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HomeMy WebLinkAbout00-03622 - ~~ ~-- - FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff KEYSTONE FINANCIAL BANK, N.A., S/I/I FINANCIAL TRUST COMPANY 2270 ERIN COURT LANCASTER, PA 17604 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 00-3622-CIVIL V ASILIKI T. PIDLLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against V ASILIKI T. PHlLLIPY , Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 6/1100 TO 7/24/00 $55,972.72 $597.78 TOTAL $56,570.50 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~cvz/{ ),rt~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATEZZ DATE, ~~ A11_~ PROPROTHY "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN IlANKRUYfCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ".~ ~-~ ~~~ .~ . "~ ~ , ~ '"~~ ~- FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, N.A., S/I/I FINANCIAL TRUST COMPANY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY VASILIKI P. PHILLIPY NO. 00-3622-CIVIL Defendant(s) TO: VASILIKI P. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 DATE OF NOTICE: JULY 11. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ,",0 ~ FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff KEYSTONE FINANCIAL BANK, N.A., S/I/I FINANCIAL TRUST COMPANY : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-3622-CIVIL V ASILIKI T. PIDLLIPY Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant V ASILIKI T. PIDLLIPY is over 18 years of age and resides at 21 CHESTNUT STREET, MOUNT BOLLY SPRINGS, P A 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~l~J~/ FEDERMAN Attorney for Plaintiff ~ ~ ..~ "" b.:i::. ~ . , (Rule of Civil Procedure No. 236 - Revised) KEYSTONE FINANCIAL BANK, N.A., S/I/I FINANCIAL TRUST COMPANY : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-3622-CIVIL V ASILlKI T. PIDLLlPY Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JULY OJ) .2000. BY~ot tlJ:k DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** t~" IUill.J!ii'""~ " , m.!!.lI>lli&i~,..'lliil.Iii'=""'"-~ '._~~' ,,~ . ~.~ - o ~; < -r.ir::'.'. rnl:'-, Z':::'U ZC Cfj ):~ r;C:' j~c: (::0-:(--->) yr'" ?; -< ~ 19 -;:-C::::, "3-t:: -C0* <:'!o 0 ~~ -D~ ~ 0 ~ (N~ -ry 0 C) <:> ~ --'d ~ f 'Iiil"~ ~~ ". ,,d lb. I I ! ~ r<:J c" ~:.~ c:; ',n (::;, '" , SHERIFF'S RETURN - REGULAR CASE NO: 2000-03622 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KEYSTONE FINANCIAL BANK N A VS PHILLIPY VASILIKI T WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PHILLIPY VASILIKI T the DEFENDANT , at 0019:45 HOURS, on the 20th day of June , 2000 at 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 by handing to VASILIKI T. PHILLIPY 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 3.72 .00 10.00 .00 31.72 So Answers: :l"'~ .. ~t:~ I R. Thomas Kline 06/21/2000 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~~ \ ~~ u y Sheriff a-- me this '7 - day of ~ AD a -h,,()~,,'/ ,,~ r thonotary' / ,~"'"""",,,~'- - ~ , , "~ . "., " - ~YSTONE FINANCIAL BANK, NA., S/I/I)ANCIAL TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION V ASILIKI T. PHlLLIPY NO. 00-3622 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) KEYSTONE FINANCIAL BANK. NA.. S/I/I FINANCIAL TRUST COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 21 CHESTNUT STREET. MOUNT HOLLY SPRINGS. P A 17065. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) V ASILIKI T. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~-~. ~ , 4. -~. ,~ ~ .. -~" li,,: NAME Name and address of the last recorded holder of every mortgage of record: FINANCIAL TRUST COMPANY LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ONE W. HIGH STREET CARLISLE, PA 17013 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania, Bureau of Individual Tax, Inheritance Tax Division, Attn: John Murphy Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Federllted Investors Tower 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 13 North Hanover Street Carlisle, PA 17013 6th Floor, Strawberry Square Dept. #280601 Harrisburg, P A 17128 P.O. Box 8486 Willow Oak Building Harrisburg, P A 17105-8486 Thirteenth Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, P A 15222 -,,- "~ ~~ , . I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 7. 2000 DATE ::Z~~~UIRE/ Attorney for Plaintiff ~~~~~i>WJW.*II!~'_'lMfu>!,j'Jr~;-ml!tlHliJf~J"~~;"1"'" \'~ '" _---......-._......""'_.....11,,;-.... ,.:., ri~ ;;~ f~~i~' -</ ~~, P-c~ Z --j -<. () <:;:; CJ 'j) i" ," .-"-" :",) ',~' .-~., ':::'-", ,::q -<. ~"',) (Jl '"""'"''' ~ ~,u I f. I I I I ". ,. ;;"" ~ ~ > FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPIDA, PA 19102 (215) 563-7000 KEYSTONE FINANCIAL BANK, N.A., SII/I FINANCIAL TRUST COMPANY 2270 ERIN COURT LANCASTER, PA 17604 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. frO _ 3(...2.:l- ~ -r;.- V. CUMBERLAND COUNTY V ASILIKl T. PHILLIPY 21 CHESNUT STREET MOUNT HOLLY SPRINGS, PA 17065 Defendant( s) CIVIL ACTION - LAW MORTGAGE FONECLOSURE NOTICE '. "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY"AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: 10029395 ,. - l "~ " tliillk'-' 1. Plaintiff is KEYSTONE FINANCIAL BANK, N.A., SII/I FINANCIAL TRUST COMPANY 2270 ERIN COURT P.O. BOX 7628 LANCASTER, PA 17604 2. The name(s) and last known addressees) of the Defendant(s) are: V ASILIKI T. PHILLIPY 21 CHESNUT STREET MOUNT ROLLY SPRINGS, P A 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/31196 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1323, Page 377. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/29/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ,'~'_'oJi'" ~ - - ~~,~,. , . ~ -'I 6. The following amounts are due on the mortgage: Principal Balance Interest 10/29/99 through 6/1100 (Per Diem $11.07) Attorney's Fees Cumulative Late Charges 5/31196 to 6/1/00 Cost of Suit and Title Search Subtotal $50,506.60 2,391.12 2,525.00 0.00 550.00 55,972.72 Escrow Credit Deficit Subtotal TOTAL 0.00 0.00 0.00 $55,972.72 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. S1680A03con the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency, a copy of which rejection is attached hereto as exhibit "B" WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $55,972.72, together with interest from 6/1100 at the rate of$I1.07 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. .,... ~:+a ,~___ .... f(;9:ankFe/~- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 'al. . . ~' cod 2270 Erin Court P. O. Box 7748 Lancaster, PA 17604-7748 K9'?tone Financial Mort~ge~, .,~ Corporatlo~ 1-800-KEY-8131 (717) 399-6498 FAX (717) 397-2834 January 31, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortGaGe on vour home is in default. and the lender intends to foreclose. Specific infonnation about the nature of the default is provided in .the attached paaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IHEMAPI mav be able to help save vour home. This notice explains how the proaram works. To see if HEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the CounselinG Aaencv. The name. address and phone number of Consumer Credit CounselinG Aaencies servina vour County are listed at the end of this Notice. Ifvou, have anv auestions. vou mav call the Pennsvlvania Housing Finance AGencv toll free at 1-800-342-2397. (Persons with impaire~ hearinG can call 17171780-18691. This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DE~ECHO A CONTINUAR V1VIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION ,INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE" EL CUAL PUEDE SALVAR SU CASA DE LA PEROIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Vasiliki T. Phillipy PROPERTY ADDRESS: 21 Chestnut Street, Mt. Holly Springs, PA 17065 LOAN ACCOUNT NUMBER: 10029395 ORIGINAL LENDER: Keystone Financial Bank, N.A., successor In interest to Financial Trust Company CURRENT LENDERlSERVICER: Keystone Financial Mortgage Corporation EXHIBIT ~ 1 ,,* " ~ I ~_~. ~ ~ lJiIit'i:...,-!l,,,, HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM yOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELlGILIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 1301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAUL ro. EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thIrty (30) days after the date of this meeting. The names. addresses and teleohone numbers of desianated consumer credit counselina aaencies for the countv in which the orooertv is,located are set forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediatelv af your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you havll' the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODSSET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can stili apply for Emergency Mortgage AssIstance.) EXHIBIT A 2 ~-" _....i!.. " ,~~ .;-! HOW TO CURE YOUR MORTGAGE DEFAULT fBrina it UP to datel. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 21 Chestnut Street, Mt. Holly Springs, PA 17065 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE BI-WEEKLY MORTGAGE PAYMENTS for the following weeks and the following amounts are now past due: $238.29 for the bi-weekly payment for November 12. November 26, December 10. December 24.1999, January 7, and January 21. 2000. LATE CHARGES AND OTHER CHARGES: $0.00 TOTAL AMOUNT PAST DUE: $1,429.74 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,429.74, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check or money order made aavable and sent to: Keystone Financial Mortgage Corporation 2270 Erin Court P. O. Box 7748 Lancaster, PA 17604-7748 IF YOU DO NOT CURE THE DEFAULT - If you do n,at cure the default within THIRTY (30) DAYS of the date of this Notice, The lender intends to exercise its riahts to accelerate themortaaae debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attomeys to start legal action tQ foreclose UDon vour mortaaaed DroDertv. IF THE MORTGAGE IS FORECLOSED UPOlll':" The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attomeys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If YOU cure the default within the THIRTY 1301 DAY Deriod. YOU will not be reauired to Day attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CLlRE THE DEFAULT PRIOR TO SHERIFF'S SALE -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the riaht to cure the default and prevent the sale at any time ua to one hour before the Sheriffs Sale. You may do so bY DaYina the tatal amount then Dast due. Dlus any late or other charaes then due. reasonable attorneY's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as saecified inwritina bY the lender andbv Derfonninll anv ather reauirements under the mortaaae. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had neyer defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE It is estimated that the earliest date that such a Sheriffs Sales of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. E',n",j I )'Y ./"\ff il' L'~~ 3 .<i/'~' ~ ~." "' ~ ~ "'~ ~~ .l!~!>~~<i!>,! HOW TO CONTACT THE LENDER: Name of Lender: Keystone Financial Mortgage Corporation Address: 2270 Erin Court, P. O. Box 7748, Lancaster, PA 17604 Phone Number: (717) 399-7082 or (800) 760-1257 Fax Number: (717) 399-7099 Contact Person: Denise Lowrie EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor ..lL may not sell or transfer your home to a buyer or tranMeree who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEED,ING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, ~~ Rebecca Boston Default Manager EXHIBIT A- 4 "I - " '",,,, STATEMENTS OF POL ICY Name of Counseling Agency: Signer and Title: Telephone number: Address: Appendix C PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNERS'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONS UMBER CREDIT COUNSELING AGENCIES FRANKUN COUNTY rev: 6/5/1999 Financial SelVice Unlimited 31 West 3'" Street Waynesboro, PA 17268 717-762-3285 Urban League of Metropolitan Hbg. 2107 N. 6'" Street Harrisburg, PA 17101 717-234-5925 Fax - 717-234-9459 CCCS of Westem Pennsylvania, Inc. 912 South George Street York, PA 17403 717-846-4176 Adams County Housing Authority 139-143 Carlisle Street Gettysburg, PA 17325 717-334-1518 Fax - 717-334-8326 Community Action Commission of Capita~Region 1514 Derry Street . Harrisburg, PA 17104 717-232-9757 fax - 717-234-2227 eccs of Westem PA 2000 Unglestown Road Harrisburg, PA 17102 717-541-1757 fax - 541-4670 YWCA of Carlisle 301 G Street Carlisle, PA 17013 717-243-3818 fax - 717-243-9348 American Red Cross - Hanover Chapter 529 Carlisle Street Hanover, PA 17331 717-637-3768 fax - 717-637-2394 EXHlsrr A ,,"" =<". ,.~~ ~ ,~, ~ . ~'~-'.,~ . Your application for a HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE LOAN has been pENIED pursuant to Act 91 of 1983, 35 P.S. Section 168.401-C et seq. and/or Agency Guidelines 12 PA Code Section 31.201 et seq. for the following reasons: DELETED IN LENDER'S COPY You may be entitled to an appeal hearing if you disagree with our decision. We must receive a written request for a hearing within 15 days of the postmark date of this letter. (Appeal requests must be in writing; a verbal request is not acceptable). The hearing may be conducted by a telephone conference call; therefore, you must include your telephone number. Requests for hearings must state the reason(s) that a hearing is requested and must be sent first class, registered or certified mail to: Chief Counsel - Hearing Request, PHFA/HEMAP, 2101 North Front Street, P.O. Box 15628, Harrisburg, Pennsylvania, 17105-5628. The Agency will attempt to schedule the hearing within thirty (30) days after the request is received. When sending your appeal, please be sure to print your name legibly and include your. social security number. You have a right to be represented by an attorney in connection with your appeal. If you cannot afford an attorney you may be eligible for Legal Services representation. You can contact a Legal Services representative through the following toll free number: 1-800-732-3545. Please be aware that scheduling an appeal hearing does not necessarily stay foreclosure proceedings. DISCLOSURE OF USE OF INFORMATION OBTAINED FROM OUTSIDE SOURCE: 1. Disclosure inapplicable. The Federal Equal Credit Opportunity' Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided that the applicant has the capacity to enter into a binding contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal Agency that administers compliance with this law concerning this creditor is the Federal Trade Commission, Equal Credit Opportunity, Washington, D.C. The Pennsylvania Housing Finance Agency EVH~PIIT n ^ IW l'-ocJ ,~ " - LEGAL DESCRIPTION ALL T~T CER~A:N ~=ac~ of land si~ua~e i~ the aorough ot Mcunt Holly springs I , Cumberland c~ur.ty, Pennsylva~ia, bounced a~d cescribed as follo~s: BEGINNING at the Northeastern corner .of Chest",ut street at a limescone adjoin~g Lot No. 3; the~ce So~th along Chestnu~ Street, Eighty (60) feet to a limestone; thence West along land formerly of John C. T=ine, (erronGously w=-i=.t:an Joh..~ C. ,Sl:rine in p=ior deeds), new or :.:o::.:::rne::::ly of Rose C. Wolf, Or-a Hund:-ed Bight:y-five (l85) feet co a limest:one; thence North along said. land now or formerly of John c. Tri~e, (erroneously wri~ten John C. Strine in ~rior ceeds), Eight (eo) feet to a limestone; thence along Lot No.3, on the plan mentioned l:>elow (lSS) feet to a limestone, the place of Seginning. BEING Lots Ncs. 4 and 5 cf the Mathew Moore Plot of the Town Lots having a width On Chestnut Street of Eighty (ao) fset and a de~th along Lot No. 3 of One Hundred Eighty-five (185) feet, and being improved with a two and one-half story frame dwelling r.ouse known as a numbered 2~ c=es~ut Street. BEING 'rHE SAME PR3MIS1l:S w/Uoh BOLlJ Corporation, a eor>,ora1:ion ol:'ganized and existi:1S' under the laws of the Ccmmonwealloh of ""nnsylvania, by its aeed dated and recorded February 27, 1.~59. ;.n and for ehe Office o~ ~he Reeorder, CUm'oe-rlano. County, Pennsylvania in BeOK 4l~, Page 312. g=an1:ec and ccn-:eyec u"co Spero J. Tc\:..lo'.lmes an? Z-,,-a N. '!o"G.loumes, his '....:.:.e, G=an;:.or;; herein. ~ ;, , 21 CBESTNlIT STREET ,'., L' ~' L.. . . VERIFICATION ROBIN YOHE hereby states that he/she is VICE PRESIDENT of KEYSTONE FINANCIAL MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage foreclosure are true and correct to the best ofhislher knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. '-I?L ~ DATE: ~ -/.2 -06 ..~~,. '_l:IiJ:~~ ~!'t~ ...~til.:t:t" .....,0;' ~~,. ..d~"... ,j",., .- ..- o ~:: ? ~;; U)~,: ' -"--" ~cj ~C' );:c5 c: z ~ .", c) ~,~<) C1 ___J Lli ~,~,.... ~~L,: ,e; '.' j.;:! ::'.i ~ ~ ..\ ~ ..L '" ~ lr- -C tJ ' ' 0 ~p & ~ . "9 t ",," .... W 'v ~ f~ ~-o "'-, . 0 . --. , ~ '",~ -- "D\JJJ .> PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 KEYSTONE FINANCIAL BANK, NA., S/IJI FINANCIAL TRUST COMPANY CUMBERLAND COUNTY Plaintiff, v. No. 00-3622 CIVIL V ASILIKl T. PlllLLIPY Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $56.570.50 / Interest from 7/24/00-12/6/00 $.1255.50 and Costs ~;' (per diem - $9.30) $57.826.00 TOTAL Note: Please attach description of property.No. ~~A~~mim~",,!,L>B~,,;~t-ii>.."""'iI~OOl'~' Jr ]1~~tli!:;w.~'1~IIiiliIi!Ii1iii~MiUi~:.!1ir;m.u.~ 11<, '. . l/l '" <:> r-- ~~ .... :;g Z < =- 0 00 00;;- 00 ... ~~ i~ ... ~ ;;;l ><...~ ...:loo >- U i:l.J;li1 .,; ~~ ~~ =- ~e ~~=- ~ ~O ... J;li1 = ,",...00 d 0J;li1 ...:l '" =00>- '" ~=- ...:l r.. Q " ~ =u ... 0.. =-......:l .D ~ . 3~ = " . ;;;l...:l ~ 0 0>- =- ... ... 0 u~ .; ~~ "'ZO S 0 ~ t;2...= N uii ;. '" ~ r..o ~ ~ ~i'" .... z... " Ou <...:l ... ~~ Sju~ ~ ... ~~ i!5< ...:l 01:: 0.. ... {", ~r:1~ ~ r..... 00 r.. Q ;;;l< J;li1u < J;li16 ] 8;j ZZ ;;- =- ~ 0< ... '" J;li1J;li1 ...i!5 u '" ~ " == ..0 .... oor.. .", ...~ >- 2 .", .~ < Z;;;l ~ =- >'-< "'u o r~ ~::: -oc" nlfY', ~i=, ~:;_/ ~.:::: (~-, >~ -'l -<::: o c:::; ~/') "'1 V .~J " r.,.J __ ~ C) ,'.::i''','j , , .---" en --; .';:',;> kl ~"". ~, :"...) ~" ~-- ~~ ~. .-' - . Ji'4i': . , DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGI~NING at the :\fortheastern corner of Chesrnut Street at a limestone adjoining Lot No.3; thence South along Chestnut Street, Eighty (80) feet to a limestone; thence West along land formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), now or formerly of Rose C. Wolf, One Hundred Eighty-five (185) feet to a limestone; thence :\forth along said land now or formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), Eighty (80) feet co a limestOne; thence along Lot No.3, on the Plan mentioned below (185) feet to a limestone, the place of beginning. BEI:"iG Lots Nos. 4 and 5 of the ~lathew Moore Plot of the Town Lots having a width on Chestnut Street of Eighty (80) feet and a depth along Lot :"io, 3 of One Hundred Eighty-five (185) feet. and being improved with a two and one-half story frame dwelling house known as a numbered 21 Chestnut Street. T X P 'RCEL N'r"IBER'J~-~"l-')~~6-"l02 A..'"\ , l"lY . _.J .J. _.J.J _ TITLE TO SAID PRE1\USES IS VESTED IN Vasiliki T. Phillipy, adult individual by Deed from Dean Touloumes and Thomas :"i. Kaunas, as Executors of the Estate of Spero J. Touloumes and Vasiliki T. Phillipy, Demetrios S. Toulournes, Nickolette S. Poyatzis and Ylelody E. S. Mav, children and residuary beneficiaries of the decedent dated 5/21/96 recorded 5/31/96 in Deed Book 140 Page 254. iilII~l~~~1JJg~l'li&~~"~~Ii\!,;i@:'*~!til;llC"':ri,4t'k>tj'~I!:~,i.1f".,;(kl " ' ~. ~~ NJ 00 ~ "'.",~ '" ~,,', --."",<, ~~ , ,', '. ~lilJ~~!II!llliii( -~ =~.' - ~ ~ , -.J '}---' '~t2G~~ '< I .-- FD ~ uf UJ ~-)'--' -. 0-., <:>-,-' -...l~~ y '<~IW!I!fi!lllf!IE'i~ o ~,; -0 tl" rnr-;' z:" ;s: c., ~,;j "': -..... "-' ~~~, ~~~; ~=-4 -< ,~ -~ ~".~ .;::' :,,0 ';--Ti ""D O.M -T ~- i;? .''-.: U1 Ill} . @I '''1 .~~ =< .-.'" , ../-, "II,ln""'. ~I>>i", ." KEYSTONE FINANCIAL DANK, NA., SIIII FINANCIAL TRUST COMPANY CUMBERLAND COUNTY Plaintiff, No. 00-3622 CIVIL v. V ASILIKI T. PHILLIPY Defendant(s). September 7, 2000 TO: V ASILIKI T. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 21 CHESTNUT STREET. MOUNT HOLLY SPRINGS. PA 17065, is scheduled to be sold at the Sheriffs Sale on DECEMBER 6, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by KEYSTONE FINANCIAL BANK, NA.. S/I/I FINANCIAL TRUST COMPANY (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the _March 7, 2001_ Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. U~ "~ ~.~ --, -~~ . ~~ ~ -~ ~ , ~; " ~. ~ -L.~c You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) yOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 '~~ " " - ~ ~,,- - ~' < '. ~ ' ~ . DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the Northeastern corner of Chestnut Street at a limestone adjoining Lor No.3; thence South along Chestnut Street, Eighty (80) feet to a limestone; thence West along land formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), now or formerly of Rose C. Wolf, One Hundred Eighty-five (185) feet to a limestone; thence North along said land now or formerly of John C. Trine, (erroneously written John C. Strine in prior deeds), Eighty (80) feet to a limestone; thence along Lot No.3, on the Plan mentioned below (185) feet to a limestone. the place of beginning. BEING Lors Nos. 4 and 5 of the :Vlathew Moore Plor of the Town Lots having a width on Chestnut Street of Eighty (80) feet and a depth along Lot :So. 3 of One Hundred Eighty-five (185) feel, and being improved with a two and one-half story frame dwelling house known as a numbered 21 Chestnut Street. T AX PARCEL Nl:MBER: 23-32-2336-202 TITLE TO SAID PREIHISES IS VESTED IN Vasiliki T. Phillipy, adult individual by Deed from Dean Touloumes and Thomas N. Kounas, as Executors of the Estate of Spero J. Touloumes and Vasiliki T. Phillipy, Demetrios S. Touloumes, Nickolette S. Poyatzis and Melody E. S. May, children and residuary beneficiaries of the decedent dated 5/21/96 recorded 5/31/96 in Deed Book 140 Page 254. ~~~m~~l!!lli:<l4WM~,~j.1l1iJ~~;*,~i!~'1r'futiW,,;,;!!lrhH.,~'EJ~'It!!,' ~. '..~~,..~" ~, ~,," '--.'~-~ ,~ -fiililIViIi!I!] ~~ -'-"......' ~li.LdL'~ (') CJ ~ C) ::--;:,~ ':.-0 .,\ -r) ,--r-' :-'1 ,,<.( rn ~:;'- '"0 -;7 -",-' C . Clj r;.t- ~","; ~--~ - ~C' ~, ;SO j~~ c J>s::;, :::\ ,~ -'. (5'\ - _.1m;, ~ f' .~-_. - , ,~ '" , ''l/,ij' .' ~ ""'t,g' FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF KEYSTONE FINANCIAL BANK, NA., S/UI FINANCIAL TRUST COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION V ASILIKI T. PHILLIPY NO. 00-3622 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~~~~IRE/ Attorney for Plaintiff ~~!~~~~R0!~.ii<li:Ii1r~~i!miii~~~jllllliH#'*,1tl~A.:,,;j,;!h-h'~<i~"l'i:'.""*ijr' '~ .. - -~ , . - ~~ " -~':ID!' .'...a~' ':"~~'l<"';~~~ijHR'ih:T;"" (') C 5: -0'" .' ~~ir ~~ ~;~:,~: .0:;, ' ~~~, :> (~: z -, / ~ c- ',--' \;::,~ ~..r:1 -,"j '\:J "T" ,"'':; -",) en ",. ~, ,-~'- AFFIDAVIT OF SERVICE PLAINTIFF KEYSTONE FINANCIAL BANK, NA., S/III FINANCIAL TRUST COMPANY CUMBERLAND COUNTY N 0.00-3622 CIVIL DEFENDANT(S) SERVE AT V ASILIKI T. PIDLLIPY Type of Action - Notice of Sheriff's Sale 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 Sale Date: DECEMBER 6, 2000 Served and made known to SERVED . \h '\','1' I p~,I\\fi . _I\.. 19 5' I " \ , , Defendant, on the :; 0 , ckes-h,,,,,, St, , tfOVlAt- Hdf" , I \e>" 1<- day of 5'(>rte"" , 200~, '3(~\tJ ')5 , Commonwealth at.5': oj , o'clockf.m., at ;;l. I of Pennsylvania, in the manner described below: X Defendant personally served. Adult family member with whom Defendant( s) reside( s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: ,_.1 1"9,- Description: Age~ Height 5 j Weightm Race 'u).. SexL Other I, C \...It e ~(e. l. c:.....1L -t~1 ~o~petent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Noti e of SherIff's Sale in the manner as set forth herem, Issued m the captIOned case on the date and at the address indicated above. Notartal Seal . Stacy L. Heefner, No ry Public Q- Sworn to and sUb~bed Cha_lSburg BolO. kll aunly befo e this day My Comml_n E 'A . 2002 Of~, 200!!..~ember, pennsy ani s 'notN J..-F ~k . Notary: ~\...R By: ;r.. ~ L) ISO' NOT SERVED On the .__ day of_ , 200~ at o'clock _.m., Defendant NOT FOUND because: Moved UOknown _ No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 -' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - LD. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 r~1 ,. ~~~~..9:la!i~;*,~!!M,1;~1L~*,>'i%.~:;'];;Ici'I.>;;,"'~!\:Ii!'l,_~.:;jtW4' ~ Iit~~~~~~~.,'"'~~"'" g~t' Cr.),:" -<. .'~' ~~;, '::;::-\ , "'S: :::::j -< (') ~ r-\::I :...> 0-, o C;F ;=> :-') ('"), >" .....i :1 II ,I "j""; " ~ ".~ ~ ",.', ,,~ ~ """O\>!o<", l' ~ ,... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEYSTONE FINANCIAL BANK, NA, S/I/I FINANCIAL TRUST COMPANY Plaintiff CIVIL DIVISION vs. No. 00-3622 CIVIL VASILlKI T. PHILLlPY Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for KEYSTONE FINANCIAL BANK. N.A.. S/I/I FINANCIAL TRUST COMPANY, hereby verify that on SEPTEMBER 14.2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see \ Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 14. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ~~ ~YA~ FRANK F: DERMAN, ESQUIRE Attorney for Plaintiff Date: November 2. 2000 o o '"' .!l z;j] j BS 1>;1_.... =",'"' =-t~ oll"", Z",; <u._ ~=... =,So .. .. 1>;1"''''' Q e" ~= !:...f t "" .. = fI.l ~ ..~'g S"""'l ~"".... ...<e "ff~_~:"""~~ J! u H ~ C J}~- '.. r..- ~.<-~ ~ kl>-Pt{~~ I~ U.S.POSTAGf ~. \:r: SH'4'oo-:1(?,~ : ,0... )>. '- -'". ::: I 5 0 :: : \. paMETER - a - << t:} 6068360 : oe .... - ..~ =:i ~ Z",'-' 0 9.0 0 ~~g: s: _;;0;;.. = Q=~ tl~~ ~ ~~8 S ~:::~ ~ "'-1>;1""= 1>;1~...~... ~ ~ < Of' .. -~~:g~ ~...I>;1;:::S ...~~:;;~.... :g ;.<8.z",,,,:;:: ~ <~;;oc~:!l .... ~<~~...< ~~::l <5?..;I513'" ",Zo ;:;l:i~"'>= '-' 5 ~ 8;;.. '" ~ ~,~ '" ~u~ ~~~ Q; S ",Q .zl>;1..;1 !:'" ~ ~ ~ ~ ; ~ ~ ~ ~!:: ~ ..;I~:S 0<~_1>;1S:: ~ - ..;I 1>;1 ~ ;;0 ~ ~ QQ.. ~ rJ ~=< <~~=!:[;l '" ~ ...:;; u ~ ;.; ..;I = .. Z < ;;.. - z;;o,,;;o ... 1>;1 - 1>;1 1>;1 ,g z~ ;;ou!;1 =s:~::.::u> .. ~ < 0 ~ J>;1 ..= < s: < o - U $1 0 ~ ~':c ~ 0 ~ ;;.. ~ ~.. . ~ ~ ~ .. a ~ 1il !il i u;...!;19e1 O~tg~; .J ~!:~f::J~~i5~~=~..;I ! ~ '" ~ ~ ..;I z ..;I e 0 ~ >s ~ ...=u ~<~..~...~;; !! ..;I:agi::u= ~~1>;1! e '" :s=-~!:= zo:;;",~o ~ u . f;", ",'" O..,.......z::l ~ ~ ~ <1>;1 1>;1 ~ :;; .. ~ 0 ~ 1>;1 i ~~o~g~~ ~~~d~~ z ~ ......Q.... u<Q~i5", ;' b~ ~ P ~ ,. Ii" {, ,;;' L.a: C; ~ ,*~~'i:f'J'" ~,~ rffJ ~~.J.~'i:l~ ~ ~ u 1 ~ Z I. u ~ <l u ~ 1i u ~'" 0$ .l!'" e~ - N 0 ~.- '" ~ '" "" r-- 00 '"' - S:! '" ~ '" z..l u - ... - - ]18 c ;:; ~it - ~ i::l !!' .;: il o:! 'S u !i ~ ~ ~ ::.;: ~ e: ~ ~ i:l.; ~ ~ &:: Bi' i(j~ ,9- ~~ ,f", ~ u ~ u ._IE 000 ~~ to. ~l;l ~'" z~ a'g ~: ... -~ - ~~ ',"~'" ,= ~, ... ,. '., <,' ....._, ~"Ib"lD55340 V ASILIKI T. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 TO: SENDER: REFERENCE: DMK SALES PS FORM 3800 SEPTEMBER 1995 -go Cortlfl..... RETURN RECEIPT SERVICE Return Receipt Fee RestrlcledDelivery Total Postage and Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do not use for International Mail ti'''~ ~ .' 'iilj.:~ ~il.lefr""'" -, ~ ',-- ~-~ "",.' '"'~~~Wl~r- ""'~, . -~ 'B ~' 1iIiMili~.1 "'llj .. - . , ,,..'.....' (') c:) fi1 c C> ~ Z -Ow '2':1 mm .-:c: Z::1) I T,1,r Zr;:: 0> ) ~.... (/)",7_ ,., ! ~' ',j~~ "'--: ;CC" -0 ~~6 ~O ~-;" >8 ~ 1"'-~i-~ ,~ Z N 'i;! =< ~o U1 -< ~, - ,", ';.. A -- ~,~ < ([;,~ " STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler ~ -----------------------------------------------------_________________________Ilecorderof Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________ Manufactures & Traders Trust Co ----------------------------,-------------------______------________________________ ~ the grantee the same haying been sold to said grantee on the ___________6_t;~________________n________n_____ day of n___~~_r:.__n____________n__________n_ A. D., ~!____, under and by yirtue of a WriL___n________ Execution . 11th _ ______________________ _____ ___ __ _____________n ISSued on the _ __ ___ __ __ ___ _________ n n __ __ _______ Sept 00 day of ___________________--_____ A. D., _n__n_' out of the Court of Cornman Pleas of said County as of Chi1 00 ___________,...__________________.,.__ ___ ----- ----- -_ -- -____ __ ___ __ ____________ __ __ ___ Term, 3622 Keystone Fin Bank N A Number ______________, at the suit of ________n____n_______n___nn__n____________n.---n------- . Vasiliki T Phillipy IS' ___________________________________agaJDst____________________________________________________ .. 237 592 duly recorded m Shenfrs Deed Boqk No. _________n_' Page _______n___. IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office th~ n-!_t?d_ day l :2-<fY of ----~-------1rl D., ~_____.c ----~#~n;~ Recorder of Deeds, Cumberland County. Cartisle. PA My Commis~on E.pires the First Monday of Jan. 2002 ,'" " , ~~., Keystone Financial Bank, N.A -vs- Vasiliki T. Phillipy In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-3622 Civil Trevor Kent, Deputy Sheriff, who being duly sworn according to law, says on October 10, 2000 at 5:09 o'clock P.M., EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Vasiliki Phillipy, by making known unto Vasiliki Phillipy at 21 Chestnut Street, Mt Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Trevor Kent, Deputy Sheriff, who being duly sworn according to law, says on October 10, 2000 at 5:09 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action on the property ofVasiliki Phillipy located at 21 Chestnut Street, Mt Holly Springs, 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 the defendant to wit: Vasiliki Phillipy by regular mail to her last known address 32 Chestnut Street Mt Holly Springs, P A This letter was mailed under the date of October 11, 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 outcry at Court House, Carlisle, Cumberland County, Pennsylvania on December 6, 2000 at 10:00 o'clock AM.EST and sold the same for the sum of $ 1.00 to Attorney Dale Shughart for Manufacturers And Traders Trust Co., Buffalo, NY,S/B/M To Keystone Financial Bank, N.A It being the highest bid and best price quoted for the same Manufacturers And Traders Trust Co., Buffalo NY,S/M/B To Keystone Financial Bank, N.A of2270 Erin Court, Lancaster, P A being the buyer in this Execution paid to SheriffR. Thomas Kline the sum of$ 703.93 it being costs. Sheriff s Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 30.00 13.41 15.00 15.00 30.00 10.00 .50 1.00 3.72 1.60 15.00 20.00 293.30 180.75 23.15 25.00 26.50 $ 703.93 Pd By Atty --" 01/05/01 Sworn and Subscribed To Before Me This N~ Dayoy"".; 2001, A.D. (2&''',0 IIA.,;j'J,A.fli Pro h notary ~ '-'-~ "'~~ ~~ A~t:~ R. Thomas Kline, Sheriff By#Z;hAL)Il/r Real Estate Deputy cvY' ~, eW :30'~ ). C:Je/ 3 J 0,,1) I1u. REAL ESTATE SALE NO. 34 WriINo.2~622 ClvilTenn , ",K~ystoi"e Anandal Sank. NAt SlI/I Flnanci8ITrusfCompanv , ',ItS " 'Va.sUlkiT. Pbiill!'Y Attv.:'Fr.ln1c: Federman . . DESCRIPTION . . -Aii THAT Ct:RTAIN tract Qf land situate in the, Botou~, .of Mount Hj)I!y Springs. Ctil,iiberland C<Wfn,ty~ 'Pennsylvania, bounded .a'n<tdescribed a.s lo1[aws:' , " BEGiNNING af the Northeastern comer of CheSfui:ir Street at'<l limestone <1djoining tot No"3" the1i,J;e SOuth along Chestnut Street, Eighty {SO) lee't 'to .l11D:I~s1tme; theru:e 'West along ,land fonnerly of, John C. Trine (eri:o':l~ous(y written John C. Strine in prior 'dct'l:bL n,ow or lonnt':rlv of Rose C. Wol(, One HUl\dre.d. Eigl{ty.five '(185) feet to a limestone;. t~el;1ce No~. along said land no~ or'{Qrmedy dfJohn C Tnne (E:'rToneously 'wntten John C. Strine ,In' prior deeds}, Eiglllv (80) feet' to a liin~t(!ne; thence along Lot Wo. 3, on the Plan ri'i'e'iltioned,be]ow (185) k:ei to a IUriestone., the . place of BEGINNING. . '.' : BEING Lots N<is: 4, and 5 of the Mathew , Moo~ Plot of 'th~,ToWTd;.ots havlOg a width on , Chestflul ~eet ,,1 Eisth,t)i '(SO) feet an9 a depth aiO:~$.1.9I No., 3 of (jiie ~un,dJ~ ~lghty.five : (185)'ft>e1. and b.eil:lS Jmp)'OVEd willi a two and o'ni;l.half story fraii1:{! d~~lnp.g house kno\\-ll as a riumb~red ~1 Chestnut S(r,eet.~ TAXPARCEPIiUMBER,2:l..:P.2336.202. '. 1TILE TO SAIl) PREMISES. IS VESTtOIN ; Visiliki t 'Phlfiipy; a~un iI1divi~ual. by D~d , from DeanTpwoumes,aiidThomasN.Kounas, as' Ex<<uto~' of "'lhe . EState of Spero }. TouJoumes' and VijSiJi.1d T. P,hillipy, Dememos S: Toul,oumes, Nicko[eUe S.' Povatzis and ~,el,~,eY~~'~'.s:""'~~ .. '~h~~e,n ana residuary ~nefiClanes, of ,the decMeri,t dated 51211% r~oJd~d 5131(96 in Deed Book 140 Page 254. .. ..... . . REAL ESTATE SALE N.o.35 . Writ No. 20J1Q-2699 . ", CivifTeriTi' BeneficIal: CQnsum,er-Oiscou!1t Co. 'dlbfa B.'.,' ne'fic!4!.J..'M'Qrtgage eo: , ':or~T)~v~nhi , ''-','...':,..,vs ' .- : ,An~na K. ,Shaver Attv:'Leon'P.'Haller ~SC~IPTJbN fi,L~ THAT .cERTAIN pi." or parcel of land lying ,~tid being 'situale)n' the Township of HopeW~ll, Cumberland Cou,nty, Pennsylvania~ bounded and described as fal1ows: BEGINNING' a~ an "irCm Pin, adjacent to a telephone pole anQ:,~rnet qfland 00'. Finkl'Y, sat9 point "being ,on lhe W~~erjy side of the road i~aQLng from Thr~ Square Hollow to Route 944; thenc~, ll.!qng t~e W~terIy side of the said road ,Npiflj"38 aegtfes West 100 feet to an iron pin; "fueb.c.e' along land of said grantors herein South'SJj' de~ West 100 feet to' an iron pin; thence bv the sam~ South 38 de8T~last 17? fee~ m9te' or less, to land of]. Frinley: then'" bv land of J.. Finley Nort" 4 degr~ 'East '125 (eet, more Qr l~sJ to an iron pin, the place oi H~qNNING. HAVING A Pl'I'EL,LlNG erected thereon knOwn, as '1425 'Three Square Hollow Road, , Newburg, PA. ..' , . BEING THE SAME PREMISE$whlrh Anna K. ShaVer, Administratix of the "Estate of Donald F. Snav~, bV qeed dtit!Ki 9/29186 and fea>rded 11110186 in Deed BO<!k Il.32, Page 4Ol: grant.d and convey<<lunto Anna K. Shaver. ' ,TO BE,SOU2.~s [he'~ropertYof Anna K. Shaver-on }aewnenf .N~. 20110 "2699. , ASSES~~~!in:..~1.:~~______ .- - " ,'tJo',j),,,, . . 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 duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principai office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin. State of Pennsylvania, owner and publisher of The Patriot. News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and ali have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their reguiar 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, piace 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 behaif of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in ~;,~::,~::~:""g,, 0000' '" '"' ''''';'C~"'O'D'"'lX''',","",'",''.'m COpy Sworn to and subscribed before m 's 1st day 0 ece 2000 A.D. SALE #34 Notarial Soal Teny L Russell, Nota'Y Public Hamsbu'll. Dauphin County My Commission Expires June 6, 2002 Member. Pennsylvania Association 01 Notaries NO ARY PUBLIC 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) $ ~~ $ 179.25 1.50 180.75 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot.News and The Sundav Patriot-News. newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duiy paid. By.................................................................... "... " I J"",-~ --",- ",~,' REAJ, ESTATE SALE NO. 34 Writ No. 2000-3622 CiVIl Keystone Flnancial Bank. N.A.. S/l/I Financial Trust Company vs. Vasl1ikl T. Phillipy Atty.: Frank Fedennan DESCRIPTION ALL TIIAT CERTAIN tract of land situate in the Borough of Mount Holly Springs. Cumberland County. Pennsylvania. bounded and de- scribed as follows: BEGINNING at the Northeastern comer of Chestnut Street at a l1me-- stone adjoining Lot No.3: thence South along Chestnut Street. Eighty (80') feet to a Urnestone: thence West along land formerly of John C. TrIne. (erroneously WI1tten John C. Strtne in prior deeds), now or for~ merly of Rose C. Wolf. One Hun- dred Eighty-five (185) feet to a Urne. stone; thence North along said land now or formerly of John C. Trine, (erroneously written John C. Strine In prior deeds). Eighty (80) feet to a Umestone; Ulence along Lot No.3, on the Plan mentioned below (185) feet to a limestone, the place of be- ginning. BEING Lots Nos. 4 and 5 of the Mathew Moore Plot of the Town Lots having a width on Chestnut Street of eighty (80) feet and a depth along Lot No. 3 of One Hundred Eighty- five '(185) feet. and being improve<l with a two and one-half stoIY'.frame dwelling house known as a, num- bered 21 Chestnut Street. TAX PARCEL NUMBER: 23-32- 2336-202. TITLE TO SAID PREMISES IS VESTED IN Vasillki T. Phillipy. adult individual by Deed from Dean Touloumes and Thomas N. Kaunas, as Executors of the Estate of Spero J. Touloumes and Vaslliki T. Phillipy. Demetrlos S. Touloumes. Nickolette S. Poyatzis and Melody E. S. May. children and residuary beneficiaries of the decedent dated 5/21/96 recorded 5/31/96 In Deed Book 140 page 254. ~~"~,. ,~~.... . '. '<'~"", PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, ofthe 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 of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ,~,f ( ~O/1llA---- Roge . Morgenthal, EdItor SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER. 2000 NOTAL SEAL lOlS E. SNYDER, NolO'Y Public Corlitl. Bora, Cumberlan!l County, PA My Cammi,.;on Expir.. ,MQrch 5. ~J 1iIiMi~,', .' KEYSTONE FINANCIAL BANK, NA., S/IJI FINANCIAL TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION V ASILIKI T. PHILLIPY NO. 00-3622 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) KEYSTONE FINANCIAL BANK. NA.. S/I/I FINANCIAL TRUST COMPANY, Plaintiff in the above action, by i~s attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date,the Praecipe for , ' the Writ of Execution was filed the following information concerning the real property located at 21 CHESTNUT STREET. MOUNT HOLLY SPRINGS. P A 17065. I. Name and iaddress of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) V ASILIKI T. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 2. Name andladdress ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and,address of every judgment creditor whose judgment is a record lien on the real property tq be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ,-~' .=~- ""' - --~ I I I 1 I I I I , ! , i t ,I i 1 11 I I II Ii , !I ,I I ':j !I 11 II !I I :1 I I I II ; ,( , [I ~i 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) FINANCIAL TRUST COMPANY ONE W. HIGH STREET CARLISLE, PA 17013 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania, Bureau of Individual Tax, Inheritance Tax Division, Attn: John Murphy 6th Floor, Strawberry Square Dept. #280601 Harrisburg, P A 17128 Department of Public Welfare TPL Casualty Unit Estate Recovery Program P.O. Box 8486 Willow Oak Building Harrisburg, P A 17105-8486 Internal Revenue Service Federated Investors Tower Thirteenth Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, P A 15222 ""~~" ~ I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 7. 2000 DATE ~~~e~sJQ~RE> Attorney for Plaintiff -'~-"'I,j , I II , il , II !;I Ii J:l , r t f ~~ . . KEYSTONE FINANCIAL BANK, NA., SllII FINANCIAL TRUST COMPANY CUMBERLAND COUNTY Plaintiff, No. 00-3622 CIVIL v. V ASILIKI T. PHILLlPY Defendant(s). September 7, 2000 TO: V ASILIKI T. PHILLIPY 21 CHESTNUT STREET MOUNT HOLLY SPRINGS, P A 17065 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY," Your house (real estate) at 21 CHESTNUT STREET. MOUNT HOLLY SPRINGS. P A 17065, is scheduled to be sold at the Sheriff's Sale on DECEMBER 6. 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by KEYSTONE FINANCIAL BANK. NA.. S/I/I FINANCIAL TRUST COMPANY (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the _March 7, 2001_ Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, YOll must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 1~ <', ~ . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. Yau may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amotmt due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 - .- ,--- '.0-- - U;;-,1" DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGI)I':\iI:\iG at the :\iortheastern corner of Chestnut Street at a limestone adjoining Lot No.3; thence SOUlh along ChestnUl Street. Eightv (8m feet to a limestone; thence West along land '- ' '-' '" ' '-' formerly of John C. Trine, (erroneously wri.tten John C. Strine in prior deeds), now or formerly of Rose C. \Volf. One Hundred Eightv-five (185) feet to a limestone; thence :\iorth along said land ..... 01 " "- now or formerly of John C. Trine, (erroneously wriuen John C. Strine in prior deeds). Eighty (80) feet to a limestone: thence along Lot )1'0 3, on the Plan mentioned below (1851 feet to a limestone. the place of beginning BEI:\iG LOts :\ios -+ and 5 of the \[athew \[oore Plot of ehe Town Locs having a '"v'idth on Chesmm Streee or' Eighty 180> feet and a depth along Lot :\io 3 of One Hundred Eighey-five (185, feet. and being improved with a (wO and one-b.:l.lf story tranle dwelling house lGowll :15 1 llumbered .: ~ ChestDw Sereet, . 'CEl ,:r '\IBER' ~- -.., '--6' '0- T.-\X P:~R .'c". . ~.l-.l_-_.J.) -_ _ TITLE TO SAID PREyrrSES IS VESTED IN V:l.siliki T. Phillipy, adule individual by Deed from Dean Touloumes and Thomas ":\i. Kaunas, as Executors of the Estate of Spero J. Touloumes and Vasiliki T. Phillipy. Demetrios S Touloumes, :\iickoleue S Poyatzis and y[eiody E. S y[ay. children and residuary beneficiaries of the decedent dated 5/11/96 recorded 5/3li96 in Deed Book 140 Page 254, ~ , . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-3622 CIVIL 19<_ CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Financial Trust Company Keystone Financial Bank, N.A., S/I/I PLAINTlFF(S) from Vasiliki T. Phillipy DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell see Jegnl degcript10n . ' ' iCX, ,~n::..,~~. ,;.,~rl:l :11' ~ ~, (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ,.,.~-----.-'~~ - ,'''~- .,~,.. f". f~\MI d 'A Ii( JftI1'J;C GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attac!MI!t;~lIS been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) aria from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthll'tttl,l!i ,d;mlt!lrfiUfIeVieClupon an subjectto attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $56,570.50 Interest from 7/24/00-1216/00 (per diem - $9.30J Atty's Comm Yo $1255.50 and L.L. coats uue Prothy Other Costs $1. 00 Atty Paid Plaintiff Paid $103.72 Date: ~~rTPmhpr 11. ?non rl'T't-;c: ~ Trml) Prothonotary. Civil Division by: .,,/~ k.~ ~ Deputy REQUESTING PARTY: Name Frank Federman. Esq. Address: Two Penn Center Plaza. Suite 900 PHiladelphia. PA 19102 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court 10 No. 12248 'iliJi" ......~'" ~!JIidiMllJd~' '~;Jwi\l11iltOtl;;it~lfj;~~iC~'~ "'.' '"~ ~ - '-l!YWnl ~~ ifItif__. REAL EST ATE SALE No}~ Gn~ 1f-?rriJ the sheriff levied upon th8d8tenc:1afll~ inteCi'lSl'n file real ;:)rrmBrty "itu?led in.fll1/ /.L../t ,~- -1/..0 ~ CiJrn!tler!(il'lr! C:OUlW " '. ,;wd numbered as:~/I'J...L.JJ/t../ -"7ltIjJ.Ji~'. ~flO more lli;,; 'J\lscribed on Ex_ "A" tiled """ :n15 writ and oy this reference incorporated henJIn. ",,;J.fI?t....L )t.~ ~~ ~~ " ~,~~, " =~ . <,,,,--, . . . " e ~ ~~ ~~':'1 r;""' ~,.-:J~) \f'.:.'::~,-l 1;,:- , .