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Home My WebLink About02-5558McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company P.O. Box 8604 Elmhurst, IL 60126 Dennis G. Deitch 136 Greason Rd. Carisle, PA 17013 and Sharon L. Deitch 136 Greason Rd. Carisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number 0~2. -- ...5".~'S~ CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE YOU have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 AVISO Le han demandado a usted en la carte. Si usted quiere defenderse de estas demandas ex-puestas en Las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y [a not [ ficacion. Hace fa[ta asentar una comparencia escrita o en persona o con un abogado y entregar a la carte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor de[ demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICiNA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Car[isle, PA, 17013 800-990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Household Finance Consumer Discount Company P.O. Box 8604 Elmhurst, IL 60126 Dennis G. Deitch 136 Greason Rd. Carisle, PA 17013 and Sharon L. Deitch 136 Greason Rd. Carisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized under the laws of Pennsylvania and doing business at the above captioned address. 2. The Defendant is Dennis G. Deitch, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 136 Greason Rd., Carisle, PA 17013. 3. The Defendant is Sharon L. Deitch, xvho is one of the mortgagors and real owners of the mortgaged property hereinafter described, and her last-known address is 136 Greason Rd., Carisle, PA 17013. 4. On 12/17/1998, mortgagors made, executed and delivered a mortgage upon the prenfises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book1507, Page 1126. 5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 136 Greason Rd., Carlisle, PA 17013. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/22/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage: Principal Balance Interest 04/22/2002 through 08/23/2002 (Plus $ 22.11 per diem thereafter) Attorney's Fee Cost of Suit Appraisal Fee Title Search $ 63,946.94 $ 8,911.03 $ 3,197.34 $ 225.00 $ 125.00 $ 200.00 GRAND TOTAL $ 76,605.31 8. 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 based on work actually performed. 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular and certified mail. WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $76,605.31, together with interest at the rate of $22.11 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged p~op, e4ty. TERRENCE J. McCAB ,~/ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, George Hernandez, hereby certifies that he is the Foreclosure Specialist of the Plaintiff iD the within action, Q~_ ]~ he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. George Hernande z / [. ALL THAT CERYAIN PROPERTY SITUATED iN THE T(~q~41P OF W, PEHNSBO~D IN THE ~OL]HT¥ OF CUI~ERLAN(I AND COk&I(~A~IEALTH OF PENNSY~¥ANIA, BEING MORE FUL~Y DESCRIBED IN A FEE SIMPLE Illll/lllll/Illlllllll t~L~TOGLGT~TG 01 Gt~TL ZT9 OE;33Nb~NI-~ G-IOH3SnOH 80:~_ ~00~ ~0 1:30 ~aaIO6~TaI~ 01 ~Ia aT9 O033NUNI~ 030H3$NOH a~ N~ 8~:~ ~00~ ~0 130 Jurbdlctt~n in wtg~h tb~ P~per~y is Io~,u~d. 'rl~ t~8~n~ oe~ sbll not limit d~ ~ ~ l:~h~ hw ~ Ipplianc~ (o) a tnn~e~ to a reb~ve ree~n~ from ~e de~h d a Borrows, (f) a ~lnsfer wino tho spruce ~ 90'd PLaIOSaSIaI60l SPIL LI9 OCBDN~NI~ ~qOH~SAOH B~ N~ SE:L ~00~ ~0 130 Imlnlllllllllllllllll LO'd ~OB~S~t~ 01 S~IL LI9 OC~ON~NI~ QqOH3SAOH ~ WU $~:L ~00~ ~0 1~0 R~OU"BST FOR I~I"IC~ OP DI~I~AULT AND PORBCLOSURB UNDBR SUPi~IOB, MOR'I~AO]~ O~. ~-!~ Ol~'I'~.L~T S77 Lmn~ Roed Illlllllllllllllllllll 80'd ~TOG~ST~TG 01 S~T~ ~19 OCBDNUNI~ O~OH3S~OH ~ W~ S~:~ ~00~ ~0 ALL TItAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin in the center line of L.R. #21034 leading fi.om Plainfield to Greason, which pin in North 4 degrees 48 minutes East 210 feet from the center line of Township Road #T-446; thence by other land of Lester Gerald Thumma and wife, North 85 degrees 12 minutes West 210 feet to a stake; thence by the same, North 4 degrees 48 minutes East, 195 feet to a stake; thence by the same, South 85 degrees 12 minutes East, 210 feet to a pin in the center line of L.R. #21034; thence by the center line of said road, South 4 degrees 48 minutes West, 195 feet to the place of beginning; containing 40,950 and being described according to a survey thereof by Noel B. Smith, R.S., dated September 8, 1972, a copy of which is attached hereto as a part of this deed. BEING subject to a building set back line, which is 40 feet West of the proposed right of way line of L.R. #21034, which latter line is 25 feet West of the existing center line of said road. SHERIFF'S RETURN - REGULAR CASE NO: 2002-05558 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS DEITCH DENNIS G ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DEITCH DENNIS G the DEFENDANT , at ~016~.'50 HOURS, on the at 136 GREASON ROAD _3rd day of Dece__~er , 2002 CARLISLE, PA 17013 DENNIS DEITCH by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing ~i~ attention to the contents thereof. Sheriff,s Costs: Docketing 18 00 Service ' Affidavit 4.14 .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this ]?~ day of ~'~ ~..~c~ A.D. Prothonotary So Answers: R. Thomas Kline ~ 12/04/2002 MCCABE, WEISBERG & CONWAY SHERIFF S RETURN - REGULAR CASE NO: 2002-055S8 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS DEITCH DENNIS G ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland CountY, Pennsylvania who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DEITCH SHARON L DEFENDANT , at 0016:50 HOURS, on the at 136 GREASON ROAD the __3rd day of December , 2__q00~ CARLISLE, PA 17013 DENNIS DEITCH (HUSBAND) by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing ~i~ attention to the contents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. ~othonotary So Answers: 12/04/2002 MCCABE, WEISBERG & CONWAY i/ D ep~ t ya~g~h e~ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 76,605.31 Interest from 8/24/02-3/4/03 $ 4,245.12 TOTAL $ 80,850.43 Rk~E ~. ~cCABE, ESQUIRE AND NOW, this~day of~L,~003, Judgment is entered in favor cf Plaintiff, Household Finance Consumer Discount Company and against Defendants Dennis G. Deitch and Sharon L. Deitch and damages are assessed in the amount of $80,850.43, plus interest and costs. BY THE PROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA : The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Dennis G. Deitch and Sharon L. Deitch are over eighteen (18) years of age, and resides at 136 Greason Road, Carisle, PA 17013. J. McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 4th DAY OF MARCH, 2003. NOTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". R~.~CE '-O'.~'McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 4zh DAY OF MARCH, 2003. NOTARY PUBLIC Curt Long Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 December 27, 2002 Dennis G. Deitch 136 Gxeason Road Carisle, PA 17013 Household Finance Consumer Discount Company VS. Dennis G. Deitch and Sharon L. Deiteh Cumberland County Court of Common Pleas Number 02-5558 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from thc 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 telepl'one the following office to find out where you can get legal help Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 TJM/cc NOTIFICACION IMPORTANTE Usted se encuenira en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personalmente o por abogado y por no haber radicado pot eserito con esm Tribunal sus defensas u objeciones a los reclamos formnlados en contra suyo. Al no tomar la aceion debida dentro de diez (10) dias de la fecha de esta notifica¢ion, el Tribunal podra, sin necesidad de comparecer usted en corte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos impor~antes. I)ebe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-910g If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CON-WAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 EXHI8[I Curt Long Prothonotary OFFICE OF THE PROTHONOTARY · COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 December 27, 2002 To: Sharon L. Deitch 136 Crreason Road Carisle, PA 17013 Household Finance Consumer Discount Company VS. Dennis G. Deitch and Sharon L. Deitch Cumberland County Court of Common Pleas Number 02-5558 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the Court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important fights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 TJM/cc NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber presentado una comparecencia escrita, ya sea personaimente o por abogado y por no haber radicaldo por cscrito con este Tribunal sus defensas u objeciones a los reclamos formulados en contra suyo. Al no tomar la accion dabida dentro de diez (10) dias de la fecha de esta notifica¢ion, el Tribunal podra, sin necesid~d de comparecer usted en ex)rte u oir preuba alguna, dictar sentencia en su contra y usted podria perder bienes u otros derechos importantes. Debe llevar esta notificacion a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en 1~. rsona o ilame pot telefono a la oficina, nombrada para averiguar si puede conseguir asistencia legal. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 at this telephone number: (215) 790-1010 EXHIBIT "A" VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Dennis G. Deitch 136 Greason Road Carisle, PA 17013 Household Finance Consumer Discount: Company Dennis G. Deitch and Sharon L. Deitch CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term NOTICE Pursuant to Rule 236, has been entered in [he above you are hereby notified that a JUDGMENT proceeding as indica~below. Curtis R. Long ~ Prothonotary X Judgment by Default Money Judgment -------- Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence j. McCabe Es uire at 215 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Lon9 Prothonotary To: Sharon L. Deitch 136 Greason Road Carisle, PA 17013 Household Finance Consumer Discount: Company Vo Dennis G. Deitch and Sharon L. Deitch CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as mon~' ~ Curtis R. Prothonotary _ X Judgment by Default Money Judgment Judgment in Replevin Judgmen~ for Possession If you have any questions concerning this Judgment, T_err__ence j. McCabe, Es__~hq~_~e at (215/ 790-1--010. please call IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount Company v. Dennis G. Deitch and Sharon L. Deitch CIVIL DIVISION FILE NO.: 02-5558 Civil Term AMOUNT DUE: $80,850.43 INTEREST: from 3/5/03-6/11/03 $1,302.42 at 13.29 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant (s) 136 Greason Road, Carisle, PA 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s) . (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: March 4, 2003 Signature: d ~~_~/~~ Print Name: TE~ENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215} 790 1010 Supreme Court ID No. 16496 ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin in the center line of L.R./121034 leading from Plainfield to Greason, which pin in North 4 degrees 48 minutes East 210 feet from the center line of Township Road #T-446; thence by other land of Lester Gerald Thumma and wife, North 85 degrees 12 minutes West 210 feet to a stake; thence by the same, North 4 degrees 48 minutes East, 195 feet to a stake; thence by the same, South 85 degrees 12 minutes East, 210 feet to a pin in the center line of L.1L #21034; thence by the center line of said road, South 4 degrees 48 minutes West, 195 feet to the place of beginning; containing 40,950 and being described according to a survey thereof by Noel B. Smith, R.S., dated September 8, 1972, a copy of which is attached'hereto as a part of this deed. BEING subject to a building set back line, which is 40 feet West of the proposed right of way line of L.R. #21034, which latter line is 25 feet West of the existing center line of said road. TITLE TO SAID PREMISES IS VESTED IN Dennis G. Deitch and Sharon L. Deitch, his wife., Deed from Lester Gerald Thumma and Gayle Ruth Thumma, his wife, Deed dated September 26, 1972, recorded September 26 1972, in Deed V-24, Page 253. BEING KNOWN AS 136 Greason Road,Carisle, PA 17013. TAX MAP PARCEL NUMBER: 46-07-0475-028A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5558 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANy, Plaintiff (s) From DENNIS G. DEITCH AND SHARON L. DIETCH (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $80,850.43 L.L. $.50 Interest FROM 3/5/03 - 6/11/03 $1,302.42 AT 13.29 PER DIEM Atty's Corem % Due Prothy $1.00 Atty Paid $130.14 Other Costs Plaintiff Paid Date: MARCH 7, 2003 (Seal) REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 CURTIS R. LONG Prothonotary Deputy Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J- McCABE, ESQUIRE Identification Nun%bet 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Dennis G. Deitch and Sharon L. Deitch CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 136 Greason Road,Carisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 o Name and address of Defendant(s) in the judgment: Name Addre s s Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Household Finance CDC 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 and 961 Weigel Dr, P.O. Box 8604 Elmhurst, IL 60126 4. Name and address of the last recorded holder of every mortgage of record: Name Address Orrstown Bank 427 Stonehedge Drive Carlisle, Pa 17013 HOUsehold Finance CDC Household Realty Corporation 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 and 961 Weigel Dr, P.O. Box 8604 Elnlhurst, IL 60126 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name ~ Tenants (s) /Occupant (s) Domestic Relations Commonwealth of Pa Address 136 Greason Road Carisle, PA 17013 Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. March 4, 2003 DATE ~R Attorney for Plaintiff E ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin in the center line of L.R. #210J4 leading from Plainfield to Greason, which pin in North 4 degrees 48 minutes East 210 feet from the center line of Township Road gT-446; thence by other land of Lester Gerald Thumma and wife, North 85 degrees 12 minutes West 210 feet to a stake; thence by the same, North 4 degrees 48 minutes East, 195 feet to a stake; thence by the same, South 85 degrees 12 minutes East, 210 feet to a pin in the center line of L.R. #21034; thence by the center line of said road, South 4 degrees 48 minutes West, 195 feet to the place of beginning; containing 40,950 and being described according to a survey thereof by Noel B. Smith, R.S., dated September 8, 1972, a copy of which is attached'hereto as a part of this deed. BEING subject to a building set back line, which is 40 feet West of the proposed right of way line of L.R. #21034, which latter line is 25 feet West of the existing center line of said road. TITLE TO SAID PREMISES IS VESTED IN Dennis G. Dcitch and Sharon L. Deitch, his wife., Deed from Lester Gerald Thumma and Gayle Ruth Thumma, his wife, Deed dated September 26, 1972, recorded September 26 1972, in Deed V-24, ldage 253. BEING KNOWN AS 136 Greason Road,Carisle, PA 17013. TAX MAP PARCEL NUMBER: 46-07-0475-028A EXHIBIT "A" McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 Your house (real estate) at 136 Greason Road, Carisle, PA 17013 more fully described as attached) is scheduled to be sold at Sheriff's Sale on JUNE 11, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $80,850.43 obtained by Household Finance Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: The sale will be canceled if you pay to Household Finance Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. o 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. o You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. o 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. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 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. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T~ OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 13th DAY OF MAY, 2003, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 13th DAY OF MAY, 2003. NOTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY= TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 136 Greason Road, Carisle, PA 17013, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 o Name and address of Defendant(s) in the judgment: Name Address Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Household Finance CDC 26 Gateway Drive Gateway Square, ate 107 Mechanicsburg, Pa 17055 and 961 Weigel Dr, P.O. Box 8604 Elmhurst, IL 60126 mortgage of record: Name Name and address of the last recorded holder of every Orrstown Bank h ~ House o ~ ~~t Address 427 Stonehedge Drive Carlisle, Pa 17013 ~T ~A~26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 and 961 Weigel Dr, P.O. Box 8604 Elmhurst, IL 60126 Household Realty Corporation 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants (s)/Occupant (s) 136 Greason Road Carisle, PA 17013 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 Commonwealth of Pa Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. May 13, 2003 DATE Attorney for Plaintiff EXHIBIT McCABE, WEISBERG AND CONWAY, P.C. BY= TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term DATE: May 13, 2003 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Dennis G. Deitch and Sharon L. Deitch PROPERTY: 136 Greason Road, Carisle, PA 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on JUNE 11, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT "B" EXH! ~0 ~ ~ o ~oo~ ~~ ~ ~ ~ ~ ~ o ~ ~ ~ 0 ~ ~ ~ ~ ~ ~ 0 ~ 0 ~ ~,601,61, ~ 6/.6~.'. i ~ o01,' ~0, ~zoz ~/./.¢Z£ZZgd g~V. LSOd'S'N I, YZI, McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff CUMBERLAND COUNTY CO%~T OF COMMON PLEAS Number 02-5558 Civil Term AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 20th DAY OF MAY, 2003, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit %%AIl . Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." TERRENCE J.~cCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 20th DAY OF MAY, 2003. NOTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 02-5558 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 136 Greason Road, Carisle, PA 17013, a copy of the description of said property ils attached hereto and marked Exhibit "A." o Name and address of Owner(s) or ]Reputed Owner(s): Name Addre s s Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 Name and address of Defendant(s) in the judgment: Name Address Dennis G. Deitch and Sharon L. Deitch 136 Greason Road Carisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the rea]. property to be sold: Name Address Household Finance CDC West Pennsboro Township Condemnation 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 and 961 Weigel Dr, P.O. Box 8604 Elmhurst, IL 60126 2150 Newville Road Carlisle, Pa 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address BiT Carlisle, Pa 17013 Household Finance CDC 26 Gateway Drive Gateway Square, Ste 107 Mechanlcsbur~, Pa 17055 aRa 961 Weigel Dr, P.O. Box 8604 Elmhurst, IL 60126 Household Realty Corporation 26 Gateway Drive Gateway Square, Ste 107 Mechanicsburg, Pa 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants (s)/Occupant (s) 136 Greason Road Carisle, PA 17013 Domestic Relations Cun~erland County P.O. Box 320 Carlisle, PA 17015 Commonwealth of Pa Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 49,94 relating to unsworn falsification to authorities. May 20, 2003 DATE TERREN~'J J.'-~cCABE, ESQUIRE Attorney for Plaintiff XHIBIT McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Household Finance Consumer Discount: Company : Vo Dennis G. Deitch and Sharon L. Deitch Attorney for Plaintiff C~4BERLAND COUNTY COI/RT OF COMMON PLEAS Number 02-5558 Civil Term DATE: TO: May 13, 2003 ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF S~RRIFF'S SALE OF REAL PROPERTY OWNER(S): Dennis G. Deitch and Sharon L. Deitch PROPERTY: 136 Greason Road, Carisle, PA 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on JUNE 11, 2003 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT "B" ! i RCstri De!iver