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HomeMy WebLinkAbout00-03732 ,'" . kj FEDERMAN AND PHELAN By: FRAJ{KFEDE~N,ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (? 1 'i) 'i"1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 Plaintiff TERM NO. 00- .313~ Ciod~ CUMBERLAND COUNTY v. KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, P A 17025 Defendant( s) rTVTT. ArTTON - T.AW MORTGAGR FORF,rT'oSTmR NOTTrR **TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: 306077955 - , -~~,~ l:~ r 1. Plaintiff is GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 2. The name(s) and last known addressees) of the Defendant(s) are: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA,PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/29/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1459, Page 1044. By Assignment of Mortgage dated 4/16/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 613, Page 1051. 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 2/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ,-".'"'~ L_. -~--> C .. 6. The following amounts are due on the mortgage: Principal Balance Interest I/I/OO through 6/1/00 (Per Diem $10.37) Attorney's Fees Cumulative Late Charges 5/29/98 to 6/1/00 Cost of Suit and Title Search Subtotal $50,485.16 1,586.61 2,524.00 72.74 55Jl.illl 55,218.51 Escrow Credit Deficit Subtotal 0.00 48...3.1 48...3.1 TOTAL $55,266.88 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $55,266.88, together with interest from 6/1/00 at the rate of $10.37 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. ~J!' F FEDE , ESQUIRE Attorney for Plaintiff ... ,.. I 1 I 1 ,,: 1 I .LL "J:'SA"r ~ p1.ece or pa.~Qe:L of' l.and si.tuate in Eas'l: >>ennsboro ~_.' cumber~and CQun~Y.~Pennsy1vania ge~n9 ~oun4e4 and deSQ~ibed aQaord~ng ~o a survey made by Michae~ c. D'Ange1o, Regis~e~ed Surveyor, dated Ju1y 26, 1976 as, fo~1ows; to wi~: BBG~NN~G at a p~n on the 8Qutb s~de of' West cumbe~land aoad (33 fee~ wLde), at the 4i.Yid~ng ~~ne'between ~3 and 14 on ~he . here1nafte~ men~io~ed p1an of ~ots; sa~d point ~e1.ng measured 218.9 ~eet west of ~he western 1~n~ 0: &nQ1a Cc~ve; thence ex~end~n~ from aala po~nt of beq~nn1nq an4 a~onq ~he.4iv1~ng 2ine qetween Lots 13 and 14 on sa1d p1a.n south OS 4agreea 06 minutes eas~ the.~~~tanae of 115.50 feet ba pin on the no~th 814e of an alley (10 feee wLde and uQopenl9ldl, 1:.benae a:tong 'sa.id a~J.ey saut:h 87. d~qre.e:s '53 m1nut:.es 30 seaonds west the ~istanee o~ 60.07 feet ~o a p1n at the ~vid1n9 l~na between LQ~S 10 and 11 on sa~d p~an; thenee a~on9 sa~d divi~ng ~ine North 05 degrees 06 m~n~tes west the d~s~an~~ of 111.00 fae't 'Co a. p.in on 1:he south s:i.de of Was"t. C1..tmber1.and Roa.d; then~e aIong sa~d Road'north 83 degrees 3S minu~es 20 secon4a eastl the d~st&nee oE 60.00 ~aet.to a Po~n~ ~he p~ace o~ BEG~NNING. BEXNG Laes 11, 12 and 13 sec. 1, Plan of Eno~a Heights beinq know as 5~~ West ~~er~and Road, r6~or~ed 1n p~an B~ok 1, Page 22. SUBJ&C'1! ora ~ c:ovenan:t.s, ~est:.r1.Q:t.Lons, and SUB.J"EC"J: to a~y state of ~acts an ace~rate survey woU1d sh~w. .,"'l''':''........ PREMISE!;: 511 WEST CUMBERLAND ROAD --- &- - ". ;. ~- ,~~ ' '" -'\;:', . VERIFICATION SHIRLEY J. EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her 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. DATE: &/r:5/oo I I ~~!i.~dlli<lJ!ll;<-ioll~;o~M~~I~.&WII~.ilr~;h&1'i~li1-m"'" ~'~ ~im~tWiI " 'Jl " . ~~ ~ ~""~liliitfdlIlIi~ .. t:J (J ~ "9- ~ ~ (." t 0 ' \, 0 1'(;) 8 , 0 "'J 3 c C) ~ ;:g g~,~ L~ r- ~~ -:-! \'-Q , I Z"J.:' >';!;1 --.0 ~ V) ~~. .."" ~ "-D -:-;(:1 --AJ Vi ~~ ,', ; ~(:' :~.. > ~7~ ;"") ;3] ;;--( -,.,-t.j ~ Pc f5rn 2: ::-I :;! :.'1 ~ cv :i"'J -< CASE NO: 2000-03732 P SHERIFF'S RETURN - REGULAR , 0 " o. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS WARD KIMBERLEE A ROBERT L. FINK, SR. Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE WARD KIMBERLEE A was served upon the 2000 DEFENDANT at 1915:00 HOURS, on the 28th day of June at 511 WEST CUMBERLAND LANE ENOLA, PA 17025 KIMBERLEE WARD by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 Sworn and Subscribed to before ....... me this 7 ~ day of Gt ;ZUVIJ A.D. J.~ a Ju~;i._-,~ B 0 honotary I So Answers: rj}~// -~ R. Thomas Kline 06/29/2000 FEDERMAN AND PHELAN By:(7{it~~~ ~ ~H. ""0 FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road, Suite 150 Horsham, P A 19044 : Cumberland COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. : NO. 00-3732-Civil Kimberlee A. Ward 511 West Cumberland Lane Enola, P A 17025 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor oftlIe Plaintiff and against Kimberlee A. Ward, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service tlIereof and for foreclosure and sale of tlIe mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 6/1/00 To 8/1/00 $55,266.88 642.94 TOTAL $55,909.82 I hereby certify that (I) tlIe addresses of tlIe Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance witlI Rule 237.1, copy attached. ~~^\~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: lJ.'y .31, ?r~ E /rl/J.-i;;, ;) f) '_ , , PRO PROT "TIllS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVlOUSL Y RECEIVED A DISCHARGE IN BANKRUYfCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. - "" , ,~ I FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. KIMBERLEE A. WARD CUMBERLAND COUNTY NO. 00-3732-CIVIL Defendant(s) TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 DATE OF NOTICE: JULY 19. 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff <,~ ~ ,.J -. ",',0 q, . '-h'i , FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563,7000 Attorney for Plaintiff GMAC Mortgage Corporation : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Kimberlee A. Ward : NO. 00-3732-Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Kimberlee A. Ward is over 18 years of age and resides at 511 West Cumberland Lane, Enola, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ FRANK FEDERMAN Attorney for Plaintiff . ~ . P': . , (Rule of Civil Procedure No. 236 - Revised) GMAC Mortgage Corporation : Cumberland COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION Kimberlee A. Ward : NO. 00-3732-Civil Defendant(s) Notice is given that a Judgnrent in tlIe above captioned matter has been entered against you on AUlrust.....J . 2000. . . ~ )2,.",," r ~O?/VI'. JDEpUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHII.ADELPlllA. PA 19102 (215) 563-7000 **THIS FmM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** d~~'~' ~i'~~!!ili~~~~~i"'~~'"""~' "....J.~'.~ ~~ 6' -() \' <l ..~ .'~ 'f!!: ~. ,t ,," IIJl.' -Cq -;0 g ~:v ~p:: -J ~ 19 ~o"', ~ d ,~, ,~","' '~~.'=I c; ~~: ur- F'-'" <: ~c ~~f) :'3 -<c . .. He. r.'~'~"'M'rl \ t:".. C,,; :;'") 1 c...:: . ,I~' :"i;.:J _; .:~ ;L~ .~-;m ~ 7:='" ....;.1.. ~, r:- Iv ~ -< J.""'"~~= ~ ~C ,~, ! " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 00-3732-CIVIL KIMBERLEE A. WARD Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $55.909.82 Interest from 8/1100-12/06/00 $U 76.32 and Costs (per diem - $9.19) $ TOTALn (n~.f"" - I F E AN, ESQUIRE T 0 PENN CENTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. No. . ~ ,~ ~"" ~- - - ~, Vl Vl 0 0 !D .I: 0 G .-0 W -,..l) VI n v) +1 y\ Jl r vJ 0 0 \J 0 c oJ , D d 0 - r ~ 0 0 0> ) ;:~ cr-' Sl.. f:,{>5<- 0 ...t. -0 ~ v 'a ~ > 0 9- b <;L r ~:;> CD i" ::P ~ +- 'i: :D ?'- ~ ~ ~ ('> " ..,.. '( -< -y+ 'lP- -:5 -.-- ",-t- &~ --< ---' % G' ,.. 0 ') ~ .-9 ;;- -W Y -J3 r;;: c 'P --r- <;) 0 .., 0-< 0 v-' (").... 0 > >,j "C ~ ~z ~. ~ ;"" R 0.. - ~ ft (I) P.- l"J~ ~ '" (") (") i '" ~(") a:,~ el ~ l"Jth~ 0 >0 z:: o ':l:l ":' ~ := ~~ >-J >0 o~= ::\. 0" = ",,' .g IJQ ::C' l"J ~ (")"" ffi t'" l"J = ~ > 00 ~ ~oo~ 1I,i~ '" ~ ~~ - S "C"" "':IS l"J < l"J ~ >(")l"J ::; "" l"J ~ ,""0 ~ ~ ....dj l"J ~ (") C~ ~ c:r ~;~ :!l 0 0 '> (I) 6'''':1 ~ ~ !:=' '" = l"J ~~ ~ thl"J~ ., ~ ~ 0 (I) ~~ ~ ~ oo"C p.. (") ts~ ~ .... I:l "" 0 <> .... t'" 0 Z ~~ ~ Z ...."':1 > ~ Will!', , _ ~ _ . ~~ 1l'!!1!?-lllJ"I!$l,~.,."",.,,,~,l.>_""~"'r~<'"~"I.%''':'''<1''.~''*''')W;~'if.W'''l'NF1'~i%'lt',,,,,~,,,,~~,~'I'1'/'l~"..f"'~~\n~'!!!'i~j;.<;;J""1"L"c~l~~~ <:>-;, - ... DESCRIPTION ALL THAT CERTAIN piece or parcel ofland situate in East Pennsboro Township, Cumberland County, Pennsylvania being bounded and described according to a survey made by Michael C. D'Angelo, Registered Surveyor, dated July 26, 1976 as follows, to wit: BEGINNING at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218.9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 115.50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the distance of 60.07 feet to a pin at the dividing line between Lots 10 and lion said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60.00 feet to a point the place of BEGINNING. BEING Lots 11, 12 and 13 Sec. 1, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book 1, Page 22. TAX PARCEL NUMBER: 09-15-1291-035 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kimberlee A. Ward, single woman by Deed from Ruth E. Smith, widow dated 5/29/98 recorded 6110/98 in Deed Book 179 Page 1. _~~21M>!4'#~-~~~"lli;'!!!lt~"""~';'i\,di.,.(,,,-,-::t:ft"~';rnI\i1li511ii~~\.O'<i;Jo!lid~=rd!il1li'-i.........."'IM!liliIl~Wlii~""'" "".', \./'t . .\ t:' ~ 1.;1' -',::') " . . "~,' ,~ " ,~~ ,?,. ~. -'~ " n S; ~ '" ,32 6' ~~-..!,'n', .\-+- f' Z:::r ; ~""'zr' -4J- c/) j> ~-' - , 8-0;:::: ...1 j>c-', . I r--. Z ,'< -;..t '0 ~t> '-.I .1 -.\)'';;; '"N L E;'~=< ~~ ~ ~~ e.:>- el \.l') ;Tl "0 , .-.J .~ 3.: ::J'i (Jl () ---~ 'l>' S:J -< . .... "j " - CI) C) .. .-i ~ .'~"",.: GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIMBERLEE A. WARD CIVIL DIVISION Defendant(s). NO. 00-3732-CIVIL AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) GMAC MORTGAGE CORPORATION, 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 511 WEST CUMBERLAND LANE. ENOLA. P A 17025. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 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.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6, Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 511 WEST CUMBERLAND LANE ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, P A 17013-2463 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. August 3 L 2000 DATE F-:):~~;i1mE~ Attorney for Plain' ___~~~~ifui.'ai!jL;~lhii.E;:",~t';if~!@,""~"illi"'~;3li'~'k""~;:~,,1~-h~",&"'d"~t;l;;''-1Uo",,-_'';-''''''~!'Y~li_L:HntQtil!~~iIiiIIi*liWWIU ~ , ", -~ ='-_uliiiM I' uF;~- ?i~'; 0>.- ig ~ "' ~;__i!ilIlUli[!fill"~ ;;:} c:. ::.~:; ,;,::) .....,) ::~:J ;.fl en .'~. : :,1') '1 "u '_J .-:;:;:-1 ~ uo" -~ ~~ - ~ ,- 1 jij"lllJli!liIb"'::' FEDE~andPHELAN By: FRANK FEDE~ Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DMSION KIMBERLEE A. WARD NO. 00-3732-CML Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () 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. ~r; . ~,' GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 00-3732-CIVIL KIMBERLEE A. WARD Defendant(s). August 31, 2000 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 511 WEST CUMBERLAND LANE. ENOLA. P A 17025, 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 GMAC MORTGAGE CORPORATION (the mortgagee) against you. Ifthe Sheriff's sale is postponed, the property will be relisted for the March 7, 2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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, "~,~" "~, ~~-~~~ " ~.- ~,~- ~" You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ; ~~ "" .w.o."; , DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland Coumy, Perillsylvania being bounded and described according to a survey made by Michael C. D' Angelo, Registered Surveyor, dated July 26, 1976 as follows, to wit: BEGI:"i:"iI:"iG at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218.9 feet west of the western line of Enola Drive; thence extending from said poim of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 11550 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the distance of 60.07 feet to a pin at the dividing line between Lots 10 and 11 on said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60.00 feet to a point the place of BEGINNING. BEING Lots 11, 12 and 13 Sec. 1, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book 1, Page 22, TAX PARCEL NUMBER: 09-15-1291-035 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kimberlee A, Ward, singlewoman by Deed from Ruth E, Smith, widow dated 5/29/98 recorded 6110/98 in Deed Book 179 Page 1. ___~,~~~~>~!!W""ik~~!i<~_wil~",~:;..~!ffiM,;f;i',",:J'jiA<",~,"'-"'Jj"-"<fu,",_\e-h"'tt!i,gl'$l~,....llf '""';''-~'iI_lilll'''''''''''-''''''''''' _. .",_^-cO'. ^' . ~. ~ -~, .. ." ~,~- -.-- '~-~! ~" 0 L::':-' C c " \,n -. U Cr -':'1 in " :J ~ ..,-~. cn .~ .:.c::. ~ r: l. . .,", ...:.::. );> \, ~.; C:~\ )...-.,. ~=; de:: n .-.- ~< <11 ..' ~..! i I ~ - .-<.. ...' . AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY No.00-3732-CIVIL DEFENDANT(S) KIMBERLEE A. WARD SERVE AT 511 WEST CUMBERLAND LANE ENOLA, PA 17025 Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 6, 2000 Served and made known to J(; ^ (31i1/;<-~,," ,q. SERVED at 7/10 , o'clock Lm., at SI/ !AJv4A-O . Defendant, on the c..v __8J/LI-_D L).I1.-<- I). C;vt31",a, day of y/ I... .200~ iN . Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer ,\f"aid Defendant(s)'s comp8jlY. J I YOther: f,jl...I",,,p S'JA'1Jw/ 'ff't6/1if, UM'1 nA"''''-'/V Description: Age -Z-Q Height )-'.1 Weight ).00 Race L Sex r Other I, _e. LI.o.AfI,P KJLJ,h/~ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. e,~..z ?p NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of . 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 . r.4lfll~~~Uj;~~<fi1iit~l'lIlii;~~~~.;bV"'-~...i!<!!;~,!!,$"3i1'1i,e:~'-1~~~fIi!m~~1.''r- . , ~.~,;.,~ (') C g -ocr; rnn-' Z::;:J ZC (f) C', ;:S ;0; ~'<,-.~ >n :~t-") PC Z; =< '....-fIIl_Jil'. i ,- --CitS':i (.::> o o C') --I (:J :71 :.:J .1:~'" .;:'-( '--~:~ ~~;) ,~:~;Q S;~fl ~ "< ".. o .!:'-' :;p ~~~ , ~ I '.- GMAC Mortgage Corporation -vs- Kimberlee A. Ward In The Court of Common Pleas of Cumberland County, Pennsylvania No, 2000-3732 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Posting Bills Law Library County Mileage Certified Mail Levy Postpone Sale Surcharge Share of Bills Law Journal Patriot News 30.00 2.69 15.00 .50 1.00 9.92 15.00 20.00 20.00 23.15 $ 137.26 Pd by Atty 09/07/00 Sor~.r.~<~P~ R. Thomas Kline, Sheriff Sworn and subscribed to before me This //12::. day of n~ 2000, A.D. ~J.--a~.~ othonotary BY /Jt:-- ,J1.7r Real Estate Deputy ).~1) ~ 3ov-!>c> Rv.-> L_", "" ,-" -~ ---.. '~ ;,--' ~'--. ,. GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIMBERLEE A. WARD CIVIL DIVISION Defendant(s). NO. 00-3732-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, 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 511 WEST CUMBERLAND LANE. ENOLA. PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KlMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 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 ,;"y,-,'. ,-':Mi~,! jl"~'~~ . . '. --0.:", <-'--'" ~ 'M ~ _ . c__ . .,;: , # 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Nallle 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 511 WEST CUMBERLAND LANE ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Redevelopment Authority of Cumberland County 114 North Hanover Street Carlisle, PA 17013-2463 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 3 L 2000 DATE ~ff~~ Attorney for Plain 'ff .'j_W - . ., ." . -1 . . GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No.OO-3732-CIVIL KIMBERLEE A. WARD Defendant(s). August 31, 2000 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECEIVED A DISCHJ\RGE 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 511 WEST CUMBERLAND LANE. ENOLA. PA 17025, 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, P A 17013, to enforce the court judgment obtained by GMAC MORTGAGE CORPORATION (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 Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To fmd out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ..,__c ",_,,_",''''''~,l~''__''- ~. J.'t'('L . ~eC , \ You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd 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 exceptious (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 TillS 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 LffiERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 - , "<,,', '",.,'-.: ", ,-.i.'-- ~__>~ - ". _" _. . \ DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Perillsylvania being bounded and described according to a survey made by Michael C D'.-\ngelo, Registered Surveyor, dated July 26, 1976 as follows, to wit: BEGI:'-i:.iI:\G at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218.9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 115.50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the distance of 60.07 feet to a pin at the dividing line between Lots 10 and lIon said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60,00 feet to a point the place of BEGINl'HNG. BEING Lots 11, 12 and 13 Sec, 1, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book I, Page 22, TAX PARCEL NUMBER: 09-15-1291-035 RECORD OWNER TITLE TO SAID PRElYlISES IS VESTED IN Kimberlee A. Ward, singlewoman by Deed from Ruth E. Smith, widow dated 5/29/98 recorded 6/10/98 in Deed Book 179 Page 1. ,- " <.f- -~', ',-~ . ,,-' -,' , ~ -.i- ' . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND NO. 2000-3732 CIVIL~ CIVIL ACTION - LAW COUNTY: CMAC MORTGAGE CDRPORATION To satisfy the debt, interest and costs due PLAINTIFF(S) from KIMBERLEE A. WARD DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell SEE ATTACHED LEGAL DISCRIPTION. (2) You are also directed tb"attach tliE! prop-erty of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: ~ -; Ii; , r~ i,' and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) notlevied upon an subjectto attachment is,found in the polisession of anyone other thana named garnishee, you are directed to notify him/her that he/she has been added as agarriisheeilrid is enjoined as above stated, Amount Due $55,909.82 L.L. $.50 Interest $1.176.32 cni cmts from 8/1/00-12/6/00 Due Prothy $1.00 (Per Diem $9.19) Ally's Comm % Other Costs Ally Paid $109.30 Plaintiff Paid Date: September 7, 2000 Curtis R. Lonq Prothonotary, Civil Division 4~-Ifl~~. ~ Deputy by: REQUESTING PARTY: Name Frank Fmennan. ERQ. Address: 2 Penn Center Plaza Suite 900 Philadelphia PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No, 12248 ;~,""=J-- ~-m"i;..~!&At!Hfu'J\it,;;iih\~IH..~~lliilii~~.",.~~%ii-~%;!~;6'lJIM:.f1''?( n- r<wrt' ~ . ~ ....- "'=~""--.... -'", -~',~ -~--.~ ~ ,,' ~,_....~_d~~,,' . REAL ESTATE SALE No. ~ 1 Ull J.p.,. a. ,"'- 1, ';)..rP the sheriff levied upon the defendams interest in the real property situated in F".~J-~~.J.-. ~lVAl1~ Cumberlam:l County, Pa., known and numbered as:~JJ 1..h_7(!, - ~~t ~a~~ and more fUlii described on Exhibit "An filed with this writ and by this reference incorporated herein. ')ate)yJL.I~ ~,:un BY:.L.Z:-- ~ -.I/l.~ ~e4-&k.dJ~ \-1 f j 1 '-, . -, I ,", ,. I - I""j 'I "; , , -- ~',I" !.. __ --; ! i" ,1 (, en, ~-~' LZ G" __,.l,." 8 d:JS ;;Jip~~(,:. ..II:J!l!tQ;]:H:~ ~ : L ;'~ : J':) ", :C,:I.'H0 _'" M. ,,~~ 0_,,,'"'.'__<_" ,. ','.,,,_ _""'," ,_~, ~_ _,,~,__ , , " .IL t,L ~ CiTil CiTil ~ uv;l, ,"-, '. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, v. No.OO-3732-CIVIL KIMBERLEE A. WARD Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $55,909.82 Interest from 8/2/00 to 6/5/02 (per diem -$9.19) TOTAL $ 6,184.87 and cost $62,094.69 ~J1J FRANK. FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. r-' J~~~'!W~'koo.!~;!IL%;lI~i'~rn!<!~\i'1I~~ifu,>fflj<'li<U!W!ii;j;2<Jiljj1, 'BI';" IWmi1>tr:ut ' "W~iIil; ~" 0._ . i or. M <::> t-- ..... -< ~ <' ....l 0 Z "'" ...-< ~ ~ O~ Z ~ 0 ....l "'> .... ~ ~~ E-< ... ~ ~ ....l", S U .,; ~Z ~ ~'F ~ 0) Zz 0 ~ i:: 0"," ~ "'" = .~ "'" 0) '" 1:: ~ '" ~~ ... 0 0) 0 < Oc:l '8 ..0 .. - ~ i;' O~ U E-< .. ~ ~ ,.; "'" S~ .. u S UZ ~ "'" <E E-< ...~ ~ ~~ ~ '" '" .. 00 ~ 0) E-<U "'" ~~ S g. ~~ !:2 ~ 01:: 0 0.. ... 0 0~ ..... 0) ..... O~ 0 ~ ","::g or. Il ::g ~'-' ~ U~ ... <n ~"'" U U '" -< ~ .i::j 0) E-<~ ~ 0) ~ - Z~ .~ ~ ... ...U I 1 , -'.. I f =. = ",. ~ - ",;:-" . DESCRIPTION ALL THAT CERT,-\I:\i piece or parcel of land situate in East Pennsboro Township. Cumberland County. Pennsylvania being bounded and described according to a survey made by .'v!ichael C D'.-\ngelo. Registered Surveyor. dated July 26. 1976 as follows, to wir: BEG[););I);G at a pin on the south side of West Cumberland Road (33 feet widel, at me dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 2189 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east dle distance of 115.50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley SOUdl 87 degrees 53 minutes 30 seconds west the distance of 60.07 feet to a pin at the dividing line between Lots 10 and lion said plan; thence along said dividing line 0iorth 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60.00 feet to a point the place of BEGINMNG. BEING Lots II, 12 and 13 Sec. 1, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book I, Page 22, TAX PARCEL NUMBER: 09-15-1291-035 RECORD OWNER TITLE TO SAID PRE;\iIISES IS VESTED IN Kimberlee A. Ward. singlewoman by Deed from Ruth E, Smith. widow dated 5/29/98 recorded 6/10/98 in Deed Book 179 Page l. .~.-O<~ _, ''il" ~ '~l;,&jIJ~ljlUl "!t~,;;'h-U!?.ill@,~!"i,i1!~ ,- '~-'~"~i",il*jjO;;';);iI'B~~ ~-~W'..",,= ~ -& L~,.>. """""IiBtll1II -r~.- , ~..... ' "-, \ , 'I, """""""'-",. . \ ~ ........ ~ "- --(J--C w 110 "- ~ '-1 "l ..) ~ (::; , Vf ~ :--- , () ~ Q Cl 0 () 0 Cj ~ 0 f';; C N 'T1 l ~ Ii' \) C> C () () ;q',,: <:..... h_~ -Ou' :Do --- l:i I 92cg Z ~;~'7 ;:::! I \ I ~ zi';;" /'..) i~~ ::::::. - \..C '-.1 ~ ~) ~:,: D ~ ~ C::C -c -~B ~ Po ::l: .... , .... , Zo I):' ~rn ~ , ~ - ~ :J..'c': '..J -..j Z ~ ~ , =< .-1 ..... " r- ~ '" '~-"'- -~ -, ~ ,. - ~- ~-' ~~ "' iiilll10 ~....... ~ "'.'! ~. .l_; GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIMBERLEE A. WARD CIVIL DIVISION Defendant(s). NO. 00-3732-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Mfidavit No. I) GMAC MORTGAGE CORPORATION, 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 ,511 WEST CUMBERLAND LANE, ENOLA. PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 3. Name and last known 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 indicate) None. -- -~ .,- -" , -~~ t , - .".., .i 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please 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 indicate) None. 7. Name and address of every other person of whom the plaintiffhas 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 indicate) Tenant/Occupant 511 West Cumberland Lane Enola, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C,S. Sec. 4904 relating to unsworn falsification to authorities. January ZZ. 2002 DATE ~FE~~ESQUffiE Attorney for Plaintiff .~,"<.'" "' ~''-"''''''~'''''liiliii.!!d ~"" ~I' '~i!;~~~~~t ""L...., ~~..&.... - ~.~ ~"'"'~."._1iIlJ ~-~-!i II il ~1 . . -~ ,~~. -:f1'-' "~<: t:., - -:- \, ',. () a () C N " s: c..... ,-, "'Om .:r~ n'r"~' Z z~; , " Z['- N "':Jrn ~~: \D ~,;~~ ~C'J ::;;; ~Cj ~ ~;1~ );:' c> r>? 01"1'1 c: ~ -" g;:- :> -.J ~ ~,...,~~. ,. ",', 1Il'''~~ - - ~-- ,-. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Snite 1400 One Penn Center at Snburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION KIMBERLEE A. WARD NO. 00-3732-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: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) 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. --'~=~'~""- -t'~~~..,:,,;,,-, ti;li~'!]~~61illlil~' - frl]~-~';~IiiIi!~ - , ~~~ lJI ,"","'- (") C n ~, C N -n s: (... :::.::1 "1JQJ ;;::m ~-;i['':''': [l1~ ~,,;: Z~~) N ~n:rn 252 ',-f:-CJ ~Z \.D () ::.... ;,-,,~,\C)_ !;20 -0 -',''''''~ -;,.:;;:: --n ~O ~- ::-:'Q ~ 5>2 r;t on' ~ 2 "'" ~ ~ ...1 =< '~,! ,i Ii II II II :1 I' II I' I I ~ I ~ i 'I I I I ,a.j' - r: ~J , GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 00-3732-CIVIL KlMBERLEE A. WARD Defendant(s). January 22,2002 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 511 WEST CUMBERLAND LANE, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 55,909.82 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you, In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings, 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.) ~_ J' . .- ,__ .,.,.' _J."= &_ ,'- '""I I , I , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .. DESCRIPTION ALL THAT CERT,\IC'i piece or parcel of land situate in East Pennsboro To\vnship, Cumberland Coumy. Pem:sylvania being bounded and described according [0 a survey made by ~[jchael C D'.\ngeio, Registered Surveyor, dated July 26, 1976 as follows. [0 \ViE: BEGIY\I'.G at a pm on the south side of West Cumberland Read 133 [eel widel, a[ :he dividillg line between 13 and 1.:1 on the hereinaf,er memioned plan of lms; said poim being measured 2139 feel west of me wesrem line of Enola Drive; thence exrending from said peim of beginning aIle along me dividing line bel\Veen Lms 13 and l-!- on said plan somh 05 degrees 06 minmes e3.S[ dce dim.l1ce of 1l5.50 feel [0 a pin on me norm side of an alley (10 feel wide and unopened); thence along said alley south 87 degrees 53 minmes 30 seconds west me disrance of 60.07 feel [0 a pin at the dividing line belween Lms 10 and 11 on said plan; thence along said dividing line North 05 degrees 06 minmes wesr the distance of 111.00 feet to a pin on me south side of Wesr Cumberiand Road; mence alan!:! said Road north 83 de2rees 35 minmes 20 seconds e::iSl. me distance of 60.00 - - feet to a point the place of BEGI:-i~TNG. BEING Lms ll, 12 and 13 SeC. 1, Plan of Enola Heights being known as 511 West Cwnberland Road, recorded in Plan Book 1, Page 22, TAX P.-\.RCEL NC?vlBER: 09-15-1291-035 RECORD O"Y~~R TITLE TO SAID PRE:\-HSES IS VESTED IN Kimberlee A. W3Id. sing!ewoman by Deed from Ruth E, Smith. widow dated 5/29/98 recorded 6110/98 in Deed Book 179 Page 1. _"IIiIIliIililllll~P!\k1/!'!l1li!w' - ~ "'Uj~~.&l..va;~~!I!r '"- '~-~,~ .. ~ ~~" ",--~~ _. >>, ,"J - 1HilIliIl~~~' MaiO' ,~~, ".., - " 0 0 0 c:: N -n s:: C- ::1 -oCf.J ),. -jl:~ /T1 fT1 Z z:n !'-) :g~ 7r' W'J::-;. u:J r'\ 1 -$"- '<0 !;,;:Cl -0 ~~~ ~S )o'~ ::;:,: Z\...I -," r:-? Orn >c: --1 Z ~ ?o - -< ..-J -< " -~ - ~- "~ ~ Docket for Case: "+ GetCaseNoO +" (" + DktTypeExpand(m.gsDktType) + ") Page 1 of3 ~ .. ~ Bankruptcy Docket Report 1 00-04004 (Harrisburg) WARD, KIMBERLEE ANN Docket items entered between 01101/1931 and 01122/2002 Filing No. Docket Entry Date , ' , ' 09/13/00 I 'VOLtJNTARY PETITION under Chapter 13, Matrix, all Schedules & Statements, Plan and ,Sunjri\arY[EOD 09/14/00] [KZ] I I I ,; 09/13/00 2 ,AP~EICi\TION to pay filing fees in installments [EOD 09/14/00] [KZ] , , 09/13/00 2A 'DEBtOR.(S) affidavit of disbursement of Trustee funds upon Dismissal and/or Conversion prior to ,conf1fllllllion. [EOD 09/14/00] [DR] 09/13/00 2B MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR [Disposed] [EOD ',09/14/00] [DR] 09/14/00 3 ORDER for payment of Filing Fees in Installments: fees due by 10/30/00 Re: Item # 2. [Complied] [EOD 09/14/00] [KZ] ,FEE, PAID Re: Item # 3. [EOD 12/01/00] [SM] 09/14/00 4 . ORI::lER t? pay trustee. Re: Item # \lB. [EOD 09/14/00] [DR] 10/06/00 5 ,CERTIFICATE of Mailing of Notice of341 Meeting, Objections to the plan are due IS days after meeting held, [EOD 10/06/00] [DS] Per Trustee 341 meeting to be rescheduled, [EOD 11/09/00] [CA] , " I 11/06/00 6 . ORDER to show cause for failure to pay filing fee in full on 12/08/00 at 09:30 A.M. at FEO.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 (EOD 11/06/00] [SM] ~ 11/13/00 7 3411I1~eting not held-to be resche~uled. [EOD 11/13/00] [CA] 12/08/00 8 CER1;'IFICATE of service ofnotic"ofrescheduled 341 Meeting [EOD 12/08/00] [CA] 12/26/00 9 ,MOTION for relief from stay by GMAC MORTGAGE CORPORATION paid 12/26/00 #564755 '$75,00 [Disposed] [EOD 12/26/00] [DR] CERTIFICATE ,OF NON-CONCURRENCE [EOD 12/26/00] [DR] 12/26/00 10 ,ORDER that answers aredue on 01/16/01 Re: Item # 9. [EOD 12/26/00] [DR] 12/28/00 11 ANSWER by DEBTOR Re: Item # 9. [EOD 12/29/00] [DR] 01/08/0 I 12 CERTIFICATE of service Re: Item # 10, [EOD 01/08/01] [DR] 01/08/01 13 CORRESPONDENCE from Movant requesting matter be listed for a telephone conference. Re: Iteni# II. [EOD 01/09/01] [JG] 01/11/01 14 CORRESPONDENCE SETTING PHONE CONFERENCE on 03/19/01 at 10:00 A.M. at FED,BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item#9. [Rescheduled] [EOD 01/11/01] [JC] 01/11/01 IS 341 meeting held. [EOD 01/12/01] [CA] .. ./nPacer?ExecThis=docket&puid=O 10 11729772&case _ no=2000-04004&office= 1 &DktType=+,l/22/02 In ~~ ... '--- ~~ . "- J II u:~; Docket for Case: "+ GetCaseNoO +" (" + DktTypeExpand(m.gsDktType) + ") Page 2 of3 0l/1l'iJ1 16 CORRESPONDENCE cancelling telephone conference, Stipulation to be filed by cOWlsel. Re: Item # 14, [EOD 01/12/01] [IG] 01/29/01 17 ORDER Confrrming Plan Re: Item # 1. [EOD 01129/01] [DR] 03/15/01 18 CORRESPONDENCE SETTING PHONE CONFERENCE on 04/27/01 at 03:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 9. [EOD 03/15/01] [DR] 03/16/01 19 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on 03/08/01 at 02:00 P.M. atFED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA, 17108 [Disposed] [EOD 03/16/01] [DR] 03/20/01 20 NOTICE to creditors that answers/objections aredue on 04/09/01 Re: Item # 19. [EOD 03/20/01] [DR] 04/10/01 21 ANSWERbyDEBTORRe: Item # 19. [EOD 04/11101] [DR] 04/12/01 22 CORRESPONDENCE SETTING HEARING on 05/10/01 at 02:30 P.M, at FED.BLDG" BKRPTCY CTRM,(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA, 17108 Re: Item # 21. [EOD 04113/01] [DR] 04/27/01 23 PROCEEDING MEMO: phone conference held - stipulation to be ftled. Re: Item # 9, [EOD 04127/01] [CL] 05/10/01 24 PROCEEDING MEMO: conference held - order to be submitted. Re: Item # 21. [EOD 05/1 % 1] [CL] 05/14/01 25 STIPULATION to lift automatic stay. Re: GMAC MORTGAGE CORPORATION Re: Item # 9. [Disposed] [EOD 05/14/01] [DR] 05/14/01 26 ORDER approving stipulation Re: Item # 25. [EOD 05/14/01] [DR] This entry disposes of motion. Re: Item:# 9. [EOD 05/14/01] [DR] , 05/16/01 27 PraecipelWithdraw by TRUSTEE Re: Ijem # 19, [EOD 05/16/01] [DR] APPROVED by the court, Re: Item # 19. [EOD 05/16/01] [DR] " 10/19/01 28 TRANSFER (ASSIGNMENT) of clairti #28 of NORTH AMERICAN CAPITAL CORPORATION in the amoWlt of$2,418.02 to MAX RI\COVERY, INC., P.O. BOX 10228, NEWARK, NI 07193- 0228 (WAIVER OF OPPORTIJNITY TO OBJECT FILED) [EOD 10/19/01] [DR] , 11/08/01 29 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on 12/13/0 1 at 02:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR,), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 1. [Disposed] [EOD 11/08/01] [DR] 12/05/01 30 CERTIFICATE OF DEF AUL T by GMAC MORTGAGE CORPORATION Re: Item # 26. [EOD 12/05/01] [DR] 12/05/01 31 ORDER granting relief from stayRe: Itfm# 9, [EOD 12/05/01] [DR] 12/20/01 32 CORRESPONDENCE from Trustee reo' hearing. No appearances for debtor. Case to be dismissed. Re: Item # 29. [EOD 12/20/01] [DR] '-.... 12/20/01-'" 33 ORDER dismissing case Re: Item # 29. , [EOD 12/20/01] [DR] , 12/26/01 34 NOTICE to creditors of dismissal of case Re: Item # 33. [EOD 12/26/01] [DR] 01/04/02 35 FINAL REPORT ofCh. 13 Trustee Re: Item # 33. [EOD 01104/02] [DR] Printed: 01122/02 15:06:50 ...n. ....... ........ .... ~ .. ./nPacer?ExecThis=docket&puid=OI 011729772&case _ no=2000-04004&office= 1 &DktType=+ 1/22/02 .' ,- ~- '11 _'0 .tfl21. ","0 _ if._ 0' GMAC Mortgage Corporation VS Kimberlee A. Ward In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-3732 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Out of County Dauphin County Advertising Certified Mail Poundage Law Journal Patriot News 30.00 20,00 15.00 1.00 25.20 20.70 15.00 15.00 2.84 $144.74 Paid by attorney 4-30-02 Sworn and subscribed to before me SOAn~#~ m&f ~ < R. Thomas Kline, Sheriff fJ !k.,/;.I< " ~, j S - I t BY "()fLq IIIAA. )\:Y\ Prothonotary Real Estate Deputy Th;, L.L 1:4 2002, A.D, ..., 9). ov ck. 3(. 'I (., \ ~. p't1) I 1 jc;"c MORTGAGE CORPORATION ",' - .'-. "--.- - --,-." ~". " CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIMBERLEE A. WARD CIVIL DIVISION Defendant(s). NO. 00-3732-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GMAC MORTGAGE CORPORATION, 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 infoITIIation concerning the real property located at ,511 WEST CUMBERLAND LANE. ENOLA, PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address carmot be reasonably ascertained, please indicate) KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA,PA17025 2. Name and address ofDefendant(s) in the judgment: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None. Ii ~ ~ ff ',. ,- .- - ~ . '" \ "", "',-" " "",. " "- ,,,,,"-w. ",. " ' ,""'""" , 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5, Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please 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 indicate) None. 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 511 West Cumberland Lane Enola, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 22.2002 DATE ~ FEk;~ ESQUffiE Attorney for Plaintiff , . GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 00-3732-CIVIL KIMBERLEE A. WARD Defendant(s). January 22,2002 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTlNG TO COLLECT A DEBT AND ANY lNFORMATlON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at, 511 WEST CUMBERLAND LANE, ENOLA, PA 17025, is scheduled to be sold at the Sheriff's Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 55,909.82 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you, In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: L 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. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe 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 LffiERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ,co '"_".__ , " . DESCRIPTION All TH.-\ T CERT,-\[:'i piece or parcel of land siruate in East Pennsboro Township, Cumberland COUEt:,. Pear:sylvania being bounded and described according to a survey made by ~!ichael C D'.-\ngelo, Registered Surveyor, dated July 16, 1976 as follows, to WiL BEG[:'i\'I:'iG ;u a oin on the south sice of West Cumberland Road! 33 fee, wiCe I, at ,:he divieiIl\J L . = line between 13 and 1.+ on the hereinafter memioned plan of Ims; said poim bemg meJ.sured 113.9 reet west of the wester:J. line of Enota Drive: thence extending from said Daim or beg:inniilg: aile . ... I. __ along the dividing line between lots 13 and l..j. on said plan south 05 degrees 06 minuces eJ.st the dist:1J1ce or' 11550 r'eet to a pin on the nonh side of an alley (10 reet wide and unopeaed); theace along said alley south 87 degrees 53 minutes 30 seconds west the distance or' 60.01 feet to a pin at the dividing line between lOts 10 and 11 on said plan; thence along said dividing line ::'iorth 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West: Cumberiand Road; thence along said Road north 83 degrees 35 minUIes 20 seconds easl. the distance of 6000 teet EO a point the place of BEGr~;\!1~G BEING lOts 11, 12 and 13 Sec. 1, Plan of Enola Heights being known as 511 West: Cumberland Road, recorded in Plan Book 1, Page 22. TAX P.\RCEl ::'il'-\-[BER 09-15-1191-035 RECORD mVNER TITLE TO SAID PRKvrrSES IS VESTED IN Kimberlee A W:rrd. singlewoman by Deed t'rom Ruth E, Smith. widow dated 5/29198 recorded 6/10/98 in Deed Book 179 Page 1, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTIl OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-3732 Civil CIVIL ACTION - LAW TO TIlE SHERIFF OF Cnmberland COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, PLANTIFF(S) From KIMBERLEE A. WARD, 511 WEST CUMBERLAND LANE, ENOLA, P A 17025 (1 ) You are directed to levy upon the property of the defendant( s) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,909.82 L.L. Interest FROM 8/2100 TO 6/5/02 (PER DIEM - $9.19) $6,184.87 AND COST Atty's Connn % Due Prothy $1.00 Atty Paid $259.06 Other Costs Plaintiff Paid Date: JANUARY 29, 2002 CURTIS R. LONG Prothonotary, Civil Division <&Y: ~~ _ 2. /?{~vry REQUESTING PARTY: Name FRANK FEDERMAN, ESQIDRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPmA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 ;:~'iillt~~jem:;;l!'ft!b~!:';'))41"i..*""~!tt.",",'"'i~li,;'j"",'''l''';'''H,.,;"",",c",""'H.,.1<,",V""-~"(.'"';"j;,,,,,,,,';.';)!1''''f,~%<'bll%;t~d~~!!iii~~~oI~g'':''",",''~'" ~.. !iili ~- -" ~'Mi..L"'~""'" ~." ~',l<'1 'REAL ESTATE SALE No, \ \ On February 6, 2002, the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A, known and numbered as 511 West ~timber1and Lane, Enola, and more fully descrihed on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2002 By: J odJ..{ ~ Real Estate Deputy ~) c;:;;:J c:;:@ ~ GV 8G1 , C\-\'t>\]d '\110.\-, ,) ',-, 'I I"' , ' ' ,,,', " \ \, _~ "',' ~ .J \, ' , Ilt ~'a\ (\ \\~ l"iZ t. 1\,). 'D"'(\~ ,',', c,', ^\:I;\O , ,u"\'~ ',', 'IJ'" 3., ^....~'" ;\--i...::;' H\\f'l\\S' '-,,!,-,",', ~,'< 1\'1 ,r,.I.", I I I ',. ,i'_'",' ~,' .k'''':" il'::,' , .. , ,! ,I' , " :!i . '" liio.i; "'"'" L "w. I 'L ..Ju' ' " 'I ,j" ~, ,. - __.,' "L", --Jo~c.e..- /hI S who cJ Id tJ (LLJ.-./L- ~ oftcu!.JJ!.--&. Yo SWv' Fpes tf.~ r.e. 4-v f f/l -OV'1 ca.. ~ 11 o. :;2.6DD -31j;l s.or~:f~_ J oci..t ."'.,~ . ~ ,~ , , ...."I~~~ I'. R&itL E&TA'l'E SA1LE NO. 11 Writ No. 2000'3732 Civil GMAC Mortgage Corporation vs, Kimberlee A. Ward Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN piece or par- cd of land situate in East Pennsboro Township. Cumberland County, Pennsylvania being bounded and described according to a survey made by Michael C. D'Angelo. Reg- istered Surveyor, dated July 26, 1976 as follows. to wit: BEGINNING at a pin on the south side of West Cwnberland Road (33 feet wide). at the divIdIng line be- tween 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218.9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the divIding line between Lots 13 and 14~an said pIan south 05 degrees 06 minutes east the distance of 115.50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the dis- tance of 60.07 feet to a pin at the dividing line between Lots 10 and lIon said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east. the distance of 60.00 feet to a point the place of BEGINNING, BEING Lots 11. 12 and 13 See, 1, Plan of Enola Heights being known as 511 West Cumberland Read. re- corded in Plan Book 1. Page 22. TAX PARCEL NUMBER: 09-15- 1291-035, RECORD OWNER TITLE TO SAlD PREMISES IS VESTED IN Kimberlee A. Ward. sin~ glewoman by Deed from Ruth E. Smith. widow dated 5/29/98 re- corded 6{1O{98 in Deed Book 179 Page 1. ~' .,--- ' 7' ,~. ',' . ,~ ~:;~ . , = . ~.~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M.MorgenthaI, Esquire, Editor of the Cumberland Law Joumal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: APRIL 26, MAY 3, 10, 2002 Affiant further deposes that he is anthorized 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, SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 NOli PublIC LOIS E. SNYDER. NotarY, ~ CalIi8Ie Bolo. C\lIlIbClIl8nd My Commi8aIon ElcpiIIa Maroh 5. . ~. .. PRAECIPE FOR WRIT 011 EXECUTIQN ~(M9RTGAGEFORECLOSURE) P.R.C.P. 3180~3183 ' GMAC MORTGAGE CORPORATION(HORSHN\f) Plaintiff, v. KIMBERLEE A. WARD No. 2liOO-3732-CIVIL Defenda..nt(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: J-- Amount Due Al'll~ Interest from\llo DECEMBER 10, 2003 (per diem -$9.19) TOTAL $55,909.82 $11,257.75 and Costs $67,167.57 }~ ]~1lA>tANl FRANK. FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. 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'Jo.l~ ' . ~ i LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania being bounded and described according to a survey made by Michael C, . D' Angelo, Registered Surveyor, dated July 26, 1976 as follows, to wit: BEGINNING at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218.9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 115.50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the distance of 60,07 feet to a pin at the dividing line between Lots 10 and 11 on said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111,00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60,00 feet to a point the place of BEGINNING, BEING Lots 11, 12 and 13 Sec, 1, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book 1, Page 22, TAX PARCEL NUMBER: 09-15-1291-035 ..... TITLE TO SAID PREMISES IS VESTED IN Kimberlee A, Ward, singlewoman by Deed from Ruth E. Smith, widow dated 5/29/98 recorded 6/10/98 in Deed Book 179 Page 1. 1_ ~ " ~ , 0" - -":;:,1 '~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-3732 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, (HORSHAM), Plaintiff (s) From KIMBERLEE A. WARD (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a narned garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $55,909.82 L.L. Interest FROM 9/7/00 TO 12/10/03 (pER DIEM - $9.19) - $11,257.75 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $418.80 Other Costs Plaintiff Paid Date: AUGUST 19, 2003 CURTIS R. LONG (Seal) protho~ '-.!3y: a...,...~,~ 7?t-fiAJ'Y' I Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ,':;-. ,,", ~ ,', - , ~'iIi\H FEDE~andPHELAN,LLP By: FRANK FEDE~ Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SmTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION(HORSHAM) CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KIMBERLEE A. WARD NO. 2000-3732-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: (X) an FHA mortgage () non-owner occupied () vacant () 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. 3~--2~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ ". '~~...., , .~tii~r1~flit~~<liE~~l ~"'"'<'IJ -I "-' ~... d.. ~r (") C ~ v'-I': mr~', ~~';- ~~:~ -C:.-.--:.. C'~ ,vs;; ,r~ .--" -< 'U/Io lie] --"'"',"""~<. ~'<j H II ,~~. "",j "'T~ '~',-) I,C, !"....l :~ =< 'J) ,1:- ,:j ~ ~- .L. "-~-~'u-.; 4 GMAC MORTGAGE CORPORATION(HORSHAM) CUMBERLAND COUNTY ,. Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION KlMBERLEE A. WARD NO. 2000-3732-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GMAC MORTGAGE CORPORATIONillORSHAMl. 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 infonnation concerning the real property located at .511 WEST CUMBERLAND LANE. ENOLA. PA 17025. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, P A 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known 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 indicate) DONEGAL MUTUAL INSURANCE CO. C/O ATTORNEY JOSEPH G. MUZIC 1195 RIVER ROAD MARIETTA, PA 17547 ~ ~,-~ " . r' 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, PA 17025 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 indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 511 WEST CUMBERLAND LANE ENOLA,PAI7025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. August 8. 2003 DATE 3JlM1R 3~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,'-~~4W1'ijj~ r "' k "-'<............W....;.~t1, ~ l!I.Wi~iOMibA~,i~~f~I!l!nl.".~ .. ,~" "aiilgij ...., . "'"~1llliI ~, Jiir,-",-~,q (") C S;, ~...-, rTi'?;" ::z: _, ffii -<~-' r;::: '.~ )>('c 6oC, Jo>e: ::0 -<. C:-J (-"~ 1-:- 2iS \!:. :--~) C,(l ,r.- . 'C, f,"1 ::D -< .- f I " II " i; jl .." , ,i'""'-~ ~ "~ .,,-,- - ~"--"-- "<;1 ,.. GMAC MORTGAGE CORPORATION(HORSHAM) Plaintiff, CUMBERLAND COUNTY No.2000-3732-CIVIL v. KIMBERLEE A. WARD Defendant(s). August 8, 2003 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at. 511 WEST CUMBERLAND LANE. ENOLA. PA 17025. is scheduled to be sold at the Sheriffs Sale on DECEMBER 10. 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $55.909.82 obtained by GMAC MORTGAGE CORPORATION(HORSHAM) (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "~-- . ' " --,~ r You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe 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 ofthe 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 LffiERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 -~~ - -~= - ~ ~ , , " ~-~~. ""'-" \~ - . r" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of !.and situate in East Pennsboro Township, Cumberland County, Pennsylvania being bounded and described according to a survey made by Michae[ C, ' D' Angelo, Registered Surveyor, dated July 26, [976 as follows, to wit: BEGINNING at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218,9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of I [5,50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the distance of 60,07 feet to a pin at the dividing line between Lots 10 and lion said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60,00 feet to a point the place of BEGINNING, BElNG Lots It, 12 and 13 Sec, I, Plan of Errola Heights being known as 5It West Cumberland Road, recorded in Plan Book 1, Page 22, TAX PARCEL NUMBER: 09-15-[291-035 - TITLE TO SAID PREMISES IS VESTED IN Kimberlee A, Ward, singlewoman by Deed from Ruth E, Smith, widow dated 5/29/98 recorded 6/10/98 in Deed Book 179 Page 1. j)~ '"'~1... " '~~--~_'tit --"'~~--d~!Ill~!lI!!!e;''''INE~~i,;n'"{il-~",_''''!i!~Aifj' IJP""'-'- 00, ...--~'~~~~ JItj' ~ -, .. (') , r-'- '-,J C Co , )'j 7 ~ -oj=;":7 rn(: '::;:) ,,""?,,"', "'--- ~. zr: ~, en , -< . " ~(~~ :i>C, L,(-~, >c r--~) Z ~ :..') ,;,:.:: ::;:l _v ,t:"" -< -il"i I I , I . ", ,,_"~W~ "0 , . (v_: AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION(HORSHAM) CUMBERLAND COUNTY KMD No. 2000-3732-CIVIL DEFENDANT(S) KlMBERLEE A. WARD ACCT. #306077955 SERVE KlMBERLEE A. WARD AT 511 WEST CUMBERLAND LANE ENOLA, PA 17025 Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 10, 2003 SERVED Served and made known to KIM BEl<. L.E E A, WARD Defendant, on the 6"" day Of~, 200~ at (,,'.'55 . o'clock,f?,m, at 51 \ Wt:,<;,\ C\Jl'V\B~LAN() RoD. t3JoLA,fA llo'2.5,Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served, Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place of lodging in which Defendant( s) reside( s), Agent or person in charge ofDefendant(s)'s office or usual place of business, an officer of said Defendant( s)' s company, Other: Description: Age ~5 HeightIT Weight~ Race W Sex F' Other I, C~\S::J. f'42.€.~1A5 , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice . , , Seal '.. herein,js~ued in the captioned case on the date and at the address indicated ahove. UlldaJ. Jumper. NolaI'{ Public CaIIsIe Boro, CumbeI1and CounlY Sworn to and su~bed My COmrriSsIon Elqlinls July 2;3. 2006 ~;for~~ ~';~y , MIInber'~~l~f"OI_~ 1 .. Notary: ~r;.~y: ~ fvvvI PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. I ICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the _.__ day of ,200_, at o'clock _,m, Defendant NOT FOUND because: Moved Unknown No Answer Vacant l,t Attempt: . 3rd Attempt: / / Time: 2nd Attempt: / / Time: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - 1.0. No. 12248 ~~~~ilJI~~ii',"~'f:li&~~.1ial\!i;~i'W~' -<" - H I~~ o c ~ -0 CO mri'"; ~~' CO ?ZC.:c: --CJ :J:>C ~ ',";;- .y.",," . ~~ c;..') (,.,,;} o (; -l GO -"" -0 ;3: f";? ;:- ...J o -n -~, ";1_--,,;-\ '::;-~g3 ~-') .t. ~~~I -:-.'.')::,1.1 '~-() .'.'C-rn ~~ )::-~ ~ ;-' ~~ ~"'~..~ - ,.,1," . ~~' ~ , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA GMAC MORTGAGE CORPORATION(HORSHAM) ) CIVIL ACTION ) vs. KlMBERLEE A. WARD ) CIVIL DIVISION ) NO, 2000-3732-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) 88: I, FRANK FEDERMAN, ESQUIRE attorney for GMAC MORTGAGE CORPORATION(HORSHAM) hereby verify that on AUl!ust 15, 2003 true and correct copies of the Notice of Sheriff s sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 4. 2003 -1MXl.JZ, 1-W0U"v1I}1) FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff ~ - - '--'. ...... l~ ~~~.~~~,-- ~j~~~" I -All; ,L . ..,.., t""' n - - - N - :; '" 00 --l 0, V. .... t.> ~. . " v. .... t.> - N - H ~~ l> "'0 ~~ ::I- 00 " ii' 0 ~ Ii' '- z c 3 e- CD ~ "'0' i ~ ~~ i I ~ 0 z H.g ~ . H '" i! ., So ~ .." ~~ ~ m > ~ I '" ~ ..,~ ~ ~ @o " -~ ~~ 0 ~ 0'" 3l ii" ~ m n ~ ,- ~ ~ ;> ;> ~ 00 ~ ~ ~~ .~ ~ ". . ~ 0 ~ il. --lz .., . .." ! '" v. v. .." '" ~' - - ~ ~ 0 '" - - iii "'.., ~ .~ ~, ~ ~ . ,a@ m '" ~ o~ Q '" ~ ~ ~ '" ., i ';l_ 00 j ~w~ !I' n ~ ~ m if ~ .1 i ~ i! 0 m ~ 0 0 ~ i ~ ~ .~ W ~ n ~ " 0 s: 0 i .~ ~ ~ ~ ~ - t.> iitf~ ~ ~ ~ ~ ~ ~ ls;lg~@; 0 ~ ~ _no Ii' " ~ 5= w~.in 0 r:;; ~ =",;; - .." I ~a' e, .il --l ~ ~ > ~ ~ ~ s. ~ 8' 13 - - -$'~BS, v. ~ --l S ~8'~g :1- P 0 .." N ipo. if 0. 0. 0 o'q8'll .. .~ S' 'R - <I> 1:0 g'1 ... ~a ~ ~ ~i~ ;:1. N 8'~o' ~ 18 - ~ .~ i ~g eo - .0. '" ~i~;~ 0. ~ ~ is''~ It ~ ~ ; ~.l:%dr' ~.~i ! '" '" [ S'~~' 1:5 .~ Fi ~ Ii"~~ .i; ~ _o' ~ ~"o' - _. 00 ~~p. .." - -' >I .". ;:! ...~-- . . i:,"'~ -'':'i~ . ~ Q 1I'I:tlt " ,"'=- ~ ;',~ ~ {-f _:,~~:_~<'-~!";T-;;;;[ITft~::..~:;;= . : ~,:'_", ""~'::S;:'!-'I'lt.nl~owl:s . "" <,.,--,,,, '$ 01 800 a .~'_"~";~'~i:!2 7 7 ~UG 1 S 2');')3 . . '">4III,-__~1~;t.E~~~ ZIP~00E 1,91 ;}3 \.ii.^ o>z -'lOl." "'Eta ~ !Jl CD =-~= ~ lOl. "Cl-o>,j [~~0 ~iit!i~ i>,j(") . , g ~~IO~ G~atJ O<<,c.. ~ ~ ~t:clc:r'tt:i :X;~a.t"' ~~~?;: "" I!l ",. $2..Q..6tt""l CD' <To' t'" ;:'",g"Cl . " ., ~. ; CD .g ~ CD 0 ., 0 liiII '-;~lli!;l__il~M~~~J","i'~J,!~~;e,'L!""'I""l~,- ~""" ,. "-~ ."V-"~~ ~"-'~IIimiiiii:m..lI'iltttil!a~~B..ii&. II -~ ,<""",,- ~.- IIti&L g 0 ~ CH ?:. :z: -l -0'0.":1 0 :i::n ~9J ..:: ;f'r I -"rn ZS "0 (fLee 0' :'~I 2~~ ,::,0 ,<'" -0 ::r.:fj ;eC :Jl: ,) "--0 "'-" .-4-rn ~2 ~ s:\ ~ N ~ 0:> ..' ~ -" -..i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which GMAC Mtg Com is the grantee the same having been sold to said grantee on the 10th day ofDec A.D., 2003, under and by virtue of a writ Execution issued on the 19th day of : Aug. A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 3732, at the suit ofGMAC Mtg Com against Kimber1ee A Ward is duly recorded in Sheriffs Deed Book No. 261, Page 1720. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this J I ~ day of , A.D2004 ecorder of Deeds IIeoorder 01 0 s, Cumbe1Iand Counly, CarlIsle PA My Commission Expires the FIlSl MondiIV 01 Jon.' 2006 ~~"",." ~~ ~ ,~ """'" -~ . , _.~'--- ~ -~, -,-......... !;J GMAC Mortgage Corporation (Horsham) VS Kimberlee A. Ward In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-3732 Civil Term David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on September 05, 2003 at 2:35 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Kimberlee AWard, by making known unto Kimberlee Ward, personally, at 511 West Cumberland Road, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on October 09,2003 at 4:07 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property ofKimberlee A Ward located at 511 West Cumberland Road, Enola, PA 17025, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency ofthe action to one of the within named defendants, to wit: Kimberlee AWard, by regular mail to her last known address of 511 West Cumberland Road, Enola, P A 17025. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being dilly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2003 at 10:00 o'clock AM. He sold the same for the sum of$1.00 to Attorney Frank Federman for GMAC Mortgage Corporation. It being the highest bid and best price received for the same, GMAC Mortgage Corporation of500 Enterprise Road, Suite 150, Horsham, PA 19044, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$765.63, it being costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge Law Journal $30.00 15.01 15.00 15.00 30.00 10.00 1.00 20.70 15.00 20.00 284.00 -~'~~~ ,. ~ .~~ -. ~ ~. "'Mi. ,,-c.., -~ Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 216,52 28.90 25.00 39.50 $ 765.63 Sworn and subscribed to before me This .lJM-\taYOf ' 2004,A.D. n u. f1 ,~ ~thonotary ._~. ~ ~.iII SOAn~ ~ ~~~~ R. Thomas Kline, Sheriff BY~~ Real Estat Deputy - "'---, ~ ~ jO,/)1l \,lf1> s'~1) Ul-Lj') ~. I'I~ 83 'I ila-- , ,-.', ~-'tU&-,! ~ , GMAC MORTGAGE CORPORATION(HORSHAM) #I CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION KIMBERLEE A. WARD NO.2000-3732-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION(HORSHAM), 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 .511 WEST CUMBERLAND LANE. ENOLA. PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known 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 indicate) DONEGAL MUTUAL INSURANCE CO. C/O ATTORNEY JOSEPH G. MUZIC 1195 RIVER ROAD MARIETTA, PA 17547 ~~ ~~" ~ ~ ~ I ' ~-~"!il;;. 4. Name and address oflast recorded holder (jIf every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA,PA17025 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 indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 511 WEST CUMBERLAND LANE ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. August 8. 2003 DATE JJlJJ./11.k :J~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff =- ~"- "^ ""-~~ . GMAC MORTGAGE CORPORATION(HORSHAM) Plaintiff, CUMBERLAND COUNTY No.2000-3732-CIVIL v. KlMBERLEE A. W AIID Defendant(s). August 8, 2003 TO: KIMBERLEE A. WARD 511 WEST CUMBERLAND LANE ENOLA, PA 17025 **TIlIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIlAT PURPOSE, IF YOU HA VE 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. ** Your house (real estate) at , 51t-WEST CUMBERLAND LANE, ENOLA, P A 17025, is scheduled to be sold at the Sheriffs Sale on DECEMBER 10, 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $55.909.82 obtained by GMAC MORTGAGE CORPORATION(HORSHAM) (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: L 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: ~15) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. - ,- I~'~~ iI'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. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner 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 maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~~ ~" ~... "~,~. -'-~I"'''; ~ . LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania being bounded and described according to a survey made by Michael C. . D' Angelo, Registered Surveyor, dated July 26, 1976 as follows, to wit: BEGINNING at a pin on the south side of West Cumberland Road (33 feet wide), at the dividing line between 13 and 14 on the hereinafter mentioned plan of lots; said point being measured 218,9 feet west of the western line of Enola Drive; thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 115,50 feet to a pin on the north side of an alley (10 feet wide and unopened); thence along said alley south 87 degrees 53 minutes 30 seconds west the diStance of 60.07 feet to a pin at the dividing line between Lots 10 and 11 on said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 11 LOO feet to a pin on the south side of West Cumberland Road; thence along said Road north 83 degrees 35 minutes 20 seconds east, the distance of 60,00 feet to a point the place of BEGINNING, BEING Lots 11, 12 and 13 Sec, I, Plan of Enola Heights being known as 511 West Cumberland Road, recorded in Plan Book 1, Page 22, TAX PARCEL NUMBER: 09-15-1291-035 --- TITLE TO SAID PREMISES IS VESTED IN Kimberlee A. Ward, singlewoman by Deed from Ruth E. Smith, widow dated 5/29/98 recorded 6/10/98 in Deed Book 179 Page 1. J ..........,. ,..,~~~ ~~~~, . 'll!IIl!1l"1~ ,,",~_ " -. ",., . -~ OfFICE OF THE SHERiff CUf,\SFPUN0 COUNTY Aoo Z! 2 S9 PM '03 (; j..,. i{ L- \ ~::, i~" ~ PENNSYLVANIA , Wi\l"""",,,,",,,,,~rn~~'I\i-~@~ ,-_. .~ I~Uk1Jl11lUH1r!!1 .,~ ,., "","," ,'. ~ ~ -~ ~ -" ...1 ~""'~"li'- '~-);c WRIT OF Ep:CUT~ON and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-3732 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, (HORSHAM), Plaintiff (s) From KlMBERLEE A. WARD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) notlevied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $55,909.82 L.L. Interest FROM 9/7/00 TO 12/10/03 (PER DIEM - $9.19) - $11,257.75 AND COSTS Atty's Conun % Due Prothy $1.00 Atty Paid $418.80 Other Costs ; Plaintiff Paid " Date: AUGUST 19, 2003 CURTIS R. LONG (Seal) ProthO~ ~ "-...llv: CJ...,.,J _P. "llAJ'V. / Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PJIILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 lIlioiI '~- .'.' ~lliii~Nlj",~~~~m,'fj;jl!ltg,jllj~:&'!~;:~tJJ1',;d:i""""lf{M~f..",-.::g--""~ -,'. 'iliRl[?~lI'~.-'~~"'Mg;1Ill;Il!.ml\\~~'!lt r ~ -,~'~"" Real Estate Sale # 32 On August 28, 2003 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland COlmty, P A known and numbered as 511 West Cumberland Lane, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 28, 2003 By:J~~ Real Estait! Deputy lI!lIljliRl':=~" ~- ~~-i " '! (eal r::;:;;) r::;:;;) c:::J c;:e> G\iiI " . .- 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and....Ib.5L Sundav Patriot-News newspapers of generai circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactiy as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. --" --~.---=--- otartalSea! Terry L. Russell, Notary Public City 01 Harrisburg, Dauphin County My Commission Exp'resJune 6. 2006 NO ARY PUBLIC Me ber Penn"'''''ania Association Of Notaries .. . m. ",,. My commisSion expires June 6, 2006 PUBLICATION COPY SALE#32 REAL ESTATE SALE No. 32 Writ No. 2000-3732 " Civil Term GMAC Mortgage Corp. (Horsham) Vs Klmberlee A. Ward Atty: Frank Federman DESCRIPTION AlL THAT CERTAIN piece or parcel of lan~ situilJe in Ea5t Penri.~boro Township, Cumberlan(/ Courii'y, Pennsylvania being bounded. and described according to a survey made by MIchael c: D'Angelo, Regist~red Surveyor, dated July 26. 1976 as follows, to"Wlt: , BEGlli"NING at a pin Oil the. south side ~ ':N.esl I Cumberland Road (33 fecI Wide), at the diytding -line: between 13 and 14 nn the beremafter"- mentioned plan of lots; said pqnt being meas~red 118.9 feel west of the weslern lme of ~o~ Dove; thence extending from said point of begmmng and . clongthedividinglinebetweenLo. 13 and 1400 'ubhsher's Receipt for Advertising Cost said. plan SQuth 0$ degrees 06 minule~ east !he .. . distance of 115.50 feet to a pin on the north SIde ubhsher of The Patnot-News and The Sundav Patnot-News, newspapers of general Cir~(lfanaU~Y_\1IOfeet,wbld8el'dndun~;n~l~u~~n~o .eceipt of the aforesaid notice and publication costs and certifies that the same have ~-a:long-satd<1leysol1 egrees. , bel- seconds west the dL~tance of 60.07 teel to a pm ~t - ~e dividing line between Lots lQ and 11 on sard plan; thence along said dividl~g Hne North 05 degrees 06 minutes wt!St the dista~ce of 111.00 feet, to a pin on tile S1Juth s!de of West Cumberland Road; thence along saId Road north "83' del!ree5 35 minutes 20 seconds east, tbe I distance of 60,00 feet to a point the place of BEGINNING. BEING Lots II, 12 and 13 Sec. 1, Plan of Enol a " Heights being !.mown ~ Sit West ~umberland , . Road, recorded 10 Plan Book t, Page ~~, . TAXPARCELNo,:{)9-15rI291'(}}?, . TITLE TO SAID PREMISES l~ vested 1Il KiOlberlee A. Ward, single 'I'.'Omao, by Deed from Rdh E. Smith, widow, dated 5129198 recDrded 6J 10/98 In Deed Book 179 Page }, CUMBERlAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y 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 Totai $ 216.52 By..........,......................,....,..,.......................... '-"~-j REAL ESTATE SALE NO. 32 ., WIit No. 2000-3732 Civil GMAC Mortgage Corporation (Horsham) vs. Kimberlee A. Ward Ally.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in East Penns- bora Township, Cumberland Coun- ty. Pennsylvania being bounded and described according to a survey made by Michael C. D'Angelo. Reg- istered Surveyor, dated July 26, 1976 as follows, to \\lit: BEGINNING at a pin on the south side of West Cumberland Road 133 feet wide}, at the dividing line be- tween 13 and 14 on the hereinafter mentioned plan of lots: said point being measured 218.9 feet west of the western line of Enola Drive: thence extending from said point of beginning and along the dividing line between Lots 13 and 14 on said plan south 05 degrees 06 minutes east the distance of 1 I5.50 feet to .a pin on the north side of an alley (10 feet wide and unopened): thence along said alley south 87 degrees 53 min- utes 30 seconds west the distance of 60.07 feet to a pin at the dividing line between Lots 10 and lIon said plan; thence along said dividing line North 05 degrees 06 minutes west the distance of 111.00 feet to a pin on the south side of West Cumber- land Road; thence along said Road north 83 degrees 35 minutes 20 seconds east. the distance of 60.00 feet to a point the place of BEGIN- NING, BEING Lots ll, 12 and 13 Sec. 1. Plan of Enola Heights being known as 511 West Cumberland Road. recorded in Plan Book 1. Page 22. TAX PARCEL NUMBER: 09-15- 1291-035. TITLE TO SAlD PREMISES IS VESTED IN Kimberlee A. Ward. singlewoman by Deed from Ruth E. Smith. widow dated 5/29/98 re- corded 6/10/98 in Deed Book 179 Page L -.... - " -'.c . ' . , . 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 : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VlZ: OCTOBER 17, 24, 31, 2003 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. SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER. 2003 dvv SEAL LOIS E. SNYDER. Notary PublIC Carlisle Boro, Cumberland County My Commission Expires March 5. '2005,