Loading...
HomeMy WebLinkAbout00-03475 ""'~~ ^~ -~ ~. .-,1 "yk SANK OF AMERICA, N.A SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB IN THE COURT OF COMMON PLEAS C~1BERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00 - .34'l.S C~d VB. CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PATRICK WOODS Defendant 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 claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE 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 SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD 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 ABOGAOOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, PA 17013 717-243-9400 " " "l:~",' BANK OF AMERICA, N.A SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. vs. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE PATRICK WOODS Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 u.s.c. S1601: 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 . '",. _Ji. ~ ~ BANK OF AMERICA, N.A SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. MJ- ..1'175' ~ "I.Lu- vs. CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE PATRICK WOODS Defendant COM P L A I N T 1. Plaintiff, BANK OF AMERICA, N.A. SUCCESSOR IN INTERST BY MERGER OF BANK OF AMERICA, FSB, is a corporation with an address of P.O. Box 26388, Richmond, Virginia 23260. 2. Defendant, PATRICK WOODS, is an adult individual whose last known address is 129 THRID STREET, WEST FAIRVIEW, PENNSYLVANIA 17025. 3. On or about December 31, 1992, the said Defendant executed and delivered a Mortgage Note in the sum of $54,573.00 payable to BANK UNITED OF TEXAS, FSB, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant 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 1111, Page 1142 conveying to original Mortgagee the subject premises. The Mortgage was subsequently to MARGARETTEN & COMPANY, INC. and recorded in the aforesaid County in Mortgage Book 450, Page 923 on August 5, 1993. The Mortgage was subsequently assigned to BANK OF AMERICA, FSB. and recorded in the aforesaid County in Mortgage Book 502, '". ~~ ~ , I,;, ''''''''i! Page 315 on August 18, 1995. Bank of America, N.A. is successor in interest by merger of Bank of America, FSB. Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 129 THRID STREET, WEST FAIRVIEW, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on December 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ (b) Interest at $11.24 per day from 11/1/99 to 7/1/00 (based on contract rate of 8.000%) 50,594.94 2,720.08 (c) Accumulated Late Charges 0.00 (d) Late charges at $20.02 per month for 8 months 160.16 (e) Escrow 0.00 (f) 5% Attorney's Commission 2,529.74 $ 56,004.92 *Together with interest at the per diem rate noted in (b) above after July 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. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. 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. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 11. plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has 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 8.000% ($11.24 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. ByPUR~LBR Leo . Haller Attorney for Plaintiff 1. D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 .',',Hi. i~ , ". ". .' %'i'~;. '," 'l'Cn. ,. v"r....~momci.;.~, ~~~ l:~::~:f. 7t. u.~.e.^<Ctl'llbl.ID F.<k...IN.. lioqlMDtlp,.A._i,oliDl1 tA..-.IF<b..IWII 00848318 PENNSYLVANIA . Cert1fi.ed' to be ,.. ~~ 0;', of the ('(",.::;'~,~: J . ..' . '.. MORTGAGE NOTE NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. $ .54 573 00 FOR VALUr:. RECEIVED, !he undersigned, PATRiCK WOODS t,l,ES! FAtR\'IE.'\lI' DECEMBER 31 ST SOLE OWNER , Pennsylvania. .19 92 3200 . hereinafter called the Maker, promises to pay 10 SOUTHWEST ?REEWAY U2000 HOUSTON ,or order, BANK UNITeo OF TEXAS FSB TEXAS 77 0 2 7 >>.X::lUtl'bKlX!l:l.n organized and cxis!ing under the laws of the hereinafter designated as lhe Payee, the principal sum of SEVENTY THREE AND 00 100 UNITED STATE::; fIFTY FOUR !HOUSAND FiVE HUNDRBD Dollars(S _ 54 573 00 per centulTI ( rh... .',aid l)linciral <lnd illlL'rL'.~1 ~h~ll he , in or'such place as the holder 100 with interest from date aI rhe rale of EIGHT AND oe.ooo 100000 ...8.000 U:"l pel ;\;\\lI\m ()\\,Ihe Ill\p;\it\ t-';Ol.l1)(C un:i\ p;lid. payabkiu lhcoffiLe01 l1,\~K UNlTED OF I!::XA$ FS& at HOUSTO~ TEXAS 77027 may designate in writing in monthly installments of FOUR HUNDRED AND 44 first day of Dollars (5 400 44 J, commencing on the . 19 93 ,and on the first day of each month thereafter until the princi~ except that the final payment of the entire indebtedness evidenced hereby, . \d payable on the first day of JANUARY , 2023. at any time, wilhom premium or fec, Ihe entire indebtedness or any Dart thereof :nllmerll. or One Hundred Dollars ($100.00), whichever is less. Prepayment in full J. Partial prepayment, other than on an installment due dale, need not be credited due date or thiny days aflcr such prepayment, whichever is earlier. lion of this Note the Maker has execUled and delivered to the Payee a 1\'lort- situated in (he COUnlY of CUMBeRLAND more particularly des.cribed in lhe Mortgage. All of Ine lerms, ~~ve\'\ant:;, nd agreements contained in said Mongagt to be kepi and performed by the ~:Iaker 10 Ihe same extent and with the same force and effC('! as if they were fully sel IS and agrees to perform Ihe same, or cause the same to be kepi and performed, ; and provisions thereof. FE lIR.IIAR Y \ 'l',"" :,.. , :.- I;.. .;;1 'I . ;J ~, i' I) ,', ~,) .~ " .'; ;!',;"I" i) . .~ I or any part Ihereof. and of any other ~ums of money secured by Lhe ~lort. fOrlhwilh, allhe option of the Payee or any subsequent holder thereof, become Jl nOlice or demand. if dcfaull be made in any payment under !his Note. and ) the due date or the nexl such iostallmt:nt; or upon the happening of any defallit iven 10 secure this Note. shall entitle the Payee, or any subsequent holder hereof. eof, to be due and payable. ower any attorney of any cour~ of rttord within the United S,ates Ih or without a decla:ation filed, and confess judgment or judgments against :e or any subsequent holder hereof. as of any tem. for Ihe entire other sums paid by the holder hereof to or on behalf of the Maker pursuant t, . .,~_. ~e>dge. a.nd aU arrearages of inteu:s\ thereOn. together with costs of suit, attorney's eommissioil of 5.0000 070 for cOlleclion, and a release of all errors. on wt,ich judgmem execution or executions ma}' issue forthwith. The maker hereby waives the righl of inquisition on all properly levied 'upon to collect the indebtedness evidenced her,eby and docs voluntarily condemn the same and aUlhorizes the Prothonotary 10 enter such condemnation, and waives and reiea5Ci aU b.ws, now in force or hereafter enacted, reiating (0 exemption. appraisement or stay of execution. The agreements herein contained shall bind. and the befll:'fits and ad~'antagcs sh~1I inure 10. the respective successors and assigns of the parties hereto. Wherever used. the singular number shall include the plural. the plural the singutar, and lhe use of any gender ~hall be applicable to aU g,enders. IN WITNESS WHEREOF. the Mak~r has caused these presents ~oJ~.e exC(' ted under seall~ day and year lirsl above written. ( . /. w,.-/'...../(. ~ Signe . Scaled and Delivered in the Presence of: \ tZ-' .:.-L /~ . ~ (Seal) It>,f__~ PATRICK W0005 (Seal) (Seal) (Seal) THtS IS TO CERTIFY that this is the NOle describ-..-d io and ;,C\:\\~ed by Mortgage of even dale herewith ~ecur;:d on "ale"at:,:;:~::e~,;~" GUMBER,L,ANO I tl;;i:~ea;; ;;;,\ _ M;~~; :''-;I~,SI~i'j''I::"ri'k~$'';l~;;Z~';.\~j~ I ,'''o/,;r) PJ'bI"?-- G.2{PAI~'Qll . VMP'MOIITG"t.G(fOl\MS.'J'1I2~'X."!!OOi~21"291 "A" ;::::-Xn\tJ:~l -'9,: ~ >~ - ~ .. ~~~'"~c Comm\\menl Number SCHEDULE C - Land Description 1505 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the borough of West Fairview in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows, according to a survey made by Gerrit J. Betz, Registered Surveyor, dated May 5, 1976, -as follows, to wit: BEGINNING at a hub on the Eastside of Third street (33 feet wide) at the corner of lands of Earl:A. Robinson, Sr., said point being measured along said Road, 416~82 feet to the centerline of Market Street j thence, ,extending from said point of beginning and along the said side of Third Street, North 15 degrees 00 minutes West the distance of 20.06 feet to a drill hole at the corner of lands of William C. Phillips; thence along said lands, South 85 degrees 31 minutes 17 seconds East the distance of 129.23 feet to a hub on the West side of an alley (20 feet wide); thence along saId alley South 02'degrees S9 minutes West the distance of 19.00 feet to a hub at the corner of lands of Earl A. Robinson, Sr.,; thence along said lands North 85 degrees 29 minutes West the distance of 123.04 feet to a point, the place of BEGINNING. BEING known as No. 129 Third Street. BEING THE SAME premises conveyed unto Patrick Woods, Mortgagor herein by deed tfrom Steve R. Roush and Jackie L. Roush, Grantors herein dated h P ~(I/71l.If/br ~ ....? I f 1992 to be recorded in the Office of the Recorder of Deeds in and for Cu~erland County, Pennsylvania. ", P<l~n~ylv:lnia 1 )~ Il:lIL'~rlf',nd ss ~ '/1: ,..!/lee f....., the rncordmg of Oeodr. , "))j """on., C""",~P J It., ::::- /.1Qe}j. ".~..' ~JfJfOItIC " I) 'It... ...b..~d.V of 19 tJ.ff -~c~ ;r..- :<;:~;;:;E;?:."" A,' '~'~:~~i~X ....",... booi1111 pmllM; STEW ART TITLE GUARANTY COMPANY UhilJ i r "i)" = --= 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, BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, N.A. 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: June 5, 2000 ~ Leon P. Haller, Esquire /' " "."> . "'l''"' ,,~_N '~I'.,',w,' .'.";;: '" '-';;';'" , ... BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BAN~ OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT 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 Defendant PATRICK WOODS 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 $11.24 from 11/1/99 to 7/1/00) Late charges ($20.02 per month to 7/00) Escrow Deficit 5% Attorney's Commission $50,594.94 $ 2,720.08 $ 160.16 $ $ 2.529.74 TOTAL $56,004.92** ** 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. PURCELL, KRUG By Leon P. Haller PA I.D. #15700 l7l9 North Front Street Harrisburg, PA l7l02 (717) 234-4178 I:\HOME\MKF\DOCS\CUMBERLA\WQODS.P - , ~ <<' I' fl1i~ili I ... BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on AUGUST 24, 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 ". - '~" ~ " , .... BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-3475 Vs. CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE PATRICK WOODS Defendant DATE OF THIS NOTICE: August 24, 2000 TO: PATRICK WOODS 129 THIRD STREET WEST FAIRVIEW, PA 17025 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, KRUG & By Leon P. Haller Attorney for Plaintiff LD. #15700 1719 N. Front Street Harrisburg, Pa. 17102 717-234-4178 iiJe' . - BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT 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 subscribed befor,. m5- this? day of ..-XUj'l-/' 2 0 dR 4tk-t/rhAA;:6/--' o ary Public LEON P. HALLER, ESQUIRE NOTARIAL SEAL MARYLAND K, FERRETTI, Notary Public LOWER pAXTONTWP" DAUPHIN County My Comml~slon ExplresAUGUST 8, 2002 .'. ,I, ~", " Hl ~ 01 \~ \ '"""'"' .,~ ~ (t-- E ~ r- ',~, ' 'f' 'I ,., .~', ~.~~~ ., ,<" '" ,,> ",,-,,,r,,.' ,. , " , ~ . ",' " ' " . .",,',-'<' , ~Q~ ~ ~~ ~ It ~ ~" . ~ a::- ~ ~ ~ ~ ~ "T; g:: ~. -<-- !;':: ?~E~' Pc: L :< - o c~ C) :-0 ''-'1 " l",,: J:'., l) "-) <0 :E -< ~: , ;; l~,"f~ .,.;,. { "' ,'~ '~, '0 ,..~ . - ~, '<_" - .. c' ;;"".,.,', '_, ~)i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Bank of America, N.A. Successor in Interest by Merger of Bank of America, Plaintiff . ) Confessed Judgment FSB, (XX) Other IN MORI'GAGE FORECLC6URE File No. 2000 3475 vs. Amount Due pe r judgment $ 56,004.92{ " Interest at $11. 24/diem 1,775.92 from 7/.1/0U to lL/fI/uU Late charges at $20.02/mo 80.08 B;cra..1 Deficit 1,560.00 osts Total $ 59,360.92 Patrick Woods, Defendant TO THE PROTHONOTARY OF THE 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. Issue writ of execution in the above matter to the Sheriff of CUMBERLAND for debt, interest and costs, upon the following described property of the defendant(s) Real Estate: 129 Third Street, West Fairview, PA 17025 County, IN MORI'GAGE FORECLC6URE 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 es ate, supply six copies of the descrip.: ; supply four copies of lengthy personalty list) EST indica trick Woo s . and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). <j~(t-- o-v p;,. C{J)W~ wi flA-dIL(~ t""<<roif, o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estat defendant(s) described in the attached exhibit. Date 7-7-rJ 0 Signature: Print Name: Address: leon P. Haller, Esquire Purcell, Krug & Haller 1719 North PP9Rt Street Harrisburg, PA 17102 Attorney for: Telephone: Supreme Court 10 No.: PIAINTIFF 717-234-4178 U5700 (over) iiI ~~, ~ 1 liio'f. ~ . . "~'1!': , ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro (formerly Borough of West Fairview), County of Cumberland, Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by Gerrit J. Betz, Registered Surveyor, dated May 5, 1976, as follows: BEGINNING at a nub on the Eastside of Thirc~ Street (33 feet wide I .' ;,\ the corner "of lands 'of EarlA. Robinson; Sr" said' point bEjing , measured along ~aiq ~oaq, 416,82 feet,to the ce~te:1ine of Market Street; thence extepding from said )?Ol,nt ot beg~nn:Lng and along toe said side of Third street, North 15'degrees 00 minutes West the distance, of 20.06 feet to a drill hole at tne corner of lands of William c. I Pnillips; thence along said lands, South 85 degrees 31 minutes 17 seconds East the qistance of 129.23 feet to a nub on the West side of an alley (20 feEjt wfde)/ thence along said alley South 02 degrees 59 minutes West the. distance of 19.00 feet to a hub at the corner of lands of Earl A. Robinson, Sr.,; thence along said lands North 85 degrees 29 minutes West the distance of 123.04 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A dwelling known as 129 Third Street, West Fairview, PA. BEING THE SAME PREMISES WHICH Steve R. Roush and Jackie L. Roush by deed dated 12/31/92 and recorded 1/5/93 in Deed Book B-36, Page 822 granted and conveyed unto Patrick Woods. TO BE SOLD AS THE PROPERTY OF PATRICK WOODS ON JUDGMENT NO. 2000 3475. ASSESSMENT: 45-17-1044-210 J ~ I' '~ ,'''''~" 0" ," " <, .~"",. ~I~ ~~~iil~iilitOO"" ~~~"'""'tt' '.itIJl!I;Jjj,* ~ ~ ,,~ ".' ~, , " ~IUiiIi!I:illI "J -- \' ~ 0 fV \' ~ .\~ ~ c- o ~: ~:.., ~~~ ~~{ -- G6 ::,>:':1" 0- R.., (n ~ & ~ ~~~ -,,...-'. I:j ~ CJ-. _,l>'- ~ ~ ~ ~f; <::> 2: --,.\ ~~ '-~',"'" . ., tl!ti~ ;t""'- :. ~'-, I ~ ,I) ;-''''1 'J - ,,-,!" r'<, N '0 i....:' :;:j ':I:'J -< r~ - .' '. "'~'.,'''' "~.",, W.~<d", <C""" '"' '", " BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT 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 129 THIRD STREET, WEST FAIRVIEW, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) : Patrick Woods 129 Third Street West Fairview, PA 17025 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) : 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 ,~"" ""c. ., ;'-- ,'. > , ' '~""" ' .' '~".' >~'"~ ; , ~ )1;.,: ~ " 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: 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 de subject to the penalties of 18 PA C.S. Section 4904 relat' to 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 7, 2000 ~'_II~ ,." ~~, ~", ^ " ~ ., "', un ....'iiiIIIiIIiil'. '~.,~,. ,.",.>, . ,,~ ,0.," ~....; .... o C <;':"" s~f,f :::<t ~2~_~' r:::c: ~~ L .-' -< , , ;1') "1'1 Cl !'<' -'-, _1.. ,'V I,.D :-.;..~ 5:J ~~ ;" . " ~ ~ ';~,! I" t BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT 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: 129 THIRD STREET WEST FAIRVIEW 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 3475 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: PATRICK WOODS "'. K';~ "" li.l!l:~i. i" . 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 (lO) 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 l70l3 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. 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 ~.- ~.J ,--, , ~'"' -L! I I I I I I ,. \ 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 .. , I ALL THAT CERTAIN piece or parcel of land situate in the Township of East pennsboro (formerly Borough of West Fairview), County of Cumberland, Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by Gerrit J. Betz, Registered Surveyor, dated May 5, 1976, as follows: ~EGINN!NG at C\ Il\lb on the Eastaide of rhirq Street (33 feet wiq!') , at the corner of 'lands of Earl A. Robinson, Sr" said point being, measured along paiq ~oaq, 416,8~ feet to the centerline of Market Street; thence ext",pding from said poi,nt of beginning and along the said side of Third street; North 15'degrees 00 minutes West the distance, of 20.06 feet to a drill hole at the corner of lands of William c. ! Phillips; thence along said lands, South 85 degrees 31 minutes I? seconds East the distance of 129.23 feet to a hub on the West side of an alley (20 feet wide); thence along said alley South 02 degrees 59 minutes West th~'distance of 19.00 feet to a hub at the corner of lands of Earl A. Robinson, Sr.,; thence along said lands North 85 degrees 29 minutes West the distance of 123.04 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A dwelling known as 129 Third Street, West Fairview, PA. BEING THE SAME PREMISES WHICH Steve R. Roush and Jackie L. Roush by deed dated 12/31/92 and recorded 1/5/93 in Deed Book B-36, Page 822 granted and conveyed unto Patrick Woods. TO BE SOLD AS THE PROPERTY OF PATRICK WOODS ON JUDGMENT NO. 2000 3475. ASSESSMENT: 45-17-1044-210 ~i"i I I I I i c 'i;il,~~~i~~~ii;;j,~il~!\h,",iji;~~&iH:iiJld~iiQl'~ ~,. .' ~ c .~..., c .~ ... 1.1 '~li'. ....' ~.,' I 1 ~ --,. -- 8 \ C' (=:-) c:: "OJ l 1 [.T~ r '".,::; -~-' m , (~,.~ r' -< ~ )> c") z j;> C': ?-- ~~~ ::.::: :~") ."" :;2 5"} \ 0 -< ..:..~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-03475 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA NA VS WOODS PATRICK DAWN KELL , 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 WOODS PATRICK the DEFENDANT at 0012:36 HOURS, on the 19th day of June , 2000 at 129 THIRD ST WEST FAIRVIEW, PA 17025 by handing to PATRICK WOODS 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 9.30 .00 10.00 .00 37.30 so:?~~! R. Thomas Kline Sworn and Subscribed to before 06/21/2000 PURCELL, KRUG & HALLER ~QWY) ~. ~ Deputy Sheriff By: ttc me this 7 - day of C}~) A~ ~ /hlllt',...., ~- Pr t onotary , ..,,,"'. .' ,,~,' .. , . . illii; , . BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I e osited in the U.S. Mails at Harrisburg, pennsyl vania on , a true and correct copy of the Notice of Sale of state pursuant to PA R.C.P. 3129.1 to the Defendants herein 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: Patrick Woods 129 Third Street West Fairview, PA 17025 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 "",' .".," I" . '" ~ '.,.",~ ~ .'~ ,',,",,,,", ".,. ~'",,<,. JOHN W, PURCELL HOWARD B. KRUG LEON P. HALLER JOHN W, PURCELL JR BRIAN J TYLER JILL M, W1NEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEFT, FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Patrick Woods 129 Third Street West Fairview, PA 17025 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. By: said YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, said Sheriff's Sale. Leon P. Haller PA I.D.15700 Attorney for Plaintiff ..< .." ....",. ,.",' '&.. Cd"'~'.' ,',,' ."';J,:~'. ,',~.~ ~'~~ BANK OF AMERICA, N.A. SUCCESSOR IN INTEREST BY MERGER OF BANK OF AMERICA, FSB PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 2000 3475 PATRICK WOODS, DEFENDANT 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 l7013 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: 129 THIRD STREET WEST FAIRVIEW 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 3475 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: PATRICK WOODS '=" u,' .".- ,'. '" ,"~" ~"",~"o;,;;"h"~ , -- d-';"'~"", ~ ~' 'h .."i-q 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 (lO) 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 ~HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania l70l3 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: l. 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. 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 .. . ~". ~, ",. 0 " " '> ,_" ,"'- ~_" '~"_'i,,,_ 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 a -""~< [ WI~I,,- ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro (formerly Borough of West Fairview), County of Cumberland, Commonwealth of Pennsylvania, bounded and described in accordance with a survey made by Gerrit J. Betz, Registered Surveyor, dated May 5, 1976, as follows: BEGINNING at a A\lb on the Eastside of Third Street (33 feet wide)' dt the corner "of .lands. of Earl A. Robinson; Sr" said' point bEling . measured along ~aid ~oad, 416,82 feet to the centerline of Market Street; thence extepding from silid point of beginning and along the said side of Third street, North 15'degrees 00 minutes West the distance, of 20.06 feet to a drill hole at the corner of lands of William C. i Phillips; thence along said lands, SoutA 85 degrees 31 minutes1? seconds East the distance of 129.23 feet to a hub on the West side of an alley (20 feE)t w{de)/ thence along said alley South 02 degrees 59 minutes West the '.distance of 19.00 feet to a hub at the corner of lands of Earl A. Robinson, Sr.,; thence along said lands North 85 degrees 29 minutes West the distance of 123.04 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED A dwelling known as 129 Third Street, West Fairview, PA. BEING THE SAME PREMISES WHICH Steve R. Roush and Jackie L. Roush by deed dated 12/31/92 and recorded 1/5/93 in Deed Book B-36, Page 822 granted and conveyed unto Patrick Woods. TO BE SOLD AS THE PROPERTY OF PATRICK WOODS ON JUDGMENT NO. 2000 3475. ASSESSMENT: 45-17-1044-210