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Home My WebLink About00-03261 J~ - ~, 1I0,vtEOWNER'S NAi'vIE(S): Ko..ren Pease- 4;<'0 N. 02/5.1" S-tYee-t- ~a.rnphill, Pa,. nOli 'l?5-115i''3''?Of YY're.daJI ion Mt?:, f'n, CraiN) 80J1)( ,,5.8, PROPERTY ADDRESS: LOAN ACCT. NO,: ORICINAL LENDER: Cl'RRE:>iT LE:>iDERlSERYtCER: HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR l'IOME FROM FORECLOSURE AND I-lfo:LP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT 01' 1983 (TlIE "ACT'), YOU MAY DE 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 ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. ( TEMPORARY S1' A Y OF FORECLOSURE -- Under the Act, you are entitled to a temporury stay of toreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice, THIS Mfo:ETING MUST OCCUR WITHIN T~m Nfo:XT GO) DA YS. If- YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR tvlORTGAGE 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 AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days ai'ter the date of this mceting. ~ames adclressUillld.Jilir.hone nUll1ncrs ill: dcsiClli,!kll.(;OI'Stllller crcdit c<ltlllScli<lc agcncics lor the ct1unlV in which Ihe propertv is locatcd are set torth at the end of this Notice. It is only necessary to schedule one fuce-to-t:1ce meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSlSTANCF.-- Your mortg(lge is in default tor the re(lsons set forth later in this Notice (see followin!:! pages for specific information (lbout the nature ofy:our def(lult.) If you have tried and are un.lble to resolve this problem with the lender, you have the nght to apply for financial as,sistance from the Homeowner's Emergency Mortgage Assistance Progr(lm. To do so, you must till out, sign and file a completed Homeowner's Emergency Assistance PrO(FUffi Application with one of the designated consumer credit counseling agencies listed at the end ot this Notice. Only consumer credit counseling a~encies have applications for the program and they will assist you in submitting a complete applicatIOn to the Pennsylvania Housin[l Finance Agency. Your application MUST be tiled or postmarked within thirty (30) days of your tace- to-tllce meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU . DO NOT fOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMl\IEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL IlE DENIED. , Page 2 of 5 EXHIBIT A ". -"'- -' s. ~~ AGENCY ACTION - Avaibble funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision aller it receives your application. During that time, no foredosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION .PURPOSES ONL Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO . COLLECT TI-IE DEBT. (If you have med b~nkruptcy you can still apply for Emergency Mortgage Assistance.) BOW TO CURF:'YOUR MORTGAGE DEFAULT (Brin~ it lip to date). IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for th~ following months and the followin amounts are now ast due: JJ. Jl. 73/' CL ber -II' 73 ,<D. 207JiJ - ~ 'fl. Other charges (explain/itemize): et1-r . Pees - " 6'7, {gl I tt.te.. Fees ~5. {gU TOTAL AMOUNT PAST DUE: ;$ I 4-.~7 . 'ij.1 ~ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ;fnot applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the ?\lte or this notice BY PAVING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ ISg<-t. ;2...:+ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or money order made oavable and sent 10: ~~.n 6o.nk.~. ,4-H-a-rh.'on: Sh{'fti Heifzha..u..sen 11'6 U.t~ OaKs ens (',assel'oeYnf. F"l. 32.707 You can cure any other default by taking the following action within THIRTY (30) DA YS of the date of this letter: (Do not use ifnot annlicahle.) IF YOU DO NOT CURE THE DEFAULT --If you do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intends to exercise its ri~hts to accelerate the mort!',!!'e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due .is not made within THIRTY (JO) DAYS, the lender also intends to instruct its attorneys to start legal actIon to roreclose upon your mortfJaae(( nropertv. . Page 3 of 5 EXHIBIT A ""'>= IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property \~i11 be sold by the Sheriff to pay otTthe mortgage debt. If the lender refers your case to its anorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the rensonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY period. vou wiII not be reouired to mlV attornev's fees. OTHER LENDER REMEDIES - The lender may also sue YO\I personally for the unpaid principal balance and all other sums due under the mortgage. - RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - !fyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun. vou still have the ri~ht to cure the default and prevent the <ole Of onv time lIn t6 one hour he fore the Sherirr< Sole. You mov do <0 hv novin~ the tornl nmollnt then n:1~t due olliS anv lar~ or other charl!es rhen dlle. reasonnhle :1ttorneyts Ic:~s nnd cosrs connected with the forec!o<ure <ole and onv other costs connected with the Sheriff's Sole as soecified in writin~ by the \ender and bv nerformino any other reouirements under [he mortllnl1e. Curing your def61!:!lt in the manner set forth in this notice will restore your mortgage to the S:lme po.sition as if you had never defaulted. EARLIEST POSSlflLE SHERIFF'S SALF. DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately l.J;; months from the date oCthis Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before th~ sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action wHl be by contacting the lender. HOWTO CONTACT THE LENDER: Name of Lender: rnwn 80-f1/(. P.5.t3 All<lrm: ID"5 Live. 00.1\5 &mens ~a55el berf1..J Fl. ;3;..,07 Phone Numher: RO()'i!A~ -Ie-51 ex::r.*- l:2Sq E.aJ.1iumJ2!.:r: 407 -;Up() -0$02.\ Coutact Pe."Son: '5h~ Hc:it-z.ha.u.s~ EFFECT OF SHERIFF'S SALF. -- You should realize that a Sheriffs Sale will end your ownership oftbe mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender nt nny time. ASSUMPTION OF MORTGAGE - You_ mayor ~'ay not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt. provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are sntisfied. - Page40f5 EXHIBIT A ,. ~~~ . . . YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PA Y OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDtNG INSTITUTION TO PAY OFF THIS DEBT. TO HA VE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HA VE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT .HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HA VE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, . TO ASSERT ANY"OnIER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION . BY THE LENDER. . TO SEEK PRO'fECTION UNDER THE FEDERAL BANKRUPTCY LA W. CONSUMER CREDIT COUNSELING AGENCIF:S SERVTNG YOUR COUNTY (Fill ill (I list 0((111 COII/lselill? Aoencies listed ill Aooelldix C. FOR THE COUNTY illwltielt tile Dro"erN is located. "si"r (,,/tIitiollal pares i(IIeces.W1rv) CUMBERLAND COUNTY .:...... CCCS ofWeslem Pennsylvania. Inc. 2000 Ung1esloWll Road H~burg. PA 11102 (717) 541.1757 . FAX (717) 54H670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro. P A 17268 (717) 762.3285 Urban League of Metropollran Harrisburg N. 6th Streel . Harrisburg. PA 17101 (711) 234- 5925 FAX (717) 234-9459 YWCA of Carlisle 301 G Stroet Carlisle. P A 17013 (717) 243.3818 FAX (717) 731- 9589 Page 5 of 5 E)CH\6\T A '. . ALL THAT CERTAIN piece or parcel of land and premises, situate, lying and being In tI,e Borough of Camp Hill, in the County of Cumberland and Commonweal!l, of Pel'1nsylvania, more particularly described as follows:. BEGINNING at a point on the westerly line of 21 st Street which point Is 483.91 !ee.t north of the northwesterly comer of 21 st Street and Park Side Road, and at dividing line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots; thence aJonJa the same in a westerly direction 112.03 feet to a point; thence along the easterly line of Lots No. 64 and 6/5 on said Plan in a norther!y direction, 65.04 feet to a point at dividing lire t:Jetweer Lots No. 48 and 49 on said Plan; thence along the same in an easterly direction 114.22 teet to a point on the westerly line of 21st Street aforesaid; thence alon" same South 12 deGrees 15 minutes East, 65 feet to a point, the place cif BEGINNING. HAVING THEREON ERECTED a one and one-half story dweiJing house more commonly known as 420 North 21 st Street, Camp Hill. Pennsylvania. ::1 !il THE A,30VE DESCRIBED property being Lot No. 49 in Revised Plan of Country ClUb Manor, Secllon A, ..s prepared by w.e. Whittock, Registered Professional Engineer, under date of July 1 S, 1955, which Pian is recorded in Pian Book 7, Page 36, en July 21. 1955. ':1 ii m [i 1 1 ,1 i \ ~ I ., BEiNG the same premises. whicl, Faye R. Love. single person. by deed dated May 31, 1989. and recorded in the Office of tI,e Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Bock 2-33, page 388. granted and conveyed unto MontadaJe Associates, Inc. and Steven Watts, Grantors herein. ., "0 ~'" - . VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for plaintiff in this matter, that he is authori3ed to take this verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 1-~:;--~ DATE: S-:J-J- 00 , ~ ~ ~ ~""" """'.- ,~ !I""h ~ r'-",'~ OFF]!, i-'" (;' " '-,~ v lln l _,IIJII!1\!IOlIII!lI!I! - iE 3l.:::'~!fF "':':!;,.i:'~TY ~ ~ ~ -',- J. .,.', _=_,,,,",,,",_n~...,..,..,~~"ffl,I\!~~\rlijl'19L~,~ .."".."RIJI~if,!.Q'lI1w,M~~",_""",,~,~,~ ~~ . ,~~~. ~~ " ,d,'_'-J.: . "'" Crown Bank FSB In The Court of Common Pleas of Cumberland County, Pennsylvania No.2000-3261 Civil -vs- James Highie Karen 1. Pease R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail Levy Postpone Sale Surcharge Law Journal Patriot News Share of Bills 30.00 14.05 15.00 15.00 .50 1.00 18.60 1.07 15.00 20.00 30.00 316.55 216.60 23.15 $ 716.52 Pd by Arty 12/11/00 Sworn and subscribed to before me So~/ ~A r~ -- R. Thomas Kline, Sheriff This .;Ji-V'dayof ~ 2000, A.D. ~r2JIMI~,),~ P t onotary BY ttn~.~-K Real Estate Deputy ,60 . de.,.?,07?? 0 ;u.. j oS'-,3 ~~ - ,-~~~, ~ i "" "'., . , CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JAMES HIGIE KAREN L. PEASE CIVIL DIVISION NO. 00-3261 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CROWN BANK.. FSB. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 420 NORTH 21ST STREET. CAMP HILL. P A 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JAMES HIGIE 420 NORTH 21ST STREET CAMP IDLL, PA 17011 PRESENT WHEREABOUTS UNKNOWN KAREN L. PEASE 420 NORTH 21ST STREET CAMP IDLL, PA 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None '; ,,"'-'".,~ ~,~ < - .. ,. ~- , -~ ~.. '--IW.,~ 1 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 420 NORTH 21ST STREET CAMP IDLL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Camp Hill Borough 2145 Walnut Street Camp Hill, P A 17011 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 oflS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 6. 2000 DATE ,v"'~.."'= ~b~ ~~ J I "--~ .. ~.;~t'i ~ ". CROWN BANK, FSB CUMBERLAND COUNTY .~ , t , Plaintiff, v. No. 00-3261 CIVIL JAMES HIGIE KAREN L. PEASE i Defendant(s). September 6, 2000 TO: JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP mLL, PA 17011 JAMES morn C/O DOLORES B. morn 215 NORTH 17TH STREET CAMP HILL, PA 17011 P.O. BOX 132 CAMP mLL, PA 17011 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at 420 NORTH 21ST STREET. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriff's Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by CROWN BANK. FSB (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 7, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT TmS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ""1:l"~""=""",,~ ... ~ ~J ,~~~. - ~l'i " ! , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. , II II 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ,-co "" 1- 'I -"~ ~-~ ~ ~ '",--, DESCRIPTION ..\LL THAT CERT.\IN piece or parcel of land and premises. situate. lying and being in the Borough of Camp Hill. in the Coumy of Cumberland and Commonwealth of Pennsylvania. more particularly described as follows: BEGl:<:<I:<G at a poim on the westerly line of 21st Street which poim is +S3.91 feet norrh of the norrhwesterly corner of 21st Street and Park Side Road. and at dividing line between Lots :<0. +9 and 50 on the hereinafter memioned Plan of Lors: thence along the same in a westerly direction 112.03 feet [0 a poim: thence along the easterly line of Lots :<0. 601 and 65 on said Plan In a northerly direction. 65.04 feet [0 a poim at dividing line between Lots No. +S and +9 on said Plan: thence along the same in an easterly direction 11+.22 feet [0 a poim on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East. 65 feet to a poim. the place of Beginning. H.\ VI2'iG THEREOl\i ERECTED a one and one-half s[Ory dwelling house. more commonly K.'1own as +20 .'Iorth 21st Street. Camp Hill. Pennsylvania. THE ..\BOVE DESCRlBED property being Lot :<0. +9 in Revised Plan of Coumry Club :vlanor. Section ..\. as prepared by W. B. \Vhitwck. Registered Professional Engineer. under date or July IS. 1955. which Plan is recorded in Plan Book 7. Page 36. on July 21 1955. TITLE TO SAID PREMISES IS VESTED 1:< James F. Higie and Karen L. Pease. Single Persons. as Joim Tenams with Rights of Sur';iq)rship by Deed rrom :vIomadale Associates. Inc.. a Pennsylvania Corporation and Steven \Vatts and Diane Watts, His \Vife dated 5120/94, recorded 5/23/94. in Deed Book 105, Page 923. ~~ "_0 ."-~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3261 CIVIIXm'IERM CIVIL ACTION - LAW TO THE SHERifF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Crown Bank, FSB PLAINTIFF(S) James Hiahie - Karen L. Pease 420 North 21st Street, Camp Hill, Pa. 17011 from DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See leqal description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a)'an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directedto notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. L.L. (per dlem-$14.7~) Due Prothy Other Costs $0.50 1.00 Amount Due ~ 89,969.34 Interest frcm -15-00 - Il-b-UU Interest 2.114.97 Atty's Comm Atty Paid Plaintiff Paid % 115.30 Date: September 12. 2000 Curtis R. Lonq Prothonotary, Civil Division by: ~ () ""fI.LJP,: ) Deputy REQUESTING PARTY: Name Fral1k Fede:rman. Esa. Address: ~t~p~~O ~pntf'r Pln"n Philnr'lplphin, Pn. 1CJ102 Attorney for.: Plaintiff Telephone: (71';) ~hl-7nnn Supreme Court \0 No. 1224B iii ~,;'I~," ~lIIIill'-~ -='~'!Il- ~..." 'Vi<I'diZH;jl~-;,"!!fuaUli'iril<i"~&]~,,~l~t,Mii&ii!iiIi!tI_~'~~~M~'~'~"" ..i~"'H'~''''''''''~1~~~~'' nlW~ . . ~"i RE~T t~~fr().~i ,n ~ J~;;vro the sheriff levied upon the defendallt, interest in the real property situated in!;;f lJ/Y'~ L~JlJ 4. Cumberland County, Pa., known and numbered as:~.:l./J 4A/L:tI~~ (~;.[;ff and more IUli'Hscribed on Exhibit "A" filed with ltlis writ ana by tnis reference incorporated herein. 'lat.:.J" ",t j.. /'J'.:J-r" By: ~~ f _!..1 ': :. Zi -'-' _-;1'- -' '_.J' @) CUi] i:Vil c:::::J (fi) 090 ":'"'" . AFFIDAVIT OF SERVICE PLAINTIFF CROWN BANK, FSB CUMBERLAND COUNTY No.00-3261 CIVIL DEFENDANT(S) JAMES IDGIE KAREN L. PEASE Type of Action - Notice of Sheriff's Sale SERVE AT KAREN L. PEASE 11 RICHLAND LANE T-11 CAMP HILL, P A 17011 Sale Date: JUNE 6, 2001 SERVED Served and made known to r.~'{I..et-l L, fe3S<::'" ,Defendant, on the 11f~ dayof ftft<.if ,200l. at J:3S' ,0'clocklL.rn.,at II ~\CI,,\SNt l<ll-'I? '1'-11,. CJ\M( HILL, ,Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant( s)' s company. Other: Description: Age-#- Height I)~-' WeightJ.,2Q Race W'''' Sex--f- Other 6(IJI-iJ I, -.eJ (lit ~ 1-.1<:. "- l. Co at.. -\, i :J: ~ competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice ofSherifrs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Notanal Seal . Stacy L. Heefner, Notary Public Sworn to and sUPii'ipbed Chambersburg Boro. Fra in County befort me this ~ day My Commission ug. 5. 2002 of~1 ,200.1. ~Member,pennsYtv a 01. Ion 0 0 Notary. ~ By: U l'l 0' NOT SERVED all the _-,---,---;..:.::-?~y of ,200_, at o'clock _,m" Defendant NOT FOUND because: ~9, Moved Unknown No Answer Vacant Other: Sworn to anc\subsr.ribed befme me thi" ____ day of___, 200_. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Snbnrban Station, Snite 1400 Philadelphia, PA 19103 (215) 563-7000 "':"~~'-';-Ii'~"&_iIl~!iI~~~i!:m~r~iiW..",'i1!u-;';;;"""""_~I\-I!$Whlfi>llllIiIi!iIiMlifeHllIMli'j7" -_rOO ~ ,'-"~','~' ~< h...- j~~""""""""'~rl\lll- "~""'""~'liI""'';''''~ -'.- ,,^,-, . 0 0 0 c: -no :? >> -OW <I " -:-Ji;: mm ;;0 Z:J:J ZC;: w ::Bj:;J (f) d;: 0 -<"'< ~~o ~o -u -f~-Ti ~o 3: .""-n ~;:o :i>8 ~ o,m Z 0 ?f5 =<! 0 -< "'^ ~ SALE DATE: JUNE 6, 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CROWN BANK, FSB No.: 00-3261 CIVIL vs. JAMES HIGIE KAREN PEASE AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 420 NORTH 21ST STREET. CAMP HILL. PA 17011. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed), and a copy ofthe notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. / ~~d--z- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ May 2,2001 " ~- - ~, -. "'-"C"I: CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JAMES HIGIE KAREN L. PEASE CML DIVISION , NO. 00-3261 CML Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CROWN BANK. FSB. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUlRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 420 NORTH 21ST STREET. CAMP HILL. FA 17011. 1. . Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JAMES HIGIE 420 NORTH 21ST STREET CAMP HILL, P A 17011 KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , ~: _...- -.- , 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 420 NORTH 21ST STREET CAMP mLL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 Camp HilI Borough 2145 Walnut Street Camp HilI, PA 17011 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 of1S Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. February 22.2001 DATE /J/~ ~tI~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - '~. ....... ,.' :....~ ~" .....- , DATE: FEBRUARY 22, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) JAMES HIGIE KAREN L. PEASE PROPERTY: 420 NORTH 21ST STREET CAMP HILL, PA 17011 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriff's Sale on JUNE 6, 2001. at 10:00 a.m. in Cumberland County Courthouse, South Hanover Street. Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH , "/ -"'--" "-.- ....~-!-,,- STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } SS. Robert P Ziegler I, _____________________________________________________'________________________Ilecorderof Deeds in and for said County and Slate do 'hereby certify that the Sheriffs Deed in which ________________ _______~___________________._____~~w~_~_~_J_~st_____________________________________ u thegr.antee the same having been sold to said gr.antee on the ____________h____~_t_~_________________________ day of June AD' _________~______________________________ . ., i 2001 d db' . f . _____, un er an y virtue 0 a wnL_____________ ____~_~~~~_<<:.~~~_________________m_____________ issued on the __QJ:_iJ._______________________________ day of ________lil!!:!;!.t____________ A. D., ,~qQ~_, out of the Court of Cornman Pleas of said County as of Civil2000 ------------------------------,.----------------- ---------________________________ Term, . ______ Number ____~2yJ______, at the suit of _______\!!P~_~~P_.~_~!'.!I________________________________________ __________________ __________ ___ __ __ against. ___J_~,:,=.:'_ ~~~_i_':_~_~~:~~__~_:~__:~ ~___ ______ __ n ___ is duly recorded in Sheriffs Deed Book No. __'!-_':~______. Page __~~~~______. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office thu ____~_____ day of _______~---------- A. D., ,}.. ~?._~ ----L4~--ti.:-~+-~ Ilecorder of Deeds ......,....O'....IwIC\1un1r........ M "llDmmilIieII EIpiIeI....filltlllllldaJ...IIII... ="- " '.-.. ~ ';1;-,-, , I' Crown Bank, FSB VS James Higie Karen L. Pease In the Court of Common Pleas of Cumberland County, Pennsylvania No.2000-326l Civil Michael Barrick, Deputy Sheriff, who being duly sworn according to law, says on April II, 2001 at 2:08 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of located at 420 North 21 sl Street Camp Hill, Cumberland County, Pennsylvania, according to law. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 12, 2001 at 2:08 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Karen L. Pease, by making known unto Karen L. Pease at 30 Hunter Lane Camp Hill(place of employment), Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants to wit: James Higie, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to his last known address of 420 N. 21 sl Street Camp Hill, Pennsylvania. This letter was mailed under the date of April 19 , 200 I and returned to the Sheriff's Office stamped Moved, Left No Forwarding 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: Karen L. Pease, by regular mail to her last known address, 11 Richland Lane T-ll Camp Hill, PA This letter was mailed under the date of April 19, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that 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: James Higie, by regular mail to her last known address, 420 North 21 sl Street Camp Hill, P A This letter was mailed under the date of April 23, 2001 and returned to the Sheriff's Office on April 27, 2001 marked attempted, not known. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock AM., EDST. He sold the same for the sum of $82000.00 to James M. Bach, it being the highest bid and the best price received for the same. James M. Bach of 352 South Sporting Hill Road, Mechanicsburg, P A 17050, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $86,248.60. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer County Mileage Certified Mail Levy Surcharge Legal Search Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed ,. ""'''~;jiJ!.tl , 30.00 1640.00 15.00 15.00 30.00 10.00 1.00 9.30 9.53 30.00 30.00 200.00 316.55 262.95 25.09 25.00 27.50 $2676.92 paid by James M. Bach Sworn and subscribed to before me So~~~ ~ r};/t}!;Or ~-<'-r -'U_ ~ This ~ day of ~ 2001, A.D. ~ (2 ~~ Pro onotary R. Thomas Kline, Sheriff ByA~ Dep Shenff ~~ '};\J'rJ'> \ lJO _" " f' c..Iu 33::>'::> iL nY:Jo1 . ~~" ~ ~l I .J " ~'~- ~ ~"~i!l!&" .' AMENDED SCHEDULE OF DISTRIBUTION SALE NO. 12 Writ No. 2000-3261 Civil Crown Bank, FSB VS James Higie and Karen L. Pease 420 North 21 st Street Camp Hill, P A 17011 Sale Date - June 6, 200 I Buyer - James M. Bach Bid Price - $82,000.00 Real Debt Interest from 8/15/00 - 6/6/01 (per diem - $14.79) Writ Costs DISTRIBUTION Amount Collected Sheriff's Costs Legal Search Transfer Tax - Local Transfer Tax - State Credit Writ No. 2000-3261 Civil Total Refund of Advance Costs $89,969.34 4,363.05 859.32 $95,191.71 $87,248.60 2,476.92 200.00 1,204.30 1,204.30 82.163.08 $ 0.00 $ 1,000.00 Date Filed - July 6, 2001 ?rr~:...t: ~-.:' R. Thomas Kline, Sheriff BY~'~~' )rvw'-t~ Re I Estat Deputy "~ .~~. ~~ I" ~\ir,' ,," ., ". SCHEDULE OF DISTRIBUTION SALE NO. 12 Writ No. 2000-3261 Civil CroWD Bank, FSB VS James Higie and Karen L. Pease 420 North 2151 Street Camp Hill, P A 17011 Sale Date - June 6, 2001 Buyer - James M. Bach Bid Price - $82,000.00 Real Debt Interest from 8/15/00 - 6/6/01 (per diem - $14.79) Writ Costs DISTRIBUTION Amount Collected Sheriff's Costs Legal Search Transfer Tax - Local Transfer Tax - State Credit Writ No. 2000-3261 Civil Total Refund of Advance Costs Date Filed - July 6, 200 I $89,969.34 4,363.05 859.32 $95,191.71 $87,248.60 2,676.92 200.00 1,204.30 1,204.30 81 963.08 $ 0.00 $ 1,000.00 ~.v ~~~~~ R. Thomas Kline, Sheriff BY~e~'sW1* Real Estat Deputy --- ""~~ - , .i _~"t .. TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 12 Held Wednesday, June 6, 2001 Date: June 6, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive. Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unftled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2001. and recorded ,2001, in Cumberland County Deed Book ,Page RECITAL: BEING the same premises which Montadale Associates, Inc. by Deed dated May 20, 1994 recorded May 23,1994 in the Office of the Recorder of Deeds in and for Cumberland County in Carlisle Pennsylvania in deed Book 105, Page 923 granted and conveyed to Stephen James S. Higie and Karen L. Pease, single persons. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of 21st. Street and Parkside Road. 6. Conditions, easements and restrictions shown on the revised Plan of section "A", Country Club Manor recorded in Plan Book 7 , Page 36. 7. Building and use conditions and restrictions as set forth in Miscellaneous Record Book 113, Page 204. ,<;".- "" ,= . ~. ""'~. ~ 8. Mortgage in the amount of $79,800.00 given by James Higie and Karen Pease to medallion Mortgage Company dated May 20, 1994 recorded May 23, 1994 in Mortgage Book 1214, Page 235. Assigned to Crown Bank, F.S.B. by instrument dated February 1, 1995 recorded March 2, 1995 in Miscellaneous Record Book 491, Page 1111, and corrective assignment recorded in Miscellaneous Record Book 506, Page 56. Said Mortgage being modified by Loan Modification Agreement dated March 1, 1999 recorded April 6, 1999 in Miscellaneous Record Book 608, Page 101. Complaint in Mortgage Foreclosure ftled by Crown Bank, F.S.B. as Plaintiff against James Higie and Karen L. Pease as Defendants in the Office of the Prothonotary of Cumberland County to ftle no. 2000-3261. Judgment entered August 17, 2000 in the amount of $89,969.34. 9. Judgment in the amount of $50,000.00 entered by Karen Pease as Plaintiff against James F. Higie as Defendant on October 6, 1997 in the Office of the Prothonotary of Cumberland County to ftle no. 97-5472. 10. Municipal lien in the amount of $640.20 entered by the Borough of Camp Hill as Plaintiff against James F. Higie and Karen L. Pease as Defendants in the Office of the Prothonotary of Cumberland County on February 28, 2000 to file no.2000-l1 03. 11. Rights granted to Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 111, Page 219. 12. Rights granted to Pennsylvania Power & Light Company by instrument recorded in Miscellaneous Record Book 112, Page 72. 13. Satisfactory evidence to be produced that proper notice was given to the holders of al1liens and encumbrances intended to be divested by subject Sheriff Sale. it is to be noted that the Mfidavit of Service filed fails to show service on Karen Pease, one of the record owners and judgment creditor. [; " ii. 14. Real estate taxes accruing on and after July 1,2001 not yet due and payable. , " It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bil11412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. \~ -L1. Robert G. Frey, Agent Note: This Title Report shall not be valid or bi until countersigned by an authorized signatory. '"1"', .. . REAL ESTATE SALE NO. 12 . ~', Writ #00-3261 Civil Crown Bank. FSB vs. James Higie and Karen L. Pease Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece or par- cel of land and premises. situate. lying and being in the Borough of Camp Hill.ln the County of Cumber- land and Commonwealth of Penn- sylvania. more particularly described as follows: BEGINNiNG at a point on the westerly line of 21 st Street which point Is 483.91 feet north of the northwesterly comer of 21st Street and Park Side Road. and at dlvid. ing line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots; thence along the same in a westerly direction 112.03 feet to a point; thence along the easterly Ilne of Lots No. 64 and 65 on sald Plan in a northerly dlrecllon, 65.04 feet to a point at dividing Ilne be- tween Lots No. 48 and 49 on said Plan: thence along the same in an easterly direction 114.22 feet to a point on the Westerly line of 21 st Street aforesaid: thence along same South 12 degrees 15 minutes East, 65 feet to a point, the place of Be- ginning. HAVING THEREON ERECTED a one and one-half story dwelling house. more commonly known as 420 North 21st Street. Camp Hill. Pennsylvania. THE ABOVE DESCRlBED prop- erty being Lot No. 49 in Revised Plan of Country Club Manor. Section A. as prepared by W. B. Whitlock. Reg- istered Professional Engineer. un- der date of July 18. 1955, which Plan is recorded in Plan Book 7. Page 36. on July 21, 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Hlgle and Kar. en L. Pease, Single Persons, as Joint Tenants with Rlghts of SurviVorship by Deed from Montadale Associ- ates. Inc.. a Pennsylvania Corpora- tion and Steven Watts and Diane Watts, His WIfe dated 5/20/94. reo corded 5/23/94.ln Deed Book 105. Page 923. '......... '-"'- "'-----... ]',. . I ....,... <., t CROWN BANK, FSB , \ CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JAMES IDGIE KAREN L. PEASE CIVIL DIVISION , NO. 00-3261 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CROWN BANK. FSB, Plaintiff in the above action, by its attorney, FRANK. FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 420 NORTH 21ST STREET, CAMP HILL, PA 17011. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JAMES HIGIE 420 NORTH 21ST STREET CAMP HILL, P A 17011 KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~, I, - '_i . 4. ~ Name and address of the last recorded,ho~der'of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 420 NORTH 21ST STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 Camp Hill Borough 2145 Walnut Street Camp Hill, P A 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 22.2001 DATE /J/~~L FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .-,,"~ - ~,~~~ . -'- r . CROWN BANK, FSB Plaintiff, '. . . CUMBERLAND COUNTY v. No. 00-3261 CIVIL JAMES IDGIE KAREN L. PEASE Defendant(s). , February 22, 2001 _ TO: _ JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 "TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at 420 NORTH 21ST STREET, CAMP mLL, PA 17011, is scheduled to be sold at the Sheriff's Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CROWN BANK. FSB (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. .. c'- _..~~..~ ,I . ~ J"" ._~ .-~.~ ~ ~".b<\."~ ~.""~-" .- ~~~,- , . " . You may need an attorney to assert yo~r rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notic.e 0.\1 page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. ' 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 - I "~L --- .' ,. .,' , , . 0, , DESCRIPrION ALL THAT CERT.-\IN piece or parcel of land and premises, situate, lying and being in the Borough otTamp Hill, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING :It a poim on the westerly line of 21st Street which poim is -1-83.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at dividing line between Lots No. -1-9 and 50 on the hereinafter mentioned Plan of Lots: thence along the same in a westerly direction 112.03 feet to a point: thence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction, 65.04 feet to a point at dividing line between Lots No. -1-8 and -1-9 on said Plan: thence along the same in an easterly direction 11-1-.22 feet to a poim on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East. 65 feet to a poim. the place of Beginning, H.-\ VING THEREON ERECTED a one and one-half story dwelling house. more commonly known as -1-20 North 21st Street. Camp Hill, Pennsylvania. THE ABOVE DESCRlBED property being Lot No. 49 in Revised Plan of Coumry Club :<Vlanor. Section .-\. as prepared by W. B. Whittock. Registered Professional Engineer. under date of July 18. 1955, which Plan is recorded in Plan Book 7, Page 36. on July 21 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Higie and Karen L. Pease, Single Persons. as Joim T en:lilts with Rights of Survivorship by Deed from :<Vlomadale Associates, Inc., a Pennsylvania Corporation and Steven Watts and Diane Watts, His Wife dated 5120/94, recorded 5/23/94, in Deed Book 105, Page 923. , . . 'hr,. c,rA,!Y;l'iOF EXECUTI6~ and/~r ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) . " NO. 00-3261 CIVIIXm TERM CIVIL ACTION - LAW TO THE SHERIFF OF c:\ \IT\hPr1 ROO COUNTY: To satisfy the debt, interest and costs due CTIlWTl RRnk. FSB PLAINTIFF(S) from, ',""TT1P" Highi'" 470 N()rth 71"t Str",pt. C:i'\lT\p Hill. PR. 17011 ::'i.Kare~ L. Pease 420 North 21st Street, Camp Hill. Pa. 17011 DEFENDANT(S) (1) You are directed 10 levy upon Ihe property of the defendant(s) and to sell 420 North 21st Street, Camp Hill, Fa. 17011 (2) You are also directed to attach the property of the detendant(s) not levied upon in the possession of .c .\-~ ':~;:'l! , GARNISHEE(S) as follows: and to not~y the garnishee(s) that: (a) an atta~~~f\"ha~;t?llenissued; (bhtl\le~l\1isl\~(s).li~crrltlln~ from paying any debt to or for the account of the defendant(s) and Yrom 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 inthe Possession of anyone other than a named garnishee, you are directed to notify hirn/herthat he/she has been added as agarnishee and is enjoined as above staled. L.L. Due Prothy Other Costs $1.00 Amount Due $Rq, qliq ,4 From 8/15/00-6/6/01 (per diem-$14.79) Imeresf 4, ~(;3. 05 AllY's Comm % Atty Paid 859.32 Plaintiff Paid Date: M"rrh Ii. 7001 C:l1rt-i!=: R. T,ong Prothonotary, Civil Division by: /t"r' 0 ~,PinJ Deputy REQUESTING PARTY: Name Frank Fede:rman, Esq. Address: One Penn Center at Suburban Station Suite 1400 Phil3ElelpRin, P3. 19103 Attorney fOl];>l R i nt iff Telephone: 215-563-7000 Supreme Court ID No. 12248 ,_o"l". lifll'liltlililllil....- "'0 lIII!IilIlIol' , .......- - ., ..... - ~-' "~~J1 ~, "'-.' ~ II~ K~ l".~lAl E. ~r\i..~ ~ia..ia .' , f. ~ r-> c;;:u c;;:u c::;::I tW ~ V" fYloMA.. ~.;lOO J the sheriff levied upon the detenoa", interest in the real property situ::\ted in Co."'P JIll! f36JOLtj A- Cumberland County, Pa., know,l and numbered as: L/Jo NOY'fj., ;;)/5+54. i:J Caf'Lp J-I-d I and more fully described on exhibit "A" flied with ~ <J'; "'" ~C' -' ""'" .U .-1 '''0 this WI1t and by this reference incorporated herein, ~;;. ~:.; 'late: fYJa.M:..A.. 0:J. 00 I By: ~~ ~ ~~"" -;.-0 ~~f;, h n:. IV .L.~ ~ ~"" V.epu .0'--fL ~r' ~.4... Y -,",. -" '" =~~~~I~, ", ,_~~ ,," _^ ~_ ,.' ,_~ " > "...., , - -~ -. ,^ - , --~EAl.ts11lT<Sl\tcNo~l,'-- Writ No, 00-3261 . CivllTenn "~~,_._"_' ..CIwI)l Bank,l'SB ." -,"""'" . "vs" ," I :"'''''.<:::;~.~, ':,. . Arty: I'ran~ I'edj)rman .,.." . OESC~IPTION..,'" ( ALl-TRAT cr.RtAl.\'i.~i,t;'!c'" or parcel of land a.~;]'o:, premises, situate. J~;nb""ltId being in the Eklroush of ump HilL inthe County ot Cumb<,rlJnd .lnd C<ii'nJii'&"n'wE'iHth of P~nns\'hania,- mOT(' I \:iaitkularlV described.1:. io]Io\\'5: ;.. B.!7.Gl\'"!\T\G at a ,point on thf: westerly lio,<,_ Df , 21st.:;lrcel \\'hicn point is 4$3.91 feel norm 01 the ncirtrw.;esteI1y con,er of 21st Street al1d Park Sidt' .Road, andat dhidins lilie be~'€en Lots ~o. 49 and 50 on the hereinafter m~ntioned Plan at lots; t~cl'lre,.along the same h, a'wesll'rr,.: dlmbon 11203 'f~)!'t to J poinl; thcnc(' Jl(lng the easterly En(. Ot lots )\0: lH .and 65 on !-aid Plan in cl r,.drthcrly directioTI, 65/14 .leet tq a -paint dt '\fuiding lint' oEhfi!.;n Lots No. ~ Jrid 49 on i-aid Pljl:o; th<'lh,:e JJong thil. ~31l1~ in illl l'J;,ll:rly .:Iiremon 1 H.22 fed t,) ,) point 011 t1h' \\"esL~rlY 1:01.' of. 21st So'~et 37oresilld: tl1~nct.' dlong San'll' . Sou~; 12 d<'gt"tX's 15 minut~ last, 65 ft'!'d to d I 'PoiJ')\.t~p\,K('ofBL-gln)"lil'l'" , .' . HA\'L\'C JHEREO~ ERECTED a bnt' .1nd anI.'- nJ.lf WJt'\" 4KeUlng ~Vlll!l(!. -morc c-omnvlnlv k!1.ol-\TI as 4~D l.....Olth ::bt SireN, Camp Hill, r~nos\,j\'Jni,1. " nir"ABO\ t m.scmSED properh' bfing lot [, Kti. 4~ in Rl..'\'L~ed P1Jn of Counlry Club ?\/anor, : '5:ec.noTl A. as preparl'd' r,' W. "B. Whittod;. , . Registered Prof~ional Enguwer. under dtlte of lut.;'lS, 1955,whid, PI,;\:. ~ r~corded in Plan Book .iirdge.36,onJul\'.n19~',,,,, ,. .1mr:rO 5.:\lD'FRBfISES1S\ESTED 1\' J~ml'$ F. Hisi-t:' Jl'rd Karen L Peas\.', Single Pl'rson,~, ,l,&foinfTeriJnts v.~th Righ~ of S.u~-j\"o~hrp by Oecl !rom },lont"JaII1 AS'>Coale.::. In'" J Pl.'nn~: lraniJ (orporjlil)n .1Ild 5t(.\ en W3H.$ J\'ld" Diane \\Jl1io, Hi~ \\"iie, dal~d ~!~OI9"Lr.€oorded 51 :~f9~~ [11 D~eJ 8oo~O~,~~~. ~_--'- , ~i I... ~" , " ":j . , . THE PATRIOT NEWS f;, THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot.News and The 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 24th day(s) of April and the 1 st and 8th day(s) of May 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character at publication are true; and That he has personal knowledge at the facts aforesaid and is duly authorized and empowered to verity 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". V;I~::I~:~~~:' ..............................</....(.................................................. COpy Sworn to and' this 21st d of M 001 A.D. S ALE 1112 NOlarialSeaI Teny L. Russell, Notary Public H.rrisburg, Dauphin County MycommisslonEXPireSJune6.2002 NARY PUBLIC Member, PennsylVania Association 01 Notar~ 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 $ 261.45 1.50 262.95 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt ot the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ~I REAL ESTl\.TE Sl\:LE Nt>. 12 Writ #00.3261 Civil Crown Bank, FSB vs. James H1gte and Karen L. Pease Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece or par- cel of land and premises, situate, lying and being in the Borough of Camp Hill, 1n the Connty of Cumber- land and Commonwealth of Penn- sylvania, more particularly described as follows: BEGINNING at a point on the westerly l1ne of 21st Street which point is 483.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at divid- ing line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots; thence along the same 1n a westerly direction 112.03 feet to a po1nt: thence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction, 65.04 feet to a point at divicling line be- tween Lots No.. 48 and 49 on said Plan: thence along the same in an easterly direction 114.22 feet to a point on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East, 65 feet to a point, the place of Be- glnlling. HAVING lliEREON ERECfED a one and one-half story dwelling house, more commonly known as' 420 North 21st Street, Camp Hill. Pennsylvania. lliE ABOVE DESCRIBED prop- erty being Lot No. 49 1n Revised Plan of Conntry Club Manor, Section A, as prepared by W. B. Whitlock, Reg- istered Professional Engineer, un- der date of July 18, 1955, which Plan is recorded in Plan Book 7, Page 36, on July 21, 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Higie and Kar- en L. Pease, Single Persons, as Joint Tenants with Rights of Survivorship by Deed from Montadale Associ- ates, Inc., a Pennsylvania Corpora- tion and Steven Watts and Diane Watts. His Wife dated 5/20/94. re- corded 5/23/94, 1n Deed Book 105. Page 923. ~- -,,'-,< ,. .. - " . " l' ....1"- .. 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 Cumqerland Law Journal, of the County and State aforesaid, being duly sworn, according to law, dep6ses 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, V1Z: APRIL 27, MAY 4,11, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~a1'Edi~ SWORN TO AND SUBSCRIBED before me this 11 day of MAY, 2001 NOTARIALS . L~ E. SNYDER;NolatY.. . PublIc. C8IIilIIlt.BclIo, CumbeItand Calm. . ~ CoIMJsalBn ElqliI8I'March 6. 2005 . ~.j',,",'""',,,,,k<tl>' . - "~ ", .J~.. - ~' , - =='" , .. , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CROWN BANK, FSB Plaintiff CIVIL DIVISION vs. No. 00-3261 CIVIL JAMES HIGIE KAREN L. PEASE Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CROWN BANK. FSB, hereby verify that on SEPTEMBER 15. 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 15. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. 7~~K~~E Attorney for Plaintiff Date: November 2. 2000 <=> <=> ~ ,!j .~ = j~M filll<=> -.... ll.<~ ~t< oll;;ll.< z.. . -<U.$ ~ ='" o,s< .. .. "",ll.<'" ""0" Sl~:a I'd"'ll.< t ... .. = '" .. ,,"'... ~ ~ = a... .. "...00 z-<'<l u tl: lt~----~ ... t=::=-___:;;: ---4!.~L I ~~ -- . -OE~ ~- . t ~ (.(l'~ I~ U.S.POSTAGi: . (~1r~~ s ~ ~woo.ht -'f~'- '" 1_ 5 0 ::::; 0 '" Pi"MEHn -. - ~ PI\. . . 6068360 .. . . A li,E. FA 190 ....- ~ . ~l ,~~. 0 ~ 0- /~ ~ , ~ ~:> N~~ l:l i:.., '" z8 = ;:Jr- .;;: .... 0.... .... .... 'OJ .... .... .... 0 <=> U~ .... <=> <=> o:! r- .... r- r- = ... .... ~~ r- .... .... 0 -< .... -< ~ u ll.< -< ~ ! ~ ..1i!:l ll.< ""'..1 llii..1 ..s ..1 ....1 .f ~ ""'llii g "'.. .... ~ =-< ..1 ..= .... Ji~ ::EU .. =ll.< <=> "0 ll.< = ll.< r- ~l ~ ::E ;:J... ::E =::E .... 8 U~ ll.< ~ -< ",,"'" ::E -< "'-< ~e B U O~ -< U "'u ..s "'''' ?:' U ?:' llii ,u 5 <l'.!f-< = .. Of-< ~ "'" z'" "'" ..1"'" .. '" "'~ = "0 ~~ Ollii ~ O~ ~ Ii ~~ ;:J"'" ll.< 'if ~~ O~ ~~ ~ 0", 1l ~fI) ..1~ llii~ 00 uiS ~ 000 .. U ~ 8 '" ~-< ~ ..... ,; U.... =!;; "'.... "",r- r:1,:; ge u u'" U= ..", ...... f4' ii:o ~ ~3 "'= "'= "'.., ~ 0= 'S~ E:i!;; ..= ..~ ..~ ...... ts ~l "0 =~ ~ ~~ =-< =llii =llii "'llii ",0 ~ .0_ ... Zo "'0 ll.<~ "'0 000 e = 0 ~z ""'z "'z ""'= 0"0 u ::Ez ::Eltl ~~ ::Eltl ::E' ~ z ~ ~ "",= 0.., -<..,. -<Cl ]1'- ~t;! U~ -<.... d z ~.... ...... ...ll.< .Ii e 0 z ~ .!! -ll 0 ~ = u ...'" o~ D"O . 'E~ .... N <'l. ..,. .,.. '" r- oo a- <=> .... N <'l ..,. .,.. z:J u .... .... .... .... .... .... ~ = ]18 ::l ~~ .. ... ........1 ... l' " ,~ ~1id:1lI1i.Jh ~"""-'" ~ . , ,-'n.' ~"" "" ""'," . .:. '. A . RE: S LESu4:: '" ":Ii;:,' "'t~~~'~",: SENDER!'b1\1K ~ .t' i 3. Article Addressed to: , JAMES RIGIE ; 420 NORTH 21ST STREET I CAMPRILL,PA \7011 I j l II .~ , 1 " .! :,5. RilCeivedBy: (P(int ~~~~~?{~SJ#j;~~~L~.s,:::"~;fK~~,'~ t~''':.S..J:~,''1lt R'~IJ1~!::~~~i-~~t..S;;;,;Z0i~;~~:~iift~i,i;;:>~;);:.; J:-, " "it! .;:ii,F"Gl' a, '.,~ 1".>"vrJ' ~'~ ,H~l;:"j:"" f,;t.t>t;;'n" Z'':''1''i.;>'''l1;<<ih-'-';;;,:'.S. ,- ".'" ,.'~>flrr1'1 ,.sf:? ;'''~H-' ,:-.,>t f:r.,i:!?i~;~.:~':f:iJ;'~~i~2f~f.f;;~::;~t!c:~!;,:'~/ ;::"-",, i' " I also wish to AlCeivethe following service (for,an~,fee): 0, REST"...TED .' .:'r;]- IIEUVERV . ~ .-:+'!,- ' ConSoR poSiITl.....toi~:; 4a. Article Number P "16"1 DSS 3 If 7 IIUllllmm.llmIIIIIIIMIIII~~~ a.Add Domestic Return ft~ .' '","",;;,ii/, ',r ~~~~~ . ~. '" P "Ib"l 055347 JAMES'HIGIE . 420 NORTH 21 ST STREET CAMP HILL, PA 17011 TO: SENDER: REFERENCE: DMK SALES . PS FORM 3800 SEPTEMBER 1995 - RETURN RECEIPT SERVICE Certified Fee RelUmReceiptFee RBSlrictedD8llYery Totar Postage and Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use tor International Mail . 0 TO: P 9b 9 0 552 b 8 JAMES HIGIE . P.O. BOX 132 CAMPHILL,PA 17011 DMK SALES SENDER: , REFERENCE: PS FORM 3800 SEPTEMBER 1995 -go Certified Fee RETURN RECEIPT SERVICE Retum ReJ;elpt FQQ Restrictecl Dellwry Total Postageancl Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use tor International Mail 0,00 :s .'. --".....'- , -' "~,;.r ;ii, F' "Ib"l 055 34b KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA I7011 .f TO: SENDER: REFERENCE: DMK SALES PS FORM 3800 SE MBER j 995 - RETURN RECEIPT SERVICE """"''''' RelUm Receipt Fee Restrlcl8dDelivery Total Postage and Feea US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 not use for International Mail ----l}.OO:-- -2.1-5- P "Ib"l 055 2b7 TO: .. . JAMES' HIGIE CIO DOLORES B. HIGIE' 215 NORTH 17TH STREET CAMP HILL, PA I7011 SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 -go RETURN RECEIPT SERVICE C"""""" RelurnReceiptFee RestrictedDellvery Tolal Poslage end Feel US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 not use for International Mail 0.0&-- -e,oo-- ----'b7--5-- '-'0 ~_I"~_ml. ~ ~ 'i "":ol\;;ir-rtJ"-'"" r- Ml!.~m~~ ~I ~". ~wtr ." J--,",~, ~' ~u .h-,~j. .~ .. '"" . ~ I 11 . () a () C c> 'T, ~: ;;e ::-:-:-.1 -Occ C:;) :'1\21 rnn', .,~:: 2:J,1 I ~2 :Z'r- 002:: 0' ;:0;0 v ~c-: -'~--n ~_. '-;Co -"- ~O W oni Pc: --1 2: '" ?G =< Co) -< , 'I _l - .J "t.; '~.i FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 CROWN BANK, FSB 105 LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. : NO. 00-3261-CIVIL JAMES mGm KAREN L. PEASE 420 NORTH 21ST STREET CAMP mLL, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against JAMES mGm and KAREN L. PEASE, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 03/01/00 TO 08/15/00 TOTAL $87,340.14 $2,629.20 $89,969.34 I hereby certify that (I) the addresses of the Plaintiff and Defendant{s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ?~1~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE:4IA1I1fj+ J1,Jf1)J J51~~~ P 0 PROTHY "THIS FIRM IS A DEIIT COLLECTOR ATIEMPTING TO COLLECT A DEIIT AND ANY INFORMATION OIlTAINED WILL liE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUYfCY AND THIS DEIIT WAS NOT REAFFIRMED, TIIIS CORRESPONDENCE IS NOT AND SHOULD NOT liE CONSTRUED TO liE AN ATIEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** "'~ """.~~.," ,', .-y ~ ~i,. FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE NO. 00-3261-CIVIL Defendant(sl TO: JAMES HIGIE 420 NORTH 21ST STREET CAMP HILL, PA 17011 DATE OF NOTICE: AUGUST 1. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRE.;~~ NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROP .. . ... IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff k"~"",.. "_.. " ." 1...0..-- , H '", I ~ Jl[ki FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE NO. 00-3261-CIVIL Defendant(s) TO: JAMES HIGIE P.O. BOX 132 CAMP HILL, PA 17001 r I A'''Jt\~ , \ I " DATE OF NOTICE: AUGUST 1. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ",-.- ~ ,,~~- "'" ~.. .....,... '"~, _ .J - . ~ > ' h ',," - "'/!IlI',; FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE NO. 00-3261-CIVIL Defendant(sJ TO: JAMES HIGIE P.O. BOX 821 CAMP HILL, PA 17001 DATE OF NOTICE: AUGUST 1. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS C.ORRESOOf.OND CE IS NOr AND SHOULD NOT BE CONSTRUED TO BE AN AT~~tr LECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINflL~O IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) d~ys from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff _iIll '~~~_~~~~W"fdtl,'h'" .,;,~O"*,b,~~dL~~J@ m'!\8i~-' I,~~, d~~~ ,. ,~ _~iillmi:fijji!l'B~'iil1m~)j.~Jo!~~a:;~i~~Nj:.. ~ . ,~ '-, -, ~ :nt~IWL- ., ~j M " ",""""""~~""",,,,,-,~"~~J~,_ ~ I J=.,,~__ - - , lO'i FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE NO. 00-3261-CIVIL Defendant TO: KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 DATE OF NOTICE: AUGUST 1. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IJIJ AN ATTEMPT ~ COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFO IN O. B.TAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU ~~USLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRE QND . IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLU CT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT N0TICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff IlIrj~.~~~ .I~""'~~ ""'ii.I!Hjlj}m!IM~~'IH~"~W,';if!E'_"'\<"~"-",oi,H'i;i'''''''':' ::>1t~''''","",T!'a~8M_''''~'.''-~,""",,,~~I(<,'fl<<"_ti'';IHc__.>U.~~Iii''''''''''''' ' ,~, "' .. - ~~ - =.~,.~. ~_,_",__ ~-", "~ . ."l'-"-,-- '<"., .~,,? q -~ "" =. ~"",,""""""--'"-- " - . FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CROWN BANK, FSB : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CML DMSION JAMES HIGIE KAREN L. PEASE : NO. 00-3261-CIVIL Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant JAMES IDGIE is over 18 years of age and resides at PRESENT WHEREABOUTS UNKNOWN. (c) that defendant KAREN L. PEASE is over 18 years of age, and resides at 420 NORTH 21ST STREET, CAMP IDLL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J~ ?-~ FRANK FEDERMAN Attorney for Plaintiff .~ .J J "I. ~ ~ (Rule of Civil Procedure No. 236 - Revised) CROWN BANK, FSB : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION JAMES IDGIE KAREN L. PEASE : NO. 00-3261-CIVIL Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on AUGUST .2000. By f~1/t; ~ /~ DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWQ PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ""-~ " -l -....in> ~--~-'--"'-J . ", ~ - -< ~ ~~ ~-,-~,.~ , ... .,..' '" '- > -- ~'~",-. - .... ''1~':-IW.iIII'r '-~j;jltiili5IC df~~ _'j)jl\EAlll!ii&JOi: ." iI'- .",- _. "''' . --- .::-) C) --n Q cJ ..~l ~ <;;,; ~ "'" :S- -a -ot:L! (i~ ....... !'> rnn:_: 7"> k 0 2::'7; i(3 ZS. ~ '* Cl Cf) ~~: -0 2t:) .'r) ~ .....D V'1 ~(J ::-'11: . _,;--ro ~ -\) ~ Z~ r;? ~~ -=u - -D PC: ~ ~ ~ ~ vJ Z -<.. -'> ::t Iv ~J~,~, ,_, ,~,~ .. . ,"~~" ~~_o_ ~ ~ .__ "'d ~ i "_ ~-, .. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (? 1~) %,-7000 ATTORNEY FORPLArnTIFF COURT OF COMMON PLEAS CNIL DNISION CROWN BANK, FSB CUMBERLAND COUNTY vs. No.: 00-3261 CNIL JAMES HIGIE KAREN L. PEASE A FFIDAVTT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to JAMES HIGIE on MARrH~. ?001 at 420 NORTH 21ST STREET, CAMP HILL, PA 17011, C/O DOLORES B.HIGIE 215 NORTH 17TH STREET, CAMP HILL, PA 17011 and P.O. BOX 132, CAMP HILL, P A 17011, in accordance with the Order of Court dated JUNE 26, 2000. The undersigned lmderstands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. ~~~~ R FEDE , ESQUIRE Date: M"rr.h 1 Ii ?001 . - ='.. ~ ~, ~~".'..~ ~;l 0- . . . - C~ ~3 . " 0.. ,,~ '< 0 "'~ 9 go ~ ~~ g it ;a' Z 8.. ag. 'O. o ~ . 0 - ~ 0" ~;;;. =>0 o 0 o . ~ ~ ~ ~ :.: ~ c..,j ~dl 'O~ 0"3 '" ~ 2- Jf if z . ~ o ~ i:' o . :;r 3. "" ..........J ., t;; :r;;: - w - - - o '" 00 '" ~ c:'l ~~ ..., ~~~ ~~~ 00;:00 =:.....=: ... ... 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L442 D44b TO: JAMES HlGlE. . 420 NORTH 21ST STREET CAMP HILL, PA 17011 SENDER: CMO REFERENCE: SALES I PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ,~ .4 1.90 1.50 0.00 3.20 ,. 7LDb 4575 1294 1442 D4bD TO: JAMES mOlE C/O DOLORES B. mOlE 215 NORTH 17TH STREET CAMP HILL, PA 17011 SENDER: CMO REFERENCE: SALES PS Form 3800 June 2000 RETURN f'<lstage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total f'<lstage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ,~ .34 1.90 1.50 0.00 3.20 '"=<'\ii~dm:m.~l!t>:iltt..>1i,lillil,jJ~!~jf,\ji;M.lil'&"'l""';;'';j,44[!''W')''i'''''''''l''''Cili'~*,o!i'~tiOM~__liiIlIIIWlIliIIIii~~;_~' ~ ~~~ - o c ;? -otD Jt1n" ZTl ~(~;" r<: c:; p,- Z" ",,0 -c Z =< co " . ~. :r. },C.... :'::':J ~.-! "1'" 'D ;~';.~{ ":J-':-r-', ~~~ ~~; ~5"" --; ;S; .~ -< C:-: .:11 .~~.... " .' -~~.- , '" ~..- ,i PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 I I I I I I I , I 1 < . ... CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. No. 00-3261 CIVIL JAMES mGIE KAREN L. PEASE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $$89.969.34 ..; Interest from 8/15/00 - 6/6/01 $4.363.05 and Costs (per diem - $$14.79) $94.332.39 TOTAL ~~OI FRANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. q"1-6 tJon&.- 2.1~ S4 CfLtv-p ,.k 11 PIt 170// ,-. "!li8/!ll'~U--llr ll\liilir"""""di.,...;;- ,~~~,..""U!.~ilMiiil!\"la-::M ~- - ';.,,' , """""-,,.-' WJil$illl.\ , ., Eo< ~ ~... Eo<S ~"'~ ",Eo< < <;!';l=- ~ N . =-='"" . Eo< '"" '""~= Zo=- ~:$ ~~~ oz Z ~U "1 ~ 0 """ ~'"" Eo-< Eo-< ...1 >< ;;;l ~ i:l.'" 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'Je fi:~ ~ DESCRlPTION ALL THAT CERT..i.IN piece or parcel of land and premises, situate, lying and being in the Borough of Camp Hill, in the Coumy of Cumberland and Commonwealth of Pennsylvania. more particularly described as follows: BEGINNING at a poim on the westerly line of 21st Street which point is +83.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at dividing line between Lots "10. +9 and 50 on the hereinafter mentioned Plan of Lots; thence along the same in a westerly direction 112.03 feet [0 a point; thence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction, 65.04 feet [0 a point at dividing line between Lots No. 48 and +9 on said Plan; thence along the same in an easterly direction 11+.22 feet [0 a poim on the Westerly line of 21st Street aforesaid; thence along same South 12 degrees 15 minutes East. 65 feet [0 a point. [he place of Beginning. HA VING THEREON ERECTED a one and one-half s[Ory dwelling house, more commonly known as +20 North 21st Street. Camp Hill, Pennsylvania. THE ABOVE DESCRIBED property being Lot No. 49 in Revised Plan of Country Club .\Ianor. Section ..i.. as prepared by W. B. Whittock, Registered Professional Engineer. under date of July 18. 1955, which Plan is recorded in Plan Book 7. Page 36, on July 21 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Higie and Karen L. Pease, Single Persons, as Joint Tenants with Rights of Survivorship by Deed from :'vIontadale Associates, Tnc.. a Pennsylvania Corporation and Steven Watts and Diane Watts, His Wife dated 5/20/94, recorded 5/23/94, in Deed Book 105, Page 923. _ ~ ,..~,......, _.J< ~~~sj;&j"'i'''''''4:'''' ~=[:litf*"~iliNtlil\1!l ~~2 ' , A::> ~ --....;j ~~ -- ~~ -f::- 0" c..:,\ J;;~_ ~ , b">>,-,,,"MWli!~.'. ,"'iU",",>,-:"'~i ;mltliliiinl"l :' j[~'f'ili ~~-- ~~""......it~l~ c:::><0 fD D '-\ c. tN ~ ')'V '->-0 :--. --.:r \:.I LN ~~)- -..... - - -l ~~ ~ _. .~ ~ "'" G, \ ., ~ () '\ )-.J " ~ - o c: <"'" ;4~n;~ Z:-t. -.?-I_~ g2~-::.' ~>' ~:~C_" );"C~' 7 ~j -, ~ . C:J -,"" .: ~" :-::< I C:'" r>? .~ CP '~'~,:;-2:< '1 1 . ~ ~ ',-;-- ::0:,_, -" , '" " I - '~~;;;i:,q_j UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL VANIA Movant C' (low 1\1 D t;' ,...>le. 8 s IJ 8 J so ) Chapter No. 7 N~. Bai1~, cv No. 00-04225 RJW 7' F rv iI1/l ~~ t.:~ ~ r;: I'" Harrisburg PA .. ;.. ..\""~-","II._~ -ll~;- , r- Illlf;":_AM..PM.. IN RE:, . Karen Lee Pease aka Karen L. Gruver Debtor(s) Crown Bank, FSB v. , JAH t 1 20m Clerk, lJ. J{arenJ.,ee Pease aka Karen L. Gruver Per I": Respondant (s) ORDER AND NOW, this 11th dayof -jf}j//{jfllUf ._,;-tr,y~ mi~'I":C:I~r~ . , 2001, upon consideration of the Motion for Relief and Motion for Default of Movant, Crown Bank, FSB, it is hereby ORDERED that the Order for Relief be entered by default with respect to premises at 420 North 21st, Camp Hill Borough, PA 17011, to allow the Movant to foreclose on its mortgage, which mortgage was recorded in Cumberland County, in Mortgage Book 608, Page 1014, to ~Iow the Movant to foreclose on its mortgage, and allow the purchase of said premises at Sheriff's sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. By the Court: /$/ Rebart J. W:.e,,':Ili\e Robert J. Woodside, Bankruptcy Judge cc: Judith T. Romano, Esquire One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 Steven C. Courtney, Esquire P.O. Box 5300, 3211 North Front Street Harrisburg, P A 17110-0300 Leon P. Haller, Esquire (Trustee) 1719 North Front Street Harrisburg, P A 17102 Karen Lee Pease aka Karen L. Gruver II Richland Lane Camp Hill, P A 17011 '. '","C ~~~j!;gI~miM.l!lii;~~,~..i!!i~'M.!i8t~'4<!;;;jl"-,8"""_".lliii.~' ''''''''-~'','-"" '" ,~. ", "'.' '.~ ~ _-'"i"'II~iHI.~~",,_,S~~ <"M> 0-.>' _,,_ j ,. -C'~;-.- rn,;"-,-- ~;~' ~~'~~ r:=C ~~ ::::J -<~ C) C ?~ C-', -- 'C~ '~'-;J c u f'...) :::> ('n """~ "" .J 0-- "-"" -';'--~hi CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. No. 00-3261 CIVIL JAMES IDGIE KAREN L. PEASE Defendant(s). , February 22,2001 TO: _ JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECf A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.' Your house (real estate) at 420 NORTH 21ST STREET. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriffs Sale on JUNE 6. 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by CROWN BANK. FSB (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ..- - ~, ... - --",..;"." : "'I'-~:i You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. ' 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as ifthe sale never happened. 5. Yon have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. Yon may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. Yon may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . ''-~ I.. "' , .~ , DESCRIPTION ALL THAT CERT.\IN piece or parcel of land and premises, situate, lying and being in the Borough of Tamp Hill, in the County of Cumberland and Commonwealth of Pennsylvania. more particularly described as follows: BEGINNING at a point on the westerly line of 21st Street which point is 483.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at dividing line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots: thence along the same in a westerly direction 112.03 feet to a point: thence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction. 65.04 feet to a point at dividing line between Lots No. 48 and 49 on said Plan: thence along the same in an easterly direction 114.22 feet to a point on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East. 65 feet to a point. the place of Beginning. H.\ V!;\[G THEREON ERECTED a one and one-half story dwelling house, more commonly known as 420 North 21st Street, Camp Hill, Pennsylvania. THE ABOVE DESCRIBED property being Lot No. 49 in Revised Plan of Country Club )'1anor. Section A.. as prepared by W. B. Whittock, Registered Professional Engineer, under date of July 18. 1955, which Plan is recorded in Plan Book 7, Page 36, on July 21 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Higie and Karen L Pease, Single Persons, as Joim T enams with Rights of Survivorship by Deed from ),{ontadale Associates, Inc., a Pennsylvania Corporation and Steven WaITs and Diane Watts, His Wife dated 5/20/94, recorded 5/23/94. in Deed Book 105, Page 923. ;_-.l,.~_ -"""'~~Ji:I!li;iijI~ii~~ ,~,~ 'J.~"'-'''''-''~'''~"e~~~_If,(~.i1.~ ""- ~Jll:i1i~ ;=g }::. ;~;~:- (f;:,- .....< :~--- r;= l~; ~- >' , 5E~ "-"" alli'h.- ~~."" o C :?~' ,--', --;:,:; C'-, ~.) ..- --4 -< :::> 0:;':' ',.d' _ L.' ... ~- /' " 'e '. j ". ,,~-./ . "~~'j CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JAMES IDGIE KAREN L. PEASE CIVIL DIVISION NO. 00-3261 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CROWN BANK, FSB, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 420 NORTH 21ST STREET. CAMP HILL. PA 17011. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JAMES HIGIE 420 NORTH 21ST STREET CAMP HILL, P A 17011 KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, P A 17011 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .- J, 1<. '" . 00' ,,~. _.. '-~l _.vt_" ~ .,. ~, L.. i " j' . , 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 420 NORTH 21ST STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 Camp Hill Borough 2145 Walnut Street Camp Hill, P A 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 22.2001 DATE /Y~ 4"L FRANK FEDERMAN, ESQUlRE Attorney for Plaintiff I!jJ -'.lWl.~i~.~~~iil~~iilll~i'" '""~""~'f.i!J'~"';;';""" . ~."iillillr":;""J" , ',", - .~ 'J L Q C~, ::-< ,"j.r--,- n';f-','-' ~~; :::-;; .- ~~(:~) Y.C 2: --" --< \...':.1-.;;... '( ,! ,I _', ~l: c:~ --r: ';';'" G' r:,:: :::> (D , --, '" - -,<--" .~-,' 'i;; FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DMSION JAMES ffiGIE KAREN L. PEASE NO. 00-3261 CML Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. d/~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - ~ " --~".. ,oj, -liiIIiiIlIiIlI.. " _.'. ~. .-, -.... "'_Ml__o.:i~_' __~ ~ > .~ '.. ", _",,~ I""",,,,, ~ ~. -..c -'~" ,,,, -". -^" ~-. - -'=, - ~."- -", iBii&-~~~1Il "" 0 .~ ,-. C~ ?::: - '"!J ~_""h n; -~ ~:::J Z :::< c: , (j) ,,'~ C' -< r" C~ ~~ ~I ," <"'7 ,~-. ~ '-- ~; "-' C I ~,' ~ .~ ~ -< C:) -'" ~"'-~ ,~, . ".L'S~-'-" ~ . . . . - ~ -, - 1lM;iL_ , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSUJRE) P.R.C.P.3180-3183 CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. No. 00-3261 CIVIL JAMES HIGlE KAREN L. PEASE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $89.969.34 Interest from 8/15/00 - 12/6/00 $2.114.97 and Costs (per diem - $14.79) $92.084.31 TOTAL J~ F K FEDE , ESQUIRE / TWO PENN C NTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. No. '. ~~t!l~m~1!li!Mb!~~;iI~~1>~'JJl""&f,,~~?,z~},,]~,-"I!<J'"\j"'-"'JH}j->iWi1-ili~~-'i' ~h.IiI~_"'Il"~~1 ~~_1' n - ~'kJ .',.,."u "I j E-< 1'>;1 ~::: E-<O l'>;1oo~ 00E-<< <~~ 1'>;1 M . ~::ti"'" . E-< "'" "'"~= Zo ~~~~ "",UO ...:$ ~ Z O~ Z ~ 0 00 00;> ... ... ... ~~ ... 1'>;1 ~ ~ ~""O . ~oo U ""~"O ~~ i:l:l ~e ...0 1: 1'>;1 OO~~Q) ci 01'>;1 00 1'>;100 1'>;1 = ... '" ... '" ~~ ...< ... <= 00<1'>;1" < ~ . ~ ~1'>;1 00:: r:l""~~.o 01: ...~ .. M. ;;... 0 ::ti. ... . ~::ti"'" oj 0 .; .~~ 0 UZ 00"'" ......"'"...S N ...~ i:l:l .. I'>;1Z :~=Z~ 5. 00 ~ ~~ ~~ ~~~~ 2: U ... t;~ 0 01:: o ~" ... <= ~~ ~ f;l;16 ~~U~~ 8za U e= U '" elf;l;1 '" ~ -i:i " E-<i:l:l .tJ " "0 z::g - .~ < ....~ ~ ~ U ~ "u, ~ ^ ... -",~~ ~~. , ^' ~ 1_, "." >- o,,~_ .,.""",,.;).,'J" 'TIt"'J ,. DESCRIPTION ALL THAT CERTA.IN piece or parcel of land and premises, situate, lying and being in the Borough of Camp Hill, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the westerly line of 21st Street which point is -1-83.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at dividing line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots; thence along the same in a westerly direction 112.03 feet to a point; thence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction, 65.04 feet to a point at dividing line between Lots No. -1-8 and -1-9 on said Plan; thence along the same in an easrerly direction 11-1-.22 feet to a point on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East. 65 feet to a point, the place of Beginning. HA. VING THEREON ERECTED a one and one-half story dwelling house. more commonly known as -1-20 North 21st Street, Camp Hill, Pennsylvania. THE ABOVE DESCRIBED property being Lot No. 49 in Revised Plan of Country Club yIanor. Section A, as prepared by W. B. Whittock. Registered Professional Engineer. under date of July 18. 1955, which Plan is recorded in Plan Book 7, Page 36, on July 21 1955. TITLE TO SAID PREMISES IS VESTED IN James F. Higie and Karen L Pease, Single Persons, as Joint Tenants with Rights of Survi\.orship by Deed from Montadale Associates, Inc., a Pennsylvania Corporation and Steven Watts and Diane Watts, His Wife dated 5/20/94, recorded 5/23/94, in Deed Book 105, Page 923. ,.' '~lliIlliilll ~~.r.J::. '-fiW~~~~~_"-"-'--~:lliil <,.~-~~~~~. ,-., _II.~ ,..., . I " C..> f= ,~.. :../) -0 r.: ~T1 n~1 --iJ Z ..,.....: cn f"..-:. -, ,-' r- ~~ ::::;;--) Co .,.-" . , L D ;,; c:: ?? ?-:i z ~t; --I (." -c -< ....... - ~y\ d ~,..~ ~~ ~, "-t rP '. ~ ~ ~ €~ ~ , ~ 11, , I\.J l.>.I .. ",. ~ h ~~~ ~ ~ ~ 't d ~ ^ --~ ,,; ,"'OC' CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS JAMES IDGIE KAREN L. PEASE CIVIL DIVISION NO. 00-3261 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CROWN BANK.. FSB, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 420 NORTH 21ST STREET. CAMP HILL. PA 17011. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JAMES HIGIE 420 NORTH 21ST STREET CAMP HILL, P A 17011 PRESENT WHEREABOUTS UNKNOWN KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , .~ .'.- ~. - '-'-:.- ~ oL r.~. 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 420 NORTH 21ST STREET CAMP IDLL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Camp Hill Borough 2145 Walnut Street Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 6, 2000 DATE ~~~ F KF E , ESQUIRE Attorney for Plai tiff iI~~~~~~i!~~_t&l~iS!iy:i~,_.:.li"-,,"_"'iielilliili<;"'~'kiiil''''<~'''''~ ~,/dIr""';';'> ~~M'~~"'" ......~"' ~, C) C- :;=;: d~f~ ~~ ...--.:: Cn -< .'-~- ~~) z~._' j>~~ -- -< ~~ '-41 :/') T1 ,] i"., ':::1 :.) OJ .:;::, ::'"< - " ,- , J ,hltlM: , CROWN BANK, FSB CUMBERLAND COUNTY Plaintiff, v. No. 00-3261 CIVIL JAMES mGIE KAREN L. PEASE Defendant(s). September 6, 2000 TO: JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 JAMES HIGIE C/O DOLORES B. HIGIE 215 NORTH 17TH STREET CAMP HILL, PA 17011 P.O. BOX 132 CAMP HILL, PA 17011 "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 420 NORTH 21ST STREET. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6.2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CROWN BANK. FSB (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the MARCH 7, 2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ."M~~ ~~~ ,~ -~ ~ =-'-~< " ,,-,,~- p 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless elCceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ,'- ", ';j""'J DESCRIPTION ALL THAT CERTAIN piece or parcel of land and premises, siruate, lying and being in the Borough of Camp Hill, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows; BEGINNING at a point on the westerly line of 21st Street which point is +83.91 feet north of the northwesterly corner of 21st Street and Park Side Road, and at dividing line between Lots No. +9 and 50 on the hereinafter mentioned Plan of Lots; thence along the same in a westerly direction 112.03 feet to a point; [hence along the easterly line of Lots No. 64 and 65 on said Plan in a northerly direction, 65.04 feet to a point at dividing line between Lots No. +8 and +9 on said Plan; thence along the same in an easterly direction 11+.22 feet to a point on the Westerly line of 21st Street aforesaid: thence along same South 12 degrees 15 minutes East. 65 feet to a point. the place of Beginning. HA VING THEREON ERECTED a one and one-half story dwelling house, more commonly known as -+20 North 21st Street. Camp Hill, Pennsylvania. THE A.BOVE DESCRIBED property being Lot No. 49 in Revised Plan of Country Club :VIanor. Section A, as prepared by W. B. Whittock, Registered Professional Engineer, under date of July 18. 1955, which Plan is recorded in Plan Book 7. Page 36, on July 21 1955. TITLE TO SAID PREMISES [S VESTED ["I James F. Higie and Karen L. Pease, Single Persons, as Joint Tenanrs with Rights of Survivorship by Deed from .'v[onrada[e Associates, Inc., a Pennsylvania Corporation and Steven Watts and Diane Watts, His Wife dated 5/20/94, recorded 5/23/94, in Deed Book 105, Page 923. ,..~' ~ 1IW1liti "'"~~..m!bimh!tl:I~r...tjf-' ~~1Smc'''';;0;J~'&'jjl'tl;_!ID!>lIl~ii!Jii!lil~~ ~, "-"~11Iilliit:ilIi:~~lJ1!llrf - ,_.. - ~. (j s-; ::~-- -GI-'- S~ C~ 0~- i~; pc'. z :'.;J llfil1f""- -:.0 --"'1 -:] t-".! ~', ~. :"'J nO) "" ~ -~ - , .~ ~~ t '1!\lM1;.: FEDE~andPHELAN By: FRANK FEDE~ Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF CROWN BANK, FSB Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION JAMES mGIE KAREN L. PEASE NO. 00-3261 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ., ,~. IL"- ~ill~~~B!lUM-ll::&i"-;;;'"*MlI~I;.o~r"''"''''''mj'f~;I;l\~~~',^""iIdI~:'''jit!I;;~~_~lUt~ -" ,,_,~v" --,,,.,~~'" - "~,=~ illiiiIIfiI~:i .- ,-' ~" ,- -~"-~ lit-wwuf ;' I' I' ~'~~~ ~ -- o c ui3~ nlt"- i.:' ........-.- r'" :::( e:::!:O>f_ i~j~,'; >- ~ co :") 'Cl J (',- :-:;.,, --.~ -c. r::J ~) ~ ,--",,- ~ -, "'-',,;k FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. !.D. #78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (? 1 ~) ~1l1- 7000 ATTORNEY FOR PLArnTllP --"'~\j CROWN BANK, FSB Court of Common Pleas Civil Division vs. CUMBERLAND County JAMES HIGIE KAREN L. PEASE NO. 00-3261 ORDER AND NOW, this z..l9- day of )2u,"",,- , 2000, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), JAMES mGIE, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 420 NORTH 21ST STREET, CAMP HILL, PA 17011. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: ~(t /14- / J. ~~ t-:;'7-00 RKS H:/Main Fonns/motions/county.comp 'ti~~~ili~c~m~-""'~!fi!k.'~.i9;lli-tl'-;;"-_~["':;~i;,.t!.?<'@ID'll>;l4"';,",~~W.~jIKgj..J'~ C"'U~~~" "'-", _l:!iill!l:l<llli.;l<lI~~ ' .:)= C\,] C\. f:::: ~ ,:j~:;; :, -) ~'-.~- "''''' ~-':J c, ~.- --<- '-' '--' , >';.::-' ._~:'~ }li! () ::::,: ("., "~:5 L_ " ~ --,.,-, ~-"~ " j ". ~'''';;:Iii, FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. J.D. #78020 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102 7.1 S) S/11-7000 CROWN BANK, FSB ATTORNEY FOR PLAThITffF Court of Common Pleas Civil Division vs. CUMBERLAND County JAMES HIGIE KAREN 1. PEASE No. 00-3261 MOTION FOR SERVICE PURSUANT TO SPRCT AT. ORnF.R OF COTTRT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 420 NORTH 21ST STREET, CAMP HILL, PA 17011 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with the Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". 3. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. ~o~ Lisa D. Blankenburg, Esquire H:lMain Forms/motions/county.comp "-,, -~ ~,- - .' -~, FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. LD. #78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (11 'i) 'i1i1- 7000 CROWN BANK, FSB ATTORNEY FOR PLAThITITF vs. COURT OF COMMON PLEAS CNll.. DNISION CUMBERLAND COUNTY No.OO-3261 JAMES HIGIE KAREN L. PEASE MRMORANTlTlM OF I ,A W Pennsylvania Rule of Civil Procedure 430( a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to detennine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment lInn7:l]pc: v<: Pnli". 238 Pa. Super. 362. 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." An~ptirm nf W~Ilc-PT, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom oflnformation Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriffs Return of Service, attached hereto and marked as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail. Respectfully submitted: ~~~b~U~ H:/Main Forms/motions/county.comp i .-,- -'. - , ," _ -~ ,; . ~,,", ",,,';""; '" - _.. SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-03261 P COMMONWEALTH OF PENNSY~VANIA COUNTY OF CUMBER~~ CROWN BANK FSB VS HIGIE JAMES ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff; ~ho being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HIGIE JAMES but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE FORECLOSURE , NOT FOUND , as to the within named DEFENDANT , HIGIE JAMES DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 S~._. rs: / ~ -~. ~~ .~ R. Thomas KlineP . Sheriff of Cumberland County FEDERMAN & PHELAN 06/06/2000 Sworn and subscribed to before me day of this A.D. Prothonotary EXH1BlTA "'~, EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: 1662250045 Attorney Firm: Federman & Phelan Subject: James Rigie Karen Pease Property Address: 420 North 21st Street Camp Hill, PA 17011 Last Known Address: 420 North 21st Street Camp Hill, PA 17011-2201 Current Address: 420 North 21st Street Camp HiD, PA 17011-2201 Last Known Number: George H. Lewis, III, being duly sworn according to law, deposes and says: I. I am employed in the capacity of researcher for EKL DATA, INC. 2. On March 27, 2000, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: 1. Credit Information A Social Secnrity Nnmber 1. James Higie: 174-46-6415 2. Karen Pease: 197-50-7913 B. Employment Search: Could not locate any employment information for the above named subjects at this time. C. Inquiry of Creditors: The creditors indicated that James Higie and Karen Pease botb reside at 420 Nortb 21st Street, Camp Hill, PA 17011-2201. II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has no listing for the above named subjects with an address of 420 Nortb 21st Street, Camp Hill, PA 17011-2201. III. Inquiry of Neighbors Contacted Mrs. Grass of 418 North 21st Street, Camp Hill, PA 17011-2201 and verified tbat James Higie and Karen Pease do indeed reside at 420 North 21st Street. N. Inquiry ofpost Office A. National Address Update: As of March 27, 2000 the National Change of Address has James Rigie and Karen Pease listed at P. O. Box 821, Camp Hill, PA 17001-0821. EXHIBIT B -.' L,-..- EKL DATA, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION V. Inquiry ofDMV The Pennsylvania Department of Motor Vehicles has James Higie and Karen Pease listed at 420 North 21st Street, Camp Hill, PA 17011-2201. VI. Other Inquiries A. Death Records: As of March 27, 2000 the Social Security Death Index has no death record on file for James Higie under his social security number nor is there a record for Karen Pease under her social security number. B. Public Licenses None found C. County Voter Registration: The county does not have James Higie or Karen Pease listed as registered voters with an address of 420 North 21st Street, Camp Rill, PA 17011-2201. D. AKA.: Jim F. Rigie - Karen L. Pease E. D.O.B.: James Rigie: 1964 Karen Pease: 1958 F. Miscellaneous Information None Subscribed and sworn before me on March 27, 2000. gLi~ /Notary Public NotarIal Seal EHen K. LewIs. Notary PublIc a.-r Merlon lWIl..MoIllllOmtl'Y County My CommissIon Expires l'eb. 24, 2003 EKL DATA, INC. e 1423 SUFFOLK LANE e WYNNEWOOD, PA 19096 Tel.: 1-888-829-5768 e Fax: 610-649-2637 e email: ekl-data@home.com EXHIBIT B ~u. - ",.... < '.- ~<, VF.RIFICATION Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: TlInp, 14. 1.000 Lisa D< Blankenburg, Esquire H:/Main Formsfmotionsfcounty.~omp ^_. 'I "~ -" "._""'-_" '^' _rK _'_, ~_ ":,w.,; :('1 1:1 " ; ~ II;,.:. " i I,' 1.1 I FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff 1'-, II " Ii.! :', , CROWN BANK, FSB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. JAMES HIGIE KAREN L. PEASE Cumberland County i:\ ; Defendants No. 00-3261 PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. J.t~ 1~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: July 3, 2000 ~_~u~~___it"llijj'l 1"P:i~~~i\lj~~~~~~-"~~.IiI''''''",~_h_o''.~ ,~. - .." , -~ ,.- ~ .,~... I.....", "'. -~; 0 0 0 C 0 "'-1 s: <- ,.-<1 -00:; t::: ~-"Fl iIJ mrTl r Z::O I --::J;f3 ZS; <.5' ,----,. I ~Z, ~:j~'~ !:2C' -0 :S::D '1>0 ~ z. 2M -c >c l'i' O' :'2 (..) ~ 0 '< "" - - ""'';;:'.-.r, FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (71 ~) ~(i1- 7000 CROWN BANK, FSB Attorney for Plaintiff : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. JAMES mGIE KAREN L. PEASE : CUMBERLAND COUNTY Defendant(s) : NO. 00-326 I-CIVIL AFFIDAVIT OF SERVICE OF COMPLAINT RV M A IT, PIJRSTJ A NT TO C:OTJRT ORnF.R I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to JAMES HIGIE at 420 NORTH 21ST STREET, CAMP mLL, P A 17011 and P.O. BOX 132, CAMP HILL, P A 170" and P.O. BOX 821, CAMP HILL, PA 17001 on 3~tD--OO , in accordance with the Order of Court dated JUNE 26, 2000. The undersigned nnderstands that this statement is made subject to the penalties of 18 Pa. C.s. ~4904 relating to nnsworn falsification to authorities. Date: Tllly 10, 7000 1MMJ ~ ~- RANK FEDERMAN, ESQUIRE Attorney for Plaintiff ",,,' "l~ -~.~II.li1nIlL:'"-"""".'o ~ ~ '.'j.j;ii'MIi1I~~~tJ;"!,,l~ .....'<j~~'--_-~-" ~~li!lIlIiiIM'IW"'" ~ 0 0 () C 0 "i.~ s: L_ V r("~ c:: m fT'l Z -,", r- .J---' Z ( '--, .. (J) ,~~:.. C<..J '--"', -< ~ -. (:::: C -D ,'r.! ~ j3: C" - Z .' -,.. ---.. (') c; >- C r'..) ~~ rr-: :z; .. (n --,...,~ ::;,: ~J '.0 -< ,~~-- .~- "~ ~ -" ~" ''''';'' . ,. FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CROWN BANK, FSB COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 00-3261 JAMES HIGIE KAREN L. PEASE DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. ~.;~. f -:7;J.,.~ . - FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: July 13, 2000 '- , .!' I' ... .' JAMES BlGIE #851183501 i , i I. I I ~ I I I i' VERIFICATION Michael D. WilliCIIIS hereby states that he/. is Assistant Vice President era.n Bank, F .S.B. of 1lE Live Oaks Gar<Ens; Casselberry, A- 'J'ZJ07 mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned ii, understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~~ Michael D. WilliilllS DATE: 5/25/00 - --...... i:.[, < FEDERMAN AND PHELAN BY: LisaD. Blankenburg, Esq. Atty. !.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 71 ~) ~1i1- 7000 CROWN BANK, FSB ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. CUMBERLAND County JAMES HIGIE KAREN L. PEASE NO. 00-3261 rF:RTTFTrATTON OF SF:RVTrF: I, Lisa D. Blankenburg, Esquire, herby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individua1(s) as indicated below by first class mail, postage prepaid, on the date listed below. JAMES HIGIE 420 NORTH 21 ST STREET CAMP HILL, PA 17011 KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 P.O. BOX 821 CAMP HILL, P A 17001 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: Tnllp. 14 7000 . ~- Lisa D. Blankenburg, Esquire Attorney for Plaintiff H:!Main Fonns/motions/county.comp _OJ,;:. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 A HORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CROWN BANK,FSB 105 LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 Plaintiff TERM NO. fJ-o- 3Ut ~T.u.--- v. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 1701 I Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan#: 851183501 _i FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 CROWN BANK,FSB 105 LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff lHJ - 3;), (" 1 (j) -. ""'T""'.t..<--- NO. ~ 1-< v. CUMBERLAND COUNTY JAMES HIGIE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE *'THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. *' You have been sued in Court. If you wish to defend against tbe claims set forth in tbe following pages, you must take action witbin twenty (20) days after tbis Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with tbe court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so tbe case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in tbe Complaint or for any otber claim or relief requested by the Plaintiff. You may lose money or property or otber rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 851183501 """";k%'i -I 1. Plaintiff is CROWN BANK,FSB 10S LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 2. The name(s) and last known address(es) of the Defendant(s) are: JAMES HIGIE KAREN 1. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/20/94 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter de~cribed to MEDALLION MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1214, Page 235. By Assignment of Mortgage recorded 3/2/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 491, Page 1111. Said Assignment was re-recorded on 10/17/95 in Assignment of Mortgage Book No. 506, Page 56. Said mortgage was modified as set forth in the modification agreement recorded 4/6/99, in Mortgage Book No. 608, Page 1014. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." . ;: ~'I .J 6. The following amounts are due on the mortgage: Principal Balance Interest 11/1/99 through 3/1/00 (Per Diem $15.65) Attorney's Fees Cumulative Late Charges 5/20/94 to 3/1/00 Cost of Suit and Title Search Subtotal $81,616.27 1,893.65 4,000.00 163.98 550.00 88,223.90 Escrow Credit Deficit Subtotal 883.76 0.00 883.76 TOTAL $87,340.14 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~ 1680A03c on the date(s) set fortb in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $87,340.14, together with interest from 3/1/00 at the rate of$15.65 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~~~ FRAJ{KFEDE~,ESQUIRE Attorney for Plaintiff . ~ - - - I I........._d ~ i:. . 05/17/2131313 1:5: 18 NO. 626 [;1132 ~ mQ.L/.14 to: rwen ft:t2Sc;~ 1f;L/;) N. .?-1~bi'.l.:amI/J"lI tt:L. /'JDIl; . . 10 :(JO.mes H!.9Ic:@f.O./*Jx82.J{I.(J(flptIlJlJfJr;....rJDOI- or-:Jr li~""" . " -to) SAP1.i:S HIJie @ '/d-O M ;lId 5r; t:./J1'1f'1I/LL-./ ~/9 1701:" , l..wr1w- f5 '11~.35o I ,- : ~ fease. . M. fare--.I ., 7()qq.:!lltxJ-o{)(>>-.;1l/f:(p~5 : iJamt:~ H~,'e...~. ~I #,'1rR1'.J'I~';}lfoll'43S~ ,'. I DATE: 'mlllz}'~' )()(J) i ! i , .. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR. HOME FROM FORECLOSURE . Thi~ i~ an o(fiei~lnotiee thnt tile mortl:lll:.l' on your home is in deCnul1. nnd the lender intendg to lor@rIM@. ~~eciii~ inform9tion about the nature of tile default il 9rovided in to nlftft4!hed P'Vel, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mll~ he 8hle to helll to save your home. This Notiee ellplllin~ how the Ilroerllm worlcs. 10 ~u~e aWMAP I!nn he1V. vou mu~t MEET WITH A CONSUMltR CREDIT COUNSRLINO AGt~CY WJ1:f':Uei 39 D^YS.QE..'IJfE DATEOrfm.s,JiQ]'JCE. Tm this Notice with you ",~eo you meet with the Counllelinr Arent;)'. The name. uddre!l.1I and phone number of Conlumer Credit Cnunlenn~ A.rend~ ~ervinl your County lire listed lit the end of this Notice. If vou have lIDV questions. vou DllIV call1he PennIVlvanift Hoi.s.illl. FinBllce J\t7@IU~\I toU trl!t! 1It l...8n{l..J42..2Jt.)7___(~erJjJns l'iithinq)!li.-@d hf!9rlnt! et.n ~!l.n om ~1!'l-l"(i9)_ This Notice contains important Icglll information. If you hllVli lIny questions, representatives_It the Consumer Crellit Counseling Agency may be able to help esplllin iI. YOII mllY also want to coniaCian nltorney In your arell. The loeal bor assoelation may be able to help you find lllawyer. LA NOTIFICAClON EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECfA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENnO DE ESTA NOTIFLCACION OBTENGA VNA TRADUCCION INMEDITAMEN"l'1i: LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSINfl FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN I)RESTAMO POR EL PROGRAM A LLAMADO "HOMl!;OWNiR'S EMERCENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL I'tlli:Oli: SALVAR SU CASA DE LA l'ERPIDA DI!:L PEllECHO A REDlMIR SU HIJ>>OTECA. eXH\B\T A 1'"G' I of S ""' - ;.01 .~ .~ . I~:;J HOMEOWNER'S NAME(S): KOJet"l Pease... PROPERTY AODRESS: 41.JJ N. c2IS;t" street- fa.mphill, fa.. nolI LOAN ACCT, NO.: $\S - 11 K'3S01 ORIGINAL LENOER: ~ iDn Mt7. ('J). CURRENT UNDERlSERVICER: Cro/un 8M/< .S. 13. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MA V BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR I-IOME FROM FORECLOSURE AND HELP YOU MAKE FUTURI~ MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACTOF 1983 (THE "ACT"), YOU MAY BE F.L1GlBLE 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 ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. I TEMPORARY ST A V OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. nlls MF.ETING MUST OCCUR WITHIN nil<: NEXT (3()) DA VS. 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 AGENClF:S -- 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 aller the date of this meeting. The mImes. address~\!Jiliphone f\\lmncrs uJ dcxi!:llil!.l:!L<;nllslIl11cr crcdit CtlllllSclill1! 1I1!cncics lor thc COlllltv in which the propertv is located are set [orth at the end of this Notice. It is only necessary to schedule one face-to-t:1ce meeting. Advise your lender immediatelv of your intentions. APPLlCA nON FOR MORTGAGE ASSISTANCE.. Your mortgage is in default tor the reasons set forth later in this Notice (see followinlJ pages for specific information about the nnlure of your e1efnull.) [fyou have triceland are unllble to resolve this problern with the lender, you have the right to apply for tinancial a~istance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must till out, sign and tile a completed Homeowner's Emergency Assistance Pro&ram Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling a~encies have applications for the program and they will assist you in submitting a complete applicalton to the Pennsylvania Housin~ Finance Agency. Your application MUST be tiled or postmarked within thirty (30) days of your tace- to-face meeting. YOU MUST FILE YOUR APPLICA nON PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, . FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL DE DENIED. . Page 2 of5 EXHIBIT A - - ,_ 0'- AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED llY THE FILING OF A PETITION IN llANKRUPTCY, THE FOLLOWING PART OFTHIS NOTICE IS FOR INFORMATION .PURPOSES ONLY AND SHOULD NOT llE CONSIDERED AS AN ATTEMPT TO . COLLECT TI-IE DEllT. (If you haye filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE' YOUR MORTGAGE DEFAULT (Brin~-it up to date). IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the followin amounts are now ast due: JI. .Jj. 73/- r:L beY - .w 73 :Z07J7) - oJ) <.p. Other charges (explainlitemize): . - - 3 15'1,1<>1 TOTAL.AMOUNT PAST DUE: . . Co..; _~I d1- B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot aoolicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the 9j1te of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TOTHE LENDER, WHICH IS $ /SC)Y. ;2..:+ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash cashier's check. certified check or money order made onvable and sent to: fa~!' rDo.n/(.~. ItH-a-rft'on: sh..fti HeifzhCl.LtSen 1n5 1_1v-e. DIlKs ens {l,Q$el'toeYYy. Fl. 3Z707 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date orthis letter: (Do not use if not aoplicahle.) .:....... IF YOU DO NOT ClJRE THE DEFAULT --If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril.hts to llccelerate the mort"ll!'e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due .is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal acllon to foreclose lIoon VOllr mort!.a..ed property. . Page 3 ors EXHIBIT A -- ..l II - - "~ oJ" """'.. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay ofT the mortgage debt. If the lender refers your case to its anomeys, but you cure the delinquency before tbe lender begins legal proceedings against you, you will still be required to pay Ibe reasonable allorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. ffyou cure the default within the THIRTY (30) DAY period. vou will not be reouired to pav attorney's fees. OTHER LENDER REMEDIES - The lender may also sue YO\I personally for the unpaid principal balance and all other sums due under the mortgage. . RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ri!?ht to cure tbe defiuilt and prevent the sale at anY time up 16 one hnur before the Sheriffs Sale. You may do so bv payin!? the total amount then past due. plus anv lale or olher char~es Ihen due reasonable attornev's Ices and costs connected with the foreclosure sale and anv olher costs connected with the Sheriffs Sale as soecified in writin!? bv the lender and bv oerformin!! anv other reouirements under the mort!!n!!e. Curing your defa!!lt in the manner set forth in this notice will restore your mortgage to the same po.sition as if you had never defaulted. EARLIEST POSSInLE SHERIFF'S SALE DATE -- [t is estimated that the eartiest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately lP months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before thci sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: wwn 80fl1(. r. 5.6 Address: 1D"5 Uve. 00.1\5 l::PnJens i?-assel DeI1'L/ . Fl. ;3;;'"10, .,. Phone Number: ROO-D'l~ -lOS, eJCt-.iF- l:zsq f.,u.liilll!Jill:: 407 -.;UK) -0=1 Coutactl'erson: 5hcrri H~it-z..ha.uSel\ EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sherift's Sale, a lawsuit to remove you and your furnishings and olher belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You_ mayor ~ay not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. , Page 4 of5 EXHIBIT A 'J YOU MAY ALSO HA VF: THF: RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PA Y 01'1' THIS DEBT. . TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT .HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE TI-IIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LA WSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY"OTl-IER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION . BY THE LENDER. . TO SEEK PRO'fECTION UNDER THE FEDERAL BANKRUPTCY LA W. CONSUMER CRF:DIT COUNSELING AGF:NCmS SERVING YOUR COUNTY IFill itllllist OffIll COII/lselill? Afellcies listed in ArJnelldix C. FOR THE COUNTY ill whiclr tire prooertv is locotetf. IIsill? (lflditiOlwl pares if lIeces.W1rvJ CUMBERLAND COUNTY '-' CCCS of Western Pennsylvania, Inc. 2000 llnglestown Road H~burg, PA 17102 (711) 541.1757 , FAX (717)541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Wavnesboro, P A 17268 (717) 762.3285 Urban Leatlue of Metropol!1an Harrisburg N. 6th Street . HarrIsburg. PA 17101 (711) 23+ 5925 FAX (717)234-9459 YWCA of Carlisle 301 G SIr..,t Carlisle, PA 17013 (717)243-3818 FAX (717) 731.9589 . Page 5 ofS E)CH\B\T A '. . _,'....c . " I I I I' I. Ii I: I' I I I, I " " Ii I., " I:; I' , , I! 1-' ,;: , " I,' , I': I Ii ALL THA T CERTAIN piece or parcel of land and premises, situate, lying and being in ttle Borough of Camp Hill, in the County of Cumberland and Commonwealtll of Pennsylvania, more particularly described as follows:. BEGINNING at a point on the westerly line of 21 st Street which point Is 483.91 feet north of the northwesterly comer of 21 st Street and Park Side Road, and at dividtng line between Lots No. 49 and 50 on the hereinafter mentioned Plan of Lots; thence alons.lhe saml!> in a westerly direction 112.03 feet to a point; thence along the easterly line of Lots No. 64 and 6!5 on said Plan in a northerly direction, 65.04 feet to a point at dIYlding line between Lots No. 48 and 49 on said Plan; thence along the same in an easterly direction 114.~2 feat to a point on 1he westerly line of 21 st Street aforesaid; thence along same South 12 degrees 15 minutes East, 65 feet to a point, the place cif BEGINNING, HAVING THEREON ERECTED a one and one-half story dwelling Ilouse, more commonly known as 420 North 21st Street, Camp Hill, Pennsylvania. THE ABOVE DESCRIBED property being Lot No. 49 in Reylsed Plan of Country Club Manor, Section A, as prepared by W, B. Whittock, Registered Professional Engineer, under data of July 16, 1955, which Plan is recorded in Plan Book 7, Page 36, on July 21, 1955. BEfNG the same premises. whicl, Faye R. Love, single person, by deed dated May 31, 1989, and recorded in the Office of tile Recorder of Deeds of Cumberland County, Pennsylvania, in Deed Soak Z-33, page 388, granted and conveyed unto Montadale Associates, Inc. and Steven Watts, Grantors herein. VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for plaintiff in this matter, that he is authorized to take this verification, and that the statements made in the foregoinc;r Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigued understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. -::r- ~ :r~ .,-. ;).J - ~OO DATE: ..) / ~~Ii_IIiI~~_~I,~,-...;.~tr~>Wd.iillli~J..~\lli'~~~' r~ " "'.I (,u ~ v ~~ I ~ ., " . ~ -"<- Ilila . ~ "^" -."- ". ./.,,,..... ~ "j.~'''''''''~'' ~ '"' E~ (~ ::::) CJ T} , ~::l , ~-!ll-:! t...) ~~;~ en 0'1 - Y ~-~""" ::-~:~ () c' ~;~~ ::.~ :;:; c-:J nl ~- --I =i. :,J ::<> (0 ::0 -< ~ r~ -f'~ Y'I ~ tr fU.. ~ "- -, =~ I 8 ? j ill ~ -t:. ~ ~ c d 8 d ~ r ;"_ il ~', " ,~- SHERIFF'S RETURN - REGULAR . CASE NO: 2000-03261 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CROWN BANK FSB VS HIGIE JAMES ET AL ~ I KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PEASE KAREN L the DEFENDANT , at 0018:48 HOURS, on the 31st day of May , 2000 at 420 NORTH 21ST ST CAMP HILL, PA 17011 by handing to KAREN PEASE a true and attested copy of COMPLAINT - MORT FORE together with FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: ~~~I~~/!,<? R. Thomas Kline 06/06/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: me thi s 1..2 <!:: day of ~;l...ITlJf) A. D . Ck-t~2~ ,~~ ~. ~. ~ ,I -k " SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-03261 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CROWN BANK FSB VS HIGIE JAMES ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HIGIE JAMES but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE FORECLOSURE , NOT FOUND , as to the within named DEFENDANT , HIGIE JAMES DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEFT NO FORWARDING WITH THE P.O. Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 S~~~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 06/06/2000 Sworn and subscribed to before me this 1:2~ day o~, . .2 IJ7J"O A . D . ~ (), h."h.., #= P honotary I ~ .~~~ '--" . , FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE lDENTIFlCA TION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 CROWN BANK,FSB 105 LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 0-0- 3:nl ~!,L.,- v. CUMBERLAND COUNTY JAMES HlGlE KAREN L PEASE 420 NORTH 21 ST STREET CAMP HILL, P A 17011 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. *' You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 We hereby certify the within to be !l. true and correct copy of the original filed of recopr~ELAN FEDERMAN AND Loan#: 851183501 TRUE COpy FROM RECORD to Testimonywhllf80f,1 hereunto s8t iny hllnd and ltle seal Of said Court at. CarlIsle, Pa. This .,2~ aL?;::z ,. .2nJ1J . a.'n.J.tI.~. ~ _ Prothonotary ; ,-, "'" I L Plaintiff is CROWN BANK,FSB 105 LIVE OAKS GARDENS, SUITE 129 CASSELBERRY, FL 32707 2. The name(s) and last known addressees) of the Defendant(s) are: JAMES HIOlE KAREN L. PEASE 420 NORTH 21ST STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/20/94 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEDALLION MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1214, Page 235. By Assignment of Mortgage recorded 3/2/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 491, Page 1111. Said Assignment was re-recorded on 10/17/95 in Assignment of Mortgage Book No. 506, Page 56. Said mortgage was modified as set forth in the modification agreement recorded 4/6/99, in Mortgage Book No. 608, Page 1014. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." .~ , 6. The following amounts are due on the mortgage: . ~ - I I I I I I Principal Balance Interest 11/1/99 through 3/1/00 (Per Diem $15.65) Attorney's Fees Cumulative Late Charges 5/20/94 to 3/1/00 Cost of Suit and Title Search Subtotal $81,616.27 1,893.65 4,000.00 163.98 550.00 88,223.90 Escrow Credit Deficit Subtotal TOTAL 883.76 0.00 883.76 $87,340.14 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. S1680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $87,340.14, together with interest from 3/1/00 at the rate of$15.6S per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff