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HomeMy WebLinkAbout00-02907 ",~,'I--n:, ~'.-.' 'C~'- "< ,'" <<"<'" ~'",,~. -'-'<';'c'o!_~'~,._ ,~",,-,;.i~-;-':1 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ,i "I VS. NO, 00 - ;ri61 Ci(.>'~l~~ ROBERT L, ROBINSON JR, A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone (717)249-3166 .-, ,". ,;,,'~ I '" ,.'.',""-,";<.,f~,,"-,'-"ii___,_ ~ ---''''~-'"' ;,,0',",,",'0--;".. ,~,'-"'<it'<i NOT I C I A Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted, LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone (717)249-3166 -". .~ _ _. ",'~',,'.- ,,,"~'i '<;"'';~ I';_~'--l"- ,;;i:;"<;;';';'i&,;,~~";:,,~~l_j,:~~p~ _c','_" ""~-'C"<';;:OI ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO, ROBERT L. ROBINSON JR, A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (3D) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor, PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Attorney ID #15700 Attorney for Plaintiff ~" '"~ '~-"'- '~'", ~-'I--'- ",,,, ,~-" '.. -. ".',<>-, ~ --" - - "'~ ASSOCIATES CONSUMER DISCOUNT COMPANY plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 0<1- .;;.90'1 ~ T~ ROBERT L. ROBINSON JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, ASSOCIATES CONSUMER DISCOUNT COMPANY, is a Corporation with offices at 1111 Northpoint Drive, Building 4, Suite 100, Coppell, Texas 75019-3931. 2. Defendant, ROBERT L, ROBINSON JR. A/K/A ROBERT ROBINSON, is an adult individual whose last known residence is 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643. Defendant, CAROL J, ROBINSON A/K/A CAROL ROEINSON, is an adult individual whose last known residence is 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643, 3. On or about September 25, 1996, Defendants executed and delivered a Loan Agreement in the sum of $69,030,332 payable to ASSOCIATES CONSUMER DISCOUNT COMPANY, which Loan Agreement is attached hereto and marked Exhibit nAn, 4, Contempo~aneously with and at the time of the execution of the aforesaid Loan Agreement, in order to secure payment of the same, Defendants made, executed and delivered to the Mortgagee, a certain real estate Mo~tgage which is recorded in the within Commonwealth and County in the Office of the Recorder of Deeds in Mortgage Book 1343, . '^,' . ~ -, ~- .'~"_"J'~__'" - >~" - "~~>;,,,~ " -' -~., '-'--";t page 620, conveying to the original Mortgagee the subject premises. said Mortgage is incorporated herein by reference. 5. The ~and subject to the Mortgage is: 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643, and is more particularly described in Exhibit "B" attached hereto. 6, The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 68,503.41 (b) Interest at $25.07 per day from 7/1/99 to 3/1/00 (based on contract rate of 13.36%) 6,092.01 (c) 15% Attorney's commission 10.275.51 TOTAL $ 84,870.93* *Together with interest at the per diem rate noted in (b) above after March 1, 2000, and other charges and costs to date of Sheriff's Sale, The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale, If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff, 8. No Judgment has been entered upon said Mortgage in any jurisdiction. '__U' ., ~ I~'-' . ^' ,'"'~, -, -,!" " ',0" """"~,, :,;~' ,-. - -' " ,'~ 'I 9. Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending to each Defendant, by regular mail, a copy of the combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice, along with a copy of the Certificate of Mailing, is attached hereto as Exhibit "C". 10, The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. 11. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13,36% ($25.07 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. PURCELL, KRUG & HALLER By Leon P. Haller Attorney for Plaintiff I. D. #15700 1719 N. Front St. Harrisburg, Pa. 17102 (717) 234-4178 -,I ,,_,c -;j Loan Agreement PENNSYLVANIA TITLEV1STMORTGAGE am,MORTGAGE OVER 550,000 VARlABLE-FIXEOFVlTE-BALlOON LENDER: ASSOCIAT~S CONSUMER DISCOUNT COMPANY ""'lloENfSClEllll!_"",'flIEI(IIIAAe""'l1dll.E1IlNlIU 180 fA 1 T 941.15 -,...... ROBINSON, CAROL IXI AGREED RATE OF INTEREST: 11 1n % per year on the unpaid principal balances, D AGREED RATE OF INTEREST: THIS IS A VARIABLE INTEREST RATE LOAN AND THE INTEREST RATE WILL INCREASE OR DECREASE WITH CHANGES IN THE BANK PRIME LOAN RATE. The interest rate will be _ percentage points above the "Bank Prime Loan RateU published in the Federal Reserve Board's Statistical Release H.15, The initial Bank Prime Loan rate is %, which is the published rate as of the last business day of ; therefore, the initial interest rate is % per year. The interest rate will increase or decrease with changes in the Bank Prime Loan rate when the Bank Prime Loan rate, as of the last business day of the preceding month, has increased or decreased by at least 1/4th of a percentage point tram the Bank Prime Loan rate on which the current interest rate is based. The interest rate cannot increase or decrease more than 2% in any year. In no event, however, will the interest rate ever be less than % per year nor more than % per year. The intefe9,t rate will not change before the First Payment Date. Interest will be computed on the unpaid principal balances. - ROBINSON, ItOBERT 73 SANDBANK RD SHIPPENSBtJRG PA 17257-9643 CHAMBERSBURG PENNSYLVANIA wr""'lloENftol,Tf 10/01/11 ,lIIlKEAfftl'AlDfltllDFlfQljEllll) $,00 ,lOOlfftlZl .Dl'ltIQTlIl , 4786,18 91204,72 ,'" (ll'lt)'(lfol') FINANCE 95990.90 +- CHARGE AlllII.NI"MlIUDI'I , 64244.14 lOTALOF""'~MENTlIII'(5) , 160235.04 .00 CIEIlITAlHlNS.PfE),l , .00 I PRII:II"'UAU.hCEll).(:II'lJ) 69030.32 ll1T""'lllENl'llAlt; , 889.91 -........ 0" .00 Adjustments in the Agreed Rate of Interest shall be given effect by changing the dollar amounts of the remaining monthly payments in the month following the anniversary date of the loan and every 12 months thereafter so that the total amount due under this Loan Agreement will be paid by the last payment date excluding any balloon payment, if applicable. Associates waives the right to any interest rate increase after the last anniversary date prior to the last payment due date of the loan. REPAYM~NT DEFAULT , A TTORNIiY FEES BAD CHECK CHARGE PREPAYIoIENT DELAY IN ENFORCIOMENT SECURITY FOR THIS LOAN I promise to pay you at your office the principal balance together with interest figured at the Agreed Rate of Interest checked above until fully paid, I will repay my loan by making the monthly payments set forth in the Payment Schedule, Payments will be made every month beginning on the first payment date stated above until the loan is fully paid. If there is no such date in any month that foltows, payment will be made on the last day of that month. Each payment I make will by applied first to interest owed to the date of payment and remainder to principal balances. \ agree to pay interest after maturity at the Agreed Rate of Interest I will be in default if I fail to pay any payment or part of a payment on time or if I fail to comply with any of the terms of the Real Estate Mortgage on the real estate given as security for this loan. If I default, you have the right to declare the entire unpaid amount of my loan immediately due and payable without giving me notice or asking me to pay, If this loan agreement is seQured by a mobile home, I will be given a notice of right to cure a default if I am entitled to this notice, If you declare the balance of my loan due and payable, you have the rights and remedies provided for in the Real Estate Mortgage that secures this loan, including the right to require me to pay any deficiency, I agree to pay reasonable attorney's fees, if this loan agreement is referred for collection to an attorney who is not your salaried employee. If any check or instrument given as payment on this indebtedness is dishonored, I agree to pay a service charge of $20.00. I have the right to pay In advance at any time. If I prepay In full, no part of thelaan fee will be refunded. You can delay enforcing your rights under this loan agreement without losing them, If I default in complying with any of the terms of my loan and you do not declare the loan balance immediately due and payable. this does not mean you cannot do so in the future if I default again, I give you a Real Estate Mortgage dated the same as this loan agreement to assure payment of my loan, If this is a first mortgage loan the Alternative Mortgage Transaction Parity Act of 1982 and the Federal Depository Institutional Deregula~ lion and Monetary Control Act of 1980 governs certain provisions of this loan. If this is a second mortgage loan over $50,000, the Allernativ~ Mortgage Transaction Parity Act of 1982 governs certain provisions of this loan, I acknowledge receipt of a completely filled-in copy of this loan agreement. ~ ~;/ L 1f~' , / . /1-",,-- ! ./7_ (WITNESS) ~o~ L~/~//-(It (!(UtU, ) C)- /~~ (BORROWER) (I 1 Iv ORIGINAL (1) ll&llna REV.ll.Q6 BORROWER COPY (1) 0021ll.QG CO-BORROWER COPY (1) -----~--'-~-- (,~ ,.Ji.. _l~ ~. . ~ - '"'..,,,~,-- BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson: thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake: thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet: thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single woman, by her deed dated January 14, 1971, and recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Deed Book "Y", Volume 23, at Page 232, conveyed to Raymond Robinson, Jr., one of the Grantors herein. TOGETHER with the right to use the right-of-way extending from the land herein conveyed to the TOln1ship Road # , and extending along the Glenn Smith land, said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and assigns in conjunction with the Grantors, their heirs and assigns. f /;;:</1 "'~ XH, ;/;- ( 0 L- '"" ~', ", ~-l>" ACT 9 1 NOT ICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortqaqe on YOUr home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) 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 THE DATE OF THIS NOTICE. Take this Notice with YOU when YOU meet with the Counselinq Aqencv. The name, address and phone number of Consumer Credit Counselinq Aqencies servinq your County are listed at the end of this Notice. If vou have anv questions, you may call the pennsvlvania Housinq Finance Aqencv toll free at 1-800-342-2397. (Persons with impaired hearinq can call (717)780-1869). This notice contains important legal information. 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 PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA, L/'x #; (6 p~ 11C [4 " , "~,",,, ,I .. ' ,,",__ '_",~-'_ .,,'''^ -,~""-"',,-;;' _~L _ January 10, 2000 To: Robert Robinson 73 Sandbank Road Shippensburg, PA 17257 Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 Re: Loan No, Property: 9643 013772610219674 73 Sandbank Road, Shippensburg, PA 17257- CURRENT LENDER/SERVICER: Associates Financial Services Co" Inc., 1111 Northpoint Drive, Building 4, Suite 100, Coppell, Texas 75019-3931 HOMEOWNERS 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 BE~OND YOUR CONTROL . IF YOU HAVE A REASONABLE PROSPECT OF RESUMING YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY 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 a representative of the creditor or with a designated consumer credit counseling agency, The purpose of this meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE, THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE, ,"~' 'W~. b_ -I,,' ""-~- C~_,--,:-",~~,_ -,h;--- .' .-"" 9 CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or with a consumer credit counseling agency identified in this notice, the creditor may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desiqnated consumer credit counselinq aqencies for the countv in which the propertv 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 tor 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 thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS 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 still apply for Emergency Mortgage Assistance.) '~L ",-'.' -_, '~"';'""k..oc.' .-~'f. "<:i;_~.- ~ .. HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT - The MORTGAGE debt held by the above creditor on your property located at: 73 Sandbank Road, Shippensburg, PA 17257 IS IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past due: Delinquent payments (7 @ $889.91) Payment due during cure period $ 6,229.37 889.91 Total amount due $ 7,119.28 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (EXPLAIN): NOT APPLICABLE 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 plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Associates Financial Serives Co., Inc, 1111 Northpoint Drive, Buildinq 4. Suite 100 Coppell, Texas 75019-3931 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: NOT APPLICABLE 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 creditor intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due 1S not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start a lawsuit to foreclose upon vour mortqaqed property. .'-0'1 'I ''':'~';,: ',;, '>~';'" 'ilil, -_6/; - >"'~,-__<;>;" -, 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 creditor begins legal proceedings against you, you wlII still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00, Any attorney's fees wllI 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 period, YOU will not be reauired to pay 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 riqht to cure the default and prevent the sale at any time UP to one hour before the Sheriff's Sale. You may do so bX paYlna the total amount plus anv late or other charges then ue, reasonable attorney's fees and costs connected wlth the foreclosure sale and any other costs connected wlth the Sherlff's Sale and by performlnq any other reaUlrements under the mortaaae. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately FOUR 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, If money is aue, such payment must be in cash, cashier's check, certifiea check or money order, made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER Associates Financial Services Co" Inc. 1111 Northpoint Drive, Building 4, Suite 100 Coppell, Texas 75019-3931 (800)438-0263 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's 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 Sherlff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property: 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 CUREuYOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ,,____"-' I, _,,,_c, .--,,"""'__'.7'~. -,""-- '".C '." · 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 CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ATTACHED) .~ CUMBERLAND COUNTY CCCS of Western PA, Inc. 2000 Linglestown Rd. Harrisburg, PA 17102 (717)541-1757 Urban Leg. of Metro. Hbg North 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX#(717)234-9459 Community Act. Commision of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 FAX#(717)234-2227 Financial Counseling Services of Franklin 31 W, 3rd Street Waynesboro, PA 17268 (717)762-3285 YMCA of Carlise 301 G. Street CaTlisle, PA 17013 (717)243-3818 FAX#(717) 731-9589 " .j """ .-d' c' .' "'; . .-"-,,.,",',;1 ,-",j <',,>_' ..0,.:.",,,,.,, ~- ,,,,,.~.; .'_~." ,--"_ '_~.-," ,>., Re: Associates vs, ROBINSON Act 6/91 Notice U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3817) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: Robert Robinson 73 Sandbank Road Shippensburg, PA 17257 Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 ~.- / ) -\ ,<~. r \.. , -. - ....>., , "./~\,.,tq~',J_\ I .( '.)Ii.' -~\.. (""~~: \ q\.;: ~.~:~,-~- - '-'.\ \._ /...,.1 \<.~ ~;~J'_ - .,' "--.- ,p-'---~;:;-;.'--~'-,,_-, _;~f.-_.-::-==--_,,-< ". -._...~-~;,-.:...:_- =-~=;:.~-- ~ ~ " ,- - : .' - ;.. ,< .. ;~"i.=: ; .2 [; :IE " -. - ,-:1 j' --.____,-11; ,A" ~< _ ~U ,',,", "'4.1';-", , - COMPANY NAME: ASSOCIATES CONSUMER DISCOUNT COMPANY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. Dated: 4- 8f3~()DDf) By i;1fuL ct0u~ Title RS('tc)0SUrt Spe~icLlist ,-", . ,~ .. .' Associates Consumer Discount Company VS Robert 1. Robinson, Jr. aIkIa Robert Robinson and Carol J. Robinson aIkIa Carol Robinson ., ,~" """'-li~,",ll' In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-2907 Civil Term R Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon Haller. Sheriff's Costs: Docketing Surcharge Law Library Prothonotary 30.00 30.00 .50 1.00 $61.50 paid by attorney 09/20/02 Sworn and subscribed to before me This ,)4 ~ day of Jp;-~ 2002, A.D. 0'f-'--' (2 ~up, Prothonotary -,,- ?~~,~~ R. Thomas Kline, Sheriff B~~~u~; I. ~;tJ c.a~ L j:< if'il ~~h;-'" . copy ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L, ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 73 Sandbank Road, Shippensburg, PA 17257: 1. Name and address of the Owner(s) or Reputed Owner(s): Robert L. Robinson, Jr. a/k/a Robert Robinson 73 Sandbank Road Shippensburg, PA 17257-9643 Carol J. Robinson a/k/a Carol Robinson a/k/a Carole Robinson 73 Sandbank Road Shippensburg, PA 17257-9643 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Greenwood Trust Company c/o Robert D, Kodak, Esquire 407 North Front Street P. O. Box 11848 Harrisburg, PA 17108-1848 G. H. Harris Associates p, O. Box 216 Dallas, PA 18612 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY." Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S, Section 4904 relating to unsworn falsification to authorities. <__ ___~ /~/ Leon P. Haller PA I,D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 7, 2000 ,- , '~ - .................L '~~ill'i!~ll:\!l ", . ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L, ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J, ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 6, 2000 TIME: 10:00 o'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold lS: 73 SANDBANK ROAD SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 02907 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disburs'ed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (lO) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken aWay. A lawyer can advise you mare specifically of these rights, If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. a Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the ~ "~, . - ". ~'''''~I,"''~~r;\.' '. Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~" . . ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton. County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows. to wit: BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to art iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) reet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS SHIPPENSBURG, PA. 73 SANDBANK ROAD, BEING THE SAME PREMISES WHICH Raymond Robinson, Jr. and Mary B, Robinson, his wife by deed dated and recorded 11/28/78 in Deed Book E-28, Page 137 granted and conveyed unto Robert Robinson and Carol Robinson, his wife, TO BE SOLD AS THE PROPERTY OF ROBERT ROBINSON A/K/A ROBERT L. ROBINSON, JR. AND CAROL J. ROBINSON A/K/A CAROL ROBINSON A/K/A CAROLE J. ROBINSON UNDER JUDGMENT NO, 2000 02907, ASSESSMENT: 39-13-0106-076 "~ ~ _.~...~ -~.,,~-~~, ., . / WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-2907 Civil Tenn CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt. interest and costs due Associates Consumer Discount Company PLAINTIFF(S) from Robert L. Robinson, Jr. a/k/a Robert Robinson and Carol J. Robinson a/k/a Carol Robinson, 73 Sandbank Road, Shippensburg, PA 17257 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notKy 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 of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to nomy him/herthat he/she has been added asa.garnisheeand is enjoined as above stated. L.L. Due Prothy Other Costs $.50 $1. 00 Amount Due $84,870.93 $25.07 per diem - $7,Ol9.60 Interest 3/1/00 to U/6/0n Atly's Comm % Atty Paid $125.92 Plaintiff Paid Escrow Deficit - $2.000.00 Date: September 12, 2000 Curtis R. Lonq 4Q~ DP:thOp~';r;~ Deputy ~by: REQUESTING PARTY: Name Leon P. Haller, Esq. Purcell, Krug & Haller Address: l719 NortH. Front Streot Harrisburg, PA l7102 Attorney for.: Plaintiff Telephone: 717-234-4178 Supreme Court ID No. 15700 ''IlIIIJU_Il;J'--.o-~~._.."",._",-,.......H' ~ L~",__ '0'. . REAL ESTATE SALE No.51 On ~ 19. :2.nV the sheriff levied upon the defendants interest in the real proDertv o;ituated in Lh7d. -Y'L .;:(""^-~~ Cumberland County, p~ . !'lumbered as:~t.1..~ JAflbt.'.A~~ and mOf~" on Exhibit "A" filed with f.nis writ ana Oy this referP'f\rated herein. ,,",,~~/i~ ~~ . ,. t:ij'~~f' - \-"1 ";j - j-',' , - :d MNI' ;!';/I!!;jh Eli! C! JilS -' '," j, -~ . ,ii;) c ;~;/ti ., -' ~- , :~. - - --. - ,- , ~ c:va c:va c;:::::2 ~ ~~ ~.. ~N " H ~ " I ~,<ko' FEDERMAN AND PHELAN, LLP By:,FRANK FEDERMAN Identification No, 12248 Attorney for Plaintiff 6NE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE, BUILDING 4, SUITE 100 COPPELL, TX 75019-3931 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 2000-02907 v. ROBERT L. ROBINSON, JR., AlK/A ROBERT ROBINSON CAROL J. ROBINSON, AlK/A CAROL ROBINSON Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ROBERT L. ROBINSON. JR.. AlKfA ROBERT ROBINSON and CAROL J. ROBINSON. AlKfA CAROL ROBINSON, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 3/2/00 to 10/8/02 TOTAL $84,870.93 $23,841.57 $108,712.50 I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~~JI'\lc ~02QJ]A11~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: ~.;2D6-... (].(~)l!. PRO PROTHY ~~_.- -, " _,<ialIt""",,,,,,,,,_ "',A..JI..I.I,J"'~~"""""" ................. ............................... BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 <;) <;(;1-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff Attorney for Plaintiff vs, COURT OF COMMON PLEAS CIVIL DIVISroh" - r. <" r. 'y. I.. 'F, CUMBERLAND COUNTY "~., ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON CAROL J. ROBINSON, A/K/A CAROL ROBINSON NO. 2000-02907 P Defendant TO: CAROL J. ROBINSON, A/K/A CAROL ROBINSON 73 SANDBJ\NK ROAD SHIPPENSBURG, PA 17257 DATE OF NOTICE: SEPTEMBER 27, 2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once, If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~ ,JiJ) '>J;JL t\{ 0 J-MWfYI Frank Federman, Esquire Attorney for Plaintiff '''''''''L -'- - "=---,,",~",' rn1.1nKlVl1\1'< 1\1'<1.1 rnnL1\1'< BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (2 I 'i) 'it'i,- 7000 ASSOCIATES CONSUMER DISCOUNT COMPANY Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION plaintiff vs. CUMBERLAND COUNTY ROBERT L. ROBINSON, JR" A/KIA ROBERT ROBINSON CAROL J, ROBINSON, A/K/A CAROL ROBINSON NO, 2000-02907 P Pefendant(s) '1'0: ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 DATE OF NOTICE: SEPTEMBER 27. 2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUN1Y CUMBERLAND COuNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 v~ ank Federman, Esquire Attorney for plaintiff " ~ .......'..""'~rr~> SHERIFF'S RETURN - REGULAR CASE NO: 2000-02907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS .c.......c.Vc".,",{#.1i1,g$~1i~~~~.. "'R~II}Ni9'~'iSI!jiR;0!B'Eft""N..,l!f~":\t'c", '..,. . ,'~, r"'._~,,-o ,_,~_"~,,- GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE ROBINSON CAROL J A/K/A ROBINSON CAROL was served upon the DEFENDANT , at 0012:45 HOURS, on the 19th day of May 2000 at 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 by handing to CAROL J. ROBINSON a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 ,00 16.00 ~~_'V<:~~ R, Thomas Kline 05/30/2000 PURCELL, KRUG & HALLER Sworn and Subscribed to before me this day of BY:AJJN~ Deputy S iff A.D. o PrOthonotary ~ ~ ~ I. __""-"'1:,"," SHERIFF'S RETURN - REGULAR 'CASE NO: 2000-02907 P COM~ONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS ROBINSON ROBERT L JR ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland county, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ROBINSON ROBERT L JR A/K/A ROBINSON ROBERT the DEFENDANT , at 0017:00 HOURS, on the 26th day of May , 2000 at 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 ROBERT L. ROBINSON by handing to a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 9.92 .00 10.00 .00 37.92 ~~~..~~~ R. Thomas Kline 05/30/2000 PURCELL, KRUG & HALLER Sworn and Subscribed to before By: 7L~ ~~7 f Deputy Sheriff me this day of A.D, Prothonotary 0"" >~~ , -.~~ ~,..;_';"""o<[ ~J, ~~iIi:i'-'- "' .. ~ ~';" - C A:J ~ 1.Q. ~ tL TQ- :-() D () C::l C "-, 0 - = "11 r' 0 ""t.1F"" 0 ().J ~ rn!E ;:-) ~_,l, -I ~ ~~~~: :n -0 I r- 3 "'Q Q:) -Gin ~(,,~ ?,;Y "'0 F- ~~f3 :-0 ,::::;cj III tv ~-"~ ;_15 :{~ - tI1~ -"~o ~') ;=----:-;:1"11 F - '-~ L 5;: -t=- =< (-, ::"'"'J -< , 'I'~~~" ~ . - 'k~IiIIl.)Mj'i~. 'I' Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ") Page 1 of3 Bankruptcy Docket Report 1 00-02659 (Harrisburg) ROBINSON, ROBERT L, SR and ROBINSON, CAROLE J Docket items entered between 0110111931 and 10/02/2002 Filing No. Docket Entry View Date document 06/15/00 1 VOLUNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Doc #1 PDF Plan and Summary [EOD 06/15/00] [CA] (41 pages) 07/1 0100 2 CERTIFICATE of Mailing of Notice of341 Meeting. Objections to the plan are Doc #2 PDF due 15 days after meeting held. [EOD 07/10/00] [CA] (6 na2:es) 0810 1/00 3 MOTION to compel Debtors to file federal income tax returns filed by UNITED Doc #3 PDF STATE OF AMERICA - IRS [Disposed] [EOD 08/02/00J [BW] (7 pages) 08/02/00 4 ORDER granting 45 days Re: Item # 3. [EOD 08/02/00] [BW] Doc #4 PDF (2 pages) 08/21/00 5 OBJECTION to plan by UNITED STATES OF AMERICA - IRS Re: Item # \. Doc #5 PDF [Disposed] [EOD 08/22/00] [BW] (5 pages) 08/23/00 6 CORRESPONDENCE SETTING HEARING on 10/26/00 at 10:00 A.M. at Doc #6 PDF FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., (2 pages) HARRISBURG,PA. 17108 Re: Item # 5. [EOD 08/23/00] [BW] 08/25/00 7 341 meeting held. [EOD 08/25/00] [CAJ Doc #7 PDF (2 pages) 10/25/00 8 Praecipe/Withdraw Re: Item # 3. [EOD 10/26100J [BWJ Doc #8 PDF (3 pages) 10/26/00 9 PROCEEDING MEMO: Hearing not held. Stipulation to be filed. Re: Item # 5. None [EOD 10126/00J [JGJ 11/03/00 10 STIPULATION by Parties Re: Item # 5. [EOD 11/06/00] [BW] None APPROVED by the court. Re: Item # 5. [EOD 11/06/00] [BWJ 12/29/00 11 TRANSFpR (ASSIGNMENT) of claim #9 of MIDLAND CREDIT None MANAGEMENT INC in the amount of$I,617.31 to B-HOLD LLC [EOD 01/02101] [BWJ 01/02/01 12 ORDER ConfIrming Plan [EOD 01/02/01] [BW] None 01/03/01 13 NOTICE to parties of transfer (assignment) of claim of Midland to B-Hold. None Objections due 01/23/01 Re: Item # II. [EOD 01/03/01] [BW] 02/09/01 14 MOTION for relief from stay filed by ASSOCIATES CONSUMER DISCOUNT None COMPANY (fee pd. $75.00, rec. #5660 I 7-CR) [Disposed] [EOD 02/09/01] [BW] CERTIFICATE OF NON-CONCURRENCE [EOD 02/09/01 J [BWJ 02/09/01 IS ORDER that answers are due on 03/01/01 Re: Item # 14. [EOD 02/09/0IJ [BWJ None 02/13/01 16 CERTIFICATE of service Re: Item # IS. [EOD 02113/01] [KZJ None 02/27/0 I 17 ANSWER by Debtors Re: Item # 14. [EOD 02/28/0 I] [BW] None ...InPacer?ExecThis=docket&puid=O 1 033570 157 &case _ no=2000-02659&office= 1 &DktTypeo 1 0/2/2002 ",""O~""" ~ "'''"''-,~~~, ~ O'~~",,, ; Docket for Case: n' + GetCaseNoO + n (" + DktTypeExpand(m.gsDktType) + n) Page 2 of3 03/29/0 I 18 STIPULATION by PARTIES Re: Item # 14. [EOD 03/29/01] [JC] Doc #18 PDF (5 pages) 03/29/0 I 19 ORDER approving stipulation Re: Item # 14. [EOD 03/29/01] [IC] None 08/14/01 20 CERTIFICATE OF DEFAULT Re: Item # 19. [EOD 08/14/01] [BW] None 08/15/0 I 21 ANSWER by Debtors Re: Item # 20. [EOD 08/16/01] [BW] None 08/17/01 22 CORRESPONDENCE SETIING PHONE CONFERENCE on 10/22/01 at 01:30 None P.M. atFED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 21. [EOD 08/17/01] [BW] 10/22/0 I 23 : PROCEEDING MEMO: phone conference not held - stipulation to be filed. Re: None 'Item # 21. [EOD 10/22/01] [CL] 01/31/02 24 'TRANSFER (ASSIGNMENT) of claim #7 of AMOCO OIL COMPANY in the Doc #24 PDF amount of $787.10 to SHERMAN ACQUISITION LP D/B/A RESURGENT (2 pages) : ACQUISITION C/O RESURGENT CAPITAL SERVICES, P.O. BOX 10587, , GREENVILLE, SC 29603-0587 (WAIVER OF OPPORTUNITY TO OBJECT FILED) [EOD 01/31/02] [DR] 07/17/02 25 MOTION for relief from stay filed by CITIFINANCIAL MORTGAGE None COMPANY, INC. as Servicers for the Mortgagee of Record. (fee paid rec#584545 $75.00) [Disposed] [EOD 07/17/02] [DS] CERTIFICATE OF NON-CONCURRENCE [EOD 07/17/02] [DS] 07/17/02 26 ORDER that answers aredue on 08/06/02 Re: Item # 25. [EOD 07/17/02] [DS] None 07125/02 27 CERTIFICATE of service Re: Item # 26. [EOD 07/25/02] [DR] Doc #27 PDF (3 nages) 07/26/02 28 TRANSFER (ASSIGNMENT) of claim #5 of UNIVERSAL CARD SERVICES in Doc #28 PDF the amount of$2,576.05 to SHERMAN ACQUISITION LP D/B/A RESURGENT (2vages) ACQUISITION C/O RESURGENT CAPITAL SERVICES, P.O. BOX 10587, GREENVILLE, SC 29603-0587 (WAIVER OF OPPORTUNITY TO OBJECT FILED) [EOD 07/29/02] [DR] 08/01/02 29 ANSWER by DEBTOR Re: Item # 25. [EOD 08/05/02] [JC] None 08/08/02 30 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on None 09/12102 at 02:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,P A. 17108 [Disposed] [EOD 08/08/02] [CR] 08/09/02 31 CORRESPONDENCE SETIING PHONE CONFERENCE WITH LA W CLERK None on 09/10/02 at 11:30 A.M. at FED.BLDG., BKRPTCY CfRM.(3RD FLR.), TlIIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 25. [EOD 08/09/02] [NP] 08/16/02 32 ENTRY OF APPEARANCE of JUDITH T. ROMANO, ESQUIRE of Doc #32 PDF FEDERMAN AND PHELAN, L.L.P. on behalf of ASSOCIATES CONSUMER (2 pages) DISCOUNT COMPANY [EOD 08/16/02] [DR] 09/10/02 33 PROCEEDING MEMO: phone conference not held - order lifting stay to be Doc #33 PDF entered. Re: Item # 29. [EOD 09/11/02] [CL] (J page) 09/11/02 34 ORDER granting relief from stay Re: Item # 25. [EOD 09/11/02] [DR] Doc #34 PDF (2 pages) 09/17/02 35 CORRESPONDENCE from Trustee re: hearing. No appearances for debtor. Case None to be dismissed. Re: Item # 30. [EOD 09/17/02] [DR] .../nPacer?ExecThis=docket&puid=O 1 033570 157 &case _ no=2000-02659&office= 1 &DktType 10/2/2002 , . . . Docket for Case: . + GetCaseNoO + " (" + DktTypeExpand(m,gsDktType) + ") Page 3 of3 . 09/17/02 36 ORDER dismissing case upon Trustee's Motion Re: Item # 30. [EOD 09117/02] None [DR] 09/20/02 37 NOTICE to creditors of dismissal of case [EOD 09/20/02] [AUT] Doc #37 PDF (2 pages) Printed: 10/02/02 10:51:28 ...... ..........- .........__'n"...._......_ ..........-.. .....-......-,-.. .. ..........-...--...--......... ................... I PACER Service Center I I Transaction Receipt I I 10/02/2002 10:51 :28 1 IPACERLogin: IIfp0039 IIClient Code: I IDescription: IIDocket IICase Number: III 2000-02659 I IBillable Pages: 114 IICost: 110.28 I .-.... ......-.............---".....- ............----...... ......'.- ........ _.--'- ~ Need help? Try the PACER User's Guide l21Pacer Service Center :;I", .../nPacer?ExecThis=docket&puid=O 1 033570 157 &case _ no=2000-02659&office= 1 &DktType 101212002 ~,.., h;' , ilII.h\~~""''''"=''''''U~ll;21"",,-'''' '""-'-"iW',!liiUiI-'] -~ll-.;,~~, ........"""'''''''''' "'.- -- ~\ - ~,-,- ~"" \ . , () C) C~ C N ,~ ""n <- 0 :,Tl -'Om (J [!JrT"1 --l ;c;'l :rJ ...;:::-::.:. ' ,- ;?-: ,-~ I -,., rn ~~~i co ""l I-i , Y ,-, (:: Ci .c., ~.- ..,' 5:; \:") :?~5~g () ;;::::: (-', .~".- '-- J s; '.j r-~) o,n ,- ~ -~-, z :> -~ C:) Xl -~ -< ~~'" ~l_ - , , ~ ~ ~~ "',~"'"'= ~~~ ""-'-"'"' FEDE~ANandPHELAN,LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 pmLADELPmA, PA 19103-1814 (215) 563-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY 1111 NORTHPOINT DRIVE, BUILDING 4, SUITE COURT OF COMMON PLEAS 100 CIVIL DIVISION Plaintiff, NO. 2000-02907 v. ROBERT L. ROBINSON, JR., AfK/A ROBERT ROBINSON CAROL J. ROBINSON, AfK/A CAROL ROBINSON 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 ROBERT L. ROBINSON, JR., AlKlA ROBERT ROBINSON is over 18 years of age and resides at , 73 SANDBANK ROAD, SHIPPENSBURG, P A 17257 . (c) that defendant CAROL J. ROBINSON, AlK/A CAROL ROBINSON is over 18 years of age, and resides at, 73 SANDBANK ROAD, SHIPPENSBURG, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1:-~ l~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff h',,;,"1 ~ ;. ,> " ~-,,--",.iiUil!. - .1Il1i!'/;!!ilf11ililll'""-'~'i!!tIfu~IJ4jjf"'l.<@i ,- - ",.- ~~ ",~.j: ,'., ~~"-.liIIl ~_.. """"--'-""',~-----;.. <> c: <" "':'ow rnrn 2:1'.' ;~~-;~ (0-"-__,, ~~C5 ~~(--:' ~~,() ,.c z -~ -< o N o ,;:-) -I I 00 C) '1"} ~~~j , ~i?.1 .~~ C~m 5i -< --0 r:? , " 'I !!l . -,~, - ! ~, _~ L 1_- _""ililllk".1 , " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff, v. No. 2000-02907 ROBERT L, ROBINSON, JR., A!KIA ROBERT ROBINSON CAROL J. ROBINSON, A!KIA CAROL ROBINSON Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $108,712.50 Interest from 10/9/02 to 3/5/03 (per diem -$17.87) $2,644.76 and Costs TOTAL $111,357.26 1-(IJ)IV\~ ~ ~, FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff . Note: Please attach description of property.No, i'~-':,h,', ",- .,..'i-:c "~.;jllllli'- - ',--'.~ ~ '..,""",-, l.ll'~~~~a.""'MI .d~ - . " " . .. _-'.:..0.- 1- ~ . ' ~, /1 , , r ~ t":l= ~~ t":l.... 0" > c:iZ '"Ij "::I t""r '" ~., 6: ~" ~ '" - :--:;::l 0 tl:I= (1) t':lt"l [ P.- t":l t":l ~O .... ~t":l ~ .... 0= > ~g ~ ~.::> j~ =.... ., >oS;; ....Z t"l @ -..1 o '"l Z'" '" t:l~ ... ",0 '" ;::;: ~O O~ t":lt":l t":l0 "0 0 IICl ~ 00 ~ ~ 8 10 ~:a g'"l (1) IICl ~ =::z !!l ~ '< (1) ~~ -< "::I'" Zt":l '" S' '"l2:! ~ ~~ F!~ 9 ~ ... ~ ., ~~ ~ "::I ~ 0 >~ -==:: 0" ~ Ol o'"l t":l> ~ t"l0 (1) ~ 5" '" t"l ~~ 1::1 Zz '" ...~ = (1) ;:;; ., ~ .... Z"::I ~ HI _~ ~t"l '" ~ .~ .,c. t""[;.; t":l "'t"" (1) ~ t":l 0 tst"l P- C ~~ C '" <:> e3 ., z ~~ .... 0 =~ ., "::I Z ....0 ""''"l ~ ~= > ~ ~ 0.... ~ Z~ ~ [ 0 ~ ~ z r ~ ~. "::I ~ "- * ...... > 6'..... w~ ~ R; .... w ...o~~ :-O~ :---6'" 0 . c.:> 0 () . ~~ -..1 4) C N .'f1 )D ",. () D D {) 0 d 1Il 8 t; B ;;:: 0 "--:::? '+ ~ ~ l! () () () c 0 -OeD ("") ~.:, ~J rnrT -l "'r--- ~ I I , ;.~::r] I -:~';8 0 0 I I I I -U ;?:::~~: en :~~~<;;t ...l'),-_;" - 'r~ ~c~- ""l:J ' " 1.;;:-" ::: ::; - -, ':~,;C) ~ ::; ~ ~2 ...-'-'. l ~ :c:":,;:f1'1 ~~~ r:~ ~", - - , ~ - - - -:. .::::. ~ ~ -- .~ '"< , ~"" I, ." ~, '~"""",-; '. ... ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania I bounded and described as follows, to wit: BEGINNING at a stake at corner of land now or fopmerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) deg~ees West three hundred forty- seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single Yornan, by her deed dated January 14, 1971, and recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Deed Book lIy", Volume 23, at Page 232, conveyed to Raymond Robinson, Jr., one of the Grantors herein~ TOGETHER with the right to use the right-of-way extending from the land herein conveyed to the Township Road n , and extending along the Glenn Smith land. said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and assigns in conjunction with the Grantors, their heirs and assigns. BEING the same premises that RAYMOND ROBINSON, JR, AND MARY B. ROBINSON, by it's deed dated 11/27/78 and recorded in the Office o~Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 11/28/78 III Deed Book Volume E-28, Page 137, granted and conveyed unto ROBERT ROBINSON AND I CAROL ROBINSON, Grantor herein. PREMISES BEING KNOWN AS 73 SANDBANK ROAD, SHIPPENSBURG, PA 17257 .1_ ~. ~. '-",*",-" FEDE~andPHELAN,LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PffiLADELPffiA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION ROBERT L. ROBINSON, JR., A!KIA ROBERT ROBINSON CAROL J. ROBINSON, A!KIA CAROL ROBINSON NO. 2000-02907 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: o 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. ..~ l',QrfJiJl~~ FRANKFEDERMAN,ESQUIRE Attorney for Plaintiff ,- ....... ~'tl!]l"'r""""-~li~~~~Jlljil,ll;!;\i,!jJ!illl.{''';''';' ,,,, 11.- "Jklllill~". I""": ~ o '" c:> n - (') C -y >- -o~ "" .. ':i "r; ~~ CC-" ~t~ yC;: -7 ~2 - 'I I \ CO o -'("1 __-1 "C ~'T"\ C),~ '-~fi(~ '-2~,f1;l ~ 2 ~ -' .- """,,,.,"",~1;/.~1 .. i ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, No. 2000-02907 v. ROBERT L. ROBINSON, JR., AlK/A ROBERT ROBINSON CAROL J. ROBINSON, AlK/A CAROL ROBINSON Defendant(s). October 4, 2002 TO: ROBERT L. ROBINSON, JR., AlKlA ROBERT ROBINSON CAROL J. ROBINSON, AlKlA CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 "THlS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 73 SANDBANK ROAD. SHIPPENSBURG. PA 17257. is scheduled to be sold at the Sheriff's Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $108.712.50 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement wiIl be made at said sale in compliance with Pa,R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: Q15) 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. 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 find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale, This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 - -', , L _~41~" . ,. ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows. to wit: BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd John~on; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson Nqrth sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single woman, by her deed dated January 14, 1971. and recorded in the Office of the Recorder \ of Deeds, in and for Cumberland County. Pennsylvania, in Deed Book "yn, Volume 23, at Page 232, conveyed to Raymond Robinson, Jr., one of the Granto~s he~ein. TOGETHER with the r~ght to use the right-of-way extending from the land herein conveyed to the Township Road n , and extending along the GLenn Smith land, said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and assigns in conjunction with the Grantors, their heirs and assigns. BEING the same premises that RAYMOND ROBINSON, JR. AND MARY B. ROBINSON, by it's deed dated 11127/78 and recorded in the Office o~Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 11128/78 III Deed Book Volume E-28, Page 137, granted and conveyed unto ROBERT ROBINSON AND CAROL ROBINSON, Grantor herein. PREMISES BEING KNOWN AS 73 SANDBANK ROAD, SHIPPENSBURG, PA 17257 ,c' ,c. "~,h ,,- ~..~'~ a-W~~il!t,l",~oo-J'~"&\lW1k.Wi~"<<""u~~~-'-"",""", "..,.,t.~ Uilillllillr~' lIIiiIIiilliII~lfiI~- . () C M~ Dre [Dr:;-; I~ '7 ~ .~ <::) I',} a C7 --l I Co o -T, :'-::;1 ':',1'T1 :rfij -,;, ~~1 ~5 ~;:2ib1 ;;-',I"n ~ 5:1 -<...; ~ ._,..... ,~} ~ ~' I <." , .~ "'~ I ~ _,...."""""'" WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 00-2907 Civil CIVIL ACTION - LAW I I i 1 I I ! I I I I i I I I I I 'I i I .1 i I i I ,I TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From ROBERT L. ROBINSON, JR" A/K1A ROBERT ROBINSON, CAROL J, ROBINSON, A/KJA CAROL ROBINSON, 73 SANDBANK ROAD, SIDPPENSBURG, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $108,712,50 L.L. $,50 Interest FROM 10/9/02 TO 3/5/03 (PER DIEM - $17.87) - $2,644,76 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $213.92 Other Costs Plaintiff Paid Date: OCTOBER 8, 2002 CURTIS R. LONG (Seal) Prothonotary .B,y: ~(!.;y. ,<. Q. 7?{Cfl/ZA')-(. f Deputy REQUESTING PARTY: Narne FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHlLADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 \. . ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT L. ROBINSON, JR., AfKIA ROBERT ROBINSON CAROL J. ROBINSON, AfKIA CAROL ROBINSON NO. 2000-02907 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) ASSOCIATES CONSUMER DISCOUNT COMPANY, 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 .73 SANDBANK ROAD. SHIPPENSBURG, P A 17257 . I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT L. ROBINSON, JR., AlKlA ROBERT ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 CAROL J. ROBINSON, AlKlA CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) G H HARRIS ASSOCIATES P.O. BOX 216 DALLAS, PA 18612 GREENWOOD TRUST COMPANY DISCOVER CARD TO BE DETERMINED i~k.' " 11. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania . Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 4. 2002 DATE 1MJY\k 1:Q~d/~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ''',,' ~,~ .'''.",W' --iBlilif-'-'&~<~_'ilIil"',", .~ ~. ~ ,'~, ~'~ " -~,~ fUfW"~i '-c ~ ....'" ,". --..' ."" o c ~ ""- '"DtQ lrrlfT, :z ::~ ;~2: -< " I~""'T -'--' 3>r'l ;SC--) ,PC". Z =< ~. -- , '::: . . a f'') o n --; C) --0 ~ i ()) '-'~ ':,'1'---) ~~:26 g~~ ::;:! 55 -< -0 -",. r:: . l , ~ FEDERMAN AND PHELAN, LLP By: Daniel G. Schmieg, Esquire Attorney I.D. No. 62205 Suite 1400, One Penn Center at Suburban Station 1617 John F. Kennedy Blvd. Pbiladelpbia,PA 19103-1814 (215) 563-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff Vs. ROBERT L. ROBINSON, JR., AIK/ A ROBERT ROBINSON, CAROL J. ROBINSON AlK/A CAROL ROBINSON Defendant( s) '.....wi,.d~~"'" ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY No. 00-2907 CERTIFICATION OF SERVICE I, Daniel Schmieg, Esquire, hereby certify that a copy of the Rule Returnable Date of December 23,2002 and a copy of Plaintiffs Motion to amend Caption And Action Nunc Pro Tunc, have been sent to the individuals indicated below on December 5, 2002. Robert L. Robinson, Jr., AlK/A Robert Robinson 73 Sandbank Road Shippensburg, PA 17257 Date: December 10, 2002 Carol J. Robinson, AlK/A Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 Respectfully submitted, Federman and Phelan,LLP ByE~~ aniel cliffiieg Attorney for Plaintiff .-.1. - .' ....1.'" I. . I,......_~ ......- , >~t~__ , - ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW ROBERT L. ROBINSON, JR" AfKJA ROBERT ROBINSON, CAROL J. ROBINSON, AJKJA CAROL ROBINSON, Defendants NO, 00-2907 CIVIL TERM ORDER OF COURT AND NOW, this 4th day of December, 2002, upon consideration of Plaintiffs Motion To Amend Caption and Action Nunc pro Tunc, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. Service of this Rule will be deemed to be complete upon mailing to Defendants (use all spellings) at their last !mown addressees). BY TIlE COURT, oJ J. J. Daniel G. Schmieg, Esq. Suite 1400, One Penn Center /,",~at Suburban Station 1617 John F. Kennedy Blvd, Philadelphia, PA 19103-1814 Attorney for Plaintiff . , . ~/ ' :rc 'r "';'i.w:lii!il!lSi~,"~$9Jit&gH~Ul~~1~...ilMiit4!i:W;;'~~*,\i"'iW"c4I!h~,""","~;,.,"<i~~~- - - , ,~" ~ -" ~- ~.d~ ~_'='~~OJljI,"......JJ,~ , ~ II~ - . (") 0 0 C N 'Tl s: <::) '-1 -ortJ ('11 T nlrT~ ..:.:-,1 -;;>--,- n ' L1r"~' ~-' zr-- :)~.J C/) :t -.J -<:;:- '~~~C) ~~~ :E.:; --,:- "1', ~ ~~~~~ Pc Z j'.) ~ --j :5J -, (.;1 -< " r.~ '. ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff v. ROBERT L. ROBINSON, JR., AlKJA ROBERT ROBINSON, CAROL J. ROBINSON, AlKJA CAROL ROBINSON, Defendants ._'i~~....:..,., -.' .'-1 . . i~~ ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 00-2907 CIVIL TERM ORDER OF COURT AND NOW, this 4th day of December, 2002, upon consideration of Plaintiffs Motion To Amend Caption and Action Nunc pro Tunc, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. Service of this Rule will be deemed to be complete upon mailing to Defendants (use all spellings) at their last known address( es). BY THE COURT, "'I 11 OJ) J. J. ./ Daniel G. Schmieg, Esq. Suite 1400, One Penn Center at Suburban Station {lOp'j 1617 John F. Kennedy Blvd. L . \ d. Philadelphia, PA 19103-1814 ~ [f\Cl.\ e. Attorney for Plaintiff ~~ J:2.-4'O~ :rc l !, H'- m.II!I~,~ .. ~ A'~ _'",--" ~. ',- - , rl\,ID-DfH~E Oc -. ,-' i~;{)r,-;r:~~<OTAnY 02 DEe -4 PH 2: 28 CU'"<:i'.'" "I', ("'UN"I l'llwci-<IU\r'LJ j"", I I PENNSY0JANI/\ --. , .,..." """",. ~T!l,,1U~. .~IIiL[~~R~, ~o" ,~ _, ~~ "~ ..J..~ll<I M'~ ~ . "I " -"'l5II>1>'.,lI<JI""" .~ FEDERMAN~AND PHELAN LLP , ,1, '1. ' By: Daniel.G. Schmieg, f\squire At'totney LD. No. 62205 Suite 1400, One Penn Center at Suburban Station 1617 John F. Kennedy Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 -' NOV 2 5 2002~ ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY No. 2000-02907 Vs. ROBERT L. ROBINSON, JRA/K/A ROBERT ROBINSON . CAROLJ. ROBINSON A/K/A CAROL ROBINSON Defendant( s) ORDER AND NOW, this day of ,2001, upon consideration of the Motion to Amend Caption and Action Nunc Pro Tunc and Memorandum of Law and any response if any, it is hereby ORDERED AND DECREED that the caption and action is hereby amended Nunc Pro Tunc to correct the defendant's name from "ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON" to "ROBERT L. ROBINSON, SR. A/K/A ROBERT ROBINSON". It is further ORDERED AND DECREED that the Prothonotary correct the docket information in accordance with this Order. By the Court: J. *"',....., ',. '"--,- ~ ~"~-" " '-'Ill' ~. I<~","""':,,",~' FEDE~ .}ND PHELAN, LLP By: Daniel,G. Schmieg, ilsquire SUite 1400, One.[>eun Center at Suburban Station 1617 JohnF. Kennedy Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY No. 2000-02907 Vs. ROBERT L. ROBINSON, JR. A/KJ A ROBERT ROBINSON CAROL J. ROBINSON A/KJA CAROL ROBINSON Defendant( s) PLAINTIFF'S MOTION TO AMEND CAPTION AND ACTION NUNC PRO TUNC To the Honorable Court: AND NOW, comes the Plaintiff, ASSOCIATES CONSUMER DISCOUNT COMPANY by and through its attorney, Federman and Phelan, LLP respectfully requests that this Honorable Court enter an Order granting Plaintiffs Motion to Amend Caption and Action Nunc Pro Tunc to correct Defendant's Name for the following reasons: I. Plaintiff commenced the above-captioned mortgage foreclosure civil action on May 9,2000, by filing its Complaint, a true and correct copy of which is attached hereto as Exhibit "A". 2. Through inadvertence or mistake, Plaintiffs Complaint erroneously listed the Defendant as ROBERT L. ROBINSON, JR. A/KJ A ROBERT ROBINSON whereas the proper spelling of the defendant's name is ROBERT L. ROBINSON, SR. A/KJA ROBERT ROBINSON. 3. It is believed, and therefore averred, that the Defendant's are disinterested in the mortgaged premises as no responsive pleadings have been filed. i!(,;jiiiill"L. I. '-~, ~"""""'''<,..", ',' WHEREFORE, Plaintiff respectfully requests that this Honorable court grant its Motion to Amend Caption and Action nunc pro tunc to correct the caption of the instant action. Respectfully, Federman and Phelan, LLP BY:~~ ~l G. Sc ieg, squire Attorney for Plaintiff , I'~? - , ,_-' ''-'c ,. '~I,~' ,'. < -"1',; . ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, NO, ROBERT L. ROBINSON JR. A/K/A ROBERT ROBINSON AND CAROL J, ROBINSON A/K/A CAROL ROBINSON Defendants NOTICE CIVIL ACTION - LAW MORTGAGE FORECLOSURE '., 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. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone (717)249-3166 , -4 >,,:)"jfA .1l , .tJ... ~ "~ , .- , ,~_,o_, ,., ,_, ~ ,; -:r, ~,.. ""': " NOT I C I A Le han demandado a usted en la corte. si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de be presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sinprevio aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONnE SE PUEDE CONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone (717)249-3166 I 1\ .."",..~ .'____'d,;,_.. d ._, ',' ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. ROBERT L, ROBINSON JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor, PURCELL, KRUG & HALLER Leon P. Haller, Esquire 1719 North Front Street Harrisburg, PA 17102-2392 (717) 234-4178 Attorney ID #15700 Attorney for Plaintiff I' 1\. ..~ ,-!.i.. '"' d" -^_." ~ ,_ '. ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. ROBERT L. ROBINSON JR. A/K/A ROBERT ROBINSON AND CAROL J, ROBINSON A/K/A CAROL ROBINSON Defendants CIVIL ACTION - LAW MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff, ASSOCIATES CONSUMER DISCOUNT COMPANY, is a Corporation with offices at 1111 Northpoint Drive, Building 4, Suite 100, Coppell, Texas 75019-3931, 2. Defendant, ROBERT L. ROBINSON JR, A/K/A ROBERT ROBINSON, is an adult individual whose last known residence is 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643. Defendant, CAROL J. ROBINSON A/K/A CAROL ROBINSON, is an adult individual whose last known residence is 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643. 3. On or about September 25, 1996, Defendants executed and delivered a Loan Agreement in the sum of $69,030,332 payable to ASSOCIATES CONSUMER DISCOUNT COMPANY, which Loan Agreement is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Loan Agreement, in order to secure payment of the same, Defendants made, executed and delivered to the Mortgagee, a certain real estate Mortgage which is recorded in the within Commonwealth and County in the Office of the Recorder of Deeds in Mortgage Book 1343,. ~; .y"'! -~ ~ L- "~iri p<J.g.e;;;.q~:9~ conveying to the original Mortgagee the subj ect premises. said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 73 SANDBANK ROAD, SHIPPENSBURG, PENNSYLVANIA 17257-9643, and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 68,503.41 (b) Interest at $25,07 per day from 7/1/99 to 3/1/00 (based on contract rate of 13.36%) 6,092.01 (c) 15% Attorney's commission 10.275.51 TOTAL $ 84, 87U{:_ *Together with interest at the per diem rate noted in (b) above after March 1, 2000, and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff, 8. No Judgment has been entered upon said Mortgage in any jurisdiction, f. )',', ,.P ~F " ~. -" L. '. - ~u -~" 9. Plaintiff has complied with the notice procedures required by Pennsylvania Act 160 of 1998 by sending to each Defendant, by regular mail, a copy of the combined Act 6/91 Notice. A true and correct copy of the Combined Act 6/91 Notice, along with a copy of the Certificate of Mailing, is attached hereto as Exhibit "C". 10. The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. 11. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13.36% ($25.07 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. PURCELL, KRUG & HALLER By Leon P. Haller Attorney for Plaintiff I. D. #15700 1719 N. Front St. Harrisburg, Pa. 17102 (717) 234-4178 .~- -,- . - -~-~-- :-,~'.'.~..1 ~~ .~ - - ,,<,,~- BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single woman, by her deed dated January 14, 1971, and recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Deed Book "Y", Volume 23, at Page 232, conveyed to Raymond Robinson, Jr., one of the Grantors herein. TOGETHER with the right to use the right-of-way extending from the land herein conveyed to the TOlvuship Road U , and extending along the Glenn Smith land, said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and assigns in conjunction with the Grantors, their heirs and assigns. f (~3 Ii ...; )<1'1 r 6-; /:.. ^ ----'~ ' ~- - ,,~ ,~" I'b" " ~:.a<t;;~,,; ACT 9 1 NOT ICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortqaqe on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This Notice explains how the proqram works. To see if HEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselinq Aqencv. The name, address and phone number of Consumer Credit Counselinq Aqencies servinq your County are listed at the end of this Notice. If yOU have any questions, YOU may call the Pennsylvania Housinq Finance Aqencv toll free at 1-800-342-2397. (Persons with impaired hearinq can call (717)780-1869). This notice contains important legal information. 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 PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. L;,' /-I; 'v ,",.-' "C_- L / '" - 1.. "..~. '-'i ~ ,",' ., ~-,"- "~'Il '. January 10, 2000 To: Robert Robinson 73 Sandbank Road Shippensburg, PA 17257 Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 Re: Loan No. Property: 9643 013772610219674 73 Sandbank Road, Shippensburg, PA 17257- CURRENT LENDER/SERVICER: Associates Financial Services Co., Inc., 1111 Northpoint Drive, Building 4, Suite 100, Coppell, Texas 75019-3931 HOMEOWNERS 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 RESUMING YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY 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 a representative of the creditor or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan or to otherwise settle your delinquency. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. .'- _ _-,-,"""'~ "-"~"-'~"4.,(-,;,"I~'_ ~,-' ..",,',.,', --,--- - CONSUMER CREDIT COUNSELING AGENCY - If you meet with your creditor or with a consumer credit counseling agency identified in this notice, the creditor may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of desiqnated consumer credit counselinq aqencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific 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 thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS 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 still apply for Emergency Mortgage Assistance.) ~,; HOW YOUR MORTGAGE IS IN DEFAULT NATURE OF THE DEFAULT - The MORTGAGE debt held by the above creditor on your property located at: 73 Sandbank Road, Shippensburg, PA 17257 IS IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS. The following amounts are now past due: Delinquent payments (7 @ $889.91) Payment due during cure period $ 6,229.37 889.91 Total amount due $ 7,119.28 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (EXPLAIN): NOT APPLICABLE 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 plus any additional monthly payments and late charges which may fall due after the date of this notice and the date you make your payment. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Associates Financial Serives Co., Inc. llll Northpoint Drive, Buildinq 4, Suite 100 Coppell, Texas 75019-3931 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: NOT APPLICABLE IF YOU DO NOT CURE THE DEFAULT - If you db not cure the default within THIRTY (30) DAYS of the date of this Notice, the creditor intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due ~s not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start a lawsuit to foreclose upon your mortqaqed property. ~ IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the ~ender rerers ~our case to its attorneys, but you cure the ?elinquency"be~ore the creditor begins legal proceedings again~t iOu, yo~ wl~l stlll be requlred to pay the reasonable attorney s rees thac 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 chey exceed $50.00. Any attorney's fees wlII 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) D~Y period. vou will not be reauired to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you for the unpaid principal balance and all other sums 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 riaht to cure the default and prevent the sale at any tlme UP to one hour before the Sherlff's Sale. You may do so bv paVlna the total amount plus any late or other charges then due, reasonable attorney's fees and costs connected wlth the foreclosure sale and any other costs connected wlth the Sherlff's Sale and bv perform1na any other reauirements under the mortaaqe. personally due under the EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately FOUR months from the date of this Notice. A notice of the actuar-Qate 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 Eayment or action will be by contacting the lender. If money is QUe, suc~ payment must be in cash, cashier's check, certified check or money order, made payable to the lender at the address set forth above. HOW TO CONTACT THE LENDER Associaces Financial Services Co., Inc. 1111 Northpoint Drive, Building 4, Suite 100 Coppell, Texas 75019-3931 (800)438-0263 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's 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 Sher~ff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. OTHER RIGHTS THAT YOU HAVE - You have additional rights to help protect your interest in the property: YOU MAY ALSO HAVE THE RIGHT: . TO SE~~ 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 HAV3 THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAV3 THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT ~AD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAV3 THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN Ao.'\lY CALE:;'uAR YEAR.) ,-.c' -'-.-1 ~,- "Ii<' l"l.ll . . · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEBDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMBNTS, · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (SEE ATTACHED) <"0,' J', T' CUMBERLAND COUNTY CCCS of Western PA, Inc. 2000 Linglestown Rd. Harrisburg, PA 17102 (717) 541-1757 Urban Leg. of Metro. Hbg North 6th Street Harrisburg, PA 17101 . (717) 234-5925 FAX#(717)234-9459 Community Act. Commision of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717)232-9757 FAX#(717)234-2227 Financial Counseling Services of Franklin 31 W. 3rd Street Waynesboro, PA 17268 (717) 762-3285 YMCA of Carlise 301 G. Street Carlisle, PA 17013 (717)243-3818 FAX#(717)731-9589 ,--;.. -- ~, ~, Re: Associates vs. ROBINSON Act 6/91 Notice U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3817) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: Robert Robinson 73 Sandbank Road Shippensburg, PA 17257 Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 j I . ~ I I i ! ~.- , ~.' '. ,',~. , .. .. /:. -----...),>.\. / ' "/ ~,,,,:,\-: "\ =-2~ \ I I "d,_' ( .-: !,. ' ~ ~ " ~i~~~~'- . j . . --!. I~ ""-.\ ,.-. .:~! \~ _" / ;I ""~Y ."'?-.;.-::.-----.. :--.:~".;{;.~ .---:~_.:.::-.::-_-:-,. -----::.--::..-:::..:.-=:._- . "'- " < . .... r __!. .~~, ': < " -'__ __ I< ~- ~. . 'c''''_'_-'.. k","^ , - ~--- .lilT :ro. COMPANY NAME: ASSOCIATES CONSUMER DISCOUNT COMPANY VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 1../- !J 8- JDDD ~'0 II} J) By . ,'jJ:)L, . cKiJuLiL . Title FDf'cC)riSU('t'.. S02GiCcliSf , ~ ^ ,- "~ ~ ,".. L~ " '''''~;;!<iItoI''2"_ .FEDRRMAN AND I'HELAN, LLP By: DaniM:G. Schmieg, Esquire Suite 1400, One .penn C~nter at Suburban Station 1617 JohnF. KennedyBlvd. Philadelphia,P1\ 19103-1814 (215) 563-7000 1\ TTORNEY FOR PLAINTIFF ASSOC~TESCONSUMER DISCOUNT COMPANY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 2000-02907 Vs. ROBERT L. ROBINSON, JR. AJKJA ROBERT ROBINSON CAROL J. ROBINSON AJKJA CAROL ROBINSON Defendant( s) PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO AMEND CAPTION AND ACTION TO CORRECT DEFENDANT'S NAME Pa. R. C.P., Rule 1033 of the Pennsylvania Rules of Civil Procedure specifically provide that: A party may, be leave of court at any time, amend his pleading. The amended pleading may aver trans- actions or occurrences which have happened before or after the filing of the original pleading... "Amendments should be allowed with great liberality at any stage of the case unless they violate the law or prejudice the rights of the opposing party." See Gutierrez vs. Pennsylvania Gas and Water Company. 507 A.2d 1230, 1232 (1986). In the instant case, the original suit referenced the Defendant's name as ROBERT L. ROBINSON; JR. AJKJA ROBERT ROBINSON whereas the proper spelling of the Defendant's name is ROBERT L. ROBINSON, SR. AJKJA ROBERT ROBINSON. WHERFORE, Plaintiff respectfully requests that this Honorable Court grant its Motion to Amend Caption and Action Nunc Pro Tunc to Correct Defendant's Name to reflect the correct name. Respectfully submitted, Federman and Phelan, LLP DATE: November 14, 2002 By:~q~ . el G. Solfulleg, Esquire Attorney for Plaintiff ~ ..........~~, talllol ~." , . -~ 1->-.-. - .'.'\m.{Io""'<~""",,lM'-, . FEDERMAN AND'l'IlELAN, LLP By: DllIlieJ G. Sc\vnieg, Esquire Suite 1400, One Penn Center at Suburban Station 1617 JohnF. Kennedy Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff COURT OF COMMON PLEAS CNIL DNISION CUMBERLAND COUNTY No. 2000-02907 Vs. ROBERT L. ROBINSON, JR. NKJA ROBERT ROBINSON CAROLJ. ROBINSON NKJA CAROL ROBINSON Defendant(s) CERTIFICATE OF SERVICE I, Daniel G. Schmieg, Esquire, hereby certify that a true and correct copy of the Motion to Amend Caption and Action Nunc Pro Tunc to Correct Defendant's Name was sent by regular mail to the following person(s): Robert L. Robinson NKJ A Robert Robinson 73 Sandbank Road Shippensburg, P A 17257 Carol J. Robinson NKJA Carol Robinson 73 Sandbank Road Shippensburg, PA 17257 Respectfully submitted, Federman and Phelan, LLP By: Dated: November 14, 2002 - j~- ~. " ~""~"^,,I\I:i_~\-,-;lli, ".. -. , . . . VERIFICATION I, Daniel G. Schmieg, Esquire, state that I am the attorney for the Plaintiff in this action, and that I am authorized to make this verification, and that the statements made in the foregoing Motion to Amend Caption and Action Nunc Pro Tunc to are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Respectfully submitted, Federman and Phelan, LLP DATE: November 14,2002 BY:~ D 'e G. S 'eg, Esquire Attorney for Plaintiff - .jlii.-~" m!!ilill'- ~ iUWliilliilllf~jM",..tiIMil'.#~t0-1~1IMfW'~t_lliilir' -'""'-"~"ii" ~~IJ-' rU;;Q7"'N" ^" ~"" =,",- >.J1lJ~_. "lIi.lt:'.; . . . . 0 0 0 C N " 5: % ....j -0\" 0 -~ ~"TI mrn .c rnF ~~ N :g? ~:z N 00 r;;:O -0 ~..,., ~O -~ 1") :!J - 7("1 ....-rT\ ~~ ~ ~ ~ ,~ :P- O'.> :Q ll' , .", ~''''W1I!>"""",,ilk,' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Central Penn Property Serv Inc is the grantee the same having been sold to said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the 8th day of October, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 2907, at the suit of Associates C D C against Robert L Robinson Sr aka Robert & Carol J aka Caorl is duly recorded in Sheriffs Deed Book No. 256, Page 2849. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this lit, day of ~ , A.D. 2003 ~~ (\, 'i. oDftrr J :Iv.- I.l ~ 0 ,~' 'Re~rder of Deeds ~ ~ '~a",,,,,~,,,,,,,,l>lU,,", Associates Consumer Discount Co. VS Robert L. Robinson, Sr. a/kIa Robert Robinson and Carol J. Robinson a/kIa Carol Robinson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-2907 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on January 22,2003 at 5:02 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defehdant, to wit: Robert L. Robinson, Sr. a/kIa Robert Robinson, by making known unto Robert Robinson, Sr., at 17 Kenneth Ave., Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on January 22,2003 at 5:02 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Carol 1. Robinson a/kIa Carol Robinson, by making known unto Robert Robinson, Sr., husband of defendant, at 17 Kenneth Ave., Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 13,2003 at 9:09 o'clock A.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert L. Robinson, Sr. a/kIa Robert Robinson and Carol J. Robinson a/kIa Carol Robinson located at 73 Sandbank Road, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following mauner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Robert L. Robinson, Sr. a/kIa Robert Robinson, by regular mail to his last known address of 17 Kenneth Ave., Shippensburg, PA 17257. This letter was mailed under the date of January 23,2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following mauner: The Sheriff mailed a notice of the pendency of the action to one ofthe within named defendants to wit: Carol 1. Robinson a1k/a Carol Robinson, by regular mail to her last known address of 17 Kenneth Ave., Shippensburg, P A 17257. This letter was mailed under the date of January 23,2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 5, 2003 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Central Penn Property Services, Inc.. It being the highest bid and best price received for the same, Central Penn Properties Services, Inc. of 100 South 7th Street, Akron, PA 17501, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $47,800.40. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed $30.00 900.00 15.00 15.00 30.00 10.00 .50 1.00 4.58 4.56 15.00 30.00 339.80 319.24 25.34 25.00 40.00 $1,805.02 Sworn and subscribed to before me .v~ This ~ day of - 2003, A.D. ~~ (1 Jtu;h. ) r honotary Af21. So Answers: r~~ :~al~~ 'N' ,,;m_~,,,,,,, / V If'> , '!J~' {fJ \. 40,;'3'1 ~ j:31jiD ~ l~ ~ ~" ~ -~" -. ~ , I " '''-'''''''JcL~b WRIT OF EXECUTION ~nd/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-2907 Civil CIVIL ACTION - LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From ROBERT L. ROBINSON, cSR AfK/AROBERT ROBINSON, CAROL J. ROBINSON, AfK/A CAROL ROBINSON, 73 SANDBANK ROAD, SHIPPENSBURG, PA 17257 (1) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property "fthe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify 1:4e garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from payiiIg any debtto or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notity himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount bue $108,712.50 L.L. $.50 Interest FROM 10/9/02 TO 3/5/03 (PER DIEM - $17.87) - $2,644.76 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $213.92 Other Costs Plaintiff Paid Date: OCTOBER 8, 2002 CURTIS R. LONG (Seal) Prothonotary ~: 0(J~ 17 ;:;.7"fr./lJUX.J Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 "",." .___,....""~_.',.0'""..".,wn'",,",D''''_.,_''''~___-- . -~~'~ Q ""'i?U ""'i?U = ~ If\fU , Real Estate Sale # 1 On October 23, 2002 the sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, P A, Known and numbered as 73 Sandbank Road, Shippensburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 23, 2002 By:C)cuuLltL-Q. g~bM '1_, " ~~. ~.-'-''\ " .-Y"" ~. -", ~~, ,,~ ,f~ '.'. 1"'.1 (-r ,,1 '- """ ,U.i1J :!:Jib"" . ..-,:> = ~; j.-1 G .' I" .L ~~ I!T'~~*-V' SCHEDULE OF DISTRIBUTION SALE NO. 01 Date Filed: April 4, 2003 Writ No. 2000-2907 Civil Term Associates Consumer Discount Co. VS Robert L. Robinson, Sr. alkJa Robert Robinson and Carol J. Robinson alkJa Carol Robinson 73 Sandbank Road Shippensburg, P A 17257 Sale Date: Buyer: Bid Price: March 5, 2003 Central Penn Property Services, Inc. $45,000.00 Real Debt: Interest: Attorney Costs: $108,712.50 2,644.76 213.92 Total: $111,571.18 DISTRIBUTION: Receipts: Cash on account (10/23/02): Cash on account (03/05/03): Cash on account (03/21/03): $1,500.00 5,000.00 42,800.40 Total Receipts: $49,300.40 Disbursements: To Sheriffs Costs: To Legal Search: To State Transfer Tax To Local Transfer Tax To Associates Consumer Discount Company Total Disbursements: Balance for distribution: so~sw : . ~~ f"J.. A -- ' -- , R. Thomas Kline Sheriff '- $ 1,805.02 200.00 858.70 858.70 45,577.98 ~,> ~ ~ , ",.." ",,",",,~Ui\'~-.; ($49.300.40) 0.00 ,~ . -I ~ " ( TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO.1 Held Wednesday, March 5, 2003 Date: March 5, 2003 TAXES: Receipts for all taxes for the years 2000 to 2002 inclusive. Taxes for the current year 2003. 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 2003, and recorded 2003, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Raymond Robinson, Jr. and Mary B. Robinson, his wife, by deed dated November 28, 1978 and recorded November 28, 1978 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book "E," Volume 28, Page 137, granted and conveyed to Robert Robinson and Carol Robinson, his wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney 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. Under and subject to rights in and obligations to maintain a private 33 foot right-of-way extending from the subject premises to the Township Road. 6. Mortgage in the amount of $69,030.00 given by Robert Robinson and Carol Robinson to Associates Consumer Discount Company. dated September 25, 1996 and recorded September 30, 1996 in Mortgage Book 1343 Page 620. Complaint in mortgage foreclosure filed by Associates Consumer Discount Company as Plaintiff against Robert L. Robinson, Sr., Robert Robinson, Carol J Robinson, and Carol - """~~'I<I .," ~ ,- I~","" . ,~'. ""'~",.1!",-"~' I Robinson as Defendants in the Office of the Prothonotary of Cumberland County on May 9, 2000 to file no. 2000-2907. Default judgment in the amount of $108,712.50 entered October 8, 2002. 7. Judgment in the amount of $4,048.58 entered on November 12, 1998 by Greenwood Trust Company and Discover Card as Plaintiffs against Robert Robinson and Carole Robinson in the Office of the Prothonotary of Cumberland County to file no. 98-6408. 8. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff's sale. 9. Real estate taxes accruing on and after July I, 2003 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 District Court. ~~.~ Robert G. Frey, Agent ~.. Note: This Title Report shall not be valid r b ding until countersigned by an authorized signato . 'z: .." 1"",,-", " ~ - . , REAL ESTATE SALE NO. 1 \ 'Writ No. 2000-2907 Civil Associates Consumer Discoucr1t Company vs. Robert L. Robinson. Sr.. a/k/a Robert Robinson and Carol J. Robinson, a/k/ a Carol Robinson Atty.: Frank Federman ALL that certain lot of ground with improvements erected thereon situ- ate in the Township of Southampton. County of Cumberland and Com- monwealth of Pennsylvania, bound- ed and described as follows. to wit: BEGINNING at a stake at comer of land now or formerly of William E. Golden et ux and comer of land now or formerly of Boyd Johnson: thence by land of Golden South sixty'-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin: thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty- seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty-seven (347) feet to the place of BEGINNING. BEING Lot No.2 of the same tract which Amanda Robinson. widow and single woman, by her deed dat- ed January 14, 1971. and recorded in the Office of the Recorder of Deeds, in and for Cumberland Coun- ty. Pennsylvania, in Deed Book "Y". Volume 23. at Page 232. conveyed to Raymond Robinson. Jr.. one of the Grantors herein. TOGETHER with the right to use the right-of-way extending from the land herein conveyed to the Town- ship Road # . and extending along the Glenn Smith land. said right-of-way to have a width of thirty-three (33) feet. said right to exist in the Grantees. their heirs and assigns in conjunction with the Grantors. their heirs and assigns. BEING the same premises that RAYMOND ROBINSON. JR AND MARY B. ROBINSON. by it's deed dated 11/27/78 and recorded in the Office of Recorder of Deeds in and for CUMBERLAND County. Pennsylvania on 11/28/78 in Deed Book Volume E-28. Page 137. grant- ed and conveyed unto ROBERT ROBINSON AND CAROL ROBINSON. Grantor herein. PREMISES BEING KNOWN AS 73 SANDBANK ROAD. SHIPPENS- BURG. PA 17257. - --,..-,~" . ,~'" .' ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT L. ROBINSON, JR., AfK/A ROBERT ROBINSON CAROL J. ROBINSON, AfK/A CAROL ROBINSON NO. 2000-02907 Defendant(s). 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT L. ROBINSON, JR., AlKJA ROBERT ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 CAROL J. ROBINSON, AlKJA CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) G H HARRIS ASSOCIATES P.O. BOX 216 DALLAS, PA 18612 GREENWOOD TRUST COMPANY DISCOVER CARD TO BE DETERMINED 'j ~i_Wrbj,JI' " " . 4. > Name and address of last recorded holder of every. mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 4. 2002 DATE '~\kl,r\ ~ ' '+' ili{J!", ~ 'I ,'I " -++'f ..(,/4-._~., \ ,,(,..cr, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,I ---., - ;~~- . ASSOCIATES CONSUMER DISCOUNT OOMPANY . CUMBERLAND COUNTY Plaintiff, No. 2000-02907 v. ROBERT L. ROBINSON, JR., A/KJA ROBERT ROBINSON CAROL J. ROBINSON, A/KJA CAROL ROBINSON Defendant(s). October 4, 2002 TO: ROBERT L. ROBINSON, JR., AlKlA ROBERT ROBINSON CAROL J. ROBINSON, AlKlA CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 73 SANDBANK ROAD. SHIPPENSBURG, PA 17257. is scheduled to be sold at the Sheriffs Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$108.712.50 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ",-I. ~~ - ~-- - ,- --''-'Ii'. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. lfthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out lfthis has happened, you may call (717) 240-6390. 4. lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYEROR 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 "," ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd John~on; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single woman, by her deed dated January 14, 1971, and recorded in the Office of the Recorder of Deeds, in and for Cumberland County, Pennsylvania, in Deed Book Hyll, Volume 23, at Page 232,. conveyed to Raymond Robinson, J-r., one of the Grantors herein. TOGETHER with the right to use the right-of-way extending from the land herein conveyed to the Township Road U I and extending along the Glenn Smith land, said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and a$signs in conjunction with the Grantors, their heirs and assigns. BEING the same premises that RAYMOND ROBINSON, JR. AND MARY B. ROBINSON, by it's deed dated 11/27/78 and recorded in the Office o~Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 11/28/78 In Deed Book Volume E-28, Page 137, granted and conveyed unto ROBERT ROBINSON AND CAROL ROBINSON, Grantor herein. PREMISES BEING KNOWN AS 73 SANDBANK ROAD, SHIPPENSBURG, P A 17257 ~ REAL ESTATE SALE NO. 1 Writ No. 2000-2907 Civil Associates Consumer Discount Company vs. Robert L. Robinson. Jr.. a/k/ a Robert Robinson and Carol J. Robinson, a/k/ a Carol Robinson Atty.: Frank Federman ALL that certain lot of ground with improvements erected thereon situ- ate in the Township of Southampton. County of Cumberland and Com- monwealth of Pennsylvania. bound- ed and described as follows. to wit: BEGINNING at a stake at COIner of land now or formerly of William E. Golden 'et ux and corner of land now or formerly of Boyd Johnson: thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin: thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixtY-one (6i) degrees East two hundred forty- seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty-seven (347) feet to the place of BEGINNING. BEING Lot No. 2 of the same tract which Amanda Robinson, widow and single woman, by her deep dat- , ed January 14, 1971. and recorded in the Office of the Recorder of Deeds, in and for Cumberland Coun- ty, Pennsylvania. in Deed Book "Y", Volume 23, at Page 232, conveyed to Raymond Robinson, Jr.. one of the Grantors herein. TOGETIlER with the right to use the right-of-way extending from the land herein conveyed to the Town- ship Road # , and extending along the Glenn Smith land, said right-of-way to have a width of thirty-three (33) feet, said right to exist in the Grantees, their heirs and assigns in conjunction with the Grantors, their heirs and assigns. BEING the same premises that RAYMOND ROBINSON, JR. AND MARY B. ROBINSON. by it's deed dated 11/27/78 and recorded in the Office of Recorder of Deeds in and for CUMBERLAND County, Pennsylvania on 11/28/78 in Deed Book Vohune E-28. Page 137, grant- ed and conveyed unto ROBERT ROBINSON AND CAROL ROBINSON, Grantor herein. PREMISES BEING KNOWN AS 73 SANDBANK ROAD, SHIPPENS- BURG. PA 17257. -'"~~, - I - ~....J~;:"f' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929),P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JANUARY 31, FEBRUARY 7, 14,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. WORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 Not " LOIS E. SNYDER, Nll!;Jly Public . CarIlsIe Ilora, (,'i.!mbllr.~i1d County My Commission Expires March 5, 2005 -_~""~I"- " "" 'I.. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daiiy and/or Sunday! Metro editions which appeared on the 28th day(s} of January and the 4th and 11th day(s} of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #1 Notanal S T eny L Russell, Notary Publi City Of Harrisburg, Dauphin My Commission Expires June 6, 2006 OTARY PUBLIC Member, Pennsylvania Assodaijon Of Nolanes My commission expires June 6, 2006 'L.A.~..... . CUMBERLAND COUNlY SHERIFFS OFFICE CUMBERLAND COUNlY 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} $ Totai $ 317.49 1.75 319.24 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By..................................................,................. I" -- ---------- i ilEAL ESTATE SALE No.1 Writ No. 2000.2907 Civil Term Associates Consumer Discount Co. vs . l::Iobert L. ROblns!,n. Sr.~ AIKIA Robert Robinson and Carol J! Robinson, A/KJA Caro"! Robinson Atty:.Frank Federman DESCRIPTION ALL !hat certain lot of ground with !'.improvemenfs erected thereon situate in the ': Township of Southampton, County of : Cumberland and Commonwealth of " Pennsylvarrla, bounded and described as fonows., b:Jwit REGINNING at a stake lit comer of land now or. : ':.f6nncr}y of William Eo Golden et ux and corner -of land now or fonnerly of Boyd Johnson; thence '"ny.land of Golden South sixty-one (6]) degrees : :'West two hundred fom'-~C'\;en and ti\le-tentl1s : :(247.5) feet 10 an iron pin: .thence along private '.lane South thirty-two (32) degrees East three n\lndredJorty-sevc.n (347) feel. t(l. a f>take~ tlw.nce .along land now or formerly or Robert Robinson North ~xty-one (61) degrees .East two hundred forty-men and five-tenths (247.5) feet; thence North thirty-two (32) deglees West three hundled ."fdrt.y-seven (347) fcet to the place of ; aEGlNNING. BEING lot NQ, "2 of the same tract with Amanda , Robinson, widow and s.in.gle' woman, by her deed , dated January 14, 1971, and recorded in the , Office of the R":corOO,~qr ,Deed~ \n and for ; Cumb~'Tland Count)', Pennsylvania, In Dee.d Book "Y:'" ,Volume", 23, at Page 232. conveyed to '.: Raymoila" 'I{obiustlo lr., Que (If, the Gramm.\, I::, herein. :. TOGETHER with the right to use the right-afM (: way e1\.tending. from the land herein conve.yed to t., the TownshIp Road #-, ilnd extending along the r Glenn Smith land, said right-of-way to have a I". width of thirty-three (33) feet, said right t<l exi~t [..in the Grantee.~, their heirs ,me assjgn~ 01 :: ,cOluunctiorJ with the Gr.antors. their heirs and ':::a.~signs, ': ,BRING the same prerrli~es that RAYMOND 1 ROBINSON, JR and MARY B. ROBINSON, by ; its deed dated lJl2m8 and recorded in the :': Office of Recorder of Deeds in artd for I, CUMB"ERLAND County, Pennsylvania em 11/ '; 28m in Deed Book Vohlooe &28, Page 117, f .granted and cLlnveycd ,unto Ro.BERT ROBINSON and CAROL ROBINSON. Grantor ',- b!.7ein, . i .PREMISES BEING KNOWN as 73 'Sandhank LR~~~nsburg, PA I72SL--__._~~ ;-,,-_-101,";'" .,*.~.. ._".M_' . ~ ,. I,"~ ,.~" ~...... .'~ ,,,"IM.''i.,,,,.ioI,'',,,,- , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: ASSOCIATES CONSUMER DISCOUNT COMPANY ) CIVIL ACTION ) vs. ROBERT L. ROBINSON, JR.. A1K1A ROBERT ROBINSON CAROL J. ROBINSON A1K1A CAROL ROBINSON ) ) NO. 2000-02907 CIVIL DIVISION AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for ASSOCIATES CONSUMER DISCOUNT COMPANY hereby verify that on 10/8/02, 12/2/02 & 12/6/02 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders. and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 10/8/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: Februarv 13. 2003 ~ ~---::;:::::= 5~:~-'-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,- ~ "'~~" , '"'I~Iriiiilriuibi~~' 1__ ~E. ......~, - :;;: - - - - ~- "'''l .z V> '" N - 0 \0 00 .... '" V> .... '" N rI.llO-El U .. ., .. = III .. r , 10-"'= ( ~g, > l!l 10- g ::I. 11 n CD z c 3 tT CD , "'0' ~. @ ,;j i Q z ",,-~>Tj ~ E ~' . 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(D :r;~oo=~ ;;J~~s.Q, ; >-I~~ = !':gCfF en "CI"CI ~ g ~;;- . ~ I :!;t- I! ~l ~3 . 0' c.. -, .;:: :> :r.-' . . c. . ~ ".., ~ 0 Ill: :';; c.. . = ~O' "'. o ~ =-90 0", s-. S I ~ ... ~ ". ~ ~ ~ t.oi ~ ~ ~ ~ ~.'.. . . , . ! I~ ~ co '" GO ... '"' ... ... ... ... .' , , . ~~~g~ .,z"'" oOOz gj~el"~ ~:::=!:lo C'l QO "l'P.qs '" ~::r:lt:l '" O';J :: ~~e ..... CI1t:l~ 2 ~~~ ",,,,0 ..,,,,i': .0'" .~ '" 0:: ~ ~ '" " ~ ~ ~.. . . . , , ~&.~ .i'Osi.:.. ......... ~'.-? .,~ #~~ ~-.... . .~......... z .. ~..--~ ~ ~ I'fl'NEVeowe; $ 01.800 0.004300377 DEC 02 2002 MAllEOFROMZIPCOOE 19103 '. "'" I I I 1 I I r I I I ~ +'/. ;; , - , : 3 =. 0'''- . . ~ ~~:a-"",,",,",,-,",,_.o'_ t'" ;; .. o>z ~c.. [('...= J:l a eo ...... II " ... 1. z . 3 ~ o ~ > ... ... ~ a j '" l . . c. '" o ~ o S n ~ > ... ... ~ a . "'<oj", ::~~ iii'~l:l tg[!l!J j=~ _.~> JOeo~ "r:l!:;',...., >- ~ .... -.... "'-= -. I>i s~ t"I ~~ ~ '" .. .. .. o i :' ~ :P.c? J , ~E - - - .... '" '" - - - '" 00 .... 0-. v. ~~ v. .... '" '" - 0 or Kg. O"~ . '< 0 '" ~ . 0 . " . ~ ~ (I _.~" ~_..' -"'--... - , ~ -..I' ''''''","I_I~ ........."'-,..,.~"y, C..., > 21 c... r:nc.e ~g ~ ~ c~=~ - ... c. .z> . " " ... ::l _. ... 0" !2. ... ~ ("0 l ~(j ~g. i~ ~~ .,,~ go -~ 0::2: Slg o 0 o . ~ (lc:t::I~'ljt::H"l f~~~ ~~~ ~~i " ~~~~' ~ tiJ~r:nr:no~o ~ t'" ::It:l:l>:s::~ f~~~ ~ ~~(l~~l'l jl6Q~ ~ ~~uJ~~ ~ "'>21'lj ~ ~~~~ ~~ ;r. [;.j ~ J'.'lj o 11-0(..... ~ ~>il:1t'" ~ "'il:1o;::l 0 Q......""'d~ ~ r:n::':~ t"'''':I ~~t'"I ..,r:n "':I'lj ~a~ ~ ~~ ~~ 0, g:~> ..., o ..... ""! ~ >....r:n 'II: ~ S <::> ~ ~ <::> <::> ~ ~ .... <::> .... ~ => ~ => V, <::> <::> (l 0 ~ .., >< "'." .gg II -" ." ~ Z ~ ~ i?, 1:' g :;: " " ~ , 'J S 'Il -"_ L " ~ ',--""- ..... . ,. .;,> '.~ 1 71bO 3901 9844 0124 95b9 TO: ROBERT L. ROBINSON, JR., NKlA ROBERT ROBINSON 73 SA1>j.DBANK ROAD SHIPPENSBURG, P A 17257 SENDER: _~ REFERENCE: .S PS Form 3800 June 2000 I RETURN Postage : I RECEIPT Certified Fee I SERVICE Return Receipt Fee j j Restricted DeliverY ! Total Postage & Fees i I i i I iTa: I 1 I j I , I I i I I No Insurance Coverage Provlded , t 00 Not Use for International M~I .. _~"n 'hn hn n ......~__.h._~__ US Postal Service Receipt for Certified Mail ;"-':,"7"'-'"~~'''---;'~-''''-=-''' .~-~ 71bO 39D1 9844 01249!17b CAROL J. ROBINSON, NKIA CAROL ROBINSON 73 SANQBANK ROAD SHIPPENSBURG, PA 17257 " SENDER: .,.i:~.m ,,'. I' . , " I REFERENCE~~M - I. PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SEA~CE, . Return ReceJpt Fee RestrictOd: DeliveJy Total Postage.& Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided I 00 Not Use for International Mail I ~-........-----.---~--~-~..--~-."",------~"_"_~____ n_____u__~_______~______._________...__________4_ O'trn ',.' . - l!iI~I!:Iili;-'m:'iIM'.[~ilili!~~~",,~.Au;~~_iIlfcllI.~~1 '-~iIIiiIiiiii'liiilil1.l J' ~'""~.~- o c .,.~- LJi_~~~ rn r-~ ~r-- (oj- ~;::.. !E: ::=~ -< ;'--' 0, c:~ (.-) ..." ! ~,-j (::D rv Ci " :}< :...J ~~~ r~ 5:J -< -I . o -n _;t~1 - '< '--' .. FEDERMAN AND PHELAN, LLP. by: Daniel G. Schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON CAROL J. ROBINSON, A/K/A CAROL ROSINSON NO. 2000-02907 AND NOW, this 2"3 f-t,day of ORDER J2.lI> ,2003, upon consideration of Plaintiff's Motion to Make Rule Absolute, Nunc Pro Tunc it is hereby ORDERED) and DECREED that the Rule entered upon Defendant(s) shall be and is hereby made absolute and Plaintiff's petition is GRANTED and it is further: ORDERED AND DECREED that the caption and action is hereby amended Nunc Pro Tunc to correct the defendants name from "ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON" to "ROBERT L. ROBINSON, SR. A/K/A ROBERT ROBINSON" and that the Protonotary correct the docket information in accordance with this Order. (-2...'(-0") N~~. ~h:~ 1\44W -tv ~ S0ML/() << ~ <....eoh~~s, 1k .,--,,~,",,", ,,- ........"...I"'~==.=...~,,~Yitj~l$.~iIIIli'.\li~t\lt>l " ~" -,~ - "'- w..........~ .... .......;....~ (") c "< -ow mfn Z:D Z1:;:: ~;Z- yC) ~O -.-0 J>c: ~ 0' o;l '-- :p' ;f:: 1'-'> CO o -n :::1 ~~::; :!J 'r- _~"m -no 96. :'[~=t; ;;!() ~rt'l. ~ 51 0< "'" :"";!>" -- i2 .,- ...J .. 1 I I "'_="'~ I .~ ' -I~- ~ FEDERMAN AND PHELAN, LLP. by: Daniel G. Schmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON CAROL J. ROBINSON, A/K/A CAROL ROBINSON NO. 2000-02907 MOTION TO MAKE RULE ABSOLUTE Plaintiff, by its Attorney, Daniel G. Schmieg, Esquire, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above captioned mortgage foreclosure action, and in support thereof, avers as follows: 1. That it is the Plaintiff in this action. 2. A Motion to Amend Caption and Action Nunc Pro Tunc, or about November 14, 2002 and Rule was entered upon Defendant(s) ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON CAROL J. ROBINSON, A/KIA CAROL ROBINSON. 3. Upon information and belief, the Rule to Show Cause was timely served upon all parties in accordance with the applicable Rules of Civil Procedure. 4. Upon information and belief, the Defendant(s) failed to respond or otherwise plead by the Rule Returnable date. WHEREFORE, Petitioner prays this Honorable Court make the Rule to Show Cause absolute and enter the Order Amending Caption and Action. Daniel G. Schmieg, Esquire Attorney for Petitioner ",~ ~ ~..l. ',; . VERIFICATION Daniel G. Schmieg, Esquire, hereby states that he is the attorney for Plaintiff in this action, that he is authorized to take this affidavit, and that the statements made in the foregoing Motion to Make Rule Absolute, Nunc Pro Tunc I 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. ~4904 relating to unsworn falsification to authorities. DATE: January 27, 2003 Daniel G. Schmieg, Esquire Attorney for Plaintiff ~~ , 1- c ~~j:ix FEDERMAN AND PHELAN, LLP. by: Daniel G. Sehmieg, Esquire Atty. I.D. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON CAROL J. ROBINSON, A/K/A CAROL ROBINSON NO. 2000-02907 CERTIFICATION OF SERVICE I, Daniel G. Schmieg, Esquire, hereby certify that a copy of the Motion to Make Rule Absolute, Nunc Pro Tunc, and has been sent to the party indicated below Januarv 27, 2003. ROBERT L. ROBINSON, J1l.. CAROL J. ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 CC)l ...... Daniel G. Sch ieg, Esquire Attorney for Plaintiff Date: January 27, 2003 -," ,,~"" "' -~l!IIi.lli - ~~-"""""'jrft""""~~~~.!Il!r . ~,- -~ > < ~-- --~~.- .y.l_ 1i*lIlIiIIIliiIii' "' ~'"" ~ IIIIIIiliIiIii8Iiii11ii11iiiii . 0 <::> 0 c (......J- .,.. 'n ul~ '- ~ill J.~/;I' z ~ t5"> 1'0 ~~ --~-'" CD ~C; :!>> :~=~ ~-) ;t;~) :[1 :Jt: 0-+1 ""0 S? ~7C) Pc Om Z --I =<! N ~ O"l -< .., ,. ~-- ~. ~~ o;,~' 1Ii- .~,~~._~ - W~ "'"""'" -". !~,"'\I-H.~'H: ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT L. ROBINSON, JR., AlKfA ROBERT ROBINSON CAROL J. ROBINSON, AlKfA CAROL ROBINSON NO. 2000-02907 Defendant( s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) ASSOCIATES CONSUMER DISCOUNT COMPANY, 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 ,73 SANDBANK ROAD. SHIPPENSBURG, PA 17257. 1. Name and address of Owner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT L. ROBINSON, JR., A/K/A ROBERT ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 CAROL J. ROBINSON, A/K/A CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 2. Name and address ofDefendant(s) in the judgment: Same as above ,~ "ill ~~ - " "L_ " '.;. 1Il1'J;\j~_~~,,,,", 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) G H HARRIS ASSOCIATES P.O. BOX 216 DALLAS, PA 18612 GREENWOOD TRUST COMPANY DISCOVER CARD C/O OF ROBERT D. KODAK, ESQ. 407 NORTH FRONT STREET P.O. BOX 11848 HARRISBURG, PA 17108 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address carmot be reasonably ascertained, please indicate) 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 carmot be reasonably ascertained, please indicate) Tenant/Occupant 73 SANDBANK ROAD SHIPPENSBURG, P A 17257 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 . ~~ ~' ...~ J.".bJ..,,,,,~,,,_,j,,....,h- , I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Februarv 13. 2003 DATE "-c->", ~ ') k> ",r-:;.. .-,-,----..- --L._."~ -- ----""-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .hi~';".~ ~1iI~~1!~~L~!!ll~-"Sl"'.>!~'~"",":"!'w..'i";~'_"'''-'ij,~.;~'@!<~~ .~. _'",N..j' _~~"" ~'i!ltr.~. "~ ........~~~Wl~~<.- o~~ . (:) 0 C) C (....,:~ ji -0 6"~i -.-, --j :,~ mrr. ::n ~~ ~-"' z r_- 'i':> (l) c::;, -< ("') r" c: :0:: ~"1") I Z';~:; .-'j ~ );... ~~~ :',...1 -.::) i ~~'; Z ,,) -" :'':J -< '1' -< ,_ ~. ; 7. ,_ " _' , ~ I., ,nL.."l"",, , ~ ,<'.~-\ ~.lIIk'. .- ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 73 Sandbank Road, Shippensburg, PA 17257: 1. Name and address of the Owner(s) or Reputed Owner(s) : Robert L. Robinson, Jr. a/k/a Robert Robinson 73 Sandbank Road Shippensburg, PA 17257-9643 Carol J. Robinson a/k/a Carol Robinson a/k/a Carole Robinson 73 Sandbank Road Shippensburg, PA 17257-9643 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Greenwood Trust Company c/o Robert D. Kodak, Esquire 407 North Front Street P. O. Bo:lC 11848 Harrisburg, PA 17108-1848 G. H. Harris Associates P. O. Box 216 Dallas, FA 18612 ~--. . "-~" -; ,. _ __b_ - 'J-; _ ,-,.," :" ~. = -~f~'I'"ilt,'i_ . 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falaification to authoritiee. '- L~ Leon P. Haller PA .D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 7, 2000 ""'''''~'';;') ,,-" "'_it;;-~"'n,,"~~~ - '"Ii~ -'"' ...~ ~ ililil'f" .--, ""'''::~1Iili~Jilll~~'"'''' -" .""'''''''-'< - . c" CJ .> C C) ~;:: '-",,') '''0 D.: ',-<'1 ]11 l"1 --::; Z Z~ ':e_ (j) r'._' -< -'~ , r;::: C: J; t-:, , --'" " ,- 5 '-_or' c: c_ -~ ::;::: :? -'c'" ~ co (). -< ~~~. ~~ ... > ". '. <--I.. ',0 ~ ,'. ~, , 'b~ t ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 DATE: WEDNESDAY, DECEMBER 6, 2000 C) ~ -0' D;}I," i~~ ' estat$) ~_,_C' ~~~ :=j ~, ~/) -'1 -":J TAKE NOTICE: , '~'I That the Sheriff's Sale of Real Property (real held: w:fn be> : ,~, --.'--,' -<;:.') 10:00 O'clock A.M. ::> 0, ',' ~J "Po' TIME: :.0 -< LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 73 SANDBANK ROAD SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 02907 THE NAME{S) OF THE OWNER{S) OR REPUTED OWNERS of this property is: ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON ~-'-- , -:,1 .~~~ -~i,"';li""'iafl;"'",- , A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the. proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these righCs. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the i~ . "_'liI\Il>;,,''; , Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served OD the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 * . Ie - "-"l<ilOm~ " ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson; thence by land of Golden South sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS SHIPPENSBURG, PA. 73 SANDBANK ROAD, BEING THE SAME PREMISES WHICH Raymond Robinson, Jr. and Mary B. Robineon, his wife by deed dated and recorded 11/28/78 in Deed Book E-28, Page 137 granted and conveyed unto Robert Robinson and Carol Robineon, his wife. TO BE SOLD AS THE PROPERTY OF ROBERT ROBINSON A/K/A ROBERT L. ROBINSON, JR. AND CAROL J. ROBINSON A/K/A CAROL ROBINSON A/K/A CAROLE J. ROBINSON UNDER JUDGMENT NO. 2000 02907. ASSESSMENT: 39-13-0106-076 I. "' FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Suite 1400 One Penn Center at Suburban Station Philadelphia, pa 19103 (215) 563-7000 Attorney for Plaintiff Associates Consumer Discount Company Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v. CUMBERLAND COUNTY No.: 2000-02907 Robert L. Robinson, Jr. a/k/a Robert Robinson and Carol J. Robinson a/k/a Carol Robinson Defendant(s) CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Attorney's Entry of Appearance was sent via first class mail, postage prepaid, to the following on the date below: Carole Robinson Robert L. Robinson 73 Sandbank Road Shippensburg, ~A 17257-9643 Matthew J. Eshelman, Esquire 2108 Market Street Camp Hill, PA 17011 DATE: J -J-O::L ~~ Frank Federman, Esquire Attorney for Plaintiff I.D. # 12248 " i1*i~lli'lJ~li.t...:. -'~__~B!J!mIJ"IW{.1~"'~~~"""'; ~~.~-- ~"I ~- ~., ~1III::liIIIBii!!iln..l " ~ ~', - 0 0 0 C N " :1::: ".. -< -0 CO c:: -. ..-.~-n mrn '" .' r Z:J:) I ."n"j ZC -' :;SQ ~:?~ ~.2(:) ~c; -0 ~~ ZC 3: .-,-... brn >>d t;;? Z -I ':W ~ =2 <1' -< ~ - FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Suite 1400 One Penn Center at Suburban Station Philadelphia, Pa 19103 (215) 563-7000 Associates Consumer Discount Company Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v. CUMBERLAND COUNTY No.: 2000-02907 Robert L. Robinson, Jr. a/k/a Robert Robinson and Carol J. Robinson a/k/a Carol Robinson Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiff, Associates Consumer Discount Co., in the above captioned action. DATE: j-]- {J2 Frank Federman, Esquire Attorney for Plaintiff LD. # 12248 ." - ~.-. l:JIi'" '~">~."'I~_R_@li.~rlh&M~$w;~~;Wgjjjl.,~~~lflllij " ~1 " liiIiilllllIi~l1I1ilIIiIiIIIlilll o c z -oi.lS ron' Z::::rJ zr;:: ~:,;? '2:c.- )....... r-, Zo Pc 3i -::: CJ N 2:: G> I -.I - ,', 4J :Jt,: o -n ._; );':0 . "C- -;:)11'1 .;~:Ji:( ".~,,-) :p::):1ri --0 Zrn o .=..j >- ~ ~ ,:..;> (1' - I ~ ' ~ .- " 1 ',._~>,--';,--,'- - -, _."".;:,";';"" "l'ii-~." _,C _,'_ '," _._ ~ " .,j ASSOCIATES CONSUMER DISCOUNT COMPANY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. NO. 2000-02907 ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON IN MORTGAGE FORECLOSURE Defendants WITHDRAWAL OF APPEARANCE Please withdraw the appearance of Leon P. Haller and Purcell, Krug & Haller for Plaintiff, Associates Consumer Discount Company, in the above case. PURCELL, KRUG & By: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney rD #15700 Attorney for Plaintiff Dated: July 29, 2002 " r ~ ',<\,I' - :.o.-~ ..- ~ , DIi~ ~ o C :? ~\J 05 rnrl"1 ~~. r::: ('~: ~. ~~ ~ "- o ,"" ::00 ~ 'G) I C) -r1 --' .-{ ::.l:":D , ,\ r~'~ :.'2h'-; ",Q }~~ Cjrn -., 5S -< -0 ~I'- f'o,,) '..0 c,,\ 1,;-'" "_0 ~' ;;G._ '" ,_ _,_, " - -~~ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Associates Consumer Discount Company, Plaintiff ( ) (XX) Confessed Judgment Other IN MORl'GAGE FORECLCl3URE 2000 02907 $84,870.93 / File No. vs. Robert L. Robinson, Jr. a/k/a Robert Robinson and Carol J. Robinson a/k/a Carol Robinson, Defendants Amount Dueper judqment .. Interest $25.07 per diem 3/1/00 to 12/6/00 Late charges Es=cw Deficit Costs 7,019.60 2,000.00 TO THE PROTHONOTARY OF THE SAID COURT: Total $93,890.53 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of QlMBERLI\ND for debt, interest and costs, upon the following described property of the defendant(s) Real Estate: 73 Sandbank Road, Shippensburg, PA 17257 County, IN MORl'GAGE FORECLCl3URE PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of ~, County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) REAL EST . cated 'Ie REAL Robe ~binson J:. al.k/a obe :.t<Robinso C an other}ilroperty of the dJllfendant( In the possession, custody or control of the said gar . ~-t)/rnJ rer~ 1iJ/t'Vf.My~tv::~V.:4::itr01- "r>"insQl:l CI (Indicate) Index this writ ~ainst the garnishee(s) as a lis pendens against real es defendant(s) described in the attached exhibit. * obinson Date 9-1-clO Signature: Print Name: Address: leon P. Haller , Esquire Purcell, Krug & Haller J 719 l'TQ':i::h "'r9ll.t StrSQt Harrisburg, PA 17102 Attorney for: Telephone: Supreme Court 10 No.: PIAINTIFF 717-234-4178 US700 (over) ~ , ~ "~ ~ , "M_t"",,,,,,,,,c_ ~ ALL that certain lot of ground with improvements erected thereon situate in the Township of Southampton, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake at corner of land now or formerly of William E. Golden et ux and corner of land now or formerly of Boyd Johnson; thence by land of Golden South Sixty-one (61) degrees West two hundred forty-seven and five tenths (247.5) feet to an iron pin; thence along private lane South thirty-two (32) degrees East three hundred forty-seven (347) feet to a stake; thence along land now or formerly of Robert Robinson North sixty-one (61) degrees East two hundred forty-seven and five tenths (247.5) feet; thence North thirty-two (32) degrees West three hundred forty- seven (347) feet to the place of BEGINNING. . -~~ HAVING THEREON ERECTED A DWELLING KNOWN AS SHIPPENSBURG, PA. 73 SANDBANK ROAD, BEING THE SAME PREMISES WHICH Raymond Robinson, Jr. and Mary B. Robinson, his wife by deed dated and recorded 11/28/78 in Deed Book E-28, Page 137 granted and conveyed unto Robert Robinson and Carol Robinson, his wife. TO BE SOLD AS THE PROPERTY OF ROBERT ROBINSON A/K/A ROBERT L. ROBINSON, JR. AND CAROL J. ROBINSON A/K/A CAROL ROBINSON A/K/A CAROLE J. ROBINSON UNDER JUDGMENT NO. 2000 02907. ASSESSMENT: 39-13-0106-076 _o~" _"I1~DJtii~ ~jojal.;kiil!i;~tillifM~jli~<i:'~l;;:Qi.i~;lIioWlJJialtllE-; to ~.,. """""" - tD ~ 9J o.\. ,~ ~ - ~ ~~- ~ ........ ~~ ~ ~ , -'& ~ }-- \ "\ "\ \ \ '''~ - , ~- - ~.~"-- <C~~ilItl -0 G~~: [[3 L' ~ L:".) , f~c,- ::<:' c:: }~;(--- 5:2 ?:. -4 -< C) ,c :':'". .~ , '-n ~n ... ~ L"-"': ':\-~ . -:::,) {jl .~.," ""7, :.< ~ -", ~-" 1,-:.<.' __Ow' -" ... ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance . Interest (Per diem of $25.07 from 7/1/99 to 3/1/00) $68,503.41 $ 6,092.01 15% Attorney's Commission TOTAL $10,275.51 $84,870.93** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 l:\HOME\MKF\DOCS\CuMBERLA\ROBINSON.P ~-" . : , ';i ~ ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L. ROBINSON, JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON, DEFENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 1 hereby certify that on AUGUST 23, 2000 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ~ #15700 """'~.....;,..~~ ii~; . ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 2000-02907 ROBERT L. ROBINSON JR. A/K/A ROBERT ROBINSON AND CAROL J. ROBINSON A/K/A CAROL ROBINSON CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: August 23, 2000 TO: ROBERT L. ROBINSON JR. A/K/A ROBERT ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, PA 17257-9643 CAROL J. ROBINSON A/K/A CAROL ROBINSON 73 SANDBANK ROAD SHIPPENSBURG, PA 17257-9643 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-249-3166 By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 717-234-4178 ~ . ~ .' < - -, I, - '--.'.'.- .' . , ",,;[1 . ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ROBERT L. ROBINSON, JR. AIK/A ROBERT ROBINSON AND CAROL J. ROBINSON A/KIA CAROL ROBINSON, DEfENDANTS CIVIL ACTION - LAW NO. 2000 02907 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subs~bed beforo/'me this '1 day of ~~ 20 t::<-O LEON P. HALLER, ESQUIRE NOTARIAL SEAL . F~RRETTI Notary Public ~~l~:t~~rx:r~~t~~~~~ ;,o~~~ '---. -, - 'r--.""; <' 'tWiiJI' \ -:tJ \~ '"'" ~\ t ~ ~ l' }.. -,,~..........' -'--,' "1.- ."~"... &(Q)~ ,. g ~~ ; ~ - ~,,' ",""" ~~ ~ ~ c! r ~ ..... CY ~ ~ ~ ~, . ----. .. ('') l,~ ':, ," ---'~ :_n \)1' '-r1 ~iJ,: ,: _\',\ 2'2:) ::'~;"' <- ?Z(} C;:;Lc' - 0 .....- :::;:::: ~l ::) ~s _<'. ell --<... ~=~~ ~..~~. " ".~''''~"" . . SHERIFF'S RETURN - REGULAR CASE NO: 2000-02907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS ROBINSON ROBERT L JR 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 ROBINSON CAROL J A/K/A ROBINSON CAROL was served upon the DEFENDANT at 0012:45 HOURS, on the 19th day of May , 2000 at 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 by handing to CAROL J. ROBINSON a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Aff idavi t Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r~.re~~? R. Thomas Kline 05/30/2000 PURCELL, KRUG & HALLER Sworn and Subscribed to before BY~ tJ~ Deputy S iff me this .R.MA( day of Ck dov-o A. D. C2.~~O h,,/e{: )1 ~ r onotary fI ~ " J .~ - . , . SHERIFF'S RETURN - REGULAR CASE NO: 2000-02907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS ROBINSON ROBERT L JR ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ROBINSON ROBERT L JR A/K/A ROBINSON ROBERT the DEFENDANT , at 0017:00 HOURS, on the 26th day of May , 2000 at 73 SANDBANK ROAD SHIPPENSBURG, PA 17257 by handing to ROBERT L. ROBINSON a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So Answers: r~~-~~~ R. Thomas Kline 05/30/2000 PURCELL, KRUG & HALLER Sworn and Subscribed to before By: 7L~,iJ "''7 'Deputy Sheriff me this ~~ day of 0-.u, .2o-r;-cJ A. D . LJ'(;{'. O. '!z-1, If: / ~. o honotary J