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Home My WebLink About00-03272 l_ J J'. . ~~ If' ''''" "'- HOMESIDE LENDING, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 03272 CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, Defendants IN MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to-wit, this day of , 2000, upon consideration of the Plaintiff's Motion for Service pursuant to special Order of court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED the posting of the Handbill on the subject premises at 113 Walton Avenue, Carlisle, PA 17013 by the Sheriff thirty (30) days before the Cumberland County Sheriff's Sale, the mailing of Notice by ordinary and Certified mail to Defendant Woutera J. M. Gentile's last known address and the publication of the notice of the Sale of the subject premises as required are sufficient notice to the Defendant of the December 6, 2000, Sheriff's Sale to satisfy the notice requirements of Pa. R.C.P. 3129.2, ~wl, ':'L ':'.23 [u..L.Lhe:.J:: ORBERliV +-n-d- t-no. C!1lnjiO("'t- rY'o.1"'I"'l-: .....-=>.<"' C!n.:=.ll nQ C!,..."l..-l li?~~ ~Re BY J ..- 6.~ C1.dVt:=L Lll::lt:::J. C1..wJ .=lcL":"8.l.!iLl@8.. , """ "."'iiWImllii!.!~.~Mi!ilI;~il~:;lO,iM,;kL~;.j~~~mmi~f~'~"'''HlilIlll..l' it ~';.i ~~ G\- t~~ .~ \ o " ,~, ,~, ...~ ~ "~.',~ ~"1lI1JrlNI : '1r""'"'~ }JN1lfffj'(/~ASNN3d . I 0.., ~,N'v'll!CJ81/lJno .., G'l :[; r~d r; - JJa 00 t!t~'\fl~--" "~' \(J\..j.liNlr'..Jd":"., "'., t"l 36[~;rO~J3li,~i ; L ~1\~1 ~=,~,," , ,. ,,=~" , " ~ ~ ."'Ii' " ~ "~'I . ~'~-" J'u.;I,,-,,1 HOMESIDE LENDING, INC., Plaintiff IN THE COURT OF COMMON PLEAS nEe 0 52000ff CUMBERLAND COUNTY, PENNSYLVANLA VS. CIVIL ACTION - LAW NO. 2000 03272 CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, Defendants IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129(b) (2) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Homeside Lending, Inc., through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by Defendants located at 113 Walton Avenue, Carlisle, PA 17013. 2. Defendant Charles William Gentile was served with the Complaint, June 12, 2000 at 418 South Hanover Street, Apt 2, Carlisle, PA 17013 and the Defendant was also served with the Notice of Sale. Defendant Woutera J. M. Gentile was served with the Complaint by Defendant's son in law, Jeff Havlman accepting served for Defendant Woutera J. M. Gentile at 105 Claridon Place, Carlisle, PA 17013. However, the Sheriff's office has been unable to serve Defendant Woutera J. M. Gentile with the Notice of Sale at the address where Defendant was served with the Complaint, at the property, or locate any new forwarding addresses for the Defendant. The Plaintiff believes that the Defendant has no interest in the property and has no desire to oppose the Sheriff's Sale. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, the Department of Transportation, Credit Bureau, and also by attempting to obtain a phone number. for the Defendant, but no new information has been received from any of the sources. . I , ~-\$;;, 4. The Sheriff heretofore posted the Defendant's property with of Sale or Handbill. Notice of Sale was also sent by and Certified mail. Sufficient notice has, therefore, been the Defendant. Plaintiff believes that service by mail in accordance with a Notice ordinary given to 5 . Rule 430 (as allowed by Rule 3129(B) (2) (ii) (A) will be ineffective and that a Special Order of Court is required. 6. The Notice of Sheriff's Sale scheduled for December 6, 2000 will be published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale. 7. Plaintiff requests an Order approving service by posting a copy of the Notice of Sale or Handbill on the most public part of the property under P.R.C. P. 3129. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. BY Leon P. Haller Attorney for Plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 -", 't' .~- '...~~~ " . ~ ",,~, = , ,", ,.....~~.""'~~~""~I"""'-,,~l~lli~~___'~';\'" ''''''K , ~" , ~. ~iliil.!iliI!iI' 'y" UI ,_......,."".'"'.,;.,~~.~'<o" "I I I I I I , , , - .'-~," , 'l~g~::y HOMESIDE LENDING, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 03272 CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE Defendants IN MORTGAGE FORECLOSUREASSOCIATES AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant Woutera J.J. Gentile in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: __~__That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. X That he has attempted to locate persons of similar name to the -----Defendant, however he has not been able to locate any. ~ That he contacted Directory Assistance for any new listing for --Defendant, however, there are no new listings. __~__That he contacted TRANS UNION Credit Bureau, a national credit _J_,_ - ,~ ~- ... service, with respect to the location of the Defendant. __K That he has conducted a search of the Pennsylvania Department of --Transportation's records with respect to the location of the Defendant. The Defendant was not found at the address provided. Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. , & HALLER BY: Leon P. Haller 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 Attorney for plaintiff Attorney ID# 15700 Sworn to and subscribed before me on this '-f day of f:::>et:..- ' 2000 ~OVI f?()~ (Notary) --------......--.., - ~~' r'"1 :ll C'~ '\ I l',JO ~IL,)-\,}>,L. 'L..Jt'..hL SI,..'h.J^\':' fJ n~t,qt\! [\\;\~;;r',' P!\I)Hr: I w,,\ll 'i . ~.,v~\j, ~ ,~,..,.u. '-' City of Harrisburg Oauphul County My Commission EY.plms NOli. 3. 2001 ii:.- - "",l ~., '='-~ '''''~,,",'' . 455 Linden Street, Allentown, PA 18102 RR 3, Box 2025, Effort, PA 18330-1901 v' Allentown Office: 610-395-8741 Pocono Office: 570-992-2425 e-mail: mkrotz@earthlink.net >~. ~~.~~ ,~ ~ Loss Preveritlon . As'set 'Searches . S'usidess1rifetf'iience Insurance Fraud" Skip-Tracing . Missing Persons Background Investigations . Witness Interviewing Undercover Investigations *' Personal Protection Pre-employment Investigations *' Surveillance Process Service .. Litigation Support RULE 43iOl JINVE5\UGAUON GOOD JF AJIlli AJFJFIDA VII INVESTIGATIONS & lEGAl SUPPORT SERVICES ~kiptra(e Report Caption HOMESIDE VS GENTILE Court Term No. 2000-03272 To: BARB VILLARIAL Your File No. H03356-17764 Date: 12/05/00 CI Doc. No. 00-340 Known Information . Name: WOUTERA J. GENTILE Address: 105 CLARIDON PLACE CARLISLE, PA 17013 SSN: 435 27-1817 INVESTIGATION REPORT Identifiers from Public . , Sources Listed on Page 2 Name: WOUTERA J. GENTILE Social Number: 435-27 1817 State of Issue: 1976 Year of Issue: LOUISIANA Year of Birth: 03/1944 Driver's License No ': NO RECORD FOUND State of Issue: NOT APPLICABLE File Creation ...a,,, . 02/1983 Last Record Found On': 07/00 MOST CURRENT ADDRESS(ES) Most recent address obtained from public records: SAME AS ADDRESS PROVIDED Address': Defendant #1 : 105 CLARIDON PL., CARLISLE, PA 17013 Defendant #2: NOT APPLICABLE !_!~~~~~.I:'_~~!~~~!~'Y..~~~,:~~5~..u________...._........_...______......_ Defendant #1: i (71 7) No Record Found .".--.....-."..."...--.---.----------."-!--.".".--.--"-."------."...--.".".".......-.".".....--."--.".".".".".".".......,.-....,......................."."...."......-..."..........-".---".".".-,"--.",",",".--'"'"."'-."."."'-.".".--."."."...."."..."....,..,..,.."...................".........,.. Defendant #2: i NOT APPLICABLE ."......"......."...".--'"-.".--.".".--."-.--."-.--."...-----.".----."."...-.........."................"........."."..........,..................................................,.-....."."."."..."."."...".".."".".-----...-".-'"-."."."."."."...........,.."..........,............"................".-....,....".".........".",".".".".-"-.".".".-".".". 1 Obtained from Consumer Credit Report Header File. DMV records are not accessible for purposes of SkipTracing. See notice on page 2 under Department of Motor Vehicle Operator Information. 2 Original date subject's record is listed in Consumer Credit Report Header Files. 3 Date most recent address was reported in Consumer Credit Report Header Files. , Most recent address found after reviewing all address sources. 5 As listed with A T& T directory assistance or from Info USA telephone database (listing most recent record). ~ "".1 -~~ ---,,;,jj CONSUMER CREDDT REPORTING AGENCY SEARCH 1-'"'"'---'.-...............--.--'".-."..---............,_.".".__._...........,........m.._."."."._........,..,..........._""""'"."'.._.................. ..............,...,....___ ,",................... ..'...'____.....__...........,............,.,.,__,...................,..'u... ........'____'......................,.... i 105 CLARIDON PI~ACE, CARLISLE, PA 17013 REPORTED ON TRACK 2 ON 07/00 i i 113 WALTON AVE, CARLISLE, PA 17013 REPORTED ON TRACK 2 ON 02/97 . iiiformatioii Sources: Ciins'umer-CrediiRepoiiiiig)\genclessea rChedTriCiudeiff;ansUiiion(CredifTieaderi};Expeilan'---' (Credit Header 2), Equifax (Credit Header 3), and proprietary information sources inciuding magazine subscription services, national telephone white pages and insurance records. UNITED STATES POSTAL SERVICE - Postal Regulation 39 CFR 265.6(d)(6)(ii). ~1l9.~Il.~t_!~.r.~~ll_rl.!!Il~!.~~~.~Il.~~~Il~~I!~:.... ..................................... ................_... 17013 PENDING ;;Celtifiedcojiy.alliichiiij'...._.... ............--..... .....,..............,...............-,.'"."."."."," , , .........,.,..............J PUBLIC RECORDS SEARCHED - State and National Records - See page 3 if records were found n"""n.....'u__.__._._"..."____._'"'__,____._.......,...__--...-.--'-----.---.....--.......-r-Tun........-"-"...---,__'__"""..__.......__.....,..,u......................n__'_'"'__'."__''''''''''.''''.'.'.'.'''''''.''''''''''_'.''''.''''_...'""..._"._'"...__..............,.........,........,..,..... ; Bankruptcy Court Records Search i Records Found ' ,...,__,_...'"'....__.............__....._...__._____.___.0__._---.--........--......--.-..........--':2-.;'.'----.................n,..,...n.......................__,",_,","."_.".......__........n__n..'..'..,....,..... ............,..,---.'.._...,................,.......,..,..,......,..,..........",,,,,__,_"_"_,___,",__,.._,",.,.,, .......................,.............. I Social Security De@th Index Search i No Records Found ;'"'"n..'......'.....n...........,..,._.......,..,...._.".".".__"'",__,...,""'''''''''''''''''''''''''''''''''''''''.'"'"'___'"'"'_"'___.L......._......_................_..,..,..,..........'"."..,.."'"."._._,".......,.....................,.....,..,...........,.....,.......____,"_,"_...._."...._..................,..,.........,..,.........,....."."."'_'"'"'"'"'_"'_'__'........."'''''''''''''''''''''''''''''' ........"......."....".,._ ".",",,,,"."....~ 1Bankruptcy records search conducted using subject's social security number in all states found in subjecfs address history. 2Social Security Death Index Search is nationwide. VOTER REGISTRATION RECORDS SEARCHED ..............'.......--...-......-...-----1-".".".".----.............--........,..........-.".".......--.".".---,"--.......--........................ County: i CUMBERLAND COUNTY, PA i"'".."''''"'-'--,.....,................................................"."t"-."-."."'-----....--....................................,..,..,..,....."."..........."..."..".....,.,-,",". ,_...._~:~~~t~_L~<::~~~~~.~_!~~~~....__....__... ...:T~~!~~~~:~~:__L 71!~?~?:::~~~~' ".".".",",",.,""j DEPARTMENT OF MOTOR VEHICLE OPERATORS INFORMATION The Federal Driver's Privacy Protection Act (OPPA) effective 9/13/97/imits access to driver and vehicle information. A signed release from the driver, or a notarized statement of intended use by an authorized requester is now needed to obtain driver and vehicle information. Driver and vehicle information is no longer available for skip tracing purposes. AFFIDAVIT OF GOOD FAITH INVESTIGATION Affiant is the principle of CONFiDENTiAL INVESTiGATIONS which performs investigative services and states that he has made a good faith investigation by performing each of the stated searches. I verify, under penalty of perjury, that the foregoing is true and correct, to the best of my knowledge. I understand that false statements herein are made subject to the penalties relating to unsworn falsification to authorities. Affiant: Megan Krotz Investigator Sworn and subscribed before me this of 20_. day P?epre.sentafiVEi or r:'E:Ni'j8Y: \-'AN!.1l, ~-,CI:Nm5fJ !1'-l\/r::ST:GATOf~ EfI{~ ~;. f<erchnBr Comlly of iVlomol2 Ucens8 No.1 03 Expires: 0.1101/200'1 Phone: 570-992..24:25 i'IIllJ'!ai''l Sea! . ,~ "' ~~. ~", ']' ,,"" ~'f"W. HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, pennsyl vania on q It ~ 100 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.s. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Charles William Gentile 418 South Hanover Street Apt. 2 Carlisle, PA 17013 Woutera J. M. Gentile 105 Claridon Place Carlisle, PA 17013 Ford Consumer Discount Company 3220 Tillman Drive Bensalem, PA 19020 Associates Home Equity Services, Inc. f/k/a Ford Consumer Discount Company 11311 Cornell Park Drive Cincinnati, Ohio 45242 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 BY~ PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~'", "" "' " .'''''~' -- - '" "'..'."<"C' ",,",'I JOHN W. PURCELL HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. BRIAN J TYLER JILL M. WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Charles William Gentile 418 South Hanover Street Apt. 2 Carlisle, PA 17013 Woutera J. M. Gentile 105 C1aridon Place Carlisle, PA 17013 Ford Consumer Discount Company 3220 Tillman Drive Bensa1em, PA 19020 Associates Home Equity Services, Inc. f/k/a Ford Consumer Discount Company 11311 Cornell Park Drive Cincinnati, Ohio 45242 Domestic Relations Office CUmberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that ou have an opportunity to protect your interest, if any, being notified of said Sheriff's Sale. By: Leon P. Haller PA I.D.15700 Attorney for Plaintiff . ""'- I~ ' '" --. 1'- '"'" " "r." '''' ~- ~ ' , .....;.". HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 113 WALTON AVENUE CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 03272 THE NAME(S) OF THE OWNER{S) OR REPUTED OWNERS of this property is: 1:\HOME\MKF\DOCS\CUMBERLA\GENTILE.NOS ,,~' ," ,,'~ _' '.,'~'" ,..,'.--."A;~ ',;,'" """~j ~'j'~ --,. .', "',, CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. .'h~ "' ,,", -- ",' '< "'--..q .''''",;,,,'''_ ., '=r~ rljJ..C' 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ,_l' 'L.h' '~, ~'. ALL that certain tract of land with the improvements erected situate in North Middleton Township, Cumberland Pennsylvania, bounded and described as follows: thereon County, BEGINNING at a point at the intersection of the Eastern line of Fifty (50) feet wide Walton Avenue "ith the Southern line of Fi fty (50) feet wide Clarindon Place; thence from said point at the place of beginning along the Southern line of said Fifty (50) feet "ide Clarindon Place, North 71 degrees 36 minutes east, a diytance of One Hundred t"enty (120) feet to a stake in line of Lot No. 15; thence through said Lot No. 15 by a line parallel to the Eastern line of Lo~ No. 16, South' 05 degrees 18 minutes East, a distance of Eighty-five and TwentY-'eight Hundredths (85.28) feet to a point on the Northern line of Lot No. 18; thence along a portion of the Northern line of said Lot No. 18 and all of the Northern line of Lot No. 17, South 76 degrees 30 minutes West, a distance of One Hundred Eleven and Forty Hundredths (111.40) feet to a stake on the Eastern line of said Fifty (5.0) feet wide Walton Avenue; thence along the eastern line of said Fifty (50) feet wide Walton Avenue by a curve to the left, having a radius of four hundred twenty-five (425) feet, an arc distanc~ of Seventy-four and seventy-nine Hundredths (74.79) feet to a point on the Southern line of Fifty (50) feet widelarindon Place, the place of BEGINNING. BEING ALL OF Lot No. 16 and the western portion of Lot No. 15 as shown on the Walton Avenue Plan. HAVING A DWELLING ERECTED THEREON KNOWN AS 113 Walton Avenue, Carlisle, Pennsylvania. BEING THE SAME PREMISES WHICH Robert P. Blanchette by deed dated 9/5/89 and recorded 9/19/89 in Deed book E-34, Page 208, granted and conveyed unto Charles William Gentile and Woutera J. M. Gentile, his wife. TO BE SOLD AS THE PROPERTY OF CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE ON JUDGMENT NO. 2000 03272. ASSESSMENT: 29-17-1585-043 Ir rn ...lI .::t' ~ ~ CJ ~ Postage $ Certified Fee Return Receipt Fee ~ (Endorsement Required) t:J Restricted Deliveiy Fee I:] (Endorsement Required) CJ CJ .::t' ITI IT' IT' CJ ~ :J :J r n WOUTERAJ M GENTilE................................... _ 105 ClARIDON PlACE.................................... CARLISLE PA 17013 Total Postage & Fees $ . ,1,- Ut~..,' ^'~ -je-, -., . .''''''' Postage $ r.\ ~::-~.." ~, "<,-"",~, ~~""'.<-'''--- ~~ P~t'k\ <a\ H'l'i'; . ~~ Certified Fee 1J Return Receipt Fee -=I (Endorsement Required) :J :J Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ CHARLES WilLIAM GENTILE ; 418 SOUTH HANOVER STREET APT 2 -CA~ltSLE PA 17013 .un__n_.______n___.___ n..__'___"__'__nh__h ~ ~ Re: Homeside vs. Gentile Cumberland Sales 12/6/00 . . U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Charles William Gentile 418 South Hanover Street Apt. 2 Carlisle, PA 17013 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Woutera J. M. Gentile 105 Claridon Place Carlisle, PA 17013 Postage: Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: , , Ford Consumer Dlscount Company 3220 Tillman Drive Bensalem, PA 19020 Postage: Postmark: .. , '"'" - ,., ", ",~ ^ A ,'^ '~" ,"~ __, ',_ , ' .. U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service For.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Associates Home Equity Services, Inc. f/k/a Ford Consumer Discount Company 11311 Cornell Park Drive Cincinnati, Ohio 45242 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service For.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 . . . . ...-'..', """f"""'''',,_ '~N'" ~,,'~ ~-.-,~~ ,"~ ,. e~h lIiIl ;' -ill ~o, ';"-" "^ o c: :s:: -om 9293 zc- CIJ ~J.::'" ~..... ~, ~:~.~=~ L.. ;-" :'f~(= ? ~ .. . '. C> c. o ,." n I 01 o -n ::;j -"~-r, rnr=:.: -nfn :,;-,0 " ~.;'" ;;~ ~A ~:,--;{ :I~ Xl -< t.:;) :;:1 (1) ,=u~ . , ......~, .I I _~~Ilc~-'I I I I I , . SHERIFF'S RETURN - REGULAR CASE NO: 2000-03272 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMESIDE LENDING INC VS GENTILE CHARLES WILLIAM ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GENTILE CHARLES WILLIAM the DEFENDANT , at 0020:30 HOURS, on the 12th day of June , 2000 at 418 S_ HANOVER ST APT 2 CARLISLE, PA 17013 by handing to CHARLES GENTILE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31. 10 So Answers: ~~ ~ 1~ R. Thomas Kline 06/15/2000 PRUCELL, KRUG & HALLER Sworn and Subscribed to before By: .tw me this do '- day of ~; O.~:' .;; Prothonotary . ,-,"" .~-, J_, ~" . .- '".' O. SHERIFF'S RETURN - REGULAR CASE NO: 2000-03272 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMES IDE LENDING INC VS GENTILE CHARLES WILLIAM ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GENTILE WOUTERA J M the DEFENDANT , at 0009:46 HOURS, on the 14th day of June , 2000 at 105 CLARIDON PLACE CARLISLE, PA 17013 by handing to JEFF HAVLMAN (SON IN LAW) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 3.10 .00 10.00 .00 19.10 So ;;~~ R. Thomas Kline Sworn and Subscribed to before 06/15/2000 PURCELL, KRUG & HA. LLER ~ n By: j) ro.. III ~ I~ P(~ h Off Deputy S erl f&.- me this ~o day of G",-,- c2 d?!I) A. D . ~ten~/I~< - ,', '"--" " ~'~~,~ . HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $13.45 from 6/1/99 to 6/1/00) Accumulated late charges Late charges ($32.65 per month to 6/00) Escrow Credit 5% Attorney's Commission $70,145.12 $ 4,909.25 TOTAL $ 489.75 $ 391. 80 $ 738.57 $ 3,507.25 $78,704.60** I 1'-: ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. it I, PURCELL, KRUG & By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 I:\HOME\MKF\DOCS\CUMBERLA\GENTILE.P .....; -.J>.'" " - ~ d, ~"", - j \L (. o. HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on AUGUST 23, 2000 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ,,".~ ~ ,,"" ,.. . ; ,""',.""~ ~"" '"" -- -. "'.'~-'.- ~" .... 0' .. HOMBSIDE LENDING, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 2000-03272 CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE Defendants CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: August 23, 2000 TO: CHARLES WILLIAM GENTILE 418 SOUTH HANOVER ST., APT. 2 CARLISLE, PA 17013 WOUTERA J. M. GENTILE 105 CLARIDON PLACE CARLISLE, PA 17013 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Court Administrator cumberland County Courthouse Carlisle, PA 17013 717-249-3166 PURCELL, By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 717-234-4178 . . , ~. 'L_ '-",'- ~^ . ",'> ,','''0", '~"...",',", -,' "-.--" " 1;&"'" . ~ -' . HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and sub~ibed : befor, ~. this I day: of~~ 20#-P : ~ ~~i ~M-A"-' !tary Pul51ic LEON P. HALLER, ESQUIRE NOTARIAL SEAL MAAYLANO K. (iilRRelil, Notary Public LOWER PAXTONlWl'., DAUPHIN County M;'Commission ~~biresAYQIJ$T 8 2002 """',;,,___,~ ~^ ,c_ """,~,,, ,l", d"'-' . -..i>Ili..J~~ ""->.~'.. ' '~~~i!iilllillillal/jllidlHiliiliilllulll~_." "''-~.IiIll--. ~,;"" ~ '" r~ ~ ~ '0' L ~ ~ ~~~ ...... ~ 8 \SJt ;8 ~ '-0 --- , , ~ , ~ ~ ~ \" ~- " 0 ..........,' ~ ti: ( ~ C) S~ <:- l)i:,,; ITJ["', z. ;::::1 {/) ~ ~L~ r-,,_ ~2 o<"~ -7 -', , . p'" ::./) .-cl ., f',,,..:.. .'--. , (--:; -;;-;J :--.~ ]:> :_.1..1 -< ::::> \0 ~ '"'^'--"..~ 1-;'--:"" ,'-,\; - ,____,,"_ ~'~, ' ~) " 0:>' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: HOMESIDE LENDING, INC., Plaintiff ( ) (XX) Confessed Judgment Other IN MORl'GAGE FORECI.C6URE 2000 03272 File No. / $ 78,704.60 2,528.60 vs. Amount Due per iudqment " Interest $13. 4 5 ,~e,r diem 6/1/00 to 12/ /60 Late charges $32.65 per mo. Escr= Deficit Costs 67.25 2,000.00 CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, Defendants TO THE PROTHONOTARY OF THE SAID COURT: Total $ 83,300.45 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act7 of 1966 as amended; and for ,eal property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMBERLI\ND for debt, interest and costs, upon the following described property of the defendant(s) Real Estate: 113 Walton Avenue, Carlisle, PA 17013 County, IN MORl'GAGE FORECLOSURE PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply si ies of the description; supply four copies of lengthy personalty list) EST indic above Ch 1 1 aFl Gent' ~d.W;utera J. M. Gentile and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). q-o-uv P--ef ~1J.f{ Mo-.ryCu.......:t .~ CJ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real e of the defendant(s) described in the attached exhibit. SEP 0 B 2110O Date Signature: Print Name: Address: leon P. Haller , Esquire Purcell, Krug & Haller 17]9 l\To-rth F=i;: St;r.eQi;: Harrisburg, PA 17102 Attorney for: Telephone: Supreme Court ID No.: PI1UNTIFF 717-234-4178 U5700 (over) ;-.;''-T'~, - .r W'l'Iil--".'"""" '~'_~l!'II,'dllilliiiiil:LLi ,.~, ~"~ n ~ - 'II i! " ~ 6- ;i ,I l:j ~I '(I ,i! 'I iil r:J "JIl ~~" '0'- "~'~ "', ... " ">-- ALL that certain tract of land with the improvements erected situate in North Middleton Township, Cumberland Pennsylvania, bounded and described as follows: thereon County, BEGINNING at a point at the intersection of the Eastern line of Fift>, (50) feet wide Walton Avenue with the Southern line of Fi fly (50) feet wide Clarindon Place; thence from said point at the place of beginning along the Southern line of said Fifty (50) feet wide Clarindon Place, North 71 degrees 36 minutes east, a distance of One Hundred twenty (120) feet to a stake in line of Lot No. 15; thence through said Lot No. 15 by a line parallel to the Eastern line of Lot No. 16, South' 05 degrees 18 minutes East, n distance of Eighty-five and Twenty-eight Hundredths (85.28) feet to a point on the Northern line of Lot No. 18; thence along a portion of the Northern line of said Lot No. 18 and all of the Norlhern line of Lot No. 17, South 76 degrees 30 minutes West, a distance of One Hundred Eleven and Forty Hundredths (111.40) feet to a stake on the Eastern line of said Fifty (5.0) feet wide Walton Avenue; thence along the eastern line of said Fifty (50) feet wide Walton Avenue by a curve to the left, having a radius of four hundred twenty-five (425) feet, an arc distane~ of Seventy-four and seventy-nine Hundredths (74.79) feet to a point on the Southern line of Fifty (50) feet wide .larindon Place, tht> place of BEGINNING. BEING ALL OF Lot No. 16 and the western portion of Lot No. 15 as shown on the Walton Avenue Plan. HAVING A DWELLING ERECTED THEREON KNOWN AS 113 Walton Avenue, Carlisle, Pennsylvania. BEING THE SAME PREMISES WHICH Robert P. Blanchette by deed dated 9/5/89 and recorded 9/19/89 in Deed book E-34, Page 208, granted and conveyed unto Charles William Gentile and Woutera J. M. Gentile, his wife. TO BE SOLD AS THE PROPERTY OF CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE ON JUDGMENT NO. 2000 03272. ASSESSMENT: 29-17-1585-043 " " -" -~ " -,~ ~i ~ ~, ,",' ,,<< ,~~" ~' ~'"~ , "~,L 'liUl.!il~n'7'~~""" ,. ,,' >il-llli\ii~"HU,,;y:,'u~m,-~~ - ",.,( "",-,,', -, " "~,--'", 't~ ~ ~ ~ iIIII<llllll --- '1--:J 9--> . \~ ..~ FD ~ ~' o . ~ UJ ~ ~':"" ('J'. ::-- ~\ ~ <6l ~ 0 ~'G - \ ........ ~r ,," - ~ ~~, --<..,,' ~, --, , ~,~ ~ ;:gr~~ Z". 2--: ~~f::-' <; ~~l :::-:.: -' -< 0') ,uq .-" j'--..... :""h -~ ~ ~ <0 ( 1 A.......... ..,. , r tl Ii -] I fi I II ~ I I I I I ~ ~ ) .1 .:;? ':-r-: =< ". "," . ~ - "~ ~ "',"', ,." '^ - ~' " " HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 113 Walton Avenue, Carlisle, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Charles William Gentile 418 South Hanover Street Apt. 2 Carlisle, PA 17013 Woutera J. M. Gentile 105 Claridon Place Carlisle, PA 17013 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Ford Consumer Discount Company 3220 Tillman Drive Bensalem, PA 19020 Associates Home Equity Services, Inc. f/k/a Ford Consumer Discount Company 11311 Cornell Park Drive Cincinnati, Ohio 45242 " ,,~- ' , " J_o-,,,,,,,-,,,.,,, '", ,'~ ' ,', "~".,__',>, ,", .1,., . 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating unsworn falsification to authorities. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 8, 2000 ";-0,, ';;'.--, Uo",.),-:;~"';~>.i~~",," ',','_ ._..__ .. "'~IIilii:Il~~ " ,.>"""""" ~-, ~ 'iii' ,"'" ,,", ...., o C ~~:. ~t!: zr: (f),~" -c I~ z =:(l ", - c::; C.:J (j) -''1 ''(J " " ;'-, ::J ,0 '~ ~ .c.' ::J::J -< " !I J~ II I' ~l i '\ ~ '" r~ \'~ " l~ II 11 ! , ~ i' Ij ~ ~ -'Ie'] ~. ,,-. - .,;" <" ,n'.." " . HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 113 WALTON AVENUE CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 03272 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: 1:\HOME\MKF\DOCS\GUMBERLA\GENTILE,NOS "-,,, ~-- ill!IiIf&l~llI. .. ""W~~",,";~il.!lliiH'-#Jj~~~'--" ...:.o.""~;'.1i .. ..~. ~ b....."..,,~, \1 ,j Ij i,i '1 'i II ~ . L', __,'_ "' ,L1c:lillii:" , CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. "', ~ ~. , \'I"'_~;j:.r~ JjiiJ iHli.~c!:~~~I~~l!iliI1ill"_ = .1"'" , U~ta>. _'L''''''''''l,j ,I " ,I I " j I ! , ~: I , , ~ ,~ ~ ~ ~ - o . ~ ~>l--,;k,\- i 20 After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~ "0 -- " ALL that ccrtain tract of land with the improvements erected situate in North Middleton Township, Cumberland Pennsylvania, bounded and described as follows: thereon County, fiEGINNING at a point at the intersection of the Eastern line of Fift~, (50) feet wide Walton Avenue with the Southern line of Fifty (50) feet wide Clarindon Place; thence from said point at the place of beginning along the Southern line of said Fifty (50) feet "ide Clarindon Place, North 71 degrees 36 minutes east, a di"t.ance of One lIundred twenty (120) feet to a stake in line of Lot No. 15; thence through said Lot No. 15 by a line parallel to the Eastern line of Lot No. 16, South" 05 degrees 18 minutes East, ll, distance of Eight.y:"five and TwentY-'eight Hundredths (85.28) fcet to a point On the Northern line of Lot No. 18; thence along a portion of the Northern line of said Lot No. 18 and all of the Northern line of Lot No. 17, South 76 degrees 30 minutes West, a distance of One Hundred Eleven and Forty Hundredths (111.40) feet to a stake on the Eastern line of said Fifty (5.0) feet wide Walton Avenue; thence along the eastern line of said Fifty (50l feet wide Walton Avenue by a curve to the left, having B radius of four hundred twenty-five (425) feet, an arc distanc~ of Seven ty-four and seventy-nine Hundredths (74.79) feet to a po i nt. on the Southern line of Fifty (50) feet wide ,larlndon Place, the place of BEGINNING. BEING ALL OF Lot No. 16 and the western portion of Lot No. 15 as shown on the Walton Avenue Plan. HAVING A DWELLING ERECTED THEREON KNOWN AS 113 Walton Avenue, Carlisle, Pennsylvania. BEING THE SAME PREMISES WHICH Robert P. Blanchette by deed dated 9/5/89 and recorded 9/19/89 in Deed book E-34, Page 208, granted and conveyed unto Charles William Gentile and Woutera J. M. Gentile, his wife. TO BE SOLD AS THE PROPERTY OF CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE ON JUDGMENT NO. 2000 03272. ASSESSMENT: 29-17-1585-043 i,-lJ-,"":"", ~'"' ~<,- 1IIl.1iI~~ ..'. ~iljH!I!iili..~~I&WO!li<f.;~i'"}1<",~,,;tJ.li;;f$lll>iJ'iiIl.tlli!l~i'Wlfl"" '.....'-. ~.31" "i1lli' ~~~"'~~ ,- o c < -c'; C:,i rnil, Z::TL ZL 59'" ~~ ~.. ~f':~ ..;:;;: :':."1 -< - [J C,:.- :n -;j -'J t ~ I , , , , " . ',~ :~-,: :::::> \0 , "" ~ "';-j -< "~- - HOMESIDE LENDING, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. dJ7/v - ,3J '7 ~ ~ CHARLES WILLIAM GENTILE AND WOUTERA J.M. GENTILE Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If 'you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim.s 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 ~oney claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUmberland County Bar Association 2 Liberty Ave., Carlisle, PA l70l3 7l7-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 7l7-243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTAVAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES D~ SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SrN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAV U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 7l7-249-3l66 Legal services, Inc. S Irvine Row, Carlisle, PA 17013 7l7-243-9400 _. .w -~ ,I', "_ HOMESIGE LENDING, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. CHARLES WILLIAM GENTILE AND WOUTERA J.M. GENTILE Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE THE fOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 91601: The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing within the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff c ~ _" ",I, , --. -",,' ~u..' {'. .' ~ " . ~ ,~! HOMESIGE LENDING, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. h7ru - 3,) 7;l.. ~ 1b- CHARLES WILL!AM GENTILE AND WOUTERA J.M. GENTILE Defendants CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, HOMESIDE LENDING, INC., is a corporation, with an address of 8120 Nations Way, Building 100, Jacksonville, Florida 32256. 2. Defendant, CHARLES WILLIAM GENTILE, is an adult individual whose last known address is 113 WALTON AVENUE, CARLISE 17013. Defendant, WOUTERA J.M. GENTILE, is an adult individual whose last known address is 113 WALTON AVENUE, CARLISLE, PENNSYLVANIA 17013. 2. On or about July 7, 1998, the said Defendants executed and delivered a Mortgage Note in the sum of $72,950.00 payable to CFS BANK, which Note is attached hereto and marked Exhibit "A". 3. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1472, Page 1131 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to RESOURCE BANCSHARES MORTGAGE GROUP, INC. and recorded in the aforesaid County in Mortgage Book 584, Page 725 on August 4, 1996. The Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and will be sent for recording. Said Mortgage and Assignments are incorporated herein by reference. ,. ,L " '-".' ..,' .'",' < --"',, '-,,". , 4. The land subject to the Mortgage is: 113 WALTON AVENUE, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "B" attached hereto. 5. The said Defendants are the real owners of the land subject to the Mortgage. 6. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 70,145.12 (b) Interest at $13.45 per day from 6/1/99 to 6/1/00 (based on contract rate of 7.000%) 4,909.25 (c) Accumulated Late Charges 489.75 (d) Late charges at $32.65 per month for 12 months 391.80 (e) Escrow Credit 738.57 (f) 5% Attorney's Commission 3,507.25 $ 78,704.60 *Together with interest at the per diem rate noted in (b) above after June 1, 2000 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 7. No judgment has been entered upon said Mortgage in any jurisdiction. , 'I ~,,, ! ' '" ,'., ,;;"~\;,,,~~""t;;~';;:';.c' "--,"" ' " ~, l".' $. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 9. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 10. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.000% ($13.45 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By Leon P. Ha Attorney for I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 ""6, ~~ 1Ii,..........."..."''IiIilW1lII1Ilt ~. ~~hiWlIilli_;~="','~illir'~"""";;.-"1iII1iI.''""'.L,' -~" ~ ., ~.. '1 , ~ .w ."dO> ."',,,^ li"l~" ,NOllE __.. 1,1 '. ~ NOTICE: THIS L0:AN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. UllOMJS11aU JUL \:' 07 -, 113 WALTON AVENUE,CARLlSLE, P,ENNSYLVANIA 17013 I~AdllI~51 .1<)98 POTTSTOWN . rENNSVI.VANI^ ICI\yj 1S......l ~ml :' i i~"'l) I. BORROWER'S PROMISE TO PAY In return for a loan t!tllt IMve reeeived, I pmmi~ to pay U.s. $ to tbe order ofthe Lender. The t.ender is CFS DANK 7:2,1)50.00 {Ihis amounl is called .pnnclpar I. I'hl-'l Ir.lem.t. : !', I understand that lhe lender may transfer this Nole. The Lend(T or anyone who takes this Note b" lransfn iUtfl ,'.Iu. I~ cnllrled tu receive payments under this Nole is called the "Note Holder," 1. INTEREST Inlerest will be clmrged on unpaid principal nnlil the full amOllnt of prmcil'lll has been paid. I will pay Inl.'I.:f.1 ai iI ~ l'lJTl~ ratl:' 01 7.001100%, The interest rate required by Ihis Seclion 2 iSlhe mte I will pay both before and aRe! any Jefault lksuibcd III :<n:...I1II11 Mill "t Illi!i NoIe. J.- PAYMENTS (A) Time and Place o(Paymmts I will pay principal and interest by making payments every month. I will make my monthly payments on tln: OtsT day of each month beginning on SEPTEMDF.ll 01, 19'11l I ,-".11 male Ihesc payments ev"ry monlh IIntill have paid all of the principal and inl~l'C5t llltd any other charges dellc! tht..d belo\\' 1I111t I Ina~ (>\\t. IInder this Note. My monthly payments will be applied 10 interest before flrincip~1. If. on AUGUST 01.2UI3 . I \lJll n\\.... alnnunts under this Nole.1 will paytllose amounts in full on lhat date. which is called lhe "malurity date,~ I will make my monthly payments at 93-22 JAMAICA AVENUE WOODHA VEN. NEW YORK lI'll (8) Amount or Montbly Payments ~ My monthly payment will be in the amount of U.S. $"" 4. BORROWER'S RIGHT TO PREPAY I h.wc the right to make p<1yments of principal al any time before they are duC". A pa~lnenl (,1' rrindrl.ll (lnl} i.. I.;IIOW" as " ~pl'tpayment." When [illake II prepayment. I willtelltlte Note Holder in wriling that [ am doing so. I may make a filII prcpa)'ment or partial prepayments witl\otll paying allY prepaylnent charge. 'IlIl! Note HIIMe! willllW all \If m~' prepayments to reduce the amount of principII I that I owe tlnder tbis Note. If 1 make a flilnial prepaynletll. there WIll \:Ie 1\11 ehang.~ in the due date or in the amount of my monlhly plIymenl unless-the Nt'le HoIII!r agrees in wriling to th<:i~e changes So LOAN CHARGES If n law. which epplies to thillloan ulld which sets maximum IOlln ch" ge!!>. is finally inlerpreted so Ihat the 11U...'fCSl tlr ("her loon charges eall'llctcd or 10 be eoll'llcted in connection with this loan exceed 11:.' pc:nnltted limits. then: ci) MY ~llch loan dllll~e shall be reduced by Ihe amount llccessary to reduce lhe chlltgc 10 Ihe pcnnined IImil; and (ill any 5Ums already collected fmlll mi:' wbich exceeded pennilled lindts witl be rerundcd to me. The Nule Bolder may ,house to make this refund by reducing Ihe J1-lil1cil"dl I owe under tltis Note or by making a direct payment to me, If a refimd reduces principal, the n:duelitln wi!1 he lteau,'1.1 as II partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Lnte Charjll! "for Overdue Payments lftl'te Note Holder Ilns not received Ihe fI!1l amount ofany monthly pa)-1nent by the end of the dale it is due. I will pay a late charge to Ihe Note Holder, The amount ofthe chargr will he I will pay Ihis late cliarge promptly but only once on each late pnyment. (BlDeCaull If! do nol pay the full amount of each monthly payment on the dale it is due. I will be in ddault, (C) Notice ofJ)efatllt lfl am in deCault. the: Notc lloldcr may liCnd me a wrilil:n 11111ice Idling lIle Ihut if I do not pay llie overdue: 1I11lU\llIt h~' a n:twin date, the Note Holder may require me to pay immedialel}'lhe full drnonnt of 11I'incipal which has not heen p..,id iUld ..11111l' lIIt....I....stllmt I owe on that nmollnt. That datc- mu.~t be at lenst 30 days after the date on which Ihe nOlice is delh'errd or mailed It> Ill...., (0) No Wain,. By Note Holder Gven if. 111 a time whcllllUtI in default. the No(e Holder does not require me to pay b'lmediately in fullu desl:'rihcd "bovc. the Note Holder will still have the right (0 do 10 if 111m in default at II ln~er time. (It) Payment of Note Holder's Costs and Expenses Irthe Note Holder hIlS required me to ray immediately in full flS described above,lhe Note Holder willlm\le the riJ;ht '0 be {lllid back by me for all of its costs and expenses in enforcing this Note lolhe eXlent not prohibited by applicable 1;(\\ n\('Sc e'(penscs include, for example, reasonable allomeys' fee;. i. GIVING OF NOTICES Unless applicable law requires a diiTercnt method, Mly nolice lhal must be given 10 me under this Nntc willI)!: ~i\'l'1\ h~ ddl\'l:'nng it or hy mailing it by first class mail to me at the Property Address ahove or al n different address if I J!i\'e the Not.... 11(.[,kr II "nlil't" 01 illY differenl address. Any notice lhat must be given 10 the Note HlIl~r under this Notc will he ~ivell hy Illailing it i'ly lir~t da~'; mnilll} Ill<" Nuk llulder at lhe address stated in Section 3(A) above or nl,l different address if I am l!ivcn a nOlice ofthnt \lillcrcnl addre~s '[ I ~ '[: I ~ I -l: ,;:i :~ or at adilferenl phll'e ifrt"qltiled by lilt, Notl:" I-lolder, 655."/0 ;' '8 .\1 ;. '~) I'; . ,; , FIFTEEN calendar days alier 4.1100 % nf IllY ""rnhlc {layment: 'o:i : ~ r !-, ,. r' L !: ~ I ~ "4'/ L:::' ~ III bI t j , MULTISTATE FIXED RATE NOTE..SJngle Femllr-FNMAlFHLMC UNIFORM 1N$TAUMENT (with VA modlflc.lIol'lll I'~r.e ! llf I iOl"l_~ '.,.: i k ~, " " , :E {"more- ..w '1*'011:. . person Is lUll)' and ....OMlly (dllipm;i to &cq, .il of die flmni~ mink: in litis.; Note. Including the promise to pa)' the full atl10\ltll ow~d. An)' pm..m whet is . gua:ntll'or. lUrdy or enOOPer fir llll~ Nole ;~ aM obli~ to do thes.e thinlY', Any person who takes OYer Ihese abllgatlort$. i~llIdillr.llle (If,liplf0n5 of a &uamnlfl1 ~lln"i\ '" C'ldllner "oflhis Nole. Is also obligated (0 keep all of the_flrmnlses made in litis Nflle, The NutI!' Jkddu m~' enfortc tiS ndlh 1/lI.kl II... Nut,: against each person individually oragainsl all 01 us together, TIlis nl1:<lIIS I~ all)' Qlle nfus ma~' be: required 10 pol~ .111 "llh.' ~lJtll(f"',S owtd under this Note. 9. WAIVERS I and any otller J)er$(ln who Im<; obligations under this Nnle waive tl\(:,ri~hls nl PI'C5cutmcnt OInd mollr': (It dl\ht'lln,. 'I're.....-lllmr:nf. means the right to require the Nate Holder 10 denul.11d Jll'lyrnclll oramaunls dUt" MNulice: ,,1 dlshUllUl~ It\t"aIli tlw: II.,:hl 10' rCllult.: (he' ;,:,,; Nate Holder 10 gi"c notice to orner persons that amounts due Ilave not beell pllid. :ti 10. ALLONGE TO TillS NOTE j., If an allonge pro....iding for l'lllymcnt adjustments or for an)' other supplemental in(onnation is executed by lhc 1\('IIII'\\l:r hlP.'thcr ~ wilh Ihis Note. the Covenants of the nll\IMge shall he incorporated inln and r,!11l11 3nlend and sUflVlemellllhe ';f\\-'enalll', tol' Ihl" N'll" a~ if ,r the allonge were a part of this Nnte, (Clleck applkllble boxl " 1" lli:' .$' '&.;. ". ~~ Olher fSpecirYI OlherlSpecify) Grnduated Payment Allonge n. UNIFORM SECUREll NOTE. Tltis Note is a unifonn instrumelll with limited variations in some j:lrisdictinlls. lit addition te. the proledlf.n.. !!l,<\'O hl:l1<' Note ;.~ Hnlder ullder this Note. a Ml'Ir1gage. Deed of Trust ar Rce:urity Deed (lhc "Secnrity Instromcmf'), dOlt<:d Ibe ~".lnl" 'll.,IC a.. 11m N,Ite. '~ protects Ihe Note Holder from possible losses which might result if I do nOI kl'ep the pmmises '.vhich I mak~ In .hl\ NUIC 111>>'~ Security Inslnlmenl des<:ribes how and under what conditions I may be required to make immedijllc pa~melll 11\ IiIIl ,,( all ;mulVllJs I ,~ owe under this Note. Some oflhose conditions are descHhcd a.'j follows: Regulations (38 C.F.R. Part 36) issued under the Department uf Veteran.'= AlTai" f'V,^,~1 (ju3mntced Loan Authority (38 U,S.C. Chapter 37) and in eITed on the dun: of loan closing shall govem tlte riglllS. dllti!:\ and Iiabilitie.,; of the parties to this lonn nnd any provisions of this Nute which are iltco1tsi!>lent \\ nh soch 1'('\!\llatl1'll' .lIl" hereby amended and supplemented to conform thereto" ' ~~. ~!' \\. E.,~.1HEHAND(S)ANIlSEAL(S)OFT"EUNDERSIG&.,h .,:;/k ..f~ " tm~I"MGE~-tt< fl I~ " f it i (~o;.tll "'-- " /2I+~A~_ t.-1"~,^~~NTILF. ("{eail .- .\.' ==:retMottPaeGTOup.lne. withoutrecom:se f. ~l11wr/1;~ Teresa Gibbons As>IJIlItlS_lalY (SaIl, .- '.. r._ ;', " ~; l&an .- l'igllfln,l:mu{/J,J.I'1 ~. :~ t i, ,!I' 1'.. .~ _.,11 1II11__..~IiIIiilIIIiUijj"iilollkL' ,,1__ ............ "" ...- -Li'id~IMJjlli '-, . , . ' VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff, HOMES IDE LENDING, INC. that said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: May 24, 2000 ~ Leon P. Haller, Esquire . -",- "',.' "~ ;,", , , ". --".., ,"-" . ~! ,,,; I' , I I, I I',: :;1! "~I !~, ;', , :1 J:i II ;t! I, I;,! 1"1 .' I:i i;1 H ," i:'i ,I 1;1 I' !'I 18 H "j i Ii I:: fi :,j d I' " ;'! I:; 1',' Ii I" f: , I II STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } SS. Robert P Ziegler I, __________________"--_________________________________________________________Ileeorderof Deeds in and for sail! C\,unty and State do hereby certify that the Sherifrs Deed in which ________h______ Veterans Affairs SEe ____________________________________________________________________________________ ~ the grantee 6th the same having been sold to said gJ,"8ntee on the ________n______n_______h________h___h_____ day of Dee 2000 ___n________________n_h______h_h___ A. D., :. - _nn' under and by virtue of a writ___nn_______ Execution 12th ______ ______________________ __ ___________ _______ issued on the _ __________h _h___n_ __ __ ________ ___ day of ___________S_':~~________n_ A. D., - - 2~~.9_, out of the Court of Cornman Pleas of said County as of Civil 2000 ______ __ __________________ ____... _______ __ ___ ___ __ ____ ____ _ _________ __ __ __________ _ Term, 3272 Homeside Lending Inc ~unober______________,atthesuitof-------------------------______________________________________ Charrles William Fentile & Woutera J M ___________ _______ _____ _____ ___ ____ againSL__ __ ___ __ ___ n n_ __ n_ h h ________ __ __ __ ____ _____n ~ 237 624 duly recorded in Sherifrs De~ Book ~o. ______n____' Page _______n___. 1'1 i;i u 1:1 "I I~ TESTIMO~Y WHEIlEOF, I have hereunto set my hand and seal of said office this _(_~___ day of ----- ~------m47 A. D., ~::::::~ T;;;:n?J d -/.1-, ' ----~-----~~---~------- "<J~ er of Deeds Recorder of Deeds, Cumberland County. Carlisle, PA My Commission Expires the First Monday of Jan. 2002 - -~~",., Homeside Lending, Inc. -vs- Charles William Gentile and Woutera lM. Gentile In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-3272 Civil Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, says on October 27, 2000 at 10:40 A.M. 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: Charles William Gentile, by making known unto Charles Gentile at 418 South Hanover Street, Apt 2 Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Richard E. Smith Deputy Sheriff, who being duly sworn according to law, says on October 9, 2000 at 12:47 P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of Charles William Gentile and W outera lM. Gentile located at 113 Walton Avenue, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the withinnamed defendants to wit: Charles William Gentile by regular mail to his last known address 418 South Hanover Street Apt 2 Carlisle, Pennsylvania. This letter was mailed under the date of November 2,2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he made diligent search and inquiry for one of the withinnamed defendants to wit: Woutera lM. Gentile but was unable locate her in his bailiwick. He therefore returns Real Estate Writ Notice Poster and Description Not Found as to the defendant Woutera J.M. Gentile. R. Thomas Kline, Sheirff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Woutera lM. Gentile by regular mail to her last known address 113 Walton Avenue, Carlisle, Pennsylvania. This letter was mailed under the date of November 6, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the above described premises at public venue or out cry at Court House, Carlisle, Cumberland County, Pennsylvania on December 6, 2000 at 10:00 o'clock A.M. EST and sold the same for the sum of$ 1.00 to Attorney Jill Winkea for The Secretary of Veterans Affairs of Washington, D.C., his successors andlor assigns. It being the highest bid and best price quoted for the same The Secretary of Veterans Affairs of Washington D.C., his successors and lor assigns of Wissahickon Avenue and Manheim Street, Philadelphia, Pennsylvania being the buyer in this execution paid to SheriffR. Thomas Kline the sum of$ 854.04it being costs. Sheriffs Costs: Docketing Poundage Advertising Posting Bills Acknowledging Deed Auctioneer Law Library 30.00 16.75 15.00 15.00 30.00 10.00 .50 .~~ -OJ ''''''''',_-''i~''' County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 1.00 9.30 .64 15.00 30.00 353.75 252.45 23.15 25.00 26.50 $ 854.04 Pd By Atty 01/08/01 Sworn and Subscribed To Before Me ~ Soans~ oP"f/: This 19!!::Dayo ' r ' ".-t:~ 2001, A.D. ~ a 'J"ndL, tlfPi R. Thomas Kline, Sheriff Prothonotary BY/?7..~th"-~ jj1,..Li Real Estate ~uty ~ 00~ 30&0 \-C:JL3107'! / s 1-- 10>> )DI.,S ~. ~. " ,~,'~~ , ...!j~-~, l' . COpy HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 113 Walton Avenue, Carlisle, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Charles William Gentile 418 South Hanover Street Apt. 2 Carlisle, PA 17013 Woutera J. M. Gentile 105 Cla~idon Place Carlisle, PA 17013 2. Name an<:i address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Ford Consumer Discount Company 3220 Tillman Drive Bensalem, PA 19020 Associates Home Equity Services, Inc. f/k/a Ford Consumer Discount Company 11311 Cornell Park Drive Cincinnati, Ohio 45242 ~" ~- A ilIl~&filIjtiiii!lil~<&L""'ti~_~l~~H~"h" ,.l'Vt ~f_~';-;'f;'"' ,--~'~> ",'ill: "'.".J'" ,. .-.W ~,'f11~':'~, e: " ~:i (j! f~, ~"" ,~ ~'" IIII!II . '-' ";;';;.mr--'" WldW~""";'''''~'' ~&"'~, ~t.i ,~' . , - ~~ "'- " loIl~~( I , 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 I (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I' " I'; I !" I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating. D unsworn falsification to authorities. A- Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 8, 2000 - . -I: ~ - =~~~.u "~!i;t, , , ..' !. i:' r ~ HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE, DEFENDANTS CIVIL ACTION - LAW NO. 2000 03272 IN MORTGAGE FORECLOSURE I; l' NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: .'i That the Sheriff's Sale of Real Property (real estate) will be held: ..:: U '" ':'1 DATE: WEDNESDAY, DECEMBER 6, 2000 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 ,; .:, ~ i THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 113 WALTON AVENUE CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 03272 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: I:\HOME\MKF\DOCS\CUMBERLA\GENTILE.NOS ~~ , _-" ~,_ , 0 _ ~,~!t. / CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exception$ to it within ten (10) days of the date it is filed. Info~mation about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. "-'- ~, " - -$ .~"~-!I!!..', .J 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 l~ '~ '~ 'L .L..c-'"""",, ~_~;o, .' ALL that certain tract of land ",i th the improvements erected situate in North Middleton Township, Cumberland Pennsylvania, bounded and described as follows: thereon County, BEGINNING at a point at the intersection of the Eastern line of Fift~' (50) feet wide Walton Avenue "ith the Southern line of Fifty (50) feet "ide Clarindon Place; thence from said point at the place of beginning along the Southern line of said Fifty (50) feet "ide Clarindon Place, North 71 degrees 36 minutes east, a di~tance of One Hundred twenty (120) feet to a stake in line of Lot No. 15; thence through said Lot No. 15 by a line parallel to the Eastern line of Lot No. 16, South' 05 degrees 18 minutes East, . n distance of Eighty:"five and TwentY-'eight Hundredths (85.28) feet to a point on the Northern line of Lot No. 18; thence along a portion of the Northern line of said Lot No. 18 and all of the Northern line of Lot No. 17, South 76 degrees 30 minutes West, a distance of One Hundred Eleven and Forty Hundredths (111.40) feet to a stake on the Eastern line of said Fifty (5.0) feet wide Walton Avenue; thence.along the eastern line of said Fifty (501 feet wide Walton Avenue by a curve to the left, having a radius of four hundred twenty-five (425) feet, an arc distanc~ of Seventy-four and seventy-nine Hundredths (74.79) feet to a point on the Southern line of Fifty (50) feet widelarindon Place, the place of BEGINNING. BEING ALL OF Lot No. 16 and the western portion of Lot No. 15 as shown on the Walton Avenue Plan. HAVING A DWELLING ERECTED THEREON KNOWN AS 113 Walton Avenue, Carlisle, Pennsylvania. BEING THE SAME PREMISES WHICH Robert P. Blanchette by deed dated 9/5/89 and recorded 9/19/89 in Deed book E-34, Page 208, granted and conveyed unto Charles William Gentile and Woutera J. M. Gentile, his wife. TO BE SOLD AS THE PROPERTY OF CHARLES WILLIAM GENTILE AND WOUTERA J. M. GENTILE ON JUDGMENT NO. 2000 03272. ASSESSMENT: 29-17-1585-043 . . , < , .--' ~'"'; '". <,.., WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3272 CIVIL>>ll TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cmnber1and COUNTY: To satisfy the debt, interest and costs due Haneside LendjnQ". Inc. PLAINTIFF(S) from Charles William Gentile 418 SOllth H;mnvpr S1-rpp1-, 11['1- ?, r"r1;"lp, p" 1701, ",,,'l Woutera J. M. Gentile 105 C1aridon Place. Carlisle. Pa. 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real Estate: 113 Walton Avenue. Car1isJe. Pa. 17011 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny 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 ptherwise disposing thereof; , "" (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee andis enjoined as above stated. Amount Due $78,704.60 6-1-00 to 12-6-00 $13.45 per diem Interest ? ~?R F;O . Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs $ 0.50 1.00 122.20 Late Charges S12.65~r mn. Escrow Deficit S67.::>5 2.000.00 Date: S~tember 12. 2000 r.llrt-i!=:. R. T,()ng Prothonotary, Civil Division bY:~" 0 n."oP:. / Deputy REQUESTING PARTY: Purcell, K:rug & Haller Name Leon P. Haller. Esq. Address: 1719 NJrth Front Street HarrisburQ". Pa. 17102 Attorney for: Plaintiff Telephone: (717) 234 -4178 Supreme Court ID No. 15700 '.lliii.'-.II.~~.;'"~~"'l!I.lilWI!llW-' -'lit' "~'.~'"~f ~~~- . .~, L, ';" ~t__~~~liIliIIi!li!liiIiiI.iiij"' '.Kb"m~atM.l,,~~!ilmloil~ir1iM .. RfJ\L ES1 f\ 1E S~lE No.. Gn ~ 1?/,).dP the snenfi levied upon the oerendants Interest in the real pmoflrtv ,ituatP,d ind-f.~_#Y..ltL 4"..,~ Cumberland County, i'c, 'umbered as: IB ~IL- ~. a A L 12.- . and 1;'(" ". ., nil Exhibit "A" filed wltn tnlS writ ano Oy thIs (8", ,,,:jorated herein. .....~~ Ij~;;uro B~~~ \;'(! I\"t'..,\'l}, {':)I :,-,~]d ; , ! " r-r.', I' i f.I," I Ii,;:, _ ;,.., EI ~3S A1H,',( " . " ",no ~~1~3HS .,,; J(, :i:';~:lO &> a:v;r CViJ c:::::a Gi) cniiir -"-- "1.' '''.' , '"''-' -" . ~'" ....-..:il ,--,- . .', -", 'il&!.t . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duiy sworn according to law, deposes and says: That he is the Acounts Receivabie Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonweaith of Pennsyivania, with its principal office and piace of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and ali have been continuously published ever since; That the printed notice or publication which is secureiy attached hereto is exactly as printed and pubiished in their regular daily and/or Sunday/ Metro editions which appeared on the 31st day of October and the 7th and 14th day(s) of November 2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimousiy 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 icellaneous Book "M", ';'~: ~~;~:~~. ,;;;,;.~;;;.;;";,;;;/g,~i~;. .......;~;;;;.. .;;';;;;;;.;;;;' .;.0. S ALE #50 Notarial Seel Terry L. Russell, Notary Public Harrisburg, Dauphin County My Commission Expires June 6, 2002 Member, Pennsylvania Association 01 Notaries My 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 $ 250.95 1.50 252.45 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circuiation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... I - ~ ~ c;"., - REAL ES'l'ATE SALE NO. 58 Writ No. 2000-3272 Civil Homeside Lending. Inc. vs. Charles William Gentile and Woutera J.M. Gentile Atty: Leon P. Haller ALL that certain tract ofland with the improvements thereon erected situate in North Middleton Town- ship, CUmberland Counly, Pennsyl- vania. bounded and described as follows: BEGINNING at a point at the in- tersection of the Eastern line of Fifty (50) feet wide Walton Avenue with the Southern line of F1fty (50) feet Wide Clarindon Place; thence from said point at the place of beginning along the Southern line of said F1fty (50) feet wide Clarindon Place. North 71 degrees 36 m1nutes east, a d1s- tance of One Hundred twenly (120) feet to a stake in line of Lot No. 15; thence through said Lot No. 15 by a line parallel to the Eastern line of Lot No. 16, South 05 degrees 18 minutes East. a distance of EigIlly- five and Twenly-elght Hundredths [85.28) feet to a point on the North- ern line of Lot No. 18: thence along a portion of the Northern line of said Lot No. 18 and all of the Northern line of Lot No. 17, South 76 degrees 30 minutes West, a distance of One Hundred Eleven and Forty Hun- dredths (111.40) feet to a stake on the Eastern line of said F1fty (50) feet wide Walton Avenue; thence along the eastern line of said F1fty (50) feet wide Walton Avenue by a curve to the left. havlng a radius of four hundred twenly-five (425) feet, an arc distance of Seventy-four and sevenly-nine Hundredths (74.79) feet to a point on the Southern line of F1fty (50) feet wide larindon Place. the place of BEGINNING. BEING ALL OF Lot No. 16 and the western portion of Lot No. 15 as shown on the Walton Avenue Plan. HAVING A DWELLING ERECT- ED THEREON KNOWN AS 113 Walton Avenue. Carlisle, Pennsylva- nia. BEING THE SAME PREMISES WHICH Robert P. Blanchette by deed dated 9/5/89 and recorded 9/19/89 in Deed book E-34. Page 208. granted and conveyed unto Charles William Gentile and Woutera J. M. Gentile, his wife. TO BE SOLD AS THE PROP- , ER'lY OF CHARLES WILLIAM GEN- TILE AND WOVTERA J. M. GEN- TILE ON JUDGMENT NO. 2000 03272. ASSESSMENT: 29-17-1585-043. ~':",," '~ ,.' . .,. , , . ' =="'~" . "-~<, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : 55. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: OCTOBER 27, NOVEMBER 3, 10, 2000 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. RO~ Editor ...... SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 NOT ARt 1 SEAL LOiS E. SNYDER, Notary Public Carlisi. Boro, CumblirkiiKI Caui\ty, PA My Commiuicm Ex"",!, Io\Qr<h,5, 2f101 "'< '- ',_b" "N',"_ .>''n'_' -, ~,.. ,"" :'~" ,_-"" -_,,c, ' "_^'_" " '- ",,~ ,~' ~~,'< " '" LEON P. HALLER, ESQUIRE PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102-2392 (717) 234-4178 ATTORNEY FOR PLAINTIFF HOMES IDE LENDING, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA plaintiff CIVIL ACTION - LAW VS. NO. 2000-03272 CHARLES WILLIAM GENTILE and WOUTERA J. M. GENTILE Defendants IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendants satisfied of record. PURCELL, KRUG & LLER BY: Leon P. Haller ID #15700 Attorney for Plaintiff DATE: Auoust 3, 2005 ~l~~""~""'-~ ~- ["Of "c - .",~ .' . 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