO MARK JUDGMENT SATISFIED AND MARK THE ACTION DISCONTINUED AND ENDED WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly satisfy the Judgment, which was entered on or about 6/21/00 in the amount of $35,543.19, relative to the instant matter. -I) Cl/~ C91 ~ Daniel G. Schmieg, Esquire October 19, 2004 ~_...,;..J.="~~~ '~= c. -='~"'IIID,,"'-i..... If""'''''<<l>M~I''''''''' .,~.~,_."""'" ~"' "." ,~_i ..',., ~.~' '< ;;.. 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