HomeMy WebLinkAbout00-02952
J" __
- ,.'..'~, ~" _____-~'"r~ __~ ,c.-'. ,"'.;,,-__--.~-,-{;... ",',"_~ "_.,_~__, -' __~,
1';
()'
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esquire
P A Attorney ID #28009
P.O. Box 373
Lahaska, PA 18931-0373
TEL: (215) 297-0411
FAX: (215) 297-5932
Attorneys for Plaintiff
NATIONSCREDIT HOME EQUITY
DISCOUNT COMPANY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CIVIL DIVISION - LAW
DAVID L. ARTZ, aud
MARYANN S. ARTZ
NO. 00-02952
IN MORTGAGE FORECLOSURE
ORDER
AND NOW, this ltl'day of J" H
, 2001 , upon motion of plaintiff pursuant
to Rule 3129 Pa, R.C,P" it is hereby ORDERED and DECREED that plaintiff shall be permitted to
make service of its Notice of Sheriff's Sale of ~al Property on DAVID 1. AR IZ, and MARYANN
S, ARIZ, the defendants herein, by posting the mortgaged premises at 142 North 33'd Street, Camp
Hill, P A 17011 and by regular and certified mail addressed to defendants at their last known address
of 142 North 33'd Street, Borough of Camp Hill, Camp Hill, P
,;(
J~ f\t-
\; \j\0
"
-- ~
~ ,~
, ,c . _~_~
'-<<,-.,,- -","-~-
" ,-
CiLLD"'C;C'F{CE
0" T' '"' """'''''''''''')''-'RY
.,'-- ,i'_-,- ";;'_nJ,lc-"">_;i\'\." 1/-1,
01 JUN ILi 11i111: I 0
CUM1JEhV\f~O COUN]y
PENNSYLVANIA
""",""
.~-,? " ~ ,.
" ,_~ !rll!1~
~' -~-'-"I.,"'.'
------a:
... "
"'"
'. ~r
,~
.> . ,
'-" ,_'_T__'
~ . ,-~ - .--.- - ,.- . it.'i
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esquire
P A Attorney ID #28009
P.O. Box 373
Lahaska, PA 18931-0373
TEL: (215) 297-0411
FAX: (215) 297-5932
Attorneys for Plaintiff
NATlONSCREDlT HOME EQUITY
DISCOUNT COMPANY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CIVIL DIVISION - LAW
DAVID L. ARTZ, and
MARYANN S. ARTZ
NO. 00-02952
IN MORTGAGE FORECLOSURE
MOTION FOR ALTERNATIVE SERVICE OF
PROCESS PURSUANT TO RULE 430(a), Pa. R.C.P.
Plaintiff, NATIONS CREDIT HOME EQUITY SERVICES CORPORATION, by and
through its attorneys, hereby applies for an Order for alternative service of its Notice of Sale of Real
Property pursuant to Rille 3129 of the Pennsylvania Rilles of Civil Procedure, and in support thereof
avers as follows:
1. On April 11 , 2001, Deputy Sheriff Michael Barrick, of Cumberland County, posted a
copy of the Real Estate Writ Notice at 142 North 33'd Street, Camp Hill, PA 17011, which is both the
mortgaged premises and the last known residence of defendants, DAVID 1. ARTZ and MARYANN
-
.-1' _i.'.
.,,,,.,,-- - - . ,-~ , ., '. - "'-' - -'~~":
S, ARTZ, At that time, he found the house to be empty, See Affidavit ofR. Thomas Kline, Sheriff,
attached hereto and incorporated herein by reference,
2. Deputy Sheriff Michael Barrick further reported that the Post Office at Camp Hill, P A
had no address change on record for defendants, DAVID L. ARTZ and MARYANN S, ARTZ, See
Affidavit ofR. Thomas Kline, Sheriff,
3, On April 18, 2001, R. Thomas Kline, Sheriff of Cumberland County, attempted to
serve the Real Estate Writ, Notice Poster, and Description on defendants by certified mail, return
receipt requested, restricted delivery, deliver to addressee only, to defendants' last known residence
at 142 North 33m Street, Camp Hill, P A 17011. Such notice was returned to the Sheriff's Office on
Apri130, 2001, marked "MOVED, LEFT NO ADDRESS", See Affidavit ofR. Thomas Kline,
Sheriff,
4, On April 30, 2001, Sheriff Kline forwarded copies ofthe aforesaid documents to each
defendant by regular mail to their last known address, 142 North 33'd Street, Borough of Camp Hill,
Camp Hill, PA 17011. Neither letter was returned to the Sheriff's Office, See Exhibit "A",
Affidavit ofR. Thomas Kline, Sheriff.
5, On May 1,2001, at counsel's request, plaintiff ordered and received a current credit
bureau report on defendants, DAVID L. ARTZ and MARYANN S, ARTZ, which report listed 142
North 33'd Street, Camp Hill, P A 17011 to be defendants' current address, See Exhibit "A" to
Affidavit of CounseL
""
,I "
-. iJ __ ~ ,.>:;: ,;'." _, ,,,' '. ',~,,;.,;;-'~, ~"lk,,"';'-""'.~~ ''''"'~ ""'''=; :'-.
-" .~-~ ~-"-.
6, Also at counsel's request, Meghan Clark, a private investigator with the firm of Gill &
Associates, conducted an investigation as to defendants' current whereabouts, including a search of
the records of the Board of Elections of Cumberland County, the Cumberland County Tax Asses-
sor's Office, the Pennsylvania Department of Motor Vehicles, a computer record search, and an
interview with the postal carrier for defendants' last known neighborhood, all of which confirmed
defendants' last known address to be 142 North 33'd Street, Borough of Camp Hill, Camp Hill, PA
17011. See Affidavit of Meghan Clark, attached hereto and incorporated herein by reference,
7, In view of the foregoing, it is plaintiff's position that defendants have vacated the
mortgaged premises, which is also their last known residence, and that their current whereabouts
cannot be determined, in spite of a thorough and reasonable attempt by plaintiff to determine same,
WHEREFORE, plaintiff respectfully requests this Honorable Court to enter an Order
granting Plaintiff leave to make service of its Notice of Sheriff's Sale of Real Property on DAVID 1.
ARTZ and MARYANN S, ARTZ, the defendants herein, by posting the mortgaged premises at 142
North 33'd Street, Camp Hill, PA 17011, and by regular and certified mail addressed to defendants at
their last known address of 142 North 33'd Street, Camp Hill, PA 17011. Alternatively, plaintiff
would request leave to make service by any other means as the Court may direct.
By:
ANDREW L. MARKO
Attorneys for Plaintiff
J,_:.d _L_
.' ,,;' " ,-_,~,_-_,;,,_ ,,,'It,-,.,,"; ,-,";--, - ~"-".
,~,-
'-I
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esquire
P A Attorney ID #28009
P.O. Box 373
Lahaska, fA 18931-0373
TEL: (215) 297-0411
FAX: (215) 297-5932
Attorneys for Plaintiff
NATIONSCREDIT HOME EQUITY
DISCOUNT COMPANY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CIVIL DIVISION - LAW
DAVID L. ARTZ, and
MARYANN S. ARTZ
NO. 00-02952
IN MORTGAGE FORECLOSURE
AFFIDAVIT OF COUNSEL
COMMONWEALTH OF fENNSYLV ANIA
: SS.
COUNTY OF BUCKS
I, ANDREW 1. MARKOWITZ, ESQUIRE, being duly sworn according to law, hereby
depose and say as follows:
1. I am counsel for NATIONSCREDIT HOME EQUITY SERVICES CORPORATION,
plaintiff in the above matter,
2, Pursuant to my request, the Sheriff of Cumberland County, R. Thomas Kline, and his
Deputy, Michael Barrick, attempted to serve the Real Estate Writ, Notice Poster and Description on
""'
.
,'.__ ',. ,n. h ,,'
,..- --~""
'.-,;-L_,.. - ;;..1';, ,. '^
defendants, DAVID 1. ARTZ and MARYANN S, ARTZ, at 142 North 33'd Street, Camp Hill, P A 17011,
which is both the mortgaged premises and defendants' last known address, According to the Return of
Service (attached hereto as Affidavit ofR, Thomas Kline, Sheriff") Deputy Barrick found the property
vacant; mail was returned to Sheriff Kline marked "MOVED, LEFT NO FORWARDING ADDRESS".
3, I then requested that plaintiff obtain a current credit bureau report on defendants, which was
received on May I, 2001. Such report showed 142 North 33m Street, Camp Hill, P A 17011 to be
defendants' current address, See Exhibit "A" to Affidavit of Counsel.
4. I then ordered investigators from Gill & Associates to attempt to determine defendants'
current whereabouts, As shown by the Affidavit ofMeghan Clark, her review of the records of the
Cumberland County Board of Elections, the Tax Assessor's Office, the Pennsylvania Department of
Motor Vehicles, various computer records, and her interview with the neighborhood postal carrier, all
established 142 North 33'd Street, Camp Hill, P A 17011 as defendants' current and/or last known address,
Attached hereto and incorporated herein by reference is the report prepared by the said Meghan Clark of
her efforts to investigate the current whereabouts of defendants,
5, I have read the foregoing and swear that it is true and correct to the best of my knowl-
ANDREW L.'
edge, information and belief.
,,~ r~'" ,;"i~
SOOt~,.N ,J, ~M'~hh~w~!~l?"l' ',_., ._~
. }~..~;~:;/.~;:.::C~\~L: >_':',:'-<~~_(~~~~I' ~.
;fi:l '\..",~~".:IJ"!,Ii>!i.-,,~~\~ r;..,<.y~'C,.; J~. 28" 20GI t
Nationscredit Home Equity
Services Corporation
VS
David L. Artz and Maryann S. Artz
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No.2000-2952 Civil
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on
April II, 2001 at 1:34 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of David L. Artz and Maryann S. Artz located at
142 North 33'd 81. Camp Hill, Cumberland County, Pennsylvania, according to law.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on
April 11, 2001, the house at 142 North 33,d Street Camp Hill, Cumberland County,
Pennsylvania, was empty, The Post Office at Camp Hill, Pennsylvania, had no addreess
change for David and lor Maryann Artz.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served
the above Real Estate Writ, Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: David L. Artz , by Certified Mail Return Receipt Requested,
Restricted Delivery, Deliver to Addressee Only to his last known address 142 North 33'd
Street Camp Hill, Pennsylvania. This letter was mailed under the date of April 18, 2001
andreturned to the Sheriffs Office on April 30, 2001 with the reason checked MOVED
LEFT NO ADDRESS.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served
the above Real Estate Writ, Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Maryann S. Artz , by Certified Mail Return Receipt Requested,
Restricted Delivery, Deliver to Addressee Only to her last known address 142 North 33'd,
Street Camp Hill, Pennsylvania. This letter was mailed under the date of April 18, 2001
and returned to the Sheriffs Office on April 30, 2001 with the reason checked MOVED
LEFT NO ADDRESS.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he
served the above Real Estate Writ Notice Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants to wit: David L. Artz by regular mail to his last known address, 142 North
33rd Street, Camp Hill, PA. This letter was mailed under the date of April 30, 2001 and
never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he
served the above Real Estate Writ Notice Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants to wit: Maryann S. Artz by regular mail to her last known address, 142 North
33'd Street, Camp Hill, PA. This letter was mailed under the date of April 30, 2001 and
never returned to the Sheriff s Office.
~~~<~
R. Thomas Kline, Sheriff
By ~~~
.-:Dep..> srt:r-(.r,p
~~ ,
~<"
.-_..~.~'~_,.__.___~_;~_ .'0' '.____ ,_;.
PAqE 1
DATE 5-01-~001 TIME 11:56:47 P@fEP V201 BPA9
DAVID L ARTZ
142 N 33RD ST
CAMP HILL PA 17011-270
RPTD: ~-90 TO 2-01 U 9X
SUB: 6004001
sS: 191-46-3499
YOB: 1956
E: CYBER WAREHOUSE COMPUT
2233 LINCOLN HWY EAST
LANCASTER Pi'I
RPTD: 5-98 TO 6-98 I
,/
E: c;ARDINAL TECH
RPTD: 9-96 I
*H2 N 23RD ST
CAMP HILL PA 17011~3815
P'PTD: 9-98 I
_______________________._______ FACS+ SUMMARY -----------~--------------------
!NPUT
>'ROM
FROM
SSN ISSUED 1969-1972 ~
2-01-01 INQ COUNT FOR SSN~O
~-01-01 INQ COUNT FOR ADDRESS~O
_______-_______-__:____--______ PROFILE SuMMARY ---------------------------.---
puBLIC RECORDS---~---2
INSTALL BAL-----$l, 689
R ~STATE 8AL--$106,855
~OT R~V BAL-----$1,079
INQUIRIES--lJ.
INQS/6 MO-nO
TRADELINE--17
PAID ACCT---7
CNT 14(26/23130
SATIS ACCTS---5
NOW DEL/DRG-n5
WAS DEL/ORG---?
OJ"O TRADE-12-88
PAST DUE AMT---$21,688
SCH/EST PAY-------$142+
RESTATE PAY----$l,OSI
TOT REV AVI\IL-nnJ.OO%.'
------_-__________________.____ SCORE SUMMARY --------------------------------
EXP(FMR ISAAC RISK SCORE 2 534 SCORS; FACTORS: 38, 18, 20, 10
_-------_______________-_______ PUBLIC RECORDS -------------------------------
*US BKPT CT PA HARRISBU 7-31-00 11-16-00 6004001 BK 7-DISCHG
DI, 3322 2
. CUMBERV'ND CO PROT HONO
01: 295200
8-01-00 6011211 $119,822 CIV CL JUDG
2 PLAINTIFF: 02952-00 NATJONSCREDIT HOME EQU
-----------------7----------------- TRADES -----------------------------------
SUBSCRIBER OPEN AMT-T'i!?l AM'l'-TYP2 ACCTCOND PYMT STATUS
SUB# KGB TYP TRM ECOA BALDATE BALANCE PYMT LEVEL MOS REV PYMT HISTORY
ACCOUNT # LAST PD MONTH PAY PAST DUE MAXIMUM BY MONTH
'NATlONSCREDIT 10-98 $107,185-0 FOREPROC DELINQ 180
1536040 FP R/C 30Y 2 3-05-01 $106,855 1-01 (18 ) 88869998BB888
4667002505191 8-99 $1,051 $18,922 84322
H fORECLOSURE ~RPCEEDING STARTED *.
'NORTHWEST CON 018 CO. 7-98 $6,~54-0 OPEN DELINQ 180
1561308 FP I/L 48 2 11-30-00 $1,000 10-00 (14 ) 6654321CCCCCC
33J.920 3-00 $142 $999 C
.* SIMPLE INTEREST LOAN *.
. FIRST USII BANK 7-93 $2,500-L $2,740-H INA(;~'IVE CUR WAS 90-2
1200320 BC CRe REV 2 6-30-96 $0 2-96 (37) 000eC21cCCCIC
510130100460 2-96 eC1CCC33221C
,'<>,
.
~~-~""~"t,-
.
DATE: 5/16/2001
TIME: 10:16:55
'.
CUMBERLAND COUNTY TAX CLAIM BUREAU
ONE COURTHOUSE SQUARE
CARLISLE PA 17013
LIEN CERTIFICATE
PHONE 717 240-6366
FAX 717 240-6354
THIS DOCUMENT CERTIFIES THAT THE TAXES/COSTS DUE ON THE PROPERTY DESCRIBED BELOW,
AS SHOWN BY THE RECORDS PROCESSED IN OUR OFFICE AS OF 5/16/01, ARE AS FOLLOWS.
******** DIST/CTL
1
1940 ********
".
ARTZ. MARYANN S.
DAVID L.
142 N. 33RD STREET
CAMP HILL PA 17011
21100-CAMP HILL S.D.
STATUS C
DATE
01/31/00
01/31/00
01/31/00
04/28/00
CODE DESCRIPTION
200 CTY-CAMP HILL
250 CLB-CAMP HILL
300 MUN-CAMP HILL
400 SCH-CAMP HILL
BORD
BORD
BORD
01/31/00 201 FILING FEE
05/03/00 202 POSTAGE RET & CLAIM
'""
SITUS-0142 N 33RD STREET
PROPERTY-BELVQIR
DESC -LOTS 132 & 133 PB 1 PG 16
-HOUSE
BOOK/PAGE
LAND USE
ACREAGE
VALUE
36N 914
R
.160
9,140 VALUE C&G
RECEIPT
NO TAX
237,64
13,71
342,75
1498,96
PENALTY
23.76
1. 37
34.28
149.90
INTEREST
28.48
1.60
41.12
146.12
1999 TAX TOTAL
1999 FEE TOTAL
1999 YEAR TOTALS & BALANCE
BALANCE DUE NEXT MONTH
, , , , , , , , - - - ,
01/18/01 200 CTY-CAMP HILL BORO 237.64 23.76 7.12
01/18/01 250 CLB-CAMP HILL BORO 13.72 1. 37 .40
01/18/01 300 MUN-CAMP HILL BORO 342.76 34.28 10.28
01/19/01 400 SCH-CAMP HILL 1540.09 154.01 46.20
01/18/01 201 FILING FEE
02/09/01 202 POSTAGE RET & CLAIM
2000 TAX TOTAL
2000 FEE TOTAL
2000 YEAR TOTALS & BALANCE
BALANCE DUE NEXT MONTH
MIse RECEIPTS - - - - - - - - - - - - - - - - -
CLAIM TOTALS
TOTAL DUE NEXT MONTH
CHARGES
289.88
16.68
418.15
1794.98
2519.69
15.00
5.00
20.00
2539.69
CERT MAIL-R/C 984030
CERT MAIL-SALE
MAP' NO 01-21-0273-186
PAYMENTS
BALANCE
DUE
,00
2539.69
2555.38
, , , , , , , ,
268.52
15.49
387.32
1740.30
---------
2411.63
15.00
5.00
---------
20 ,00
2431 ,63 ,00
, - - , - , , ,
4971.32 .00
, , , - -
2431.63
2447.63
4971.32
5003.01
Jjf~{~
VERIFIED
^'('~:i
PAGE
1
INT ADDED
EACH MO
1. 78
,10
2.57
11.24
15.69
1. 78
,10
2.57
11.55
16.00
31. 69
"'~_.'. ,~',. ",_ ._n' "
.-,= .0'-',,"' '-.'< - ,-..I F
,- _..:,",- ,~
'--"""",,i'-
-~~ -";'::~.' F- ---,.~.T.'C' ;~.", _,_",~,.__'~".'~:'.
~-''''''>'
~
,.
AFFIDAVIT
I, Meghan Clark, depose and say that I conducted various investigative methods in an attempt to locate David Artz and
his wife Maryann Artz, for the purpose of serving a civil action complain upon the aforementioned, Through research
conducted within the Board of Elections in Cumberland County, Pennsylvania, it was determined that both David and
Maryann Artz are registered to vote in at the address of 142 North 33rd Street, Camp Hill, Pennsylvania. Further
investigations at the Cumberland County tax assessor's office yielded no record of either David or Maryann owning
property within the county, A vehicle search done through the Pennsylvania Department of Motor Vehicles showed cars
registered to David Artz at the above mentioned Camp Hill address. The computer record search was conducted under
the name David Artz, This search also yielded the above mentioned address. A computer record search was conducted
under the name Maryann Artz. This search again showed the previously stated Camp Hill address. At this time the postal
carrier that services the 100 block of North 33" Street was contacted regarding David and Maryann Artz. At this time
the postal carrier stated that there was no forwarding address for David and Maryann Artz, I find this Affidavit, consisting
of one page and prepared on May 25, 2001, to be true and correct.
l!fiJ{',.,~~
fLU.r" !o- ~~u-Gc-r.'J ~e f'1L
r--~' '~,,' m...,__ . ,-t,
_I - ,.'i'i'.; ~
~ P. f'"..~ '.-'''-' ' :
I '&:~[;"".'" ,
a-.-. , ". '" " -,'. '" '., ",__-"". . _ . _. ,~1
, -Iffj
r~7 1 ~/f/~ 200{
.'
;:;
,<'
~.;""'...............c..""...~_,.,..._,..
PUT KN()ilI~j INFC'RMI'\:ION Ol~ UNES BELOW
.--m_. .,,__
_~_Jitl_L}<0, "..__...,L-'--,-------HtJ::L---- ','
N.'l'T',e IGlrs\) (M,;,; (Last)
__.._..._~~._.....,.. ,'^_,",.~'...._____~.,-_._~. ..,__.~__~\_..~~.,___,.._~_~_......._...__,.~--.,,---.-......"-_._ __ -., ~u~_.~~_.'T_~_._'~.~_.__:...."__
A.ddress Including Zip C\Jch"?
__~,\f~ . ~Ot y~.f)..LLJk\3~'--.-,'----_-.------------~'-.-.------".-,_._,,~
,t\,:ldltkmallrf()(,'r,,,ti(:n 12nd address alias, household f1"!embers, oper It, 0 (1,8, EItel
....,....~...--..............J\...........__..,-,-,-.,-_._--'*""....,..,~ ..,,_.~. .'.-..'-',,~., .'.--.'.~'.'--'--..------.-.--;-.--r--,._-_._-~-.._---------_..--t---'----~~..........._".......~.~.-,~~,..--,,-,..-,- .,~. ".-".
h,j
E:<pirV
Yr/MElhe'!~"ocJ(!!
KNlv\lli Title arjrJ'ol v (',~
OiECk: (X) BELOW FOR Q_E~mEQ INf'ORMATION
(X! l,asic inlo 0!1 vehicle dat(l givM ) !rlslJr~noe as 01____,,_______
Vehlcl~ seerch 01 indi'lid\I\\1 ) Encutnbrance
Ihiorecord of Irdlviduai de a I Title History
HQUSf)rlOld ~3\lafch I, ) MO':\1 rfK~ent
, I HOiJsehOld Searer. ( ) COMPLETE
(See PennDOT Form Dl-135)
PLEASE WlllTf NJY ADDITIONAL INSTRUCTIONS OR COMMENT IN THIS ,A,REAI
.~~w~\!~ 1(), .~~tc,i
1'...,.1__
T_--.-....'.
RES~F1VED FOR PAL.B COM~AENTS
( ) No reccrq Q" i\bov(~ individual a1 given address
( ) Did ",cwse~'old no racord fit given address
:, ~_~_:~_::::::'O\.~2i~,z 1l!-.</-d ~~______~,_,,~___,____,_____~_,_,_'
-,~----,-,----_._~"""""".,._....""""",~P..........-.._----"""""~--_._~'---,------,-,.....".,.
,,--,..... ....--. ",-~..--..,.~_.-..._-_.__._-~.;.._._-,-~---,_.__.....--~-----'-'--I_-""'-.'--._~'-~-
.--..--.~_._-_.-.~-,'--~--
,._.___._,~______.~......____._.~~~.w_____.~"_~-_~~~".__~_..,.~..,
....~_____.__..___..,.__.-'_._-,..-._-~~-~~,--L----..---~----~-~-'-",~.w.'._. .,.,..--.-...,--..,.......
. ...'" .-, - -..---.-..-.-..----.--,.------.,.",---...-------..-----._.,."---._.._~"--,...........'~,_.~
'J.
Q'JNFR
T1 Tl E NUMBER
TAG NUMBER
VIN
MAKE
MODEL
RENEWAL WID
PREVIOUS TAG
LIENS
STOPS
~ ~_.'
~._~.
--~----
--
.--",-,.......
., " '~
Ii
------
.------'- \
-_.^,-..~~r; e, e\C.
PENNSYLVANIA nEPA~TM~NT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
5/22/01
PAGE 1
="
"'
,....'
,.,-.,.
011420311000496 024
DAVID L & MARYANN $
AR1Z
142 N 33RD S1
CAMP HILL PA 17011
LESSEE
NOllE
,
,.
(,2207141
PD7944B "
JMIGD2224K171Z814
'rITLEl)ATE
, I .
REGISTRATION!i;XPIRV DAiTE:
,'ia~nY,'TYeE "'1)'
l;riDOME'~~RREADIN6' I,
.",:ifACfUAl0'/llitt!llGE' '." ;
'V,UPLICATE ntLE,'COutfl; ,
'VEHICLE YEAR:') , ,
,:,,',,.,, 'I' .
I, L.~TOLEN DATl'!,';':i'
MAZD,~ '.'
626,' "...,'.
O1l2~4lJ~7bollZS9
,73414ilP>
'! "~~'~,';/U:":."
001
,: , ..i:: :. ~; ;::
.,":::;;::::;:;
" ,:'"..
Tl Tl E BRAND I NFdllMA tfQN
':,.;:;:,;.;'::::;..;:;,
:,' .>::>..':i,:
:;;;'::..;,:.:i:ii:':.',
,:h'd;i:;~iin.<: ;':.~,:i':';'
TITRe...'....,"
:'.:'":-:;,:;:}{i/i{!iJ;n;;.:' "
".., :<;;~ii\~;;><:,~;,:',:.;;:;.
'.
, :::i::;L;
NO TITlE BRANDS ;E*'t'$t fOR THIS
"". <J~?!,:;
..,.J".'"
." ',,'I;
;:;.'::::;,:."i'
",.....,..;"i:.:::;:,:-'.
. ,il.
",.
!!'!,!,i'iW"!.'Ji!:
, "
d,
..,..',
. ;,,'.,,,.
'd
!,.'
>t",:,
;;,.,.:".
"
,V'
ADDRESS CORRESPONDENCE TO:
DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD SERVICES
PO BOX 68691
~ARRISBURG. PA 17106-8691
INFORMATION, (7:00
IN STATE
QUT-Of-STATE
TDD IN STATE
TDD OUT-OF-STATE
WWW.DOT.STATE.PA.US
08/31/89
10/01
SDN
56,043*
o
1989
AM TO 9,00 PM)
1-800-932-4600
717-391-6190
1-800-228-0676
717-391-6191
, -
_~J
--, "L"J
,'.~k H .-", 'J'"
.-1.
~, .C
~ - -,I
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esquire
P A Attorney ID #28009
P.O. Box 373
Lahaska, PA 18931-0373
TEL: (215) 297-0411
FAX: (215) 297-5932
Attorneys for Plaintiff
NATlONSCREDlT HOME EQUITY
DISCOUNT COMPANY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
CIVIL DIVISION - LAW
DA VlD L. ARTZ, and
MARYANN S. ARTZ
NO. 00-02952
:
IN MORTGAGE FORECLOSURE
MEMORANDUM OF LAW IN SUPPORT
OF PLAINTIFF'S MOTION FOR
ALTERNATE SERVICE OF PROCESS
Under Rule 430 of the Pennsylvania Rules of Civil Procedure, this Court clearly does have
the power to grant leave to use a different or alternate method of service than that required by Rule
3129, As Rule 430 states in paragraph (a):
(a) If service cannot be made nnder the applicable rule the plaintiff may move
the court for a special order directing the method of service, The motion shall
be accompanied by an affidavit stating the nature and extent of the investigation
which has been made to determine the whereabouts of the defendant and the
reasons why service cannot be made.
In this case, at plaintiff s request, the Sheriff of Cumberland County and his Deputy
attempted to make service of the Real Estate Writ, Notice Poster and Description on defendants,
DAVID L. ARTZ and MARYANN S, ARTZ, at the mortgaged premises at 142 North 33'd Street,
,< "
.~-'~h--'''_~ ""A",
_~ --,"v.'" .^,.",~",_..,~,,- ~ "'>~.~. _'0 j,_
;- -~-
b(
Camp Hill, P A 17011" which is also defendants' last known address, but found the property vacant
and certified mail returned, marked "MOVED, LEFT NO ADDRESS", Subsequent thereto, plaintiff
obtained a current credit bureau report showing such address to be the last known one for defendants.
::!
Plaintiff's private investigator made a thorough search of County and Commonwealth
records and neighborhood sources, only to discover that 142 North 33'd Street, Camp Hill, P A 17011
il
is the last known address for defendants,
k
i
~ :
Plaintiff has made a reasonable and good faith attempt to locate the defendants, but as set
i-!
I:
l.
forth in such Affidavits, has been unable to determine defendants' current whereabouts,
!i
Under these circumstances, it is submitted that plaintiff should be granted leave pursuant to
Rule 430 to make service of its Notice of Sale of Real Property in the above matter on defendants,
DAVID L. ARTZ and MARYANN S, ARTZ, by posting the mortgaged premises at 142 North 33'd
Street, Camp Hill, PA 17011, and by regular and certified mail addressed to defendants at their last
known address of142 North 33'd Street, Camp Hill, P A 17011. Alternatively, plaintiff would request
leave to make service by any other means as the Court may direct.
An appropriate form of Order is attached hereto.
Respectfully submitted,
By:
ANDREW I{;
,
Attorneys for
.
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esq.
ID 11 28009
PO Box 373
Lahaska, PA. 18931
215-297-0411
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
10401 Deerwood park Boulevard
Jacksonville, FL. 32256
vs.
DAVID L. ARTZ and
MARYANN S. ARTZ
142 North 33rd Street
Camp Hill, PA. 17011
CIVIL
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 com.
plaint and notice are served, by entering a written
appearance personally or by attorney and filing in writ-
ing 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 with.
out further notice for any money claimed in the com-
plaint 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 LAW.
YER OR CANNOT AFFORD ONE, GO TO OR TELE-
PHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP,
, LAWYE:R REFERENCE SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA. 17013
TEL: 717-249-3166 or
800-990-9108
'.",
00- ~9~
e'~l{Y~
:"-
Attorney for
plaintiff
IN THE
, COURT OF COMMON PLEAS
OF' CUMBERLAND .. COUNTY
DIVISION
TERM,
No.
,MORTGAGE FORECLOSURE
113010
ACTION
A VISa
Le han demandado a usted en la corte. Si usted
quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo
al partir de la fecha de la demanda y la notificaci6n.
Hace falta asentar una comparencia escrita 0 en persona
o con un abogado y entregar a la corte en forma escrita
sus defensas 0 sus objeciones alas demandas en contra
de su persona. Sea avisado que si usted no se defiende,
la corte tomara medidas y puede continuar la demanda
en contra suya sin previo aviso 0 notificaci6n. Ademas,
la corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisiones de esta
demanda. U sted pued;, perder dinero 0 sus propiedades
u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO
IMMEDIATAMENTE. SI NO TlENE ABOGADO 0 SI
NO TIENE EL DINERO SUFIClENTE DE PAGAR
TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR
TELEFONO A LA OFICINA CUYA DlRECCI6N SE
ENCUENTRA ESCRITA ABAjO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL.
SERVIC10 DE REFERENCIA LEGAL
,-," -,~~ ,-- c"_,'__" ,",," '0< '-l~;.~ ,~,.,,-,..
'-';".' "Ct_,., --~<",.'" ~;.._,' ; '.,. ,~__ "d-',., C__~ ,_ ,
I
I
,
MARKOWITZ & MARKOWITZ
By: Andrew L. Markowitz, Esquire
P A Attorney ill #28009
P.O. Box 373
Lahaska, PA 18931-0373
Tel.: (215) 297-0411
Attorneys for Plaintiff
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
10401 Deerwood Park Boulevard
Jacksonville, FL 32256
v.
DAVID L. ARTZ and
MARYANN S. ARTZ
142 North 33n1 Street
Camp Hill, PA 17011
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL DIVISION - LAW
IN MORTGAGE FORECLOSURE
COMPLAINT
1. Plaintiff, NATIONSCREDIT HOME EQUITY SERVICES CORPORATION
(hereinafter referred to as "NATIONSCREDIT"), is a corporation duly organized and doing business
under the laws of the State of North Carolina, having offices at 10401 Deerwood Park Boulevard,
Jacksonville, FL 32256
2, Defendants, DAVID L. ARTZ and MARYANN S, ARTZ, are the real owners and
mortgagors and grantees in the last deed of record to the hereinafter described real estate located at
-.1 "~ -'""--
.~--. ,~ ," - ~ ':..-- "-';;f;.;."",, _ "0 ,.,,'~- o,,_:'"'~"
,-,".',-
.
142 North 33'd Street. CampHill,PA 17011, Tax Parcel #01-21-0273-186. Defendantsresideat
142 North 33rd Street, Camp Hill, PA 17011,
3, On October 26, 1998, defendants executed and delivered to WMC Mortgage
Corporation (hereinafter referred to as " WMC") a mortgage upon the premises hereinafter described
as security for the payment by defendants of certain sums due and owing by them under a promissory
note executed by them on the same date in consideration for a loan made to them by WMC, Said
mortgage is recorded in the Office of the Recorder of Deeds in and for Cumberland County, in
Mortgage Book Vol. 1505, page 619, and is incorporated herein by reference by virtue ofPa, R.c.P.
~ 1019(g),
4, On or about January 15, 1999, the aforesaid mortgage was assigned by WMC to
plaintiffherein, said assignment being du1y recorded in the Office for Recording of Deeds in and for
Cumberland County, the book and page number of such recording being not yet available,
5, The premises subject to the aforesaid mortgage is described in Exhibit "A", which is
attached hereto and incorporated herein by reference, The address of the mortgaged premises is 142
North 33m Street, Borough of Camp Hill, Camp Hill, PA 17011, being tax parcel
#01-21-0273-186,
6, The aforesaid mortgage is in defau1t because the required monthly payments due under
the terms of the aforesaid note and mortgage have not been made for the months of September, 1999
through the present date, By the terms of the said mortgage, upon breach and failure to cure said
breach after notice, all sums secured by said mortgage shall be immediately due and owing,
..... Ii.=.>. ",C-i.:
"
,.',;'!
'.,.'~" . ".,,1_ ,:, .- ,..
,"--" "",;-,-,'. ',--.- "-
"':1
I
7, The terms of the said mortgage further provide that iJ?- the event of default, defendants
shall be liable for plaintiffs costs and attorney's fees,
8, The following amounts are due on said mortgage:
$106,855.49 (principal balance)
$ 4,315.43 (accrued interest through 4/30/00)
$ 40,00 (late charges)
$ 4,810,11 (pre-payment penalty)
$ 800,00 (attorney's fees estimated for foreclosure)
$ 75,00 (vrior costs and fees)
$116,896,03 (total amount due)
plus costs, interest at the rate of$33,25 per diem for each day after April 30,2000 until the entry of
judgment, and interest from the date of judgment as provided by law,
9, Plaintiffhas demanded the total amount due from defendants, but defendants have failed
to pay the same,
10, A written notice of defendants' rights under the Homeowners' Emergency Mortgage
Assistance Act (Act 91), combined with a notice of intention to foreclose as required by Act No, 6,
was sent to defendants on January 20, 2000 pursuant to the provisions of both of such Acts, a
copy of said notice being attached hereto as Exhibit "B" and incorporated herein by reference,
Defendants' application to the Pennsylvania Housing Finance Agency under Act 91 was denied by
that Agency on April 25, 2000,
." 'I'
. ,~ ,-' , ."f,~',,-
,.".-"
~J'-"-'
- ; ~i
"l,i
q
r,'l
,~
'I
11. Pursuant to the Fair Debt Collection Practices Act, 15 U.S,C, ~1692 et seq. (1977),
defendants may dispute the validity of the debt or any portion thereof. If defendants do so in writing
within thirty (30) days from the date this pleading is received, counsel for plaintiff will obtain and
provide defendants with written verification thereof; otherwise, the debt will be assumed to be valid,
~
Likewise, if requested within thirty (30) days of receipt of this pleading, counsel for plaintiff will send
defendants the name and address of the original creditor if different from above,
By:
ANDREW
Attorneys for Plaintiff
II
il
II
I,
"~
II
~
l,l
Ii
"j
','.,',
!j
"
I';'
iil
I,
k~
i:~
PI
'I
1,'1"
II:
'1
,I
I
Ii,,:
'i
WHEREFORE, plaintiff demands that judgment be entered in its favor and against
defendants in the amount of$116,896,03, plus costs, interest per diem and interest from the date of
judgment as provided by law,
~,~",~"_..L
.
--I
AFFIDA VIT
ST ATE OF FLORIDA:
COUNTY OF DUVAL:
I, ANDREA OYLER, being duly sworn according to law, hereby depose and say that I
"
-'
am Foreclosure Administrator of NATIONS CREDIT HOME EQUITY SERVICES
CORPORATION, plaintiff in the above matter; and that I am authorized to make this Affidavit on
its behalf; and that the facts as set forth in the foregoing Complaint are true and correct to the best
of my knowledge, information and belief.
Sworn to aDd subscribed
this ). }71: day
of UP,W',2000.
,
-v
r-\lY Pu. OFFICIAL NOTARY SEAL
0.... "<~ DANA DENI$E BEVEL
~ ~r '.: -......,. .-..
~ ~ if CC801782
"'1;- ~ MY COMMISSION!XPIRES
OncO FEB, 1,2003
,'.'
~ '~.'
- - ~..~
~Mi)"
fl""
",,"'.'
';."-'-'
".
',,,..
LEGAL DESCRIPTION
r::"
t :~.:,~.
.
AU, THAT ceRTAlN .itha.~ c>->L JXI'..'I.e...e. 0'~1d an.ct
-Vj.t.n-s t>.rtd 6"'1.>'9 -i.rL .th... BO-'LotLSl. 0' e<vnp H-LU
Cum6~ and. Co,.",no~ 011 P..........!I,e.....a.nA..ct..
ctc..&~6e.d d.& ,0,lt.l._ I
Oil Tl-flil NORTH 611 Las.." S-b.I>.lU: I on .-th... E~ 611 I3Uua.u.. Au............' <>n
,-ti1.... ,gou-tl. 6JJ LO~ loll>. I 31 Ol\. .f;J1G. h.'""-....u~.uv.. men.:t.-Lo,.e.ct P.ltul;...1d 0/1.
.the. W~ 611 ... ~e a.t.I.e.lI. ' '
lJeu/llI LOTS NO. - 1".)2 tUld 133 on. p.e..w. all L~dll " BUuo.u.." . BtvLOf.LJ!/k.
04 Ccunp f-I..L.U. . eumb4!4t.cv1d Col..U1.Jt.y J Pll.tU1A!J~aJt.-L:L,.a.a...t.d p1la.Ja. -'l.e..c:.0Itde..d
-i.rL ~ R~_'''' 0,i4.l..a.e- .u.. cu1d -/1<>'1. Cwnbot.1t.land Cat.lWt1l .u.. p~ I.Iooh.
,No. I, _lie. 16.
SAIP LOT !lO.n! CONTAINING T1IlEIITY (20 I 1I1>.l>.'t. .u.. '''-OM 0/1. BUuo-Vr.
A""'\U4 CU\d ~uuU>~9 ba.ch. an. e."el1 w-tcLtJl 0/1.1>. :hWu:tI1e.ct wid
~-II-t"e. I 1251 'I",e.t: h> .th.... cr.4 OJ<e._ -<.C( 'J:1U.i>4.--l.<!. ~!I.
SAIOt.or NO. 13JCONTAINING THIRTY-FOUR AND FIVe-TENTHS, [34,51
-tI...e.t: .ul 4"-0n.t. .... I3duo-Vr. A"ct1Ue- ..,ut ~t<lUJ1.9 ba.ch. alt....~e.ct o.nd
_1.>1:1/-11-<'''''' 11251 ,...l>.'t. ~O .f;lt.a. <>-&.........-.Ld PtL6tle a.Lt.e.!I. '
HAVIIIO THEREON ERECTED a. .6-Ln9~ ""-Lc.h. and a..hurt.uwm ...~ t:.........e..
-.LeI. ~~e-6 6e.u.S /u..,.......... 142 ,N~' 33Jui ~e.e;t..
pl't,41nL6...... J ~-.tl...,:t.<<.~
.u1- .the C"w~ ,04
mQ.'Lc!' pc::tIL*,j AU e.a..~ ;,
/
NG THE SAME PREMISES which Maryann S, Artz and Rita FrataIIi, by deed dated September 22, 1993, and recorded in lh,
ce of the Recorder of Deeds in and for Cumberland county on September 23, 1993, in Deed Book N, Volume 36, Page 914
lted and conveyed unto Maryann S, Artz and David L. Artz, her husband.
'~-""""",~J~'''-~'~
-
L..
-
J _,,,"',,,"
,
Date: JANUARY 20, 2000 .
ACT 91 NOTICE
TAKE ACTIOI~ TO SAVE
YOUR HOME FROM
FORECLOSURE
NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM AND
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
This is an official notice that the mortgage .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 pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to
help to save your home. This Notice explains how the program works. "
Tosee.ifHEMAP 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 Counseling Agency.
The name, address and phone number of Consumer Credit Counselintg Agencies serving your
Connty are listed at the end of this Notice. If you have any questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
. hearing can call (717)780-1869).
This Notice coutains 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 h'e able to help you. find a
lawyer.
LA NOTIF'ICACION EN ADJUNTO ES DE SUMA IMPORtANCIA, PUESAFECTA SU DERECHO A
CONTINUARVlVIENDO ENSUCASA. SINO COMPRENDE EL CONTENIDODE ESTANOTIFICACION
OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYL VANIA
. HOUSING FINANCE AGENCY) SIN CARGOS. AL NUMERO MENCIONADO ARRIBA. PUEDES SER
. . ELEGIIJLE PARA UN pRESTAMOPOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDESALV AR SU CASA DE LA PERDIDA DEL
. DERECHO AREDlMIRSUHIPOTECA.
HOMEOWNER'S NAME(S):.
DAVID L. ARTZ and MARYANN S. ARTZ
PROPERTY. ADDRESS:
142 North 33rd Street
Camp Hill,PA. 17011
'.1ft,;
LOAN ACCT. NO.:
ORIGINAL LENDER:
#7002505191
WMC MORTGAGE CORP.
.' CURRENT LENDERlSERVICER:
NATIONSCREDIT HOME EQUITY SERVICES CORPORATION
,~
'-~""-''''"~'-:''''- . ~...
~~
.'"'...~~
,,'
-
-..- ~ f"l!~i:J!j>fu.h
. .
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
lFYOUCOMPL YWITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES
BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO
PAY YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGmILITY REQUIREMENTS
ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE
AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30}days from the date of this. Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the consumer credit counselingagencies listed at the end
of this Notice. THIS MEETING MUSTOCCURWITHIN THE NEXT THIRTY (30) DAYS. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENClES- If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting. The names. addresses and telephone nnmbel"soCdesil!natedconsnmer
credit counselinl! al!encies Cor theco~ntv ili which the property is located are seHortbat the end oHbis
Notice It is only necessary to schedule one face-to~face meeting.' Advise your lender imm1ldiatelvofyour
intentions,
APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in.default forthe reasons set forth
laterin' this.Notice( see following pages forspecific infunnation about the nature of your default). If you have
. tried and are unable to resolve this prqblemwiththe lender, you have the right to apply for financial assistance
from the Homeowner's Emergency Mbrtgage Assistance Program.. To do so, you must fill out, sign and file a
completed Homeowner' sEmergency Assistance, Program Application withone of the designated consumer credit
counselingllgencieslisted at the end of;thisNotice. Only consumer credit counseling agencies have applications
fortheprogramandthey will assist youinsubmitting a complete application to the Pennsylvania Housing Finance
Agency. Your application MUST be filedorpostmarked within thirty (30) days of your face-to-face meeting.
YOUMUST FILE YOUR APPLICATION PROMpT bY. lFYOUFAIL TO DOSOORIFYOUDO
NOTFOLLOWTHE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAlNSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR
MORTGAGE ASSISTANCE WILL BE DENIED.
~~>'Ii"'ilii'_I-'''~''''--
,.......,
.- ~-~
.-~ ~ ~~,-
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
Agencybas sixty (60) days to make a decision after it receives your application. During that time, no foreclosure
proceedingsvvill 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 0f 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
,'c,
ONLYANDSHOULDNOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(Ifyoll have filed bankruptcy you can still apply for Emergency Mortgage' Assistance).
HOW TO CURE YOUR MORTGAGE DEFAULT(Bringit up to date).
NATURE 0 F THE DEF A UL T- The MORTGAGE debt held by the above lender on your property located
at: 142 North 33rdStreet, Camp Hill, PA. 17011
ISSERIOUSL Y IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and
the following amounts are now past due:
Regularpaymentof$ 1,051.24 each for the months o,f SEPTEMBER, 1999
through and including JANUARY, 2000
Othercbarges (explain):
Late charges of $80.00 plus legal costs of $37.50
TOTAL AMOUNT PAST DUE: $ 5,373.70
B.YOUHAVE FAILED TO TAKE THE FOLLOWING ACTION (EXPLAIN):
N/A
HOW TO CURE THE DEF A UL T,.. You may cure the default within TIllRTY (30) DAYS of the date of this notice
BY PAYING THE TOTAL AMOUNT PAST DUE TO TBKLENDER, WHICH IS $ 5 , 373. 70 , PLUS AN.Y
MORTGAGE PA YMENTSANDLATE CHARGES WHICHBECOME DUE DURING THE. THIRTY (30)DA Y
PERIOD,Pavments must be made either bv cash. cashier'scbeck. certified check o~ monev ord'er made oavableand
sent-to: -, ',,,-
Andrea Oyler" Foreclosure Administrator
EQUlCREDJT CORPORATION OF AMERICA,
10401 DeerwoadParkBoulevard, &iICode #FL9-015-02-14
Jacksonville, FL 32256
You'cancure any other default by taking the following action within THIRTY (30) DAYS of the date
of tbisletter:
N/A
..,"
~" -.
I
".-~ .
-""",
C "I
IF Y()U DO NOT CURE THE DEFAULT-Ifyo.u do. no.t cure the default within THIRTY (30) DAYS o.fthedate
oftbisNo.tice,. the lender intends to. exercise its rights to. accelerate the mo.rtgage debt. This means that the entire
o.utstandingbalance o.fthis debt will be co.nsidered due immediately and yo.u may lo.se the chance to. pay the mo.rtgage
in monthly installments. Iffull payment o.fthe to.tal amo.unt past due is no.t made within THIRTY (30) DAYS, the lender
also intends to. instruct its atto.meysto. start a legal actio.n to. fo.reclose upo.n vo.ur mo.rtl!al!e pro.pertv.
IFTH&MORTGAGE IS FORECLOSED UPON- The mo.rtgaged property will be so.ld by the Sheriff to. payo.ffthe
mo.rtgage debt. lfthe lender refers yo.ur case to. its atto.rneys, but yo.u cure the delinquency befo.re the lender begins legal
proceedings against yo.u, yo.u will still be required to. pay the reaso.nable atto.rney's fees that were actually incurred up
to. $50.00. Ho.wever, if legal pro.ceedings are started against yo.u, yo.u will have to. pay all reaso.nable atto.rney's fees
actually incurred by the lender even if they exceed $50.00. Any atto.rney's fees will be added to. the amo.untyo.u o.we
the lender, which may also. include o.ther reaso.nable Co.sts. Ifvo.u cure the default within the THIRTY (30) DAY
period. you will not be required to pay atto.rnev's fees.
OTHER LENDER REMEDIES- The lender may alSo. sue yo.u perso.nally fo.r the unpaid principal balance and all o.ther
sums due under the mo.rtgage
RIGBTTO CURE THE J1)EF AUL T PRIOR TO SHERIFF'S SALE- If yo.u have no.t cured the default within the
THIRTY (30) DAY perio.d and fo.reclosure pro.ceedings have begun, Vo.u still have the ril!ht to. cure the default and
prevenfthe sale at anv time liP to. o.ne (1) hour before the Sheriff's Sale. Yau mav do so bv payinl! the to.tal
,amount then past due. plus anv late chal1!es o.r o.ther chal1!es then due. reasonable atto.mev'sfees and Co.sts
co.nnected with the fo.reclo.sure sale a'nd anv o.ther Co.sts co.nnected with the Sheriff's Sale as specified in writinl!
by the lender andbv perfo.rminl! anv o.ther requirements underthe mort~al!e. Curing yo.ur d,efault in the manner
set forth in this notice winl resto.re yo.ur mo.rtgage to the same po.sitio.n as if yo.u had never defaulte~,
EARLlEST POSSffiLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such a Sheriff's Sale o.f
the mortgaged property co.uld be held wo.uld be approximately five (5) months fro.m the date o.f this No.tice. A notice
o.fthe actual date o.fthe Sheriff's Sale will be sent to. yo.u befo.re the sale. Of co.urse, the amo.unt needed to. cure the
de1iwltwill increase the lo.nger yo.uwait. Y o.u may find o.ut at any time exactly what the required payment o.r actio.n will
be by contacting the lender.
BOW TO CONTACT TIlE LENDER:
Name o.f Lender:
Address:
Pho.ne N um her:
FlU Number:
NATIONSCREDIT HOME EQUITY SERVICES CORPORATION
EquiCredit Center.. 10401 l)eerwo.o.ll Park Boule, vard".TaeksQRvI'lIe. FL 32256
- .' Ma~1 Cone *FL9~\'115~1l2- IJ
800-759-6380 x. 73 5 39
904-457-4081
.."
Contact Perso.n:
Andrea Oyler, Foreclosure Administrato.r
~~'--
~-~"
."~ri
.~,~ .......,~...""""'"
i.:c
EFFECT OF SHERIFF'S SALE- You should realize thataSh,eriff'sSale will end your ownership of the mortgaged
property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit toremovevou
, iihd your furnisbings and other belongings could be started by the lender at any time. -
ASSUMPTION OF MORTGAGE - You _ mayor ,xxxxxx may not(CHECK ONE) sell ot transfer your home
to a buyer or transferee who willassume the mortgage debt, provided that all the outstanding payments,chargeslllld
attorney's fees and costs are paid pi'iorto or at the sale and that the other requirements of the mortgage are satisfied.
YOUMA Y ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROWMONEY
, .
FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HA VB THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEF AUL T OCCURRED,1FYOU
CURE THE DEF AUL T (HOWEVER, YOU DO NOTHA VE THIS RIGHT TO CURE YOURDEF AULT MORETBAN
THREE TIMES IN ANY CALENDAR YEAR).'
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER
LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
SEE ATTACHED.
Very truly yours,
NATIONS CREDIT HOME EQUITY
SERVICES' CORP.
Enclosure: List of Consumer Credit By: Andrew 1. Markowitz, Esquire
Counseling Agencies Title: Attorney
NOTE: Pursuant to the Fair Debt Collection Practices Act, if you dispute, in writing, this debt or anypertion
thereof, we will obtain and mail to you verification ofsameand the name.andaddressoftheoriginalc~r,
if different. lfyou donot dispute this debt within thirty (30) days after receipt of this letter, itwill be,assumed
to be valid.
~".'-
This communication is an attempt to collect a debt. Any information obtained hereby will be uied ror
that purpose.
/
:/
2870
STATEMENTS OF POLICY
CCCS of Western PA
219-A College Park Plaza
Johnstown, PA 15904
(814) 539-6335
Lycoming-Clinton Counties ,
. Commission Far Community Actwn (STEP)
2138 Lincoln Str""t
p, 0, Box 1328
Williamsport, PA 17703
(570) 326-0587
. FAX (570) 322-2197
eccs of Northeastern PA
201 Basin Street
Williamsport, PA 17703
(570) 323-6627
FAX (570) 323-6626
CLINTON COUNTY
CCCS of Northeastern PA
1631 S Atherton St
Suite 100
State College, PA 16801
(814) 238-3668
FAX (814) 238-3669
COLUMBIA COUl'<"TY
31 W. Market Street
POB 1127
Wilkes-Barre, PA 18702
(570) 821-0837 or (800) 922-9537
FAX (570) 821-1785
"'Commission on Economics Opportunity of Luzerne County
163 Amber Lane
W1lkes-Barre, PA 18702
(570) 826-0510 or (800) 822-0359
FAX (570) 829-1665-CALLBEFORE FAXING
(570) 455-4994 HAZELTON
FAX (570) 455-5631-CALL BEFORE FAXING
(570) 836-4090 TUNKHANNOCK
CCCS of Northeastern' Perinsylvania
1400 Abington Executive Park
Suite 1
Clarlts Summitt PA 18411
(570) 587-9163 or (800) 922-9537
FAX (570) 587-913419135
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814)453-5744
FAX (814) 453-5749
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898-1243
CRAWFORD COUNTY
Greater Erie Community Action Committee
18 West 9th Street'
Erie, PA 16501
(814) 459-4581
FAX (814) 456-0161
Shenango Valley Urban League, Inc
601 Indiana Avenue
Farrell. PA 16121
(412) 981-5310 .
eees of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisbutg, PA 17102
" (717) 541-1757
, Urban League of Metropolitan Harrisburg
N, 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234-9459
Community Action Comm of the Capital Region
1514 Deny Street
Harrisburg, PA 17104
(717) 232-9757
, , FAX (717) 234-2227
CUMBERLAND COUNTY
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesbaro, PA 17263
(717) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
i
I
I
PENNSYLVANIA BULLeTIN, VOL, 29, NO. '23. JUNE 5, 1999
";-
~ ~ ~ !II
...t J!::;.'.ili
'"
,
MARKOWITZ & MARKOWITZ
BY: Andrew L, Markowitz,
ATTORNEY 1.0, NO, 28009
,p, o. BOX 373
lAHASKA,PA.1B931
12151297-0411
Esq.
ATTORNEYS FOR
Plaintiff
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
DIVISION
TERM,
vs.
No.
2000-02952-CV
DAVID L. ARTZ
MARYANN S. ARTZ
AFFIDAVIT OF SERVICE IN ACCORDANCE
WITH RULE 3129.2(c) PA. R. C. P.
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS:
I, ANDREW L. MARKOWITZ, being duly sworn according to law,
hereby depose and say that I am counsel for plaintiff in the
above matter, and that notice of the execution sale of the
real property located at
142 North 33rd Street, Camp Hill, PA
17011
II
!I
iI
..
,~-
Ii!!
, (
to be served on defendants DAVID L. ARTZ and MARYANN S. ARTZ
by certified mail, return receipt requested, on the
29th
day of
June, 2001
, XlID9X , in accordance with
Rule 3129.2(c) (i) (B), and on the following persons, on
the 29th day of
June, 2001
}Q,~
by first-class
mail, postage pre-paid, addressed as indicated:
1)
DAVID L. ARTZ
142 North 33rd
Camp Hill, PA
(also certified mail to same address)
Street
17011
2) MARYANN S. ARTZ (also certified mail to same address)
142 North 33rd Street
Camp Hill, PA 17011
3) BOROUGH OF CAMP HILL
2145 Walnut Street
Camp Hill, PA 17011
4) DOMESTIC RELATIONS SECTION
COURT OF COMMON PLEAS
Cumberland County Courthouse
Courthouse Square
Carlisle, PA 17013
Attached hereto and made a part hereof are the certificates
of mailing and return receipt for certified mail referred
to above.
ANDREW L.
Sworn to and subscribed
.-rC
before me thisc5LJ
JL< 1..-1/ .;20() (, ~
V' .............
.' ,~~':. :n\l1f'II'UI'!II<,
J.IlWtI(CiWlTZ, ~NII
i,~~~~~_
,
.llll!illlliiillllii ~,'--'"o .' -'II. dii~~1iM!ll~liIlir "'w~~it:'''''''''''~Mil~..:&i.~..-
..........""'~tiillllil. f"i~~ l,'~~
.,
~
,'^'~
_~I'.r
o
o
~
-ot:P
~IT'
'jt.:P
~~.
'2.0
~~
:z,
:2
-
~
~)
,
1""
'-0
::t,
... "Ii
II
Ij
~
C1
--q
tP.
?
~
.'
,-0
\-:~l:;;;;;
_~~\fa
',1.
--. 'c.~'
~~-~ ::(~
r~~'o
/_,....-n
0,'
~
::.<;
I U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
.
.MAY ElE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROViDE FOR lNSURANCE-POSTMAST R
Rsceived From:
Markow1.tz,
373
PA. 18931
Andrew L.
P. O. Belt
Lahaska,
One piece of ordinary mail addressed to:
DAVID L. ARTZ
142 North 33rd
Camp Q:ill, PA
Street
17Q11
r
\
PS Fa,m }8_1'LJ~.!'''1'.'Y 20Q1_
,
,~.S. POSTAL SERVICE
CERTlFICA Te OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil DOES NOT
~OV1DE FOR INSURANCE-POSTMASTER '
, RecElivedFrom:
811dLew L. lVldrRuwi"t:.z, .t.;sq.
P. O. Box 373
Om;! piece of ordinary mail ~ddressed -to:
MARYANN s.
142 North
Camp nill,
ART?
33rd Street
>',/\ 17011
\
, ' v corm 3817, January 2001
~
~:;~~~~~~~\\
, \
U,. M 2. P~~1OO: )l
Restricted Delivery Fee r r
(Endorsement Required) 1~~~~1~>,Y
Total Posta9& & Fees $ ";,~.;;:13 ,~,;J;';'#"
~.~~:~~_t:~_~~:~~:=~~_~~i7\C~V;_O__~_~r:~~A/ir2_____________"__
Street,Apt.No.;orpOBOx~ '2.- III J]r--d J-r~
_mnnnnn'...'mmm_nn.n/'Y.m'''nmmn , ,"n_nn"',_'n_"'n_
CIty, Stole, ZIP+4 (jl1l tit (..[,.
'"
'"
'"
'"
Esq.
'"
g~
~
~~
%l.Tl
~ r ~
:::t,Z ':D U'l
;3: _:c"'tl-
g:g~~~1)
2'W7'00
-\~-"f' ~
-u :p
:p '"
en
Affix fee here in stamps
". meter postage and.
. '-",' of
i
~ ;fi_, ,
.111'"
'"
B~ J)~ r- C:
&- ~1\)"'~"1J.in
co......, r:::(Jjm=r>J)
',;::! ;:0:. w!i?......"1J
::::~, ---t~.--;z> OfX
- '0 -I
'" if;
rn
U.S. POSTAL SERVICE
Affix fee here in stamps
or meter postage and
post mark. Inqu!re of -
Postmaster for current
fee,
CER'7IFICAT-E OF MAILING
1In'ky' BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
~ecejvedFrom:
Esq.
Andrew L.
r. O. BUA
Lahaska,
Markowitz,
:313
PA. 18931
g; . H4l
~ ;,&
!I~
f./S
One piece of oroinary mail ad<:lresood to:
BOROUGH OF CAMP HILT.
2145 Walnut Street
Cane!) IIill, PA liBl1
'"
"'~ '-
&c::::; ::c> t.:; , r- c::
VI <;. J) ,
1:0. 51\)--,;z:-"'O.~
tfl......... I t;::cof8::bJ)
'(J'j. ~ C:, tv~""""1J
(::I -I._,:e.Oo
-, ~ _ 0
- '0 ....
" if!
rn
I
>'''SF",m 3817, January 2001
f M:;~~\
posfm~r'
" ,," 2 9 20~f)
Total Postage & Fees $ 'Yr t:.i ,{:/~JY
_~~:~~_~~_~~:~~:=~~_;;J::'1(to;:,:~~-~~-----AJ-!~-----------
Street, Apt. No.; or PO Box No. tt? r' ~
'c,;y:Siii.:zip+4mm.. ",!<f,2-__!":-"m,..~,3..':'n_..~_"""""
C,4t>1~ r/"..t 4? /701
Postage $
Certified Fee
Return Receipt Fee
(Endorsement Required)
.J]
<Q
f1J
I:]
Certified Fee
'"
f1J
I:]
I:]
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
I:]
I:]
.J]
9.
II:]
,
, I:]
I c:f
! I'-
',,'
o
'3
...
'"
-
:-'
'-
"
"
C
"
-<
N
o
"l
-
,
.
>d~.:~':'~~""::''''',--""
Postage $
0-<
0 50,
, om-;< "U
ntl . 1:"''0 8' me! 0
~ ~O> en
00 .' \>l . Om -1
c:~ 2 po p., ::00. ;t>
!:<It<:! a \>lOti ~~ ~
0
800 a en . ~ c"'" m
8 , ?;' ~o ;0
. d@ :::;
OH ~ \>ltJj "m "
":In 3 0 I:"' ~~ [T1
~ x .
. 0"
n!:<l 0 '0 0>)>
ot<:! 0 :o-w:;<:: ~2
il "0
~g; . -.Jill )>-
. 0>2
.
0 wti ~~ n
mm
08 !=f ..... ?;' ;0;0 "'
ZH co ~ 2 ~
'<
0 \0 0 :;:;
'OZ w 1-" 2 n
1:"'00 ..... rT )>
~ ~
t<:! N "
:0-00 )> m
i"
CIlt<:! 0 0
n t<:! 0 ."
m s:
8 en 0>
H 2 l>
0 '" r=
z z
G)
IO-6~8~~OOO 0000
~L'O$
:!:>,~~:!,~<'~-><;",
lNnOW~ S3J."lJ503J.fNn
IO,'6ZNnr ~
1[681
~d'~~S~H~l
OI~d
3~81S0d 's'n
~~.-":"'li.<""-;""-;;:;""
l
"
.
" ,." .'iL ,,', eGg,," ,:ie,';;""'''''''"'''' i, ,,,,~,,"":,,"i;j'''':''''i,i ,,'
.
"
'C' __, .il~ -',,"
.'"" .,_:,~_ -' ~'; ~'L]H
"
'.
"
0 0' 0
~ -n
,,,.. --;
~lB c:: ;-=,:D I
Cl ,I :r:
I -pm
ZC :']'0
(J~-,i'.: f'-..J
-'--.,;1 ,..
r::i~: .
~ "
;2" -,--".- ~~.~. f~~
~~ 't1 ~ .
~ 0 ~
.;;:-
~
, ,l
~, '~ ,."'-
.' ,}
~,
.;I~l~t;\
,-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CNlL DNISION
NATIONS CREDIT HOME EQUITY
SERVICES CORPORATION
vs.
DAVID 1. ARTZ
MARYANN S. ARTZ
00-02952 CV
PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE
To the Prothonotary:
Issue writ of execution in the above matter:
Amount $ I 19,822.03
Interest accrued
from 08/01/00 to 06/06/01 $ 6,107.00
Other costs $
Total $
NOTE: Please attach description of property.
ANDREW.
PO Box 373
Lahaska, PAl
,. , ,~, .- .,' <'.- " ,,-
;,." -~ ,~
.,;',i., '"
.~
,.
"
NATIONS CREDIT HOME EQUITY
SERVICES CORPORATION
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
00-02952-CV
DAVIDL.ARTZ
MARYANN S. ARTZ
WRIT OF EXECUTION
(Mortgage Foreclosure)
Commonwealth of Pennsylvania
County of Cumberland
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYL V ANlA:
11
To satisfy the judgment, interest and costs in the above matter you are directed to levy
upon and sell the following described property (specifically described property below):
ALL real property and improvements located at 142 North 33rd Street, Borough of Camp Hill,
Camp Hill, PA 17011.
BEING Parcel No. 01-21-0273-186, and as more fully described in attached description.
Amount Due
Additional Interest from 08/01/00 to 06/06/01
Plus Costs
Total
$ 119,822.03/
$ 6,107.00
$
$
(Clerk) Office of Judicial Support,
Common Please of Cumberland County, P A
Dated
(SEAL)
llfi.
L', ~"' .'.
'"
-
a
~
:>
CJ
1
N
V)
0-
N
o
.
o
o
o
Z
'N,~,,< ,'u" __."
'"I"
'~!Oi~
;j-~
00
~
....
~ ~
~ ~
~ 0
g ~
I..lr..z
r..o<
o ;
~ ~
o ~
I..l I..l
!il
Eo<
Z
...
,._...",y.".
~
...z
go
~f::
~~
::c~
f-<o
.....u
~~
uu
00;>
~~
.....~
f-<rIJ
~
.cO< .'~' ,- < ,
. J" , ~ ,.
~
.5
'"
1i:
N
Ng
g<
<00
~ ~~
~~
. '"
'-.
..,,,,','
~
-g
~
"
o
z
0,....,
~ f
~ ;
U~
~ f
~ 0
~~
~~
01:llJ
t
~~
~
cc". ,,~,
", ",,"'" ,
'-,
j
6
00
~
~.
~ E
o~ CX)
~'.;:I .-<.-<
~,::IM .-<
~'ar- ~
-("1"').::(0
~ ""I
. ;...:><: r-
.... <S 0 .0'1
C> "'>!I III N
;;> >. .-: I
gz a . ~;;;-
CloO.c::.-<
Z t " IllN
<<""..:1-
l~
- .~
M.' ]1(.<:
.
PKOPERTY DESCRIPTION
ALL THAT CERTAIN tract or parcel ofland and premises, situate, lying and being in
the Borough of Camp Hill in the County of Cumberland and Commonwealth of
Eennsylvania, more particularly described as follows: .
BEGINNING on the North by Logan Street; on the East by Belvoir Avenue; on the South
by Lot No. 131 on the hereinafter mentioned Plan; and on the West by a public alley.
BEING LOTS NO. 132 and 133 on Plan of Lots of "Belvoir", Borough of Camp Hill,
Cumberland County, Pennsylvania, said Plan recorded in the Recorder's Office in and for
Cumberland County in Plan Book No.1, Page 16.
SAID LOT NO. 132 CONTAINING twenty (20) feet in front on Belvoir Avenue and
extending back an even width orehundred and twenty-five (125) feet to the aforesaid
public alley.
SAID LOT NO. 133 CONT AlNlNG thirty-four and five-tenths (34.5) feet in front on
Belvoir Avenue and extending back one hundred and twenty-five (125) feet to the
aforesaid public alley.
RAING THEREON ERECTED a single brick and aluminum split level, said premises
being know as 142 North 33rd Street.
BEING PARCEL No. 01-21-0273-186.
BEING the same premises which Maryann S. Artz and Rita Fratalli, by Deed dated
09/22/1993 and recorded 09/23/1993 in the County of Cumberland in Deed Book N,
Volume 36, Page 914 conveyed unto Maryann S. Artz and David 1. Artz, husband and
wife, in fee.
SEIZED and taken in execution as the property of David 1. Artz and Maryann S. Artz
under Judgment No. 00-02952.
,--,.
-'~fiI_~""'"
_1!lirlm\~~,jojj,cj,,"f{fW!@j1l>
'. _.' =oi~"";-'-";t""-"";;:Mm!Mrli~dmI
;jja.iIIi_"'~B
\?9~
,.fJ,;.'y'c,.--
-
C)
"'<:'
<><:)
-t
-
~
L}./
~
'~'.'> "~ "
~'I"f~"'1'_ ,.-,>~""'_'.,,,",'1'<>"
-t<.,~ ~. ',.. ~'d
I"'"-G
\' ,::
-.
<->.
c:::l
'.' ~c..,
-,
(. 0 ,
r:~
\ ()-\
~
,<::)
'.
'l!lIilIi!I~~:&..
~~
~
('-'
c~
- G-, ~, h-~
-...J (>\ ,- \
~ ~ ~ '\.>" 'cd
\)
~
u..
C!
(")
c:
"7
:~'.
IJCQ
nlf"
Z-IJ
-?r'
(02e:
-<.r.:.
GCJ
""
~Q
--Li
)>c:
Z
~
C)
(),
-n
:J~
S;
J]
;~~
!5~('5
..".
r'')rn
'=-l
>-
:Q
,-
-v
-..,,-
~~,'....
!:Y
~:.:>
c-v
-.\1.
.
,-
(0)
,
-,-, -
"""'
-".,'--
'~.', >
, ~
, '..t-
. .,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA
vs.
00-02952
,
i
Ii
I
I
I'
I
I
I'
i
,
I
i
t
I
i
t
!:
,:
NATIONS CREDIT HOME EQUITY
SERVICES CORPORATION
DAVID 1. ARTZ
MARYANN S. ARTZ
AFFIDAVIT PURSUANT TO RULE 3129.1
Nationscredit Home Equity Services Corporation, plaintiff in the above action, sets forth
as of the date the praecipe for the writ of execution was filed to following information
concerning the real property at 142 North 33'd Street, Camp Hill Borough, Camp Hill, PA
170 II.
1. Name and address ofOwner(s) or Reputed Owner(s):
David 1. Artz
Maryann S. Artz
142 North 33'd Street
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the Judgment:
David 1. Artz
Maryann S. Artz
142 North 33'd Street
Camp Hill, PA 17011
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Borough of Camp Hill
2145 Walnut Street
Camp Hill, P A 17011
4. Name and address of the last recorded holder of every mortgage of Record:
NONE OTHER
5. Name and address of every other person who has any record lien on their
property:
NONE OTHER
.', 'j~
- , .".,~-"--. . -
.
'.
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:
NONE OTHER
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:
Domestic Relations Section
Court of Common Pleas
Courthouse
Carlisle, P A 17013
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 P A C.S. Sec. 4904 relating to unsworn falsification to
authorities.
Dille: March 9, 2001
. " -~. - .
'''tj
l
I"
,
I,
['I
:;!
i,!
,
r~
:~i
,^!
"
i'"
~i
[.j
I~
1'1
i,1
!:
i;:
i-;
;;;
';i
1-.:
!:i
,
..'
;~
,
iIIi""""~
.'d..:
'-'
<
~, '.f"'"''''
"~~ .~~, -~".
-~. _ _ "" ~b-.
- - ,~ , .. -
.. ~"~ii'<ltr~;-""'"~
~ """"
-, "
0"," ""
. -~ "
C")
fi;
-O"~
rr'i,'f
~::zi
"" r--
~~~'
C:<';
);;;0
<:0 -0
:SO ~
~
~
,--
'.~- ~~-
,,-
".
.
>0
'-
o
'<'1
, :lr
~.
,..,~
::0::>
.~
;-2FG
,[1:]
i,,,,,J'---f
_J L
S:J!;
sj ::d
<0
om
j;!
::J;J
-<:
-.
~.
f\.)
"
<v
r",
I
. ...,
...
- "-
~~
~ - ~ ~bo'4f!iIiJ
,.~. -~ '.d...olOli_'I""""",,",~_"'~~~~'~
~ ~--~~
MARKOWITZ,&-MARJ{()WI'I'Z
Andrew 1. Markowitz, Esquire
P A Attorney ill #28009
PO Box 373
Lahaska, P A 18931-0373
Tel.: (215) 297-0411
Attorneys for Plaintiff
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
vs.
00-02952 -cv
DAVID 1. ARTZ
MARYANN S. ARTZ
NOTICE OF. SALE OF REAL PROPERTY
TO: David 1. Artz
Maryann S. Artz
142 North 33rd Street
Camp Hill, PA 17011
Your real property at 142 North 33rd Street, Borough of Camp Hill, Camp Hill PA 17011 is
scheduled to be sold at Sheriff's sale on June 6, 2001a>cl0: 00 a .m. in the Commissioners
Meeting Room, * to enforce the court judgment of $119,822.03 obtained by Nationscredit
Home Equity Services Corporation against you on August 1, 2000.
*at the Cumberland County Courthouse, Carlisle, PA 17013.
NOTICE OF OWNER'S RIGHTS
NOTE: This law firm is a debt collector and is attempting to collect a debt on
behalf of plaintiff in this matter. This notice is an attempt to collect a debt
and any infonnation obtained hereby will be used for such purpose.
,"~-^~ ~-.."~~
........._""
-~.., ~
&i!t:'i;
""..... ~ .l..
NOTICE OE-OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriff's sale you must take immediate action:
1. The sale will be cancelled if you pay to plaintiff, the amount of the judgment plus costs,
back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call Andrew 1. Markowitz, Esquire at 215-297-0411.
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 STllLLBE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriff's sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calIing the Sheriff at 717 - 2 4 0 - 6 3 9 0 .
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 the Sheriff at 717 - 2 4 0 - 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 a 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 that was paid for yo1Jl' property. A
schedule of distribution of the money bid for your property will be filed by the Sheriff
within thirty (30) days of the' sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with the schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after the schedule of distribution is filed.
~,
\,
J;. i,v'
~-'
~.~
fv~
-~ ~
7 . You may also have other rights and defenses, or ways of getting your property back, if
you act immediately after the saie.
YOU SHOULD 'fAKE TIDS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
1-800-990-9108
717-249-3166
M~"~;IllI"~~)j
-
......,,.,,;jj~~;;lij.:Jlm~'M~~!!I1lllI~~."~~~' ,'"""""''IIiii~-
ltl.
cO
......."S:-
tjf6'",
;;;::rJ}
0(/
:::c,-~-'
~~>.
j;5,'i
~tr
ff
,
-,....,....-l~.~:...'l., ,"-'
~"'d;:"
52
"""
~"'"
-~,;;;;,
~
.....
-0
[)
Ii
.~:..~
" ';,::=;:
;::?'fJ
~'>y(.....
'.' .~_J
LYf;'
_:i;'}~
~0
'..!;~
~
0)
""4:'
~
I~
\)
II~I
~'
.'_"r"-
_"", . -.'i~,,';, _, - L :.' -L~ "'; 'J ,~
,t'.-
~',,' ...-..:
MARKOWITZ & MARKOWITZ
Andrew L. Markowitz, Esquire
P A Attorney ID #28009
PO Box 373
Lahaska, PA 18931-0373
Tel.: (215) 297-0411
Attorneys for Plaintiff
NA TIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
vs.
00-02952
DAVID L. ARTZ
MARYANN S. ARTZ
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
TO THE SHERIFF:
I hereby certify that I am counsel for plaintiff in the above matter against real property
and further certify this property is:
[
]
Not subject to Act 91
[XXX]
Is subject to Act 91 of 1983 and that plaintiff has complied with all
provisions of said Act.
I further agree to indemnify and hold harmless the Sheriff for any false statement given
Andrew .
herein.
L ,,"
ilIiI' ~~ ~
,_~'"h~
,: ='. ._-~
-
~,~
"~'.
,;." ",
~~
,;~~,c. .
,......
.~ ,.
0 C:, r)
C ..;of--;
S; 3:: --'
-om ~ -::~-n
m,,: ::0
~~' -',jj!
~ -~10
(/)?: .c- " 1
~~, -~~:! (~
~c:! " ~1""
,;::-):D
~o ::k :0;..0
:>2 r:-? arn
S'
~ w 55
f'0 --<
-
-...'
,
."
--~'''~"'
Form QIS-l0(Ofliciql Form 18)
, (9/97)
142 NORTH 33RD STREET
CAMP Hill, PA 17011
UNITED STATES BANKRUPTCY COURT
--"---M1fIDt:E-Bt8'ffil6'f OF PENNSYLVANIA-
)
)
)
) Case Number: 00-03322RJW-1
)
)
)
)
) Chapter: 7
)
)
)
Debtor )
)
)
)
)
)
)
Joint: 188-46-6304
In Re:
ARTZ, DAVID l
-
ARTZ, MARYANN S
142 NORTH 33AD STREET
CAMP Hill, PA17011
Social Security No(s).:
Debtor: 191-46-3499
DISCHARGE OF DEBTOR
It appearing that the debtor is entitled to a discharge,
IT IS ORDERED:
The debtor is granted a discharge under section 727 of title 11, United States
Code, (the Bankruptcy Code).
Dated: November 16,2000
SEE BACK SIDE OFTtIlS ORDER FOR IMPORTANT INFORMATION
028465
.._-..J"""~llilllW:l~~~~lIlitti~,"'Jl.jj*,,~,~W~~~..;
,
~1IiiiiilIi!i\ll"_ ~. ,
^~rR!lMIll
o
c
~
;:gfri
""ref;
'5:f'
C75,J>
r;~E.~
~o
:i>
20
:sO
~
=<
~,- -
ry
w
r",
.
o
o
-'q
'-
::!::
:z,;.
=0
:.!";--..,
'! :;--2
l~~
C5m
);!
:v
-<:
--
~)
::%
,
l
,
~-~_.
~.!f I
SHERIFF'S RETURN - REGULAR
CASE NO: 2000~02952 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONSCREDIT HOME EQUITY
VS
ARTZ DAVID L ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County, Pensy1vania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ARTZ DAVID L
the
DEFENDANT
, at 0018:35 HOURS, on the 24th day of May
, 2000
at 142 NORTH 33RD STREET
CAMP HILL, PA 17011
by handing to
MARYANN S. ARTZ
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:
18.00
9.30
.00
10.00
.00
37.30
r~Ii~~~~
R. Thomas Kline
OS/26/2000
MARKOWITZ & MARKOWITZ
Sworn and Subscribed to before
By:
7~A-?/ fJjITf?
Deputy Sheri
me this .l. ~ day of
~ ~WO A.D.
~ t2 ~/ 4fv?'
Prothonotary ,
--
~
-~
,I
f
\
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-02952 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONS CREDIT HOME EQUITY
VS
ARTZ DAVID L ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County, Pensy1vania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ARTZ MARYANN
the
DEFENDANT
, at 0018:35 HOURS, on the 24th day of May
2000
at 142 NORTH 33RD STREET
CAMP HILL, PA 17011
by handing to
MARYANN ARTZ
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
6.00
.00
.00
10.00
.00
16.00
So Answ~~ '..P' ~
~~J'!r'~1' ~ -~
R. Thomas Kline
OS/26/2000
MARKOWITZ & MARKOWITZ
Sworn and Subscribed to before
By:
7h~ i/.
Deputy Sheri~
me this ;}-...< day of
~ ,;lom) A.D.
~ a. hrJ ".-~ 1/ q"'i
Prothonotary I
~ "nJIlI ~
I
MARKOWITZ & MARKOWITZ
BY: Andrew L. Markowitz, Esq.
ATTORNEY 1.0. NO, 28009
P. O. BOX 373
LAHAsKA,PA.1B931
(215)297-0411 ATTORNEYS FOR
plaintiff
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
vs.
DAVID L. ARTZ
MARYAl\iN S. ARTZ
10."";';;'"
COURT OF COMMON PLEAS
DIVISION
TERM,
No.
00-02952
IN MORTGAGE FORECLOSURE
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter default judgment against defendant DAVID L. ARTZ
and MARYANN S. ARTZ
for failure to answer or respond to the Complaint within the time
required by the Pennsylvania Rules of Civil Procedure. Pursuant to
Rule 1037 and 1141 of the Pennsylvania Rules of Civil Procedure,
kindly assess damages as follows:
$ 75.00 (prior costs)
$ 106,855.49 (principal balance)
$ 4,3l5.43(accrued interest to 4/30/00)
$ 2,926.00 (interest 5/1/00-jdg @ $33.25 pd)
$ 8~R. RR(attorn~y.tse feheasl)ges)
$ 4,8~tl:~~ (pre-payment penalty)
$ 119,822.03 (Total)
I
I,
Ii
By:
MARKOWITZ
ITZ
"'-iiIl~ lIi!r'""
~
~
I
~l(XK~X~XJRX
FROTHONOTARy
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
>>>>KK~~XOOXK~XK~~~X~KX~X~X~XX
Courthouse, Carlisle, PA 17013
. .
To: DAVID L. ARTZ
MARYANN S. ARTZ
142 North 33rd Street
Camp Hill, PA 17011
. .
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
(pr~~County)
CUMBERLAND
Term, 19
i
,
i
rl
~
'I
'I
I
'I
:1
vs.
00-02952
DAVID L. ARTZ
MARYANN S. ARTZ
No.
NOTICE
Pursuant to Rule 2j6 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment bas been entered against you in the above proceeding as indicated below.
~btXXXXlOOlIDI:gf{~
ProthonotoM)
>>XX Judgment by Default
o Money Judgment
o Judgment in Replevin
o Judgment for Possession
o Judgment on Award of Arbitration
o Judgment on Verdict
o Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY
Andrew L. Markowitz,
Esquire
lInSf!rt Altomr;' s N 1Im~)
at this telephone number:
215-297-0411.
5-60 17i {;l:....... l178l
"Iir'
-
"~"
I
MARKOWITZ & MARKOWITZ
BY: Andrew L. Markowitz, Esq.
ATTORNEY 1.0. NO. 28009
p, o. BOX 373
LAHASKA. PA. 18931
(215) 297-0411 ATTORNEYS FOR
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
DIVISION
TERM,
vs.
DAVID [,.. ARTZ
MARYANN S. ARTZ
No.
00-02952
~
!
AFFIDAVIT OF NON-MILITARY SERVICE
i
, I
, I
I i
I I
I I
! i
II
, I
,
I
I
,
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUCKS:'
I, ANDREW L. MARKOWITZ, being duly sworn according to
law, hereby deposes and says that the defendants DAVID L. ARTZ
and MARYANN S. ARTZ
are over the age of twenty-one years and that defendants are not
in the military service or naval service of the United States
or its Allies or otherwise within the provisions of the Soldiers'
and Sailors' Civil Relief Act amended, and that defendant reside
at
142 North 33rd Street, Camp Hill, PA 17011.
I,
I
II
Sworn to and subscribed before _._..
h' Zh -r.d' fU"jL.7JZ"Od'Jm;~ii\L SeAL ANDJ
he ~/S ' a 0 I SUSAN J. 'MAffi?O\l\l,'TZ, Notary Publici
Solebury Twp., Bucks County
M Commission ExplrBS June 26. 200.,. 1
1IIi-
"~ il'!IlI!i>I_-;o
I
MARKOWITZ & MARKOWITZ
BY: Andrew L. Markowitz, Esq.
ATTORNEY 1.0. NO, 28009
P.. O. BOX 373
LAHASKA,PA.1B931
12151297-0411 ATTORNEYS FOR
I
i
1
i
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
, COURT OF COMMON PLEAS
DIVISION
TERM,
vs.
DAVID L. ARTZ
MARYANN S. ARTZ
No.
00-02952
CERTIFICATION
OF
COUNSEL
I, ANDREW L. MARKOWITZ, counsel for plaintiff in the above
matter, do hereby certify that I caused a copy of the accompanying
ten-day notice of default to be served on defendants DAVID L. ARTZ --
and MARYANN S. ARTZ
by placing a copy of same, on June 21, 2000
,
in the Uni ted
States mails, postage pre-paid, addressed to defendants at their last
known residence of
142 North 33rd Street, Camp Hill, PA 17011.
ANDREW L
-
"~ -
,11
~
~:",:
OFFICE OF THE PROTHONOT AR Y
COURT OF COMMON PLEAS
~~I"~XX~X~XX~~~X~~XEX~~
Courthouse, Carlisle, PA 17013
Ji))tM:]!J{XK~l!Xl1G~X.
PROTHONOTARY
.
To:
DAVID L. ARTZ
MARYANN S. ARTZ
142 North 33rd Street
Camp Hill, PA 17011
.
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
vs.
DAVID L. ARTZ
MARY ANN S. ARTZ
.
Date of Notice:
JUNE 21., 2000
, :"~
Certified Mail No.
.
COURT OF COMMON PLEAS
(RROCOCdel:~X County)
CUMBERLAND
Term, 19_
No.
00-02952
NOTICE, RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed
to take action required of you in this case.
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 follow-
ing office to find out where you can get legal
help.
NOTIFICACION IMPORTANTE
Usted se encuentra en est ado de rebeldia por
no haber tomadola accion requirida de su
parte en este caso. Al no tomar la accion
debida dentro de un termino de diez (10) dias
de esta notificacion, el tribuna podra, sin necesi-
dad de compararecer usted en corte 0 escuchar
preuba alguna, dictar sentencia en su contra,
usted puede perder bienes y otros derechos
importantes. Debe llevar esta notificacion
a un abogado immediatamente si usted no
tiene abogado, 0 si no tiene dinero suficiente
para tal servicio, vaya en persona 0 Harne
NOTICE: This law firm is a debt por telefono a la oficina, cuya direccion se
collector and is attempting to encuentra escrita abajo para averiguar donde
collect a debt on plaintiff I s behalf. se puede conseguir assistencia legal.
Any information ~btai~ed will be used for such purpose. .
Lawyer Keterence :>ervlce ServlclO De Referencla Lega'!
WltleIDiKXlHK~~f{~X1iO& CUMBERLAND COUNl'JN~KE!i~~{:S~~so
~~~~~K3~X BAR ASSOCIATION ~~~~~~
m~~jj:yq~~~x:j{~x 2 Liberty Ave. ~~~M~Jl;:3lroQ{
'~~ Carlisle, PA 17013 x~~
TEL: 717-249-3166 or 1-800-990-9108
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
Andrew L. Markowitz, Esquire
(Name of Attorney or Plaintiff)
P. O. Box 373, Lahaska, PA. 18931
(A ttorney's or Plaintiff's Address)
at this telephone number: 215-297-0411
5-154
~.,. ~ "".~
-
"~ ~
-
~~
. L!2' ~
~n
1,-, '.
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} SS.
Robert P Ziegler
~ --___________________________________________________o________________________Ilecorderof
Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ________________
Nationscredit Home Equity Serv Corp
---------------------------.------------____________________________________________ m the gr.antee
1st
the same having been sold to said grantee on the _______________________________________n______ day of
01
n___' under and by virtue of a writ______________
14th
Execution .
_____n_____________________ __________ ___ nn_n ISSued on the ___ ___ __n_n ___ _nnn_ _____________
01
_____) out of the Court of Cornman Pleas of said County 'as of
August AD'
________________________________________ . ", 1
March
day of __________________________ A. D.,
Civil
__________________________ ____.... __ n___ ___ __ _____ ____ _____ _______ n __n __n_ _ _____ Term, :
2000
.. . Nationscredit Home Equity Serv Corp
Number __29.5..Z._______, at the SUIt of __n__________n__n______________n______________n___________
David L Artz & Maryann S
___________________________________ against_ n_ ____ n ___n _ _________ n________ ____ ______ ____ __ _ is
248 2580
duly recorded in Sherifr. Deed Book No. n_n___n__' Page ____________.
IN TESTIMONY WHEIlEOF, I have hereunto
set my hand and seal of said office this ___:l:k___ day
of _______;[~'C_________n___ A. D., ~L
~--~-----R;~;d,;;.-~i~
"""'"'......_1"" ~ '" .
.'"
".=""~J1lQ.
,
Nationscredit Home Equity
Services Corporation
VS
David 1. Artz and Maryann S. Artz
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No.2000-2952 Civil
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on
April 11, 2001 at 1:34 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of David 1. Artz and Maryann S. Artz located at
142 North 33rd St. Camp Hill, Cumberland County, Pennsylvania, according to law.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on
April 11, 2001, the house at 142 North 33rd Street Camp Hill, Cumberland County,
Pennsylvania, was empty. The Post Office at Camp Hill, Pennsylvania, had no addreess
change for David and lor Maryann Artz.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served
the above Real Estate Writ, Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
d~fendants to wit: David 1. Artz , by Certified Mail Return Receipt Requested,
R~stricted Delivery, Deliver to Addressee Only to his last known address 142 North 33rd
Street Camp Hill, Pennsylvania. This letter was mailed under the date of April 18, 2001
and returned to the Sheriff's Office on April 30, 2001 with the reason checked MOVED
LEFT NO ADDRESS.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served
the above Real Estate Writ, Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Maryann S. Artz , by Certified Mail Return Receipt Requested,
Restricted Delivery, Deliver to Addressee Only to her last known address 142 North 33rd
Street Camp Hill, Pennsylvania. This letter was mailed under the date of April 18, 2001
and returned to the Sheriff's Office on April 30, 2001 with the reason checked MOVED
LEFT NO ADDRESS.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he
served the above Real Estate Writ Notice Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants to wit: David 1. Artz by regular mail to his last known address, 142 North
33rd Street, Camp Hill, PA. This letter was mailed under the date of April 30, 2001 and
never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he
served the above Real Estate Writ Notice Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants to wit: Maryann S. Artz by regular mail to her last known address, 142 North
33rd Street, Camp Hill, P A. This letter was mailed under the date of April 30, 2001 and
never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on August 1,2001 at 10:00 A.M., E.D.S.T., and sold the same for the sum
of $1.00 to Attorney Andrew Markowitz for Nationscredit Home Equity Services Corp.
~........
H_~2':
It being highest bid and best price received for the same, Nationscredit Home Equity
Services Corp. of 10401 Deerwood Park Boulevard, Jacksonville, FL 32256, being the
buyer in this execution paid SheriffR. Thomas Kline the sum of $894.54, it being costs.
Sheriff's Costs:
Docketing
Poundage
Posting Handbills
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
17.54
15.00
15.00
30.00
10.00
.50
1.00
8.68
16.68
15.00
30.00
307.25
300.30
25,09
25.00
2L.5.Q
$814.54
Sworn and Subscribed to Before Me
;;-~:~,<~~
R. Thomas Kline, Sheriff
This .3;o.vt Dayof {)ffJ~. .
200l,A.D.~ C. ))"Li,,,.'~
Prothonotary
Byi)tdM~
Real Estat'e Deputy
~
3:J ,uU fuJu:
L~D
(~ 3103(.,
uL 1/1.2/)
__.... _~~ M~. _~
__, 4 ._i
=<
]l;j ~'ilIffi,'L
"'- -,
IN THE COURT OF COMMON-PtnA:S-erFetlMBERLAND COUNTY. PENNSYLVANIA
NATIONS CREDIT HOME EQUITY
SERVICES CORPORATION
vs.
00-02952
DAVID 1. ARTZ
MARYANNS.ARTZ
AFFIDAVIT PURSUANT TO RULE 3129.1
Nationscredit Home Equity Services Corporation, plaintiff in the above action, sets forth
as of the date the praecipe for the writ of execution was. filed to following information
concerning the real property at 142 North 33rd Street, Camp Hill Borough, Camp Hill, PA .
17011.
1. Name and address ofOwner(s) or Reputed Owner(s):
David 1. Artz
Maryann S. Artz
142 North 33rd Street
Camp Hill, PA 17011
2. Name and address ofDefendant(s) in the Judgment:
David 1. Artz
Maryann S. Artz
142 North 33rd Street
CampHill,PA 17011
3. Name and address of every judgment creditor whose judgment is a record lien
on the real property to be sold: .
Borough of Camp Hill
2145 Walnut Street
Camp Hill, PA 17011
4. Name and address of the last recorded holder of every mortgage of Record:
NONE OTHER
5. Name and address of every other person who has any record lien on their
property:
NONE OTHER
,<>\_._."'-~"
.. "-
L 1~ ~
">
~~ "-
,\,
,. ......
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:
NONE OTHER
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:
Domestic Relations Section
Court of Common Pleas
Courthouse
Carlisle, P A 17013
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
authorities.
Dme: March 9, 2001
- "~"
.
A " ,'~ ~"" :'. .',"" ,. ,~. _.~"-;",,'~~, , ,=':h- , ""-"<0;' :;/'''':''-',;(. ;"l-O_ ,;0"," 0",",,"
^' ,
MARKOWITZ & MARKOWITZ
Andrew 1. Markowitz, Esquire
P A Attorney ID #28009
PO Box 373
Lahaska,PA 18931-0373
Tel.: (215) 297-0411
Attorneys for Plaintiff
NATIONSCREDIT HOME EQUITY
SERVICES CORPORATION
COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
vs.
00-02952 -cv
DAVID 1. ARTZ
MARYANN S. ARTZ
NOTICE OF SALE OF REAL PROPERTY
TO: David 1. Artz
Maryann S. Artz
142 North 33'd Street
Camp Hill, PA 17011
Your real property at 142 North 33'd Street, Borough of Camp Hill, Camp Hill PA 17011 is
scheduled to be sold at Sheriff's sale on June 6, 200I!l'lt:l0: 00 a .m. in theCemmissioners
Meeting Room, * to enforce the court judgment of $119,822.03 obtained by Nationscredit
Home Equity Services Corporation against you on August 1,2000.
*at the Cumberland County Courthouse, Carlisle, PA 17013.
NOTICE OF OWNER'S RIGHTS
NOTE: This law firm is a debt collector and is attempting to collect a debt on
behalf of plaintiff in this matter. This notice is an attempt to collect a debt
and any information obtained hereby will be used for such purpose.
~ "
., I"',', '''' .~.., "
"'. ., --di,' " .;~:"", i.,'~J.i..,.(.cO" W' - - ~":k"""'> 'c'~--"",,, -. "
~ ~,
,
--
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE
To prevent this Sheriff's sale you must take immediate action:
1. The sale will be cancelled if you pay to plaintiff, the amount of the judgment plus costs,
back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call Andrew 1. Markowitz, Esquire at 215-297-0411.
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 find out the price bid by calling the Sheriff at 717 - 2 4 0 - 6 3 9 0 .
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the
sale. To fmd out if this has happened you may call the Sheriff at 717-240-6390.,
4. If the amount due from the buyer is not paid to the Sheriff, you win remain the owner
of the property as if the sale never happened.
5. You have a 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 that was paid for your property. A
schedule of distribution of the money bid for your property will be filed by the Sheriff
within thirty (30) days of the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with the schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after the schedule of distribution is filed.
..
-
,,,'~,, " O~~', ','",. ~",.~", "~"""""_':;'" ":,;~~".",.,- ",..,,,,~_'., ~"",_.-," ';';"";,._...':':f;.;<h',,i.\_" ,,"'",,;"".{
,
.
7. You may also have other rights and defenses, or ways of getting your property back, if
you act immediately after the sale.
YOU SHOULD TAKE TIDS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
1-800-990-9108
717-249-3166
J
..'=.,;
,
WRIT OF'EXeeUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-2952 CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
To satisfy the debt. interest and costs due Nationscredi t Home Equity Services Corp.
from
17011.
David L. and Maryann S. Artz, 142 North 33rd St., Camp Hill
PLAINTIFF(S)
PA
(1) You are directed to levy upon the property of the defendant(s) and to sell All real
and improvements located at 142 North 33rd St., Camp Hill PA
(See attached legal description.)
DEFENDANT(S)
property
17011.
(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/are enjoined from paying any
debtto or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof:
(3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other
than a named garnishee. you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated,
A tD $119,822.03
moun ue
8/1/00 - 6/6/01 $6,107.00
Interest
LL
Due Prothy
Other Costs
$.50
$1. 00
AIIY's Comm
Atty Paid
Plainmf Paid
%
$125.30
Date:
March 14, 2001.
CURTIS R. LONG
~
i
Deputy
by:
,
;
\
n . ary. Civil Division
REQUESTING PARTY:
N Andrew L. Markowitz, Esq.
ame
Address:
POBox 373
Lahaska PA 18931
Attorney for:
Telephone:
supreme Court ID No,
Plaintiff
(215) 297-0411
28009
..1 .1 t1h~~.oo~.iIIi;~{~~'la~OOI!!WilI~~'"' '~.(lM ,= ',"
w.d ' '0' '"~ "' .,
r ..
REAL [STAlE SALE No, 0..; 7
vll /1'1,/ ~ ", ~ J c/ I the sheriff levied upon the detenoarhL
interest in the real property situated in&l-f' /u.! ~~y
Gumberland County, Pa., knowr :Jnd numbered as: #..2 f(/ .3':h,././i.J
~ and more fUli<'!:oed on Exhibit "A" flied wit!'
this writ and by this referencP'I)(Qorated herein.
"'';jte;/J1).ew...c~ It,C26 (/)
By:.~/.L,I~h
~tU1~~
,tl~!\\~S,~'~3d
'It X1C;\ \iJ""
,I '" 0\ ll~~
\0. ~d Gz"l J
. "\,\\lI'lM
}.lllncO ~~{ ~o 3n\~::lO
J:i\\\3\\S
-
-,.,. .,'
^ ,
~
c:;;;J
c:;;;l
c:;:::a
ee>
liiiY
.
o.
~
-ll.: ,~
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} S8
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivabie Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place af business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of Illil
Patriot-News and The Sundav Patriot-News newspapers of generai 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 ail have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 24th day(s) of April and the 1 st and 8th
day(s) of May 2001. That neither he nor said Company is interested in the subject maller of said printed notice or
advertising, and that ail of the ailegations 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 severaily 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 Miscerl ,. eous Book "M",
Volume 14, Page 317. G
PU BLICA TION .,..,.......................,....,.,..../.;;.....1,.,...........,..........,...,..............
COpy Sworn to and subscribed b/tore me this 21st d of 2001 A.D.
SA L E #47 &./
Notarial Soal I- r
Terry L. Russell, Notary Public I",
Harrisburg, Dauphin County
My Commission Expires June 6, 2002
Member, Pennsylvania Association at NOlarl
N TARY PUBLIC
commission expires June 6, 2002
.
",
,
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
.....
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
298.80
1.50
300.30
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circuiation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By..........................................................H........
-----------
'"
.
,.--.--c-;'''-'''- ,,,,,..,""..~,-""--
;h
REAL ESTATE SALE No, 47
Writ No, 2000-2952
ClvilTerm
Natiol'lscredlt 'Home 'Equity
ServIces co:,~.poratlon
~.
llavldL,Artt
and Marvann $, Artt
A"'J: Andrew Mar_II<
DESC!llPT10N
~:AU. n-iA1 CER1AlN tract or parcel of land
, ',#nd premises, $ltuai..e, tying an.d being in
~he Borough of camp run 'rn the Count\' of
cumberland and commonwe-alth' of
'f,fl.1nf>yl."'i'lnia.. more particularlY described
?~~ fqlloWS: "
'~.EG1NNfNG on the North by Logan Street:
I 'Qn l\:'1e East by ~\l,'oir Avenue: on the
, 'Soutti' by Lot No. 131 on the hereinafter
\ 'Ji-,entiotied Plan; and on the West by a
, publiC alley. '
SElNG lOTS1'lCM, 132 ",d 133 on plan of
Lots of "Belvoir", "Borough' of Camp Hm.
Cumberland County. PennsYlvania, said
Flan recorded in the Recorder'S Office in
, ,and for cunibe.rland County :in Plan Book
Nti,l,l'a 016,0>' " ,.,' ,.,. '
SAID L@11'lO, 132 c<l;1lalning twenty (20)
fed, in front on Iful.voir Avenue and
, ~tend\.r\g back ai' even v.'5dth on~ hundred
< '~'pd 't\,,1enty-nvc (115) t~et 'to the afort.'said
, 'P.l.\blicalleV, ~
SAID tQ't NO. \,,;3 containing th'i:rtY~four
an9. f~\'e.-tenths {34.,s) feet in front ort
~l"oir A'.'eOue and extending back on~
'hundred and tvventy-ftvc <.,1:!5) feet to tne
-aforesaid public alley. ,
, 'HAVING THER(ON ERECTED a si:ngle
c':~- ,;.aitd ',(\lu.mtnum sp1it leveL, y"aj.,d"::
W.~~b'lngknQ,<'-"14~ N~~~3ia:)
fz~~;:f.~~N9;~~'ll:i~~k~n/;
:(S'G't!irtZ and Rita ~atal1i, by Deed dated ()9/ ~;,'
:'.~.1i93 ,nd ",corded09I2311993 il, the'i
;c:C1Jlt'TIty ,Q,I cumberland i'O Deed Book N.
, Vo1.uroe' '}6, Page 914 conveyed unto
Maryann 'A. A.rtz an.a~ Dav1:.d t. Afa,
\ husband and wife, in fee.
StlZED arid' taKen in eXE!cution as the
property of Oavid 1. AIlz- Md Maryi\M 5.
Ariz. under Judgme.nt No, 00-02952.
i ~~
-,-------
-,-,--------------------'-' -----' ~-
,
,
.
,
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.1784
STATEOFPENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2,1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law
Journal on the following dates,
VIZ:
APRIL 27, MAY 4,11, 2001
Mfiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~t/L-
Roe(er M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of MAY. 2001
NOTARIAL SEAL
, lOlS E. SNYDER, NOlal'jf Public
Cllrlisl~,BMl. Cumoolland CountY
My ComIr~oo ExIllres M!lfCh 5, :z005
-\ 1l.-
REAL ESTATE SALE NO. 47
~
Writ No. 2000-2952 Civil
Nationscredlt Home EqUity
Services Corporation
vs.
David L. Artz and Maryann S. Artz .
Atty.: Andrew MarkoWitz
PROPERTY DESCRIPTiON
ALL TIIAT CERTAIN tract or par-
cel of land and premises, situate. :'
lying and being in the Borough of
Camp Hill in the COWlty of Cumber- !
land and Commonwealth of Penn-
sylvania. more particularly described
as follows:
BEGINNING on the North by Lo-
gan Street; on the East by BelvoJr
Avenu.e; on the South by Lot No.
131 .ori the' hereinaffer mentiOned
Plan; and on the West by a public
alley.
BEING LOTS NO. 132 and 133
on Plan of Lots of "Belvoir", Bor-
ough of Camp Hill. Cumberland
County, Pennsylvania. said Plan re-
corded in the Recorder's Office in
and for Cumberland County in Plan
Book No. I. Page 16.
SAID LOT NO. 132 CONTAINING
twenty (20) feet in front on Belvoir
Avenue and extending back an even
width one hundred and twenty-five
(125) feet to the aforeSaid public
alley.
SAID LOT NO. 133 CONTAINING
thirty-four and five-tenths (34.5) feet
in front on Belvoir Avenue and ex-
ten,!il!~_b_a~k ~ ~I].~,--Jl~~dre9:_,--~nd
twenty-five (125) feet to the afore-
said public alley.
HAVING THEREON ERECTED a
single brick and aluminum split
level. said premises being know as
142 North 33rd Street.
BEING PARCEL No. 01-21-0273-
186.
BEING the same premises which
Ma:ryann 8. Artz and Rita Fratalli.
by Deed dated 09/22/1993 and re-
corded 09/23/1993 !Il. the County
of Cumberland in Deed Book N, Vol-
ume 36. Page 914 conveyed unto
Ma:ryann S. Artz and David L. Artz,
husband and wife. in fee.
SEIZED and taken in execution
as the property of David L. Artz and __
Maryann S. Artz under Judgment I
No. 00-02952.