The URL can be used to link to this page

Home My WebLink About02-5526McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A., as Trustee 10790 Rancho Bernardo Road San Diego, CA 92127 Attorney for Plaintiff Cumberland County Court of Common Pleas V. Fay L Bickhart 3405 Walnut ST. Camp Hill, PA 17011 Number 2 - ,ssZ (A C I 'U ill CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after th is complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. AVISO Le ban demandado a usted en la torte. Si usted quicre defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de pluo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de so persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo avi so o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas [as provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Citibank, N.A., as Trustee 10790 Rancho Bernardo Road San Diego, CA 92127 Cumberland County Court of Common Pleas V. Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 Number CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Citibank, N.A., as Trustee, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Fay L Bickhart, who is the mortgagor and real owner of the mortgaged property hereinafter described, and her last-known address is 3405 Walnut ST., Camp Hill, PA 17011. On 09/29/1999, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Decision One Mortgage Company which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1574, Page 283. On 12/17/2001, the aforesaid mortgage was thereafter assigned by Decision One Mortgage Company to Chase Manhattan Mortgage Corporation by Assignment of Mortgage recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage Book 683, page 653. 5. The aforesaid mortgage was thereafter assigned by Chase Manhattan Mortgage Corporation to Citibank, N.A., as Trustee, Plaintiff herein, by Assignment of Mortgage which will be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 3405 Walnut St., Camp Hill, PA 17011. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/04/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $ 11 Interest 06/04/2002 through 11/11/2002 6,213.77 (Plus $ 32.25 per diem thereafter) $ 5,192.25 Attorney's Fee $ 5 Late Charges ,810.69 NSF $ 207.16 Miscellaneous $ 40.00 Cost of Suit $ 1,000.00 Appraisal Fee $ 225.00 Title Search $ 125.00 $ 200.00 GRAND TOTAL $ 129,013.87 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs Sale. If the mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged based on work actually performed. 10. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular and certified mail. WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $129,013.87, together with interest at the rate of $32.25 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. TERRENCE J. MCCABE, SQUIRE Attorney for Plaintiff VERIFICATION The undersigned, Jennifer Mendoza, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, /?C?b ./v A AAn,.,.-f-_ and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. JrI'YER MENDOZA 263-015-002; 263-015-002-000F eft her, Mvi M ?vefN+ e Whm Rmr4od MW To; Dftdm ONhtmyeOM. LLC .Ranh DD?enum n Iw WOU Abm IM 1i1 Fm Ler,%q yyl C THn MRTC Aog t• MORTGAGE Lab bt.MebMM »so o? q?hu dft if wmwdwm c7+ea7 Mda3 k?p- iU hmmwci do= =f a 6 a1a e deemed www Comm MA 7 _ die lW p,,rl M*fk Pm d Many ? use my ry j?Ydua16°E pgk+9 ATrA m ?I?sMZ= W w ?« ?J-?'rgj101 ?hb:h hu me Mddtm p( ??12TJ PaT hmaSYbOda 17011 IauN Vii. 04 ?--(-ftgaO'Addrm9: nan p1gS?fA+gNb FMmiy.Iy.oi 1MWlay Hwe UAllpl6t LL'41kililT PMrn ]MM f9e J rre/ga+J IV, 1 ??? 263-OT5-00:: 263-015-002-001 F i r Kt. come. COM' vrMENT FOR TITLE IR ------------ URANCE SM12ULE a cowama Commitment Mo. PAMPSagos Legal Ducription ALL '0" CUMM place °a Of cl umihenberlandaw an and M stareae¦ Ofparotl of land, siteete is the Borough o= ?ylvamia, bounded and described am r lot, to ouaGY BBOXIMM at a point on the Weethsrc lies of feet Neat 4f the 8suthraat Melnet dGrat 150 faaG ride) One bnodred 8traaG turner of the interoactior of palm e street andda alas baleq to the dt"ditg lima batmen rota sr", 17 and is 4tIt tax NO. 16oa dl mentioned Plat of [steal Meese south , 81eok Me. 16 a diatonae of ow al as 31 ad r ood the 9t - dhepbood, thanes hundno by , wee Yi °) foot p1 to a N point at land oof the all"b of Oats! Y fi than"" w ha) feet to • poise at Oa t NO, 10 IMMIltar 44152`6416 87 mioatms Womb a diataen of 1170 by name Mouth 01 degree 33t"'i'Mom m the tence of am land Plan a y f feet to a point an the aoutlurn ¦ida of Vml Nest a dim mrtlry tveae straps North as d"ras z7 m+t dersetr phonon point, the Mace of BRMMMlMpmi, Butt dintames of sr.¦mty_five 17s) Cost beta REMO Lot No. 17. Block •o' on plan of part M Reardon Oaadeta, said plan begin recorded in the Cumparland OOUnt Y Ucarder of Deeds off Joe in P1sA 8eok 6. Papa ao. U MM T granted a oee story dre11109 leeosa pea as no. 3405 Insane gtraat. by D. P. AaffsASPargor. A.8.. Mavadoar 13, 1040. USMgR MM AND OU?.7iCi' and re in LAM to the 1 Hof a eortgaga given by Robert a. Aoaly, r- and 14W& F. Sweplay. big and rot Cumberland edge,bbztg*Wto ?? Company n dated October Pra0ala $22.440. i1969 2p. ft aymeaa to pay Principal mane, , AoY,coseiw coma, Slack 52A, a auoap?mid moem " nu ee 0"L u L. Ud Mee, .a. tr.a a w.a,r.....a .erwk. ¦ ¦tl a aa. as pee Chicago Title MMMAaoe Company 263-015-002:263-015-002-002F • , • wrim in a kpRObq now Oc - Few, AU of Am 11 PO 01 ft PVPWW. AS jWbagan MW alMdoft OW an W OW46mg 17 a& 410"Mom ad HORRpMpla (?pymyuW 'M* WtrArA=yd -ftogaW.• 9Ubm=1. mdvM ""S" r=q.dedderd6NapeO V" aunka xof A MOMW asael6ae=onlp? bwaaaa ?b Wltlasa atd Gdred L Z9rwtwRlrlpd adbmi jLrdrrn?sat?y+i!+ . ??10r1>tar ??°rOOytaeNeMrdayPa4?!'ataWlae?????aA4?dadiepeEorlp( w abe w'??ka4 ?+aiadaerakrdrNoe. gauq, Manna" + eqy a7erMlalsta w Jr.sdar demon ara ?erNor h? aGy, mw 4 Bw ° MSear ; (Ayatb> reap ma° :?6) IMaiaYlgmMr pwasrwk lm ?°l a i. In of dw ?°af ?Oa4aary. tr ?(tea"°e°"aal?aa ll Zly don. 1914M? low =4+b6 lbr r nx* de at b" rM& in a®? _rleate0bd "NOws0aaaa iadetr )UPor MAPAL WOO. Lamm + "Caft da,1 d p ?eeep?r woe da?1A ? a4 Thl Nuodt*Ababeylaq ?o6a?a ?+?+rettar=gaaaN?t« _ Need +w1T ae6at Larder sy I Wit MR ladwdeprpbi4atrb 0damai dwp No room hr 101 Loa Eea Lahr dol V* do Fn* °10 p, OWEINOW URM 40 as ° _?in, I IW M ChftsL oal by Under m,e o ke W y?m?tlbea?m IWOM ad Mao" Lab= dw tsar kW*b ,fewr?eillalwrp+Kvrp ab'4armcro? dagrdr. btiCto Pdd 06 60 PMdl6 LMWL Pak Fewb* dop, IM WW and C we dke1???oaaloiatliaad6*kwdePaka'amPO a M*dlheaDOnpna' sticb out Nax at am ft* or amad=e6 a6d dr 69 r?di?ilaaiY6. u4arhytwaaradtpj >oerr/ar b °°a aAldaoca _ 1talds amardbPlaade 001ft p9mm. 1eadlre p ?aQ yb ' er' ?q{'rfeOaYer WD Yrhrd6deyr?'larawadiateatlw 1'p= mm" in dd(ot+O=rtaaadby & Axa* pa * b da ea(al b tsndW & or" "OM,Ldadw ?r rge?am.aIW & i. 6e4wkki6a 6r J& r aaedle Mdaa rk 6aw aecmari ad x ehepy °aP9UM& fiq4 0 ?my MOPWOM tl ?Direbia b ?mrWM odd eLL bJ' db ftrd4 a,L ? Low dam *LM y&M ad bM, q bay"IcckwpwrdaWderrdie1?ou ANOM igtblraa p ? x Olin Ooft ebre Offodd M 1nmaow dic "a4, 10*9rar l "pbmu a?i ?Mdar+aAMelie w de gepeap . ad ><taaaa?araeba Own Pont P"M.3M6wrihrd 2GmlWawl?6a p OfDOO *Wm**wOftupw dkt* a? db*W a?'naWdaap°?Sgd?blvdRr a° be PW by. r ddzft fir) of do Eby da llr re +a9 ? ` AMde"ua e "humou at de ua: or (e)aanaana6Sodaat? eaue?oa.e_rwon a 'P'I0q° aP99"de 0' e6e. Leodr dp0''Ne Han°a aOurta??'rwervis *=see Hmvm* 1br14'", am alasacfiminrawabraAk10dryrrdr>dabi6faidrr. ?Mbaexaorrlawr 000130 (1177) llva 747! 7176 Ow7 i/+)' m) 263-015-002: 2637015-002-003F dall Waom am Ingsaw tlYtmbosbaadkraautelaameP7gtlry bMW ROOM INA by Am Laude NdWWwh Mofo{. ar Wild LaBhr 0a"W" Ed aqY alherLmdl, ucbdlp? Geoda m ' 71te 1omtMOOa 1o<aime ad is odic" Is die domt sad larch paioda an L= ft be dMM by owns" wlddrld. R Batossec 61, in btmm4 wimp 1"cow Dr10 aws, Loft Am. At aadoe''tLlot ka ds IbkYr ddptt h W IiopplY le tlea?daoee whh ynrpr?47. ? alma. ahttle AN WWWO Lars on d* 10=1MIl areeNdatammis. a?hismiredaod>baneacpdeae*giveApla ft rw.lipaOtP? Pia m Imma1 no". Is do aemt of 1oa, ) ? ? w* Ida jj give bm m card n LAAd d Lander airy mb poWatLaa Umt M& peoM?r 49 Baaoaat. P aliw a em easier ad Leach. ftwM 6war",umanaaadoearw%*u mtsaico , ksraermeRmisess * in rdmwp? K dde repetr amt 00 dbMbk m okibiwig aatlrAd giLenaloatiam OM" V dth ? h168010 rs. ?aor Am ?Lv egad,MLmamxPamdtArGMippbdlodteor POM, or dam sat aoewra wLhb Wd"jaed=bwL4O Wrier bw atle darida by dia> ?a,hedia or oft 9" a ]w M PabdremwilN?tarlLgpawbw Asthrmttoeada po Rbp?m1tlQYad ILds Laada ad lmowm mdaf'M?, P"M ibe dmeatiLe omiYb P4eata wdwta?d a h rq Vj ' of "1010 b ps?d tldt sot a PP so on FjqMv pdw WAPEO 21 die Ptapsty Is 1010120d by Laodw, Bamwar'a Lw ? sa r MaQ &m dope ?yRbtmetl ate 1? b Leader m lLe gpataJtlrotooia?LyiYaipmtyL?wMlqlddeq? t s. QecrpaaeP, MwilSiao[eAndPratalloadtba Lmvftw * mid n? a ssanowrraprlsefpd0aewyoaa.wLhYduy? ?amdeead 6b Boca he do of aeospmq, wf=IMIs. &a rw6e?laP?tlBOAMOO6 LP*NWMNW Mara Leiaaaeyosradef o wttlop; wLlri aearea aLdl as It 10948008" wytrd4 or vaba ?baaAMaetb aah rddtl b.;A -M - ..._.. ?W_ maWiaeat. IM Mt dia R Ma doatlaees mraap a Cott m " mbeaw wiy aquivalmt mat me4aatd7l of do y" wwr be is dw. tamw w® Maw ftvmb MAY 10 WW ben* dua Lmvkr mgwm) is mal b CMD a1R 01971 moR. Lose mum t and hr dia paw Ba nwa"pay fft-3619 M Maeld6pyrrl 263-01'5-002: 263-015-002-004F ea& a"WftdooooAu wEm1a? Y N/ke, ai 10loa?ge ammo trove, ma AA "*me t sz mrwp !• lmdpo2l . Lmaer of tar OW rrdeodmrdmrW dsdldmerappairabielaw. Mob! lbrtowQ amm a the 'mater r? and mtpatlab dmdAapmry. Lm krAedl are 7d. > se°?wM?aememisemmtbrmeh;aedm, t amdmmadm. Tb pmeeeda d ay 8"d or shim tier dWMM dbem w medowAdm or amm algw of Awpmdmelimpemy.armrmaegbmYlYad aome4mrhl.mNawimwlmEW 00 bepddmLmdw- w ms +dprdw vheYU oe gr4m " at Ind ? or16e fmprq, tN,"a k WRd m ie mm smiM by ddl lamft yoemmw balm tore Of me dm ift mW dltemapW aaOmraC.YdamdbdfapemdMAIofdmliopmyis.hichdohN w kook Wa mmr Pa4' meuquphe4udbarpaarmrmeeematetdww babedbydrh hwmmIy bePoae me tddep taler lmeoam and Lbdm ammwdm Nr! in waltlo& dm bar by SecYy laaaameat tell be mdood N attar ara......,_ am= aw w If award or L.wa Y ae .. N dm ?itmo-inr lauw? AN" mme.wmat. :rlmielY,ear,?eiYpe hm°r ombKYg at bomb* me de ukkg r Ym mm mo emeor d evclmd I rypb bah a ft Wq Wm lM&qQawIw ?itarA?meat ?m?i?ml?.mrMmmL?M?Osdmmr t0 Y AN&W y-em.es.artr.dllmmmo at dmbylabrblgrMSeemnl6o aeddrelYra?arlosrNN rim ? dholalm, 1m:wer ha m mrpmd bLetlawiiYfOdgedlmmedretlmmdpY?vapptv M&PINOW16 at hl m g , Raft ?Um du .,. ram,dMmblammmldaar depabdtN lioper4f atbtha mom Win d tmdmdoeddmemomYlypgmaeeMftmdbY ~• rtlradfy?omedrbpdeck dollmlammdorposom }m rVU 1 md%m *=pin drama %t m* EnKtwwm U. agrtwoer Nm 7YMdmk iarI , Ift l"dwIm a Wwivw. smom a of dw dare ter yqma 4w aw adman ormr small mama by mr boa ft mmmm omYd b Lamwb mg mdbbm it immea ataYRawardeda as tdaaee me fairy a ibd eddW sadbwe rleommrke mmmmn Y mtmm. Ladwdbm art be regoYd m dme+mor mmnd acaarermmRaaootnhmYmumddmrbrj gmssaralimw- mryemmWrm by J w* bautwaot by mma d mw dm nd d by mearym: laoorrdr,momm'a aormmyr by Lbw 6 .emmia?marl?dorspdNr6raa4nmororpwdmaame !s trtewmotr dad Aatym sooty Are mrd enrol U&Mk + C&dpmd. Tae bembm w mpwbbm ard* emmiq mmmmt dwA bad w bmft dr mmomm w amAm of Lmww 1lorbw- .Aram b elm pmdAlm or dmmmmlm me rwiore W h Ad N idw w W ARIL Any somowm oft co rym min Tazft lmawem abut &M rm ftroweNa bdm m dw Pmpmgmdmdlsoms I'tawoa Wmar -30 m mcmW by dd aaoalp Lomabm: nape dwm ma r.rdmmyYdamm?wbr grm+. iffier a0 tw Imodbandormratomtrmoipmettnmeaarmeltaawbhomtbat7abwmsmmmL L Lau lCkmWL ay b Yeemaredaamd an low IS f7sat4y bymhedbtlgbKd Is b aYr trelobommblmam Jam dbigea, w rymdd m madmmrm oroberleft dbm aamm wwbemGawhmmwdm%F gwbm avmw me e6dmdIWy,dm W miimdamperrN.aduoadlbyymarwemtmmadr? dmWiDgm UMMed ram , AM. w (b) qy mart dhow amod from tamowm warm mm&bd 1r?pN ens N eMmded b b saMMIfIfm mrmomy'daftdmprrdpdawsdwtlm4mMmesbmb6gadmpgmer amrmdM & RwPd.dr'dmWmwMTm, Yapm pjgpWm widmmWpmplymrta®r by rot dbee mm wig m b br tamr Sebdpr m?umdmt mm b arm l>y dellraYe b cr by and ftjg . ow amen addmw emowa law mtpdrr oK ardaadmr memad. rbeeatlaa rode b.draaed b w hwpm tldd m « ardor mom bmem or dripem by moat b Lbw. Aq Ndad b Laaderdre bw ihm by 14m dm m& to Ltjmws ldrfemb!'mip mamoneotdNGbedeetoa ahasbmgradtolaaaorrm Lmft Omma. appA & look m bll drh to 7e. Corral LAM dimdedbpy.7lm Seca* mmagwm ram b. poamgdly tbdmi i.w am A?lpr ardb jmWlmloa wbri me Pmpeglabawd rd OreamimagPeevgimftdb efdk%ha hwuumue«maNamComO=vu ppoddd rw. roar om01a mm w aa ammbgammpaovldNrd dog tyrauamamermeNaeNddlewsbedremaAba deldy rdaldoa. TO tbh and dm p m of tW ririob of Sum* 11 110 add and Nam dm dmfmd b N 146. sarrowar4 Copy 11mmdtm yprva am coo rod rapt ofdw Mom and of *b ?g lam, 17.llrfi rordujh ulpwo ov&ldb*Kbdblmmwdr. sold ILmac ?Aanefma or mmarmd for If a bwmReLl harm in emwaw r old ae amdozed w BeAawdr r ga d p roolwilurhmhi OWNW. Lama any, a tia apra, ngrma lmemm pdyaem m art! dm aoq tammd>q ow Seauky mammm•yprydyQ Smmiq bmmmm. °p10O abm NO N eaadaed by Lwder uamdaa r pml d by dedwr rw m of and oboe or,Ob am oilo (itr7) •ms lb!!r!e 6w Jf dpye+) 263-01'5-002; 263-015-002-005F • ,as *m 30 awn aeo+b h aa -- Rdum, ? u ? a" k PRUMW by d* SO=- - AL bo6vwmo@ for hvl w ers IM* WWWN- buy ofafa.q ' bo naidd be duet ,-? Mom" saft". my 4fiaire a typo * 80 amdw* wa&we fs ?,,?ssa_.,r 4f ? cry, R v=oo sw be am amO as sues n8emcco an as Gm `' ? oa it In ? dw Propov of am am ad b wwokvmm a o u nrwova ?s 1 d au as nod in ob ff moo p0/? I+a bawd i AN =Peso boom mu am mm as or Or aLam M71R. 7k Nall or a Paid do oft *a RM ?R?Qldwm? It adaw<.. 14 0 Pealoat Ladery. saris aq)r paths Ra?ali Meareridy a9 ? h Wow, aswed 1rwr W i+m Laaatrao ?ma aN1i? are. Ob) raw aq *of* of SW COW wwomm oRIDM w?Mof IbliNd IN "homir MWARd °k rM=tdb dwA . s?1TYdaearpaw?odw Way ?Olomw Maus dwo aAeaty7( Y deftbolooL Thop-, ow be or know and _-r,•-•••asaoaaade•7lnswim wpdp my "Or or PM* I+moRwdw aw * w rdz= as ?p1aaa' aaalaa er,efaaaaf? IF airaa of OW. Nstlaa s?aaRMe ducat aaRaas"at V* ft p?eae,n?a!a PpPO?? ieaeer SY>tiaakeoadovap wpatai miwae ado ac - aupatama,,? i k 'Rule am an Mwalcmilk R?harl palluo 20 TW&om -m t??. `m ' wft a H=W=sfu6aar, OrG*wr> Al*WbyaW datapsgd.eo,saq.Doaoaar mmdv'k. ? WANDIMO eesw.a a IV now $*mam= IV iaabaaaaa kr®malAea<ama`paoygWOdatoS+oa e StAs um in 3I. ""tOrroasraed Lodw landrbMIM fakesad On Idow ww..after- 1a ' 7a war.rdf .ayeap aa4aw.aaa.d%Mlbh e x twelcoft ow kh ysPt Al ian baU ? mew wwasom4wallm ?drOllaaiebrab!°al°A""'rhraptao? Lftdw ? ?blt carat kaewdlndfaA 'fi°rfaW.. ?a?ja P" rodiondi aagriai `t ?O dMtteaaidiaMr oslae.aetlb.,v, a" do +aiaarm a mK 49 Iortrsab? k ?Lowerat Maa,rmr?OWWW°fBoff w004eodRwaaadMwore kubM# e opomabcorv" WMiaNa ?Fo0>?raWed, YM ab+eyad a6a11 re P?t of ON pw sad b' "MumbY 21' ?• bat mat Now 2323. woksas ysywya p ? pq opY aaosdadw Lmdc ftU d? ad wiry Ab seer dq+mdtraamn am* a,"k am a"2 tlio? mbasaasala haft "?"Offielraefkof bdwwed "low my sm3r orb R RNuaataM- rjmLAny andakaed Pra?°r NsvNatbraagef MMMUMMMI o(riddrq a1 a lhWfr sd or? nk vivy" in a4dt aarmd a pa bdd ate r Y a..,, %a* am boa mow m m. L.awaaadaa ? aw n Yoaarerr s hula aak s UkD 0150 0193) Prts3aw fm 0005afQoft 263-0 f5-002: 263-015-002-006F • 1• ie 27. ? to V* m aedo?m Wbg aftva?me'?'1?d%meecramftdoe 8etlaroe. da • H aee ar mae dd m Nave. so "Veauft ad "Em" =* ddor hmmemm ft+tWwasa pw of ° ft iImft be.. . iamd*mr ??'? Roe R1der O ? Rlm Orm'd ??9wtmt R1dte ? li Pads Rye ? OOtbwm(w"m ORMbwavommt Rhla Osww mxww Rldee BY amm m d wo mated 1p °?r+?m ft" .= ?W" m be rams and Ovum= aomdaed m mk daad9 bmemmM and Ia ?FIwE.?l rte n-- _ R!'?e•dv-'Ah 1Lv om>bm.to MY Co=w im &O km L do of , "i No me rumae.od.dmo. 0'. J became e,t,ep, bmd.od? omold0,,,,,> r1f7. be(om me, me UWWrjamd Dom) to be the pamm apm Mmewowwne % - - lam 31" *m ywpd4r6pgeq i r? ? a I Pa, w w -c? _ f. y. l P- U SHERIFF'S RETURN - REGULAR CASE NO: 2002-05526 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK N A VS BICKHART FAY I KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BICKHART FAY DEFENDANT , at 1720:00 HOURS at 3405 WALNUT ST CAMP HILL, PA 17011 FAY I BICKHART the on the 15th day of November , 2002 by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before m?-ey this o7,2,to day of A.D. aPa,r -Prothonotary' So Answers: ®`r"! R. Thomas Kline 11/18/2002 MCCABE WEISBERG CONWAY By. ?)atUVi A *L Deputy Sheriff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary To: Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 Citibank, N.A., as Trustee V. Cumberland County Court of Common Pleas Fay I. Bickhart Number 02-5526 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default - Money Judgment - Judgment in Replevin - Judgment for Possession Curt Long Prothonotary If you have any questions concerning this Judgment, please call Terrence J. McCabe Esquire at 12151790-1010 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Fay I. Bickhart Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-5526 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 11/12/2002-12/30/2002 $129,013.87 $ 1,548.00 TOTAL AND NOW, this o7'Lday of J aA--) $130561 87 TERRENCE J. cCABE, ESQUIRE , 2003, Judgment is entered in favor of Plaintiff, Citibank, N.A., as Trustee, and against Defendant, Fay I. Bickhart, and damages are assessed in the amount of $130,561.87, plus interest and costs. BY THE PROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Fay I. Bickhart Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-5526 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Fay I. Bickhart, is over eighteen (18) years of age and resides at 3405 Walnut ST., Camp Hill, PA 17011. SWORN TO AND SUBSCRIBED BEFORE ME THIa !DAY OF 2002. Notary Public ?f TERRENCE J. cCABE, ESQUIRE Attorney for Plaintiff ip, f h HOLac1K, Nab i of Philadelphia 1'hlle. r ?ibtk i C McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Fay I. Bickhart Attorney for Plaintiff Cumberland County Court of Common Pleas Number 02-5526 Civil Term CERTIFICATION Terrence J. McCabe, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN TO AND SUBSCRIBED BEFORE ME THIS36 DAY OF IoAbxj? , 2002. TERRENCE J. M ABE, ESQUIRE Attorney for Plaintiff NOTARY PUBLIC HOLACIK, NotEq - o! Philadelphia Phil, C( Pubtic C- oti! a ,a Exoirt M? 28 1 ?i VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. TERRENCE J. cCABE, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary To: Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 Citibank, N.A., as Trustee vs. Fay I. Bickhart December 10, 2002 Cumberland County Court of Common Pleas Number 02-5526 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice , a judgment maybe entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 TJM/cc NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado por escrito con este Tribunal sus defenses u objeciones a los reclamos formulados en contra suyo. Al no tomar la accion debida dentro de diez (10) dies de la fecha de esta notificacion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o ]lame por telefono a la ofcina, nombrada para averiguar si puede conseguir asistencia legal. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 :x,. M 1 c 71 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 02-5526 Civil Term Citibank, N.A., as Trustee AMOUNT DUE: $130,561.87 V. INTEREST: from 12/31/02-6/11/03 Fay I. Bickhart $3,476.52 at 21.46 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 3405 Walnut ST., Camp Hill, PA 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. March 3, 2003 h DATE: Signature: Print Name: TERRE CE McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Walnut Street (50 feet wide) one hundred (100) feet West of the Southwest corner of the intersection of Walnut Street and 341h Street also being at the dividing line between Lots Nos. 17 and 16, Block "G", on hereinafter mentioned plan of lots; thence South 01 degree 33 minutes East along Lot No. 16 a distance of one hundred twenty (120) feet to a point at land of the Church of the Good Shepard; thence by same South 88 degrees 27 minutes West a distance of seventy-five (75) feet to a point at Lot No. 18 on the hereinafter mentioned plan of lots; thence by same North 01 degree 33 minutes West a distance of one hundred twenty (120) feet to a point on the Southern side of Walnut Street; thence along Walnut Street North 88 degrees 27 minutes East a distance of seventy-five (75) feet to a point, the place of beginning. BEING Lot No. 17, Block "G" on plan of part of Hampden Gardens, said plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, Page 30. HAVING thereon erected a one-story dwelling house known as 3405 Walnut Street. UNDER AND SUBJECT NEVERTHELESS, to the lien of a mortgage given by Robert H. Rowley, Jr. and Linda F. Rowley, his wife, to Clarke Mortgage Company dated October 15, 1969 and recorded in Cumberland County Mortgage Book 518, Page 852 to secure $23,400. The present principal balance is $21,655.29. Grantee hereby assumes said mortgage and agrees to pay the same according to the terms and conditions thereof. TITLE TO SAID PREMISES IS VESTED IN Fay I. Bickhart, Deed from Robert H. Rowley and Mary Lou Rowley, his wife, dated October 15, 1973, recorded July 16, 1974, in Deed Book R-25, Page 993. BEING known as 3405 Walnut ST., Camp Hill, PA 17011 . TAX MAP PARCEL NUMBER: 01-21-0273-237 X) w a 4 ? of "PSI ? ? p O w 4 MJ 1 h 1 ? n McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Fay I. Bickhart Number 02-5526 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3405 Walnut ST., Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Commonwealth of Pa, School Employees Retirement Fund Being Searched Beneficial Mortgage Corp 100 Business Center Drive Route 22 Ste 202 Brewster, NY 10509 and 961 Weigel Drive P.O. Box 8604 Elmhurst, Il 60126 Chase Manhattan Mortgage Corp 343 Thornhall St Edison, NJ 08837 Banc One, N.A 825 Tech Center Drive Gahanna, OH 43230 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants(s)/Occupant(s) Address 3405 Walnut ST. Camp Hill, PA 17011 Domestic Relations Commonwealth of Pa Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. March 3, 2003 DATE TERREN E J. MCCABE, ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Walnut Street (50 feet wide) one hundred (100) feet West of the Southwest comer of the intersection of Walnut Street and 34m Street also being at the dividing line between Lots Nos. 17 and 16, Block "G", on hereinafter mentioned plan of lots; thence South 01 degree 33 minutes East along Lot No. 16 a distance of one hundred twenty (120) feet to a point at land of the Church of the Good Shepard; thence by same South 88 degrees 27 minutes West a distance of seventy-five (75) feet to a point at Lot No. 18 on the hereinafter mentioned plan of lots; thence by same North 01 degree 33 minutes West a distance of one hundred twenty (120) feet to a point on the Southern side of Walnut Street; thence along Walnut Street North 88 degrees 27 minutes East a distance of seventy-five (75) feet to a point, the place of beginning. BEING Lot No. 17, Block "G" on plan of part of Hampden Gardens, said plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, Page 30. HAVING thereon erected a one-story dwelling- house known as 3405 Walnut Street. UNDER AND SUBJECT NEVERTHELESS, to the lien of a mortgage given by Robert H. Rowley, Jr. and Linda F. Rowley, his wife, to Clarke Mortgage Company dated October 15, 1969 and recorded in Cumberland County Mortgage Book 518, Page 852 to secure $23,400. The present principal balance is $21,655.29. Grantee hereby assumes said mortgage and agrees to pay the same according to the terms and conditions thereof. TITLE TO SAID PREMISES IS VESTED IN Fay I. Bickhart, Deed from Robert H. Rowley and Mary Lou Rowley, his wife, dated October 15, 1973, recorded July 16, 1974, in Deed Book R-25, Page 993. BEING known as 3405 Walnut ST., Camp Hill, PA 17011 . TAX MAP PARCEL NUMBER: 01-21-0273-237 EXHIR ?r 99WI J - ; ?fe ti cl .. -? tz) McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Fay I. Bickhart Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5526 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 Your house (real estate) at 3405 Walnut ST., Camp Hill, PA 17011, more fully described as attached) is scheduled to be sold at Sheriff's Sale on JUNE 11, 2003, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $130,561.87 obtained by Citibank, N.A., as Trustee against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Citibank, N.A., as Trustee the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 the following notice 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 C .,,?, ., ? _ ? ??. ;? f- ; } y ? _ :? _ tJ-'t'- -- %-t'" _ ? -- . 4 -.J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5526 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK, N.A., AS TRUSTEE, Plaintiff (s) From FAY I. BICHART (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $130,561.87 L.L. $.50 Interest FROM 12/31/02 - 6/11/03 $3,476.52 AT 2 1.46 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $120.35 Other Costs Plaintiff Paid Date: MARCH 7, 2003 CURTIS R. LONG Prothonota (Seal) Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 XcCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Fay I. Bickhart Number 02-5526 Civil Term AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 22nd DAY OF APRIL, 2003, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." TE RENCE J McCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 22nd DAY OF AP IL 2003. NOTAR P IM) NO-fAR1AL SEAL WrA T. WATTS, Notary Pabfc ICI d phHadellhia, Phila -MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Fay I. Bickhart Number 02-5526 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3405 Walnut ST., Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Commonwealth of Pa, School Employees Retirement Fund 3405 Walnut.Street Camp Hill, Pa Beneficial Mortgage Corp 100 Business Center Drive Route 22 Ste 202 Brewster, NY 10509 and 961 Weigel Drive P.O. Box 8604 Elmhurst, 11 60126 Chase Manhattan Mortgage Corp 343 Thornhall St Edison, NJ 08837 Banc One, N.A 825 Tech Center Drive Gahanna, OH 43230 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants(s)/Occupant(s) Domestic Relations Commonwealth of Pa Address 3405 Walnut ST. Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. April 22, 2003 TERRENCE . McCABE, ESQUIRE Attorney for Plaintiff DATE •MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee V. Fay I. Bickhart DATE: April 22, 2003 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5526 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Fay I. Bickhart PROPERTY: 3405 Walnut ST., Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff Is Sale on JUNE 11, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. b a a O ?U °a .aa y W V ! +_ I $ a * 'p W0 LL er p Q? b v o .IP N N ? o ? U m ! 1 r ? U ? m LL UO (D CL 'V 4 Q 7f El I 8 g i NO On a e; = N m?Ny a m .? foe At a8 ? Ll mm e^? CO ' 4 E c ? ? ?' M ccc , E5o Q? gm3 co 12 m d =V a t CC E E'm'a l0 m ° ° ? v O ? a$o[p ? m w ? ? E? E g a Ea ao ` 6 Nt s g?aNE 'O El m c r a C a, m ° p ° a m ?Q I?'? -- o al m .O Q 1 PEW O a y s Q 1100D m U ? ? U p $ m E Z ? O m F E C3 I 2 o O m g c UUpID Q W m j 130000 m a° { m m F w 16 O a W y.?.aCA E >a N z' a Ev z> Roz i a0a N N Q € 0 U + O m a { .0 JO) ma Z 1 i 'i7u a) 3 w m Q O V 0 0 C> N h Q ti r! Cl) " - i ... r r C77 ? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citibank N A Tr is the grantee the same having been sold to said grantee on the 9th day of July A.D., 2003, under and by virtue of a writ Execution issued on the 7th day of March, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 5526, at the suit of Citibank N A Tr against Fay I Bickhart is duly recorded in Sheriff's Deed Book No. 258, Page 3531. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this / K day of A.D. 2003 Recorder of Deeds ftomW Of 0002?0?wnb~ T=. COW PA my owaftsim #* PQ dJNL2= Citibank, N.A., as Trustee In The Court of Common Pleas of VS Cumberland County, Pennsylvania Fay I. Bickhart Writ No. 2002-5526 Civil Term Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 12, 2003 at 7:55 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Fay I. Bickhart, by making known unto Fay Bickhart, personally, at 3405 Walnut Street, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 08, 2003 at 5:37 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Fay I. Bickhart located at 3405 Walnut Street, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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: Fay I. Bickhart, by regular mail to her last known address of 3405 Walnut Street, Camp Hill, PA 17011. This letter was mailed under the date of April 04, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on July 9, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Terrence McCabe for Citibank, N.A., as Trustee. It being the highest bid and best price received for the same, Citibank, N.A., as Trustee of 10790 Rancho Bernardo Road, San Diego, CA 92127, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $883.62. Sheriffs Costs Docketing $30.00 Poundage 17.33 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.70 Postpone Sale 20.00 Levy 15.00 Surcharge 20.00 Law Journal 335.15 Patriot News 263.20 Share of Bills 25.24 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 883.62 Sworn and subscribed to before me Sowgs. This .L?.t day of R. Thomas Kline, Sheriff 2003, A.D. Q. r ? I rothonotary BY?_, Real Estat Deputy 236 . Cro cQ''`d Y3 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQ`.TIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Citibank, N.A., as Trustee Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS V. Fay I. Bickhart Number 02-5526 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3405 Walnut ST., Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Fay I. Bickhart 3405 Walnut ST. Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein. 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. Commonwealth of Pa, School Employees Retirement Fund Being Searched Beneficial Mortgage Corp 100 Business Center Drive Route 22 Ste 202 Brewster, NY 10509 and 961 Weigel Drive P.O. Box 8604 Elmhurst, Il 60126 Chase Manhattan Mortgage Corp 343 Thornhall St Edison, NJ 08837 Banc One, N.A 825 Tech Center Drive Gahanna, OH 43230 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants(s)/Occupant(s) Domestic Relations Commonwealth of Pa Address 3405 Walnut ST. Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. March 3, 2003 J IA q TERRE E J. McCABE, ESQUIRE Attorney for Plaintiff DATE ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Walnut Street (50 feet wide) one hundred (100) feet West of the Southwest comer of the intersection of Walnut Street and 34& Street also being at the dividing line between Lots Nos. 17 and 16, Block "G", on hereinafter mentioned plan of lots; thence South 01 degree 33 minutes East along Lot No. 16 a distance of one hundred twenty ( 120) feet to a point at land of the Church of the Good Shepard; thence by same South 88 degrees 27 minutes West a distance of seventy-five (75) feet to a point at Lot No. 18 on the hereinafter mentioned plan of lots; thence by same North 01 degree 33 minutes West a distance of one hundred twenty (120) feet to a point on the Southern side of Walnut Street; thence along Walnut Street North 88 degrees 27 minutes East a distance of seventy-five (75) feet to a point, the place of beginning. BEING Lot No. 17, Block "G" on plan of part of Hampden Gardens, said plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, Page 30. HAVING thereon erected a one-story dwelling house known as 3405 Walnut Street. UNDER AND SUBJECT NEVERTHELESS, to the lien of a mortgage given by Robert H. Rowley, Jr. and Linda F. Rowley, his wife, to Clarke Mortgage Company dated October 15, 1969 and recorded in Cumberland County Mortgage Book 518, Page 852 to secure $23,400. The present principal balance is $21,655.29. Grantee hereby assumes said mortgage and agrees to pay the same according to the terms and conditions thereof. TITLE TO SAID PREMISES IS VESTED IN Fay I. Bickhart, Deed from Robert H. Rowley and Mary Lou Rowley, his wife, dated October 15, 1973, recorded July 16, 1974, in Deed Book R-25, Page 993. BEING known as 3405 Walnut ST., Camp Hill, PA 17011 . TAX MAP PARCEL NUMBER: 01-21-0273-237 EXHIBIT `A' ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Walnut Street (50 feet wide) one hundred (100) feet West of the Southwest corner of the intersection of Walnut Street and 3411 Street also being at the dividing line between Lots Nos. 17 and 16, Block "G", on hereinafter mentioned plan of lots; thence South 01 degree 33 minutes East along Lot No. 16 a distance of one hundred twenty (120) feet to a point at land of the Church of the Good Shepard; thence by same South 88 degrees 27 minutes West a distance of seventy-five (75) feet to a point at Lot No. 18 on the hereinafter mentioned plan of lots; thence by same North 01 degree 33 minutes West a distance of one hundred twenty (120) feet to a point on the Southern side of Walnut Street; thence along Walnut Street North 88 degrees 27 minutes East a distance of seventy-five (75) feet to a point, the place of beginning. BEING Lot No. 17, Block "G" on plan of part of Hampden Gardens, said plan being recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, Page 30. HAVING thereon erected a one-story dwelling. house known as 3405 Walnut Street. UNDER AND SUBJECT NEVERTHELESS, to the lien of a mortgage given by Robert H. Rowley, Jr. and Linda F. Rowley, his wife, to Clarke Mortgage Company dated October 15, 1969 and recorded in Cumberland County Mortgage Book 518, Page 852 to secure $23,400. The present principal balance is $21,655.29. Grantee hereby assumes said mortgage and agrees to pay the same according to the terms and conditions thereof. TITLE TO SAID PREMISES IS VESTED IN Fay I. Bickhart, Deed from Robert H. Rowley and Mary Lou Rowley, his wife, dated October 15, 1973, recorded July 16, 1974, in Deed Book R-25, Page 993. BEING known as 3405 Walnut ST., Camp Hill, PA 17011. TAX MAP PARCEL NUMBER: 01-21-0273-237 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5526 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK, N.A., AS TRUSTEE, Plaintiff (s) From FAY I. BICHART (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $130,561.87 L.L. $.50 Interest FROM 12/31/02 - 6/11/03 $3,476.52 AT 2 1.46 PER DIEM Atty's Comm % Due Prothy $1.00 Atty Paid $120.35 Other Costs Plaintiff Paid Date: MARCH 7, 2003 CURTIS R. LONG Prothonot ry (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) as JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of April and the 6th day(s) of May 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ..........................COPY Sworn to and subs me 14th day of M 20S A L E #38 Notari/ Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County f ? "Oe My Commission Expires June 6,2006 NOTARY PUBLIC Membar, Pennsylvania Associatbn Of Notarllly commission expires June 6, 2006 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 $ 261.45 Probating same Notary Fee(s) $ 1.75 Total $ 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... AIN pu?'ccoaq of ail ALL 9 Zyo Gmp t?l "C?mb #A fetle+n m ? W of anddat °3 at a Pow m t 3 jiAmd poi (SD (to of ft Ne& O of 1 > a beleg *t divi?nn? 00 io? od 6 ? ot o e doom pteal , Of 110K , , Lt po. l6 a of the C?+ 'Coo fell to a pow me 90 4 g 21 MWO " IA WaISO, feet to a pow A W'. ? fiva t ;M*' j IWeal a of ej't?2a tD *XW aim of of `i?ma ?ieaEsrka *01% five to s Pp1 . of ovem" Of bt#nO* p't1 as of DOW$ Of CMWY 10, die 11tH of a W0>t Strut COP 0 kOV" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND :- ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 25, MAY 2, 9, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. WORN TO AND SUBSCRIBED before me this 9 day of MAY, 2003_ L013 E. RM Cache's M <.k my Ca mvWm E*w @Avch 5, REAL ESTATE BALE NO. 98 Writ No. 2002-5526 Civil Citibank, N.A., as Trustee VS. Fay I. Bickhart Atty.: Terrence McCabe ALL THAT CERTAIN piece or par- cel of land, situate in the Borough of Camp Hill, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Southern line of Walnut Street (50 feet wide) one hundred (100) feet West of the Southwest corner of the intersection of Walnut Street and 34th Street also being at the divid- ing line between Lots Nos. 17 and 16, Block "G", on hereinafter men- tioned plan of lots: thence South 01 degree 33 minutes East along Lot No. 16 a distance of one hundred twenty (120) feet to a point at land of the Church of the Good Shepard; thence by same South 88 degrees 27 minutes West a distance of seventy-five (75) feet to a point at Lot No. 18 on the hereinafter men- tioned plan of lots: thence by same North 01 degree 33 minutes West a distance of one hundred twenty (120) feet to a point on the South- ern side of Walnut Street; thence along Walnut Street North 88 de- grees 27 minutes East a distance of seventy-five (75) feet to a point, the place of beginning. BEING Lot No. 17, Block "G" on plan of part of Hampden Gardens, said plan being recorded in the Cum- berland County Recorder of Deeds Office in Plan Book 6. Page 30. HAVING thereon erected a one- story dwelling house known as 3405 Walnut Street. UNDER AND SUBJECT NEVER- THELESS, to the lien of a mortgage given by Robert H. Rowley, Jr. and Linda F. Rowley, his wife. to Clarke Mortgage Company dated October 15, 1969 and recorded in Cumberland County Mortgage Book 518, Page 852 to secure $23.400. The present prin- cipal balance is $21,655.29. Grant- ee hereby assumes said mortgage and agrees to pay the same accord- ing to the terms and conditions thereof. TITLE TO SAID PREMISES IS VESTED IN Fay I. Bickhart, Deed from Robert H. Rowley and Mary Lou Rowley, his wife. dated Octo- ber 15. 1973, recorded July 16, 1974, in Deed Book R-25. Page 993. BEING known as 3405 Walnut St., Camp Hill, PA 17011. TAX MAP PARCEL NUMBER: 01-21-0273-237.