HomeMy WebLinkAbout00-03895
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
STEVE N. CHICOINE AND
TRICIA A. CHICOINE
(Mortgagor(s) and Real Owner(s))
Term
No.
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
00- 3~S Ct~;C'7-~
'>Jii !\t:TrON: MORTGAGE
r<)F.I:;ClOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUmberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE RAN DE:MANDADO A USTED EN LA CORTE. S1 DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVlDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCBSO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SINNOTIF1CARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTEn CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERnER DlNERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
81 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (8ERVICIO DE REFERENCIA DE ABOGADOS) ,
215-238-6300.
Cumberlano County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990~9108
Legal Ser~ices Inc.
8 Irvine ROW, Carlisle, PA 17013
(717) 243~9400
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COMPLAINT IN MORTGAGE FORECLOSURE
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1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box
9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481.
2. The name(s) and address(es) of the Defendant(s) is/are
STEVE N. CHICOINE, 6979 Wertzville Road, Enola, PA 17025 and TRICIA
A. CHICOINE, 6979 Wertzville Road, Enola, PA 17025, who is/are the
mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On November 30, 1995, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
HART MORTGAGE CORP., which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County in Mortgage Book 1294,
Page 518. By Assignment of Mortgage recorded August 9, 1996, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 1294, Page 520. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
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 January 1, 2000, 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.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 12/ 1/99
through 6/30/00 at 7.000%
Per diem interest rate at $16.65
Attorney's Fee at 5%
of Principal Balance
Late Charges 1/ 1/00- 6/30/00
Monthly late charge amount at $29.43
Costs of suit and Title Search
Escrow Balance Deficit
Monthly Escrow amount $
$ 85,652.52
3,546.45
4,282.63
176.58
560.00
$ 94,218.18
69.30
$ 94,287.48
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 Sheriff's
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. The within mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $94,287.48, together with interest at the rate of
$16.65, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
cKEEVER
Jr., Esq.
.
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VERIFICATION
I, Dennis Kieft , as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date:
G--.2 .;) -cnJ
i ft, Vice President
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First American Title Insurance Company
Commitment No. 546910
SCHEDULE C
. ALL THAT CERTAIN piece, parcel and tract of land located in the Township of Silver
Sprln~, Cumberland County, Commonwealth of Pennsylvania, more parlicularly bounded and
described as follows:
BEGINNING at a point on the southern dedicated right of way line of Werlzville Road
(S.R. 0944), said point being loealed and referenced in an easlerly direclion from the interseclion
of the <;astern right of ~ay line of Old Willow Mill Road and Ihe southern righl of way line of
Werlzv"le Road approxlOlately 800 feet; Ihence from said point of beginning along the dedicated
righl of way line of Werlzville Road, Norlh 84 degrees 14 minures 40 seconds East a distance
of 125.11 feel to a point; thence atong Lot No. I (lands of Kevin P. Culley and Denise C.
Culley), Soulh 02 degrees 14 minutes 18 seconds East a distance of 247.07 fect 10 a point;
thence along Ihe same, Soulh 85 degrees 13 minules 08 seconds West a distance of 125.00 feel
10 a proposed iron pin; thence along lands now or late of Samuel L. Gerace and Mary D.
Gerace, North 02 degrees 14 minutes 18 seconds West, a distance of 244.94 feet to a point on
the southern dedicated .righl of way line.of Wertzville Road (S.R. 0944) and also the point of
beginning.......
SAID tract contains,Q;71 acres to:the dedicaled right of way and this being Lot #2 on the
Final Subdivision Plan for KevipPc, Culley, and Denise C. Culley prepared ~y J. Michael Brill
& Associales, Inc. with a lasl revised dale of M:u;chl5, 1994 and recorded wllh Ihe Cumberland
County Recorder of Deeds Ofnce on June 10, 199~ in Plan Book 68, Page 33.
ALL THAT CERTAIN tract of larid located along the southern righl of way of S.R.
0944 in the Township of Silver Spring, C~riiberland c:ounty, Pennsylvania, shown as additional
dedicated right of way for Lot No.2 and depicted ona Final Subdivision Plan, more particularly
bounded and described as follows;
BEGINNING al a poinl, approximately 0.51 miles westwardly of Township Road No.
596 along the cenlerline of Werlzville'Road (S.R. 0944) and South 02 degrees 14 minules 18
seconds East a distance of 30.06 feet from centerline of Werlzville Road, to said beginning
point, The following courses and distances describe said additional dedicaled right of way for
Lot No.2:
I. North 84 degrecs 14 minutes 40 seconds East a dislance of 125.11 feel;
2. South ,02 degrees 14 minutes 18 seconds East a distance of 5.,01 feet;
3. South 84 degrees 14 minutes 4,0 seconds West a distance of 125.11 feel;
4. Norlh 02 degrees 14 minutes 18 seconds Wesl a dislance of5.01 feet to the poinl
of beginning.
CONTAINING an area of 0.,0143 acres, more or less.
Being the same premises conveyed to Steve N. Chicoine and Tricia A. Chicoine
by deed of Kevin P. Culley and Denise C. Culley dated November 30, 1995
and recorded with the Cumberland County Recorder of Deeds Office herewith.
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-03895 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST NATIONWIDE MORTGAGE CORP
VS
CHICOINE STEVE N ET AL
SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CHICOINE TRICIA A
the
DEFENDANT
, at 1354:00 HOURS, on the 29th day of June
, 2000
at 6979 WERTZVILLE ROAD
ENOLA, PA 17025
by handing to
TRICIA CHICOINE
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answe~~~
R. Thomas Kline
Sworn and Subscribed to before
06/30/2000
GOLDBECK MCCAFFERTY & MCKEEVER
By : I/J
~~m.
~ Deputy Sheriff
me this Id.- ~ day of
~ cl<rv-0 A.D.
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othonotary /
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SHERIFF'S RETURN - REGULAR
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\ CASE NO: 2000-03895 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FIRST NATIONWIDE MORTGAGE CORP
VS
CHICOINE STEVE N ET AL
SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CHICOINE STEVE N
the
DEFENDANT
at 1354:00 HOURS, on the 29th day of June
2000
at 6979 WERTZVILLE ROAD
ENOLA, PA 17025
by handing to
TRICIA CHICOINE, WIFE OF DEFT
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
6.82
.00
10.00
.00
34.82
So Answers: r~~
R. Thomas Kline
me this
d-
/.2~
day of
06/30/2000
GOLDBECK MCCAFFERTY & MCKEEVER
By: ~ '7'rt jl IJ
Deputy Sheriff ~
Sworn and Subscribed to before
~ 02071?J A.D.
el. (} ~ A..ipP'
~notary ,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
Term
No. 00-3895 CIVIL TERM
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR
THE PURPOSE OF COLLECTING THE DEBT.
Enter Judgment in favor of Plaintiff and against TRICIA A. CHICOINE
and STEVE N. CHICOINE by default for want of an Answer.
(X)
Assess damages as follows:
Debt
$
94,833.06
Interest 12/ 1/99 to 7/31/00
Total $
(Assessment of Damages attached)
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS
ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM
THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be entered and
to his attorney of record, if any, after the default occurred and at least
ten days prior to the date of the filin of his pra ipe. copy of the
notice is attached. R.C.P. 237.1
h A. G
ey for
1. D. #16132
AND NOW {)/I~/.u;+...:2 ,~t::u:>n , Judgment is
entered in favor 0 FIRST NATIONWIDE MORTGAGE CORP., and against TRICIA A.
CHICOINE and STEVE N. CHICOINE by default for want of an Answer and damages
assessed in the sum of NINETY FOUR THOUSAND EIGHT HUNDRED THIRTY THREE
DOLLARS AND 06 CENTS ($94,833.06), as per the above certification.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP. IN THE COURT OF COMMON PLEAS
PO Box 9481
Mail Code: 22-528-1011 OF CUMBERLAND COUNTY
Gaithersburg, MD 20898-9481
Plaintiff CIVIL ACTION - LAW
vs. :ACTION OF MORTGAGE FORECLOSURE
TRICIA A. CHICOINE AND STEVE N. Term
CHICOINE (Mortgagor(s) and No. 00-3895 CIVIL TERM
Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of FIRST NATIONWIDE MORTGAGE
CORP., and against STEVE N. CHICOINE and TRICIA A. CHICOINE for
failure to file an Answer in the above action within (20) days
(or sixty (60) days if defendant is the United States of America)
from the date of service of the Complaint, in the sum of NINETY
FOUR THOUSAND EIGHT HUNDRED THIRTY THR LLARS D 06 TS
($94,833.06) .
I hereby certify that the above names are correct and that
the precise residence address of the judgment creditor is PO Box
9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481 and
that the name(s) and last known address (es) of the Defendant(s)
is/are STEVE N. CHICOINE, 6979 Wertzv' 1 Roa En la, B 7025;
TRICIA A. CHICOINE, 6979 Wertzville oa, En 7
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ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal balance $ 85,652.52
Interest from 12/ 1/99 through 7/31/00 4,062.60
Attorney's Fee at 5% of principal balance 4,282.63
Late Charges 206.01
Costs of Suit and Title Search 560.00
$ 94,763.76
Escrow Balance Deficit 69.30
$ 94,833.06
AND NOW, this (;2^->cL... day of
damages are assessed as above.
iJc..<q(A..$f- , 200~0
/.<;/ aM-i;-",'.) k- ~
'Pro Prothy
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VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant, TRICIA A. CHICOINE, is
about unknown years of age, that Defendant's last known residence
is 6979 Wertzville Road, Enola, PA 17025 and is engaged in the
unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions
of the Soldiers' and Sailors' Civil Relief Action of Congress of
1940 and its Amendments.
Date:
5779912536 - CHICOINE,TRICIA A.
....
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VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant, STEVE N. CHICOINE, is
about unknown years of age, that Defendant's last known residence
is 6979 Wertzville Road, Enola, PA 17025 and is engaged in the
unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions
of the Soldiers' and Sailors' Civil Relief Action of Congress of
1940 and its Amendments.
Date:
5779912536 - CHICOINE,STEVE N.
"'-'.'
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TO: TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-101~
Gaithersburg, MD 20898-9481
Plaintiff
vs.
STEVE N. CHICOINE AND TRICIA A.
CHICOINE (Mortgagor(s))
(Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-3895 CIVIL TERM
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
DATE OF THIS NOTICE: July 20, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
,
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ Joaeph --4. (jotdteck. J".
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
~11 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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TO: STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
fIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
vs.
STEVE N. CHICOINE AND TRICIA A.
CHICOINE (Mortgagor(s))
(Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
Of CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-3895 CIVIL TERM
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
DATE OF THIS NOTICE: July 20, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ Joaeph -A. (jotdteck. Jr.
GOLDBECK McCAFFERTY 6< McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
6979 Wertzvi11e Road
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-3895 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$
94,833.06
Interest from 12/ 1/99 to
7/31/00 at 7.000% $
(Costs to be added)
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ALL THAT CERTAIN piece, parcel and tract of land located in the Township of Silver Spring,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
.
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (S.R.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
Wertzville Road approximately 800 feet; thence from said point of beginning along the
dedicated right. of way of Wertzville Road, North 84 degrees 14 minutes 40 seconds East a
distance of 125.11 feet to a point; thence along Lot No.1 (lands of Kevin P. Culley and Denise
C. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247,07 feet to a point;
thence along the same, South 85 degrees 13 minutes 08 seconds West a distance of 125.00
feet to a proposed iron pin; thence along lands now or late of Samuel L. Gerace and Mary D.
Gerace, North 02 degrees 14 minutes 18 seconds West, a distance of 244.94 feet to a point
on the southern dedicated right of way line of Wertzville Road (SR. 0944) and also the point
of beginning.
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33.
ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot No.2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING ata point, approximately 0.51 miles westwardly of Township Road No. 596 along
the centerline of Wertzville Road (S.R. 0944) and South 02 degrees 14 minutes 18 seconds
East a distance of 30.06 feet from centerline of Wertzville Road, to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot NO.2.
1. North 84 degrees 14 minutes 40 seconds East a distance of 125.11 feet;
2. South 02 degrees 14 minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes 40 seconds West a distance of 125.11 feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
TAX PARCEL #38-13-0985-086
BEING PREMISES: 6979 Wertzville Road, Enola, PA 18025
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215~627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO BOx 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
Term
No. 00-3895 CIVIL TERM
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above
action, by its attorney, Joseph A. Goldbeck, Jr., 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:
6979 Wertzville Road, Enola, PA 17025
1. Name and address of Owner(s) or Reputed Owner(s) :
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
STEVE N. CHICOINE
6979 wertzville Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
STEVE N. CHICOINE
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6979 Wertzville Road
Enola, PA 17025
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
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.
(attach separate sheet if more space is needed)
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
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subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED: July 31, 2000
BY:
McKEEVER
ldbeck Jr., Esq.
Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner (s) )
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
Term
No. 00-3895 CIVIL TERM
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is
scheduled to be sold at Sheriff's Sale on December 6, 2000, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE
CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
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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 below on how to obtain an attorney) .
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY 1lND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 price
by calling the Sheriff of Cumberland County at (717) 240-6390.
2. You maybe 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 the Sheriff of Cumberland County at (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
happefied,
5. You have a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At that time, the buyer may bring legal proceedings to
evict you.
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 thirty' (30) days from the
date of the sheriff" s sale. This schedule will state who wilT 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
;gett-i;n9';ygirr.h~se"back, if you act i mmediate"IY<lC:f't.E'!":i:"."t:Iles"2rl-e, '
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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
a Irvine Row, Carlisle, FA 17013
(717) 243-9400
.06,-' . ~"~~ .
.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION -LAW
" vs.
:ACTION OF MORTGAGE FORECLOSURE
,
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
Defendant (s)
Term
No. 00-3895 CIVIL TERM
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COL,r,EC'l' A ,D,EBT. ANY, INFORMATION OBTAINED
FROM YOU WILL BE USED, FOR THAT PURPOSE.
TO:
NOTICEOFBHERIFF'S SALE OF REAL PROPERTY
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA.l 7025 "
Your house at 6979 wertzville, Road, Enola, PA 17025 is
scheduled to be sold at Sheriff's Sale on December 6, 2000 ,at'
10: 00 a. m"inCumberland,.County, CommissionersHearingRoom,2.nd,
Floor, Courthouse, Carlisle, PA 17013 toS!nforce the court
judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE
CORP. against you. '
NOTICE, OF OWNER'S RIGHTS
~_"YOU",MAYBE;o-ABLE,TO,.BR~ THIS SHERIFF,'S- SALE
~ _0- _ . _
- "~.~-_.'-,~,..,
TO prevent this Bheriff,'.s Sale you must take immediat,e
action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. you may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
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f
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 below 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 NOT 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 price
by calling the Sheriff of Cumberland County at '(717) 240-6390.
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 the Sheriff of Cumberland County at (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 a right to remain in the property until, the full
amoUnt due is paid- to the Sheriff and the Sheriff gives 'a deced to
the buyer. At that time, the buyer may bring legal proceedings to
evi,ct 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
yburhousewiUbefiledby the Sheriff thirty (30raays from the
"', ,<iate.of~heSheriff' sSa.le.,thiEl~sch,ed':llec""illstate wh()willbe
receivi.rigthatmoriey.' Theinoney willbepald out in accordance'
- with this i~fcheduleuriless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten ,(10)
days after the schedule of distribution is filed:
7. ",YqcimayalJ?911aYe other rights anddefen~es,o:r:_ways of
--gefi't,irtg"youT""holls#ba'c:k'r-i f-Y6u--~ct"'ln(m-gtliately afterth~' 'sa::1e..' '
,.,"_"w.,.~,_".'
YOU SHOULD TAKE THIS PAPER ""TO YOUR LAWYER AT ONCE. IF YDU']jONO"T
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 Bar Association
2 Liberty Avenue, Carlisle, PA
(600) 990-91Q6
Legal Services Inc.
a Irvine Row, Carlisle, PA 17013
(717) 243-9400
~IIYitiiliilii'1l9l&limIDtl,.nliMM"&J@'r,"rli!!i~i{g!jtJtilllht~,O;~If"I-''''-\i!Iii$W~-IMBi'
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GOLDBECK McCAFFERTY & McKEEVER
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
Term
No. 00-3895 CIVIL TERM
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am
the attorney of record for the Plaintiff in this action, and I
further certify that this property is not subject to Act 91 of
1983 insofar as it is an FHA insured n
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.P.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney fo~ Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
vs.
CHICOINE AND STEVE N.
(Mortgagor(s) and Record
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
TRICIA A.
CHICOINE
Owner(s))
(Record Owner(s))
ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-3895 CIVIL TERM
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2(c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
made by:
( Y ) Personal Service by the Sheriff' s Office/",,-_..._~~.._ _i..~~L (copy of
{' return attached) .
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) .
Certified mail by Sheriff's Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached) .
Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein
penalties provided by 18 P.S. Section 4 4.
subject to the
TO:
P "16, "10 3.1 I.f 1 b
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
SENDER: GOLDBECK McCAFFERTY & McKEEVER. JulY 31, 2000
REFERENCE: CHICOINE,STEVE N. I FN-Q084
12/ 6/00 . CUMBERLAND
PS FORM 00 EPT MBER 1995
PooIBg,
RETURN
RECEIPT
SERVICE
""""'N
Retum ReceIpt Fee
RestrlctedDellvery
TotllIPoslageandFees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do not use tor International Mail
="- ,
TO:
P "16"1,031417
, .
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
SENDER: GOLOBECK MCCAFFERTY & MCKEEVER 'July 31, 2000
REFERENCE: CHICOINE,STEVE N. I FN-0084
12/ 6/00 . CUMBERLAND
PS FORM 3800 8EPT MBER 1995
PooIBg,
""'... Fee
RETURN
, RECEIPT
, SERVICE
Return Receipt Fee
Restricted Dellvery
TolalPoslagaandFeea
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do not use tor Intemational Malt
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First Nationwide Mortgage Corp.
-vs-
Tricia A. Chicoine and Steven N.
Chicoine
In the Court Of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-3895 Civil
Michael E. Barrick Deputy Sheriff, who being duly sworn according to law, says on
August 10,2000 at 5:50 o'clock P.M. EDST, he served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon one ofthe within named
defendants to wit: Tricia A.Chicoine by making known unto Tricia Chicoine at 6979
Wertzville Road, Enola, Cumberland County, Pennsylvania, its contents and at the same
time handing to her personally the said true and attested copies of the same.
Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on
August 10,2000 at 5:50 o'clock P.M. EDST, he served a true copy of Real Estate Writ
Notice Poster and Description in the above entitled action upon one of the within named
defendants to wit: Steven N.Chicoine, by makin gknown unto Tricia Chicoine wife at
6979 Wertzville Road, Enola, Cumberland County, Pennsylvania its contents and at the
same time handing to her personally the said true and attested copies of the same.
Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, says on
October 6, 2000 at 3:45 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of Tricia Chicoine and Steven Chicoine located at
6979 Wertzville Road, Enola, Pennsylvania according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendant sot wit: Tricia A.Chicoine by regular mail to her last known address 6979
Wertzville Road, Enola, P A. This letter was mailed under the date of October 9, 2000 and
never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Steven Chicoine by regular mail to his last known address 6979
Wertzville Road, Enola, PA. This letter was mailed under the date of October 9, 2000 and
never returned to the Sheriffs Office.
(:o lij) ~ ./:fl.
- wA~~,,~-€'
. Thomas Kline, Sheriff
BY&:,~ .)1...77:
Real Estate Deputy
,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22~528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner (s) )
Term
No. 00-3895 CIVIL TERM
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above
action, by its attorney, JosephA. Goldbeck, Jr., Esquire, sets
forth as of the date the praecipe for the writ of execution was
filed the following information concerning the real property
IOGated at:
6979Wertzville Road, Enola, PA 17025
1. Name and address of Owner(s) or Reputed Owner{s):
TRICIA A. CHICOINE
6979 W@rtzville Road
Enola, PA 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
STEVE N. CHICOINE
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6979 Wertzville Road
Enola, PA 17025
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has ahy,record interest in the property which
, maybe affected by the 'sale.
7. Name and address of every other person of whom the plaintiff
nas knowle,dge Wh9 has any interest in the property which may ,be
affected by the sale.
(attach separate sheet if m0re space is needed)
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
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subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
FFERT McKEEVER
ldbeck Jr., Esq.
Plaintiff
DATED: July 31, 2000
BY:
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First Nationwide Mortgage Corp. In The Court of Common Pleas of
Cumberland County, Pennsylvania
-vs- No.2000-3895 Civil
Tricia A. Chicoine and Steven N. Chicoine
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
Law Joumal
Patriot News
Share of Bills
30.00
20.96
30.00
30.00
.50
1.00
13.64
1.07
30.00
20.00
30.00
479.30
360.00
23.15
$ 1,069.62 Pd by Atty
12/14/00
Sworn and subscribed to before me
so~ ~
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R. Thomas Kline, Slieriff
This H1/..d-dayof ~
2000, A.D. ~ f2 !h<Lt,. ), ~
rot onotary
Byfit:;;~
Real Estate Deputy
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff,
:ACTION OF MORTGAGE FORECLOSURE
vs.
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
Term
No. 00-3895 CIVIL TERM
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above
action, by its attorney, Joseph A.Goldbeck, Jr., 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:
6979 Wertzville Road, Enola, PA 17025
1. Name and address of Owner(s) or Reputed Owner(s):
TRICIAA. CHICOINE
6979 Wertzville Road
Enola, PA17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
STEVE N. CHICOINE
.
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6979 Wertzville Road
Enola, PA 17025
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge,who has any record interest in theprElpertywhich
maybe affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge .wpohas any interest in the property which may be
affected by the sale.
(attach ,separate sheet if more space-is needed)
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
V","'
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subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED: July 31, 2000
BY:
McKEEVER
ldbeck Jr., Esq.
Plaintiff
-
__- L
,.:
~
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION -' LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
Term
No. 00-3895 CIVIL TERM
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is
scheduled to be sold at Sheriff's Sale on December 6, 2000, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE
CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT ,THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
" ~
-.-~'. - --'"'., .,'~ '""",- ''" "~-, '"'\I[
'"'
.......
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 below 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 NOT'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 price
by calling the Sheriff of Cumberland County at (717) 240-6390.
2. You may be able to petition the Court to set aside th~ 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At that time, the buyer may bring legal proceedings to
evict you.
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 thirty (30) days from the
date of the Sheriff's 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house 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 B~r Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
B Irvine Row, Carlisle, PA 17013
(717) 243-9400
-";:'.
;, .....',
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
PO Box 9481
Mail Code: 22-528-1011
Gaithersburg, MD 20898-9481
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
TRICIA A. CHICOINE AND STEVE N.
CHICOINE (Mortgagor(s) and
Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
Term
No. 00-3895 CIVIL TERM
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is
scheduled to be sold at Sheriff's Sale on December 6, 2000, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE
CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE
MORTGAGE CORP., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. YoU may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
,~
. -.
of
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 below 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 NOT 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 price
by calling the Sheriff of Cumberland County at (717) 240-6390.
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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full
amount due is paid to the Sheriff and the Sheriff gives a deed to
the buyer. At that time, the buyer may bring legal proceedings to
evict you.
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 thirty (30) days from the
date of the Sheriff's 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house 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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
" ~~,o,
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ALL THAT CERTAIN piece, parcel and tract of land located in the Township of Silver Spring,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (SR.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
WertzviJ!~J~.oad<!pproximately 800 feet; thence from said point of b.eginningalong the
dedicated rightofwayof Wertzville Road, North84 degrees14 minutes 40 seconds East a
, '....',., .djstance.o:h125<j\kf~H0oapoint;thencealong. L'Ot~~!o.1 (lands of KevinP, Gulley aml Denise'
C,. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247.07 feetto a point;
-,',~,-" .tl:leBw.,aIQRQthe.same,.South 85 degrees 13 minutes {)8seconds West a distance of 125.00
feet to a proposed ironpin; thence along lands now or late of SamuelL. Gerace and Mary D.
uu_ ' Ger<We,North,02degrees14 minutes-18 seconds West, a distance of-244.94 feet to a point
_ "~on tbe;gouthern.dedicatedright of way line of Werlzville Road. (SR 0944} and also the point
of beginning.-----,.-
,
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33.
ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot No.2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING at a point, approximately 0.51 miles westwardly of Township Road No. 596 along
the centerline of Wertzville Road (S.R. 0944) and South 02 degrees 14 minutes 18 seconds
East a distance of 30.06 feet from centerline of Wertzville Road, to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot No.2.
1. North 84 degrees 14 minutes 40 seconds East a distance of 125.11 feet;
2,. South 02 degrees 14 minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes40 seconds West a distance of 125.11 feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
TAX PARCEL #38-13-0985-086
BEING PREMISES: 6979 Wertzville Road, Enola, PA 18025
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 00-3895 CIVIL ~ Tenn
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cwnberland
COUNTY:
To satisfy the debt, interest and costs due First Nationwide Mortgage Corp.
PLAINTIFF(S)
from Tricia A. Chicoine and Steve N. Chicoine (Mortgagor's) and Record Owner(s)),
6979 Wertzville Road, Enola, PA 17025
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are alsO dire6ie1i~~lIaOi1ttlill'J:it0perty'bf the defendant(s) not levied upon in the possession of
.cI"".-"""''-''-_.'''''''''''~'''.-."
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GARNISHEE(S) as follows:
"":h~lt'~ i'~,'lil1:'
and to nomy the garnishee(s) that: (a) an allachmenl has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) 3tl<:I'irem delivering any property of the Qefen~a\llt~ o,r.q!helVJise disposing
thereof;ll"r. ,',' '
(3) If property oflhe,d!1!\,ln~!)!~}!2t!e'yied upon an subject to attachment is found inthe possessiq?,Ofanyone other
than a named garnishee, you are directed to notify him/her that he/she has been added as a g'amishe'e and'is enjoined as above
stated.
Amount Due
Interest
Ally's Comm
Atty Paid
Plaintiff Paid
$94,8'1'1,06
L.L.
S.50
S1.00
%
Due Prothy
Other Costs
$122.82
Date:
August 2, 2000
Curtis R. Long
Prothonotary, Civil Division
~: Mo/Yl (J _ [} 7tza7/)~-L.r
Deputy
REQUESTING PARTY:
Name Joseph A. Goldbeck, Jr. B Esq.
bUlte:>oo 'ltle Jj()urse ldg.
Address: 111 g Tnr!"f"'nr!pn,.." M" 11 1"""t-
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court 10 No. 16132
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Cumberland County, Pa., known ilnd numbered as: t, 979 tJu<f;;;dt.,~ ~
~ and more fui" .i'.:scribed on Exhibit "A" fll8d with ~
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thiS wnt and oy this reference incorporated herein.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs.
CIVIL ACTION - LAW
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
6979 Wertzville Road
Enola, P A 17025
ACTION OF MORTGAGE FORECLOSURE
No. 00-3895
Defendant( s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
$94,833.06
J
Amount Due
Interest from
12/01/1999 to
07/31/2000 at
0.0100%
(Costs to be added)
GOLDBEC
McKEEVER
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WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183 AND Rule 3257
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
In the Court of Common Pleas of
Cumberland County
vs.
TRICIA A. CHICOINE
STEVE N. CHICOINE
6979 Wertzville Road
Eno1a, PA 17025
No. 00-3895
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of Cumberland
To the Sheriff of Cumberland CountyL Pennsylvania
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the
following described property:
PREMISES: 6979 Wertzville Road Enola, P A 17025
See Exhibit "A" attached
AMOUNT DUE
$94,833.06
Interest From 12/01/1999
Through 07/31/2000
(Costs to be added)
Dated:
Prothonotary, Connnon Pleas Court
of Cumberland County, Pennsylvania
Deputy
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Al.,L THAT CERTAIN piece, parcel and tract of land located in the Township of Silver Spring,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (S.R.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
Wertzville Road approximately 800 feet; thence from said point of beginning along the
dedicated right of way of Wertzville Road, North 84 degrees 14 minutes 40 seconds East a
distance of 125.11 feet to a point; thence along Lot No. 1 (lands of Kevin P. Culley and Denise
C. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247.07 feet to a point;
thence along the same, South 85 degrees 13 minutes 08 seconds West a distance of 125.00
feet to a proposed iron pin; thence alon~Llands now or late of Samuel L. Gerace and Mary D.
Gerace, North 02 degrees 14'rT1irlutes11lseconds West, a distance of 244.94 feetto a point
on the southern dedicated right of way line of Wertzville Road (S.R. 0944) and also the paint
of beginning.
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33.
ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot NO.2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING at a point, approximately 0,51 mileswestwardly ofTownship Road No. 596 along
the centerline of Wertzville Road (SR. 0944) and South 02 degrees 14 minutes 18s,econds
East a distance of30.06 feetfromcenterline ofWertzvi1le Road; to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot No.. 2.
, ,
1. North 84 degrees 14 minutes 40 seconds East a distance of 125.11 feet; ,
2. South02_degrees 14-minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes 40 seconds West a distance of 125.11feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 6979 Wertzville Road, Enola, PA 17025
SOLD as the property of TRICIA A. CHICOINE and STEVE N. CHICOINE
TAX PARCEL #38-13-0985-086
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FlRST NATIONWIDE MORTGAGE CORP.
Plaintiff (s)
From TRICIA A. and STEVE N. CmCONE, 6979 WERTZVlLLE ROAD, ENOLA P A 17025.
(I ) You are directed to levy upon the property of the defendant (s land to sell REAL ESTATE
LOCATED AT 6979 WERTZVILLE ROAD, ENOLA P A 17025 (SEE ATTACHED
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 debito or for the account of the defendant (s) and from delivering any property ofthe 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $94,833.06
Interest 12/1/99 TO 7/31/00 @ $.010%
Ally's Connn %
Ally Paid $1,194.94
Plaintiff Paid
Date: JANUARY 3, 2003
L.L.
Due Prothy $1.00
Other Costs
(Seal)
CURTIS R. LONG
'ro'~ ~}~
BY:(j~' f
' D uly
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQ.
Address: 111 S INDEPENDENCE MALL EAST
PHILADELPHHlA PA 19106 1
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ill No. 16132
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Jospeh A. Goldbeck, Jr.
Attorney LD. #16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215.627.1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528.1011
Gaithersburg, MD 20898.9481
Plaintiff
IN THE COURT OF
COMMON PLEAS
Ys.
of Cumberland County
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
6979 Wertzville Road
Enola, PA 17025
CML ACTION . LAW
ACTION OF
MORTGAGE FORECLOSURE
Defendant( s)
NO. 00.3895
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this
action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all
the provisions of the Act.
Joseph A. oldbeck,
Attorney D r plaintiff
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~dbldbeck McCafferty & McKeever
~ BY: Joseph A. Goldbeck, Jr.
Attorney LD. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs.
CML ACTION - LAW
TRICIA A. CmCOINE
STEVE N. CmCOINE
(Mortgagor(s) and Record Owner(s))
6979 Wertzville Road
Eno1a, P A 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, JosephA. Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, PA 17025
l.Name and address ofOwner(s) or Reputed Owner(s):
TRIClA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CID,1BERLAND COUNTY
PO Box 320
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Carlisle, PA 17013
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P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Nlll1W aud address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
340 I Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other persou of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be ~ffected by the sale.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: December 13. 2002
& McKEEVER
Jr , Esq.
C
BY: JosephA. oldbe
Attorney for PI . tiff
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00-3895
., ~OLDBECK McCAFFERTY & McKEEVER
BY: JosephA. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
,.
FIRST NATIONWIDE MORTGAGE CORP.
P.o. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
VS.
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant( S
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TIDS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: cmCOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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00-3895
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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 below 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 NOT TAKE PLACE.
1. lfthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd
out the price bid price by calling the Sheriff of717-240-6390.
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 fmd
out if this has happened, you may call the Sheriff of717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriffs 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 schedule of distribution is filed.
7 . You may also have other rights and defenses, or ways of getting your house 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 BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. cmcolNE
STEVE N. cmcolNE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant( s
TIDS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TIDS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, TRICIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11,2003, at 10:00 AM, in Commissioners Hearing Rrn 2nd FL Courthouse to enforce the
court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
,
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.
00-3895
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 below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may frod
out the price bid price by calling the Sheriff of717-240-6390.
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 the Sheriff of 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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriffs 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 schednle of distribution is filed.
7 . You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
LEGALSERVlCESTINC
8 Irvine Row
Carlisle, PA 17013
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First Nationwide Mortgage Corp.
VS
Tricia A. Chicoine and
Steve N. Chicoine
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3895 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck.
Sheriffs Costs:
Docketing
Surcharge
Prothonotary
Mileage
Levy
Poundage
30.00
30.00
1.00
6.21
15.00
1.64
$ 83.85 paid by attorney
02/21/03
Sworn and subscribed to before me So Answers:
This ;2'1tf: dayof,i {!"" A'7 .r"'~~"'< #~
o . omas Kline, Sheriff
2003, A.D. 'Z4f';- (l. '!-hjk " # BY Jotl J'mill1
Prothonotary Real E' te Deputy
\,1fO cet..3q8:)~
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Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-10 11
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
TRICIA A. cmcolNE
STEVE N. cmcolNE
(Mortgagor(s) and Reeord Owner(s))
6979 Wertzville Road
Enola, P A 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORl'., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, P A 17025
l.Name and address ofOwner(s) or Reputed Owner(s):
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
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Carlisle, PA 17013 .
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzda!e Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6,. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected hy the sale.
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.
(attach separate sheet if more space is needed)
1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s. Section 4904
relating to unsworn falsification to authorities.
DATED: December 13,2002
T & McKEEVER
Jr, Esq.
I
C
BY: Joseph A. oldbe
Attorney for PI intiff
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: JosephA. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIlE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
YS.
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, PA 17025
Term
No. 00-3895
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE-ARE ATTEMPTING TO
COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, TRICIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 11,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
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 FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
"~
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00-3895
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
wi1\ have of stopping the sale. (See notice below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property wi1\ be sold to the highest bidder. You may fmd
out the price bid price by calling the Sheriff of717-240-6390.
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 wi1\ go through only if the buyer pays the Sheriff the full amoWlt due in the sale. To fmd
out if this has happened, you may call the Sheriff of717-240-6390.
4. If the amoWlt 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 a right to remain in the property until the full amoWlt 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 thirty (30) days from the date of the
Sheriffs 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house 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 BAR ASSOClA nON
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-10 11
Gaithersburg, MD 20898-9481
IN TIlE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale ou
Wednesday, June 11,2003, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of$94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
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 FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To [md out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
.
"
^ - ",. ~ ;~;
--< .
,.
. .
00-3895
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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390.
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 Tmd
out iftbis has happened, you may call the Sheriff of717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriff's 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 BAR ASSOCIA TlON
2 Liberty Avenue
Carlisle, P A 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
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A~L THAT CERTAIN piece, parc,el and tract of land located in the Township of Silver Spring,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (SR.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
Wertzville Road approximately 800 feet; thence from said point of beginning along the
dedicated right of way of Wertzville Road, North 84 degrees 14 minutes 40 seconds East a
distance of 125.11 feet to a point; thence along Lot No. 1 (lands of Kevin P. Culley and Denise
C. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247,07 feet to a point;
thence along the same, South 85 degrees 13 minutes 08 seconds West a distance of 125.00
feet to a proposed iron pin; thence along lands now or late of Samuel L Gerace and Mary D,
Gerace, North 02 degrees 14 minutes 18 seconds West, a distance of 244,94 feetto a point
on the southern dedicated right of way line of Wertzville Road (S.R. 0944) and also the point
of beginning,
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33,
ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot No, 2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING at a point, approximately 0,51 miles westwardly of Township Road No. 596 along
the centerline of Wertzville Road (S.R. 0944) and South 02 degrees 14 minutes 18 seconds
East a distance of 30.06 feetfrom centerline of Wertzville Road, to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot No.2,
1, North 84 degrees 14 minutes 40 seconds East a distance of 125.11 feet;
2. South 02.degrees 14 minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes 40 seconds West a distance of 125.11 feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 6979 Wertzville Road, Enola, PA 17025
SOLD as the property of TRICIA A. CHICOINE and STEVE N. CHICOINE
TAX PARCEL #38-13-0985-086
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WRIT OF EXE~UTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORP.
PI~intiff (s)
From TRICIA A. and STEVE N. CmCONE, 6979 WERTZVILLE ROAD, ENOLA P A 17025.
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 6979 WERTZVILLE ROAD, ENOLA P A 17025 (SEE ATTACHED
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 subj ect to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $94,833.06 L.L.
Interest I2/I!99 TO 7/31/00 @ $.010%
Atty's Comm %
Atty Paid $1,194.94
Plaintiff Paid
Date: JANUARY 3, 2003
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
By:
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK JR., ESQ.
Address: 111 S'lNDEPENDENCE MALL EAST
PHILADELPHHIA PA 19106
Attorney for: PLAINTIFF
Telephone: (215) 627-1322
Supreme Court ill No, 16132
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Real Estate Sale # 11
On February 5, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, P A
known and numbered as 6979 Wertzville Road,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: February 5, 2003
By;J?!-!J~
Real Estate Deputy
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Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs.
CIVIL ACTION - LAW
TRICIA A. CHICOINE
STEVB N. CHICOINE
Mortgagor(s) and Record Owner(s)
6979 Wertzville Road
Enola, P A 17025
ACTION OF MORTGAGE FORECLOSURE
No. 00-3895
Defendant( s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$94,833.06
Interest from
12/01/1999 to
07/31/2000 at
0.0100%
(Costs to be added)
GOLDBECK
BY: Joseph A.
Attorney for PI
TY & McKEEVBR
k, Jr.
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A~L THAT CERTAIN piece, parcel and tract of land located in the Township of Silver SpliRg,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described\
as follows:
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (S.R.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
Wertzville Road approximately 800 feet; thence from said point of beginning along the
dedicated right of way of Wertzville Road, North 84 degrees 14 minutes 40 seconds East a
distance of 125.11 feet to a point; thence along Lot NO.1 (lands of Kevin P. Culley and Denise
C. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247.07 feet to a point;
thence along the same, South 85 degrees 13 minutes 08 seconds West a distance of 125.00
feet to a proposed iron pin; thence along .Iands now or late of Samuel L. Gerace and Mary D.
Gerace, North 02 degrees 14 mhlutes'18 seconds West, a distance of 244.94 feet to a point
on the southern dedicated right of way line of Wertzville Road (SR. 0944) and also the point
of beginning.
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33.
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ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot No.2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING at a point, approximately 0.51 miles westwardly of Township Road No. 596 along
the centerline of Wertzville Road (S.R. 0944) and South 02 degrees 14 minutes 18 seconds
East a distance of 30.06 feet from centerline of Wertzville Road, to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot No.2,
1. North 84 degrees 14 minutes 40 seconds East a dist~nce of 125.11 feet;
2. South 02 degrees 14 minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes 40 seconds West a distance of 125.11 feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 6979 Wertzville Road, Enola, PA 17025
SOLD as the property of TRICIA A. CHICOINE and STEVE N. CHICOINE
TAX PARCEL #38-13-0985-086
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORP.,
Plaintiff (s)
From TRICIA A. CmCOINE AND STEVE N. CmCOINE, 6979 WERTZVILLE ROAD,
ENOLA, PA 17025
(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) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $94,833.06
Interest FROM 12/1/99 TO 7/31/00 AT 0.0100%
L.L.
Atty's Comm %
Due Prothy $1.00
Other Costs
Atty Paid $1303.79
Plaintiff Paid
Date: MAY 23, 2003
CURTIS R. LONG
(Seal)
prothL%
'--.lly: ~ ..
P ,~AA.h~J
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOL1>BECK MCCAFFERTY & MCKEEVER
SliTI' 500 - THE BOURSE BLDG.
111 S. INDEPENDENCE MALL EAST
PHILADELPffiA, PA 19106
Attorney for: pLAINTIFF
Telephone: 215-627-1322
Supreme Court ill No. 16132
~~
'",' ..-- ~~
Goldbe~.~ McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney LD. #16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CML ACTION - LAW
TRICIA A. CmCOINE
STEVE N. CmCOINE
(Mortgagor(s) and Record Owner(s))
6979 Wertzville Road
Enola, PA 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth 3S of the date the praecipe for the writ of execution was filed the following information concerning the real
property located at:
6979 Wertzville Road
Enola, P A 17025
I.Name and address ofOwner(s) or Reputed Owner(s):
TRICIA A. CmCOINE
6979 Wertzville Road
Enola, P A 17025
STEVB N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
STEVBN. CHICOINE
6979 Wertzville Road
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
J.,
"=
"
.
P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
,
.
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, P A 170 II
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
maybe affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, PA 17025
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn fglsification to authorities.
GOLDBECK
BY: JosephA.
Attorney for PI .
DATED: May 22.2003
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GOLDBECK McCAFFERTY & McKEEVER
,
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CML ACTION - LAW
vs.
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, PA 17025
Term
No. 00-3895
Defendant( s
TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, TRICIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriff's Sale on
Wednesday, September 03,2003, at 10:00 AM, in Commissioners Hearing Rrn 2nd FL Courthouse to
enforce the court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP.
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay call:
215-627-1322
~ ,-
~":-i
00-3895
~
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may f'md
out the price bid price by calling the Sheriff of717-240-6390.
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 the Sheriff of717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 Sherifftbirty (30) days from the date of the
Sheriffs 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 schedule of distribution is f'11ed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: JosephA. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attomey for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. CmCOINE
STEVE N. CmCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant( s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TIDS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
T<;): CIDCOlNE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP.
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
-
... o.
~ ,,_, .._. "v
.-j'
;
00-3895
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. Yau may f'rod
out the price bid price by calling the Sheriff of717-240-6390.
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 throngh only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with tbisschedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriffwitbin ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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Docket for Case: " + GetCaseNoO + " (" + DktTypeExpand(m.gsDktType) + ")
Page 1 of3
Bankruptcy Docket Report
1 00-05293 (Harrisburg)
cmCOINE, STEVE Nand CmCOINE, TRICIA A
Docket items entered between 01101/1931 and OS/22/2003
Filing No. Docket Entry View
Date document
12/05/00 ~ . VOLUNTARY PETITION under Chapter 13 & Mailing Matrix [EOD 12/05/00] [KZ] None
12/05/00 :2 NOTICE of intent to dismiss case unless missing documents are filed: due by None
. 12/20/00 Re: Item # 1. [Complied] [EOD 12/05/00] [KZ]
01/04/01 3 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. None
[EOD 01/05/01] [CA]
01/16/01 4 CERTIFICATE of Mailing of Notice of341 Meeting. Objections tothe plan are due None
15 days after meeting held. [EOD 01/16/01] [CA]
-,-
01/31/01 5 OBJECTION to plan by FIRST NATIONWIDE MORTGAGE CORPORATION as None
servicer for the mortgagee of record Re: Item # 3. [Disposed] [EOD 01/31/01] [BW]
01/31/01 6 CORRESPONDENCE SETTING HEARING on 04/25/01 at 02:00 P.M. at None
FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS.,
HARRISBURG,PA. 17108 Re: Item # 5. [EOD 01/31/01] [BW]
02/07/01 7 Anlendment to Schedule(s): F. Fee Paid, receipt # 565924, $20.00. Re: Item # 3. None
[EOD 02/07/01] [BR]
02/15/01 8 341 meeting held. [EOD 02/15/01] [CA] None
04/25/01 9 PROCEEDING MEMO: phone conference held - amended plan to be filed. Re: Item None
# 5. [EOD 04/25/01] [CL]
07/11/01 10 CORRESPONDENCE from Movant requesting matter be relisted for a telephone None
. conference as the Amended Plan was never filed. Re: Item # 5. [EOD 07/12/01] [IG]
07/13/01 11 CORRESPONDENCE SETTING PHONE CONFERENCE on 09/14/01 at 01:30 None
P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS.,
HARRISBURG,PA. 17108 Re: Item # 10. [Rescheduled] [EOD 07/13/01] [SP]
08/01/01 12 MOTION to Modify Plan by DEBTORS [Disposed] [EOD 08/02/01] [SP] None
This entry disposes of motion. (Motion not needed) Re: Item # 12. [EOD 09/06/01]
[CG]
08/01/01 13 Amended Ch. 13 Plan (Requested Proof of Service) Re: Item # 3. [EOD 08/02/01] None
[SP]
This entry disposes of motion. Re: Item # 5. [EOD 08/02/01] [SP]
This entry cancels the previous due date. Re: Item # 11. [EOD 08/02/01] [SP]
08/09/01 14 CERTIFICATE OF MAILING RE: NOTICE ON CHAFTER 13 PLAN None
AMENDMENT Objectionsdue on 08/30/01 Re: Item # 13. [EOD 08/10/01] [CG]
09/06/01 15 ORDER confIrming amended plan [EOD 09/06/01] [CG] None
09/07/01 16 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on None
10/11/01 at 02:00 P.M. at FED.BLDG., BKRPTCY C1RM.(3RD FLR.), THIRD &
WALNUT STS., HARRISBURG,PA. 17108 [EOD 09/07/01] [CG] I
I
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Docket for Case: II + GetCaseNoO + II (" + DktTypeExpand(m.gsDktType) + ")
Page 2 of3
10/29/01 17 STIPULATION by PARTIES Re: Item # 16. [EOD 10/29/01] [CG] None
11/20/01 18 MOTION to Modify Plan by DEBTORS Re: Item # 13. [Disposed] [EOD 11/21/01] None
[CG]
11/20/01 19 Amended Ch. 13 Plan (Requested Proof of Service) Re: Item # 18. [EOD 11/21/01] None
[CG] .
11/20/01 20 MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR None
. [Disposed] [EOD 11/21/01] [CG]
11/23/01 21 ORDER to pay trustee. Re: Item # 20. [EOD 11/23/01] [CG] None
11/27/01 22 Order Allowing Petition to Modify Plan Re: Item # 18. [EOD 11/27/01] [CG] None
12/07/01 23 TRANSFER (ASSIGNMENT) of claim #1 of HOUSEHOLD FINANCE COMPANY None
in the amount of $3,105.16 to MAX RECOVERY TRUST I (Waiver of Notice) [BOD
12117/01] [CO]
05/15/02 24 TRANSFER (ASSIGNMENT) of claim #2 SEARS ROEBUCK & CO IN THE None
AMOUNT OF $680.83 TO MAX RECOVERY, INC. (WAIVER OF
OPPORTUNITY TO OBJECT FILED) [BOD 05/15/02] [CR]
08/28/02 25 MOTION for relief from stay RE: FIRST NA TIONWIDEMORTGAGE Doc #25 PDF
CORPORA nON AS SERVICER FOR THE MORTGAGEE OF RECORD. FEE (3 oa~es)
PAID, RECEIPT #586107, $75.00 [Disposed] [BOD 08/29/02] [CR]
CERTIFICATE OF NON-CONCURRENCE [EOD 08/29/02] [CR]
08/29/02 26 ORDER that answers aredue on 09/18/02 Re: Item # 25. [EOD 08/29/02] [CR] None
09/06/02 27 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on None
10/10/02 at 02:00 P.M. atFED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD &
WALNUT STS., HARRISBURG,PA. 17108 [EOD 09/06/02] [JC]
09/1 0/02 28 CERTIFICATE of service Re: Item # 26. [BOD 09/11/02] [DS] None
09/20/02 29 TRANSFER (ASSIGNMENT) of claim #5 CONSECO FINANCE SERVICING None
CORP IN THE AMOUNT OF $7,322.84 TO B- YOND LLC (WAIVER OF
OPPORTUNITY TO OBJECT FILED) [EOD 09/23/02] [CR]
09/20/02 30 TRANSFER (ASSIGNMENT) of claim #4 CONSECO FINANCE SERVICING None
CORP IN THE AMOUNT OF $29,997.05 TO B-YOND LLC (WAIVER OF
OPPORTUNITY TO OBJECT FILED) [EOD 09/23/02] [CR]
10/02/02 31 MOTION for defaultjudgmentRe: Item #25. [Disposed] [EOD 10/02/02] [CR] Doc #31 PDF
(3 pages)
10/02/02 32 ORDER granting default judgment Re: Item # 31. [BOD 10/02/02] [CR] Doc #32 PDF
ORDER granting relief from stay Re: Item # 25. [EOD 10/02/02] [CR] (3 pages)
10/07/02 33 MOTION to reconsider Order FILED BY DEBTORS. Re: Item # 32. [EOD 10/08/02] None
[CR]
10/10/02 34 CORRESPONDENCE SETTING HEARING WITH mDGE JOHN J THOMAS Doc #34 PDF
PRESIDING on 11/18/02 at 10:00 A.M. at FED.BLDG., BKRPTCY CTRM.(3RD (l "a~e)
FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 33. [EOD
. 10/10/02] [CR]
11/01/02 35 ANSWER by FIRST NATIONWIDE MORTGAGE CORPORATION. Re: Item # 33. Doc #35 PDF
[EOD 11/01/02] [CR] (3 oa~es)
11/18/02 36 PROCEEDING MEMO re hearing held - record taken; matter settled - stip. to be filed None
within 30 days; otherwise motion to be reconsidered will be denied.; mailing not
required. Re: Item # 33. [BOD 11/19/02] [CL]
,
~"
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- ~~." -~~
Docket for Case: n + GetCaseNoO + n (n + DktTypeExpand(m.gsDktType) + n)
Page 3 00
12/16/02 37 CORRESPONDENCE from Movant requesting this matter be re-listed for hearing. None
(per Proceeding Memo entered on November 18, 2002, stipulation has not been filed.
Motion to reconsider should be denied and Order lifting stay will remain.) Re: Item #
25. [EOD 12/18/02] [IG]
01/17/03 38 STIPULATION by TRUSTEE AND DEBTORS. Re: Item # 27. [EOD 01/17/03] None
[CR]
01/17/03 39 APPROVBD by the court. Re: Item # 38. [EOD 01/17/03] [CR] None
03/14/03 40 CERTIFICATE OF DEFAULT Re: Item # 38. [EOD 03/14/03] [CR] None
03/19/03 41 ORDER dismissing case UPON TRUSTEE'S CERTIFICATE OF DEFAULT [EOD None
03/19/03] [CR]
03/24/03 42 NOTICE to creditors of dismissal of case [EOD 03/24/03] [AUT] Doc #42 PDF
(2 oafles)
Printed: OS/22/03 09:33:55
I PACER Service Center I
I Transaction Receipt I
I OS/22/2003 09:33 :55 I
IPACER Login: Iba0060 IIClient Code: I
IDescription: IIDocket IICase Number: III 2000-05293 I
IBillable Pages: 113 IICost: 110.21 I
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1
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, P A 19106
215-627-1322
Attome for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
I
r
of Cumberland County
Plaintiff
vs.
CNIL ACTION - LAW
TRICIA A. CmCOINE
STEVE N. CmCOINE
Mortgagors and Record Owners
ACTION OF MORTGAGE FORECLOSURE
No. 00-3895
6979 Wertzville Road
Enola, P A 17025
Defendants
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached).
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record
(proof of mailing attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
","p~'fully mbm1l~, b J)J..) 9.
Jos h . Goldbeck, Jr.
A rney for Plaintiff
,~.~.. '-~ilW~ &7
TO:
cmCOlNE, TRlCIA A.
TRICIA A. CHICOINE
6979 Wertzville Road'
Enola, PA 17025
SENDER:
I FN-0084
09/03/03 ~ Cumberland
PS Form 3800 June 2000
RETURN Postage
RECEIPT C rt'f' d
SERVICE e lie Fee
Return Receipt Fee
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Total Postage & Fees
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TO:
CHICOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzvill" Road
Enola, PA 17025
I FN-0084
09/03/03 -: Cumberland
US Postal Service
Receipt for
Certified Mail
No Insurancs Coverage Provided
00 Not Use for International Mall
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First Nationwide Mortgage Corp.
VS
Tricia A. Chicoine and Steve N.
Chicoine
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3895 Civil Term
Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that
on June 12,2003 at 5:25 o'clock PM, he served a true copy of the within Real Estate
Wri~, l\[oti(:e and Description, in the above entitled action, upon the within named
defeh~arit, to wit: Steve N. Chicoine, by making known unto Tricia Chicoine, wife of
defli,n~~t,at 6979 Wertzville Road, Enola, Cumberland County, Pennsylvania, its
cont~~~siuid at the same time handing to her personally the said true and correct copy of
I'
the same.
, "I'
','Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that
on June 12,2003 at 5:25 o'clock PM, he served a true copy ofthe within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Tricia A. Chicoine, by making known unto Tricia Chicoine,
personally, at 6979 Wertzville Road, Enola, Cumberland County, Pennsylvania, its
contentSaI).d at the same time handing to her personally the said true and correct copy of
the sarile. ',., , . '
, I)ayi!iMcKil1llt:Y, DeplIty Sheriff, who being duly sworn according to law, states
that on July 10,2003 at 7:05 o'clock P.M., he posted a true copy of the within Real Estate
Writ, No~ice, Poster and Description, in the above entitled action, upon the property of
Tricia A. Chicoine and Steve N. Chicoine located at 6979 Wertzville Road, Enola,
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 of the action to one of the within
named defendants, to wit: Steve N. Chicoine, by regular mail to his last known address
of 6979 Wertzville Road, Eno1a, PA 17025. This letter was mailed under the date of July
03, 2003 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The E)heriffmai1ed a notice of the pendency ofthe action to one of the within
named def~dants, to wit: Tricia A. Chicoine, by regular mail to her last known addr, ess
-'-"--',,1"' , :,,-', ,- - "_,, , "",' "
of 697ci WertzVille Road, Eno1a, P A 17025. This letter was mailed under the date ofJu1y
03, 2003 and never returned to the Sheriff's Office.
Sworn and subscribed to before me
~~~
R. Thomas Kline, ~~
This _ day of
Prothonotary
BY l J~ wvul~
Real Esta Deputy
2003, A.D.
K~ ~
,
. ,
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"
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney ID, #16132
Suite 500 - The Bourse Bldg,
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
p,o. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
TRIClA A. CHICOINE
STEVE N, CHICOINE
Mortgagors and Record Owners
ACTION OF MORTGAGE FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Defendants
No, 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP" Plaintiff in the above action, by its attorney, Joseph A Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, PA 17025
LName and address of Owners or Reputed Owners:
TRICIA A, CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N, CHICOINE
6979 Wertzville Road
Enola, P A 17025
2, Name and address of Defendants in the judgment:
TRICIA A, CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N, CHICOINE
6979 Wertzville Road
Enola, P A 17025
3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
.-""
"-,,:
PA DEPARTMENT OF PUBLIC WELFARE
Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P,O. Box 2675
Harrishurg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO,
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6, Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, PA 17025
(attach separate sheet if more space is needed)
I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: August 5. 2003
~
DB CK cCAFFERTY & McKEEVER
. Joseph A. Goldbeck, Jr., Esq.
omey for Plaintiff
.
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First Nationwide Mortgage Corp.
VS
Tricia A. Chicoine
Steve N. Chicoine
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3895 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck.
Sheriff s Costs:
Docketing
Poundage
Posting Bills
Advertising
Mileage
Levy
Surcharge
Law Library
Prothonotary
Law Joumal
Patriot News
Share of Bills
30.00
19.53
15.00
15.00
15.18
15.00
30.00
~
1.00
479.30
347.23
28.90
$ 996.14 paid by attorney
9/4/03
Sworn and subscribed to before me
This q{f dayof l,.:t;;;;..L... .
2003, A.D. ~/1' Cr)Yuif~# '
So AnS~ 4-r.
~ ~ne<.J<,'f__ ~
R. Thomas Kline, Sheriff
Prothonotary
OVC~
J. 0e. VIQ,,/9
~ 1'O~ol"
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.'
, Goldbeck McCafferty & McKeever
"BY:' JosephA. Goldbeck, Jr.
Attorney 1.D. #16132
Suite 500 - The Bourse Bldg.
Ins. Independence MaJl East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs.
CIVIL ACTION - LAW
TRICIA A. CmCOINE
STEVE N. CmCOINE
(Mortgagor(s) and Record Owner(s))
6979 Wertzville Road
Enola,PA 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, P A 17025
I.Name and address of Owner(s) or Reputed Owner(s):
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
-.
. ".~' ~~o-u
"~ ~, '-
-.~
""--_:."""~,,'
4
P A DEP AR1MENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - 'Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
I
.
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
maybe affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, PA 17025
(attach separate sbeet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOLDBECK
BY: JosephA.
Attorney for P
DATED: May 22, 2003
~"".=
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.
"
00-3895
..
)
GOLDBECK McCAFFERTY & McKEEVER
BY: JosephA. Goldbeck, Jr.
Attomey I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence MaIl East
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CML ACTION - LAW
vs.
lRICIA A. CffiCOINE
STEVE N. CffiCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Tenn
No. 00-3895
Defendant(s
TffiS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
.,
TO: CIllCOINE, TRlCIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
. Enola, P A 17025
Your house at 6979 WertzviUe Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $94,833.06 obtained by FlRSTNATIONWIDE MORTGAGE CORP.
against you.
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 FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
"
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,
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"
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- 'r ~ ~
-"'.....~~-""....""'~
~'I~..~'" ~~ ~...-Plilllll
""-_.'""-1ilI~.Ii!'
00-3895
2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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 below 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 NOT TAKE PLACE.
I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court tQ set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through ouly if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 f'1led by the Sheriff thirty (30) days from the date of the
Sheriff's 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 Sheriffwitbin ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES lNe
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
~"
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-
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00-3895
-'
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attomey for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
VS.
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant( s
TIllS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: cmCOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriff's Sale on
Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP.
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TffiS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To f'md out how much you must pay call:
215-627-1322
=~-
-
~'ur~"""",lh",,,Il!.'_I<i,,
00-3895
,
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open 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 attomey to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd
out the price bid price by calling the Sheriff of717-240-6390.
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 fmd
out if this has happened, you may call the Sheriff of 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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bnug legal proceedings to evict you.
6. You maybe entitled to a share of the money which was paid for your house. A schednle of
distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the
Sheriffs 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 Sheriffwitbin ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIA nON
2 Liberty Avenue
Carlisle, PA 17013
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A~L THAT CERTAIN piece, parcel and tract of land located in the Township of Silver Spring,
Cumberla'1d County, Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
1
BEGINNING at a point on the southern dedicated right of way line of Wertzville Road (S.R.
0944), said point being located and referenced in an easterly direction from the intersection of
the eastern right of way line of Old Willow Mill Road and the southern right of way line of
Wertzville Road approximately 800 feet; thence from said point of beginning along the
dedicated right of way of Wertzville Road, North 84 degrees 14 minutes 40 seconds East a
distance of 125.11 feet to a point; thence along Lot No.1 (lands of Kevin P. Culley and Denise
C. Culley), South 02 degrees 14 minutes 18 seconds East a distance of 247.07 feet to a point;
thence along the same, South 85 degrees 13 minutes 08 seconds West a distance of 125.00
feet to a proposed iron pin; thence alongJands now or late of Samuel L. Gerace and Mary D.
Gerace, North 02 degrees 14 minutes 18 seConds West, a distance of 244.94 feetto a point
on the southern dedicated right of way line of Wertzville Road (S.R. 0944) and also the point
of beginning.
SAID tract contains 0.71 acres to the dedicated right of way and this being Lot #2 on the Final
Subdivision Plan for Kevin P. Culley and Denise C. Culley prepared by J. Michael Brill &
Associates, Inc. with a last revised date of March 15, 1994 and recorded with the Cumberland
County Recorder of Deeds Office of June 10, 1994 in Plan Book 68, Page 33.
ALL THAT CERTAIN tract of land located along the southern right of way of S.R. 0944 in the
Township of Silver Spring, Cumberland County, Pennsylvania, shown as additional dedicated
right of way for Lot NO.2 and depicted on a Final Subdivision Plan, more particularly bounded
and described as follows:
BEGINNING at a point, approximately 0.fi1 miles Westwardly of Township Road No. 596 along
the centerline of Wertzville Road (S.R. 0944) and South 02 degrees 14 minutes 18 seconds
East a distance of 30.06 feeUrom centerline of Wertzville Road, to said beginning point. The
following courses and distanced describe said additional dedicated right of way for Lot No.2.
1. North 84 degrees 14minutes 40 seconds East a distance of 125.11 feet;
2. South 02 degrees 14 minutes 18 seconds East a distance of 5.01 feet;
3. South 84 degrees 14 minutes 40 seconds West a distance of 125.11 feet;
4. North 02 degrees 14 minutes 18 seconds West a distance of 5.01 feet to
the point of beginning.
CONTAINING an area of 0.0143 acres, more or less
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 6979 Wertzville Road, Enola, PA 17025
SOLD as the property of TRICIA A. CHICOINE and STEVE N. CHICOINE
TAX PARCEL #38-13-0985-086
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION c. LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To ,satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORP.,
Plaintiff (s)
From TRICIA A. CmCOINE AND STEvE N. CmCOINE, 6979 WERTZVILLE ROAD,
ENOLA, PA 17025
(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 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 $94,833.06
Interest FROM 12/1/99 TO 7/31/00 AT 0.0100%
L.L.
Atty's Comm %
Atty Paid $1303.79
Plaintiff Paid
Date: MAY 23, 2003
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothonz
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Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQillRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SillTE 500 - THE BOURSE BLDG.
111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ill No. 16132
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REAL ESTATE SALE No. S7
On June 3, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, P A
Real Estate Sale # 37
known and numbered as 6979 Wertzville Road,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 3, 2003
By: Jlrfi..w ~
Real ~tate Deputy
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-- REAL ESTATE-SAU, No:37 ---
Writ No. 2000-3995
Civil Term
First Nationwide
. Mort9~; Corp.
Tricla A. Chicoine and
Steve N. Chicoine
Atty.: Jo.eph Goldbeck
DESCRIPTION
ALL THAT CERTAIN piece, parcel and tract of
land located in fr~~" Township of Silver Spring.
County of Cumberland, Commonwealth Qf
pennsylvania more particularly bOlJl1ded and
I described as follows:
BEGINNING a~ a point on' the southern
dedicated nb>i1t-of-WllY line of WertzviUe Road
(SK 0944), said point being 1000"ated and
referenced in all eastedy direction from the
intersection of the eastern right-or-Way line ofOtd
Willow Mill Road and the southern right-of-way
of WertzVille Road a\lproxtmately 800 fect;
thence from said point of beginning' along the
dedicated right-of-way of Wertzville Road, North
84 degrees 14 minutes 40 seconds East a distance
o( t25.11 feet to a point; thence along Lot No.1
(funds of Kevin p, Cu.11ey and Denise C. Culley),
South 02 degrees 14 minutes 18 sec<locls East a
distance of 247.C7 feet to a poin~; thence along
the same., Soutl-. 85 degrees 13 minutes 08
se::onds_ West a distance of 125.00 feet to a
propOllediron pm; thence along lands now or late
of Samuel L. Qe.nre and Mary D. Gerace, North.
02 degrees 14 minutes 18 secon& West, a
distance of 244.94. feel to a point on the southern
dedicated right-of-way line of Wertzvnte Road -
(S.R. 0944) and also the point of BEGINNING.
SAID tract contajrr:; 0.71 acre;; to the dedicated
right-of-way and this being 1.9t #2 on the Final
Subdivision Plan for Kevln P. Culley and Denise
"C: Culley prepared -by - 1. Michael Brin- -~-
A~sociates.,' IDe. v.'ith a last revised date of March
14, 1994 and recorded with the Cumberland
County Recorder' of Deeds Office of June lO,
1994inPlan Book 68, Page 33.
ALL THAT CERTAIN tract of land located
along the southern right-of-way, of S.R. 0944 in
the Township of, Silver Spring, Cumberland
County, Pennsylv~nia, shown as additional
dedicated right-of-way for Lot No.2 and depicted
on a Final Subdivision Plan, more partIcularly
bounded and des;:ri.bed as follows:
BEGINNING at a pqint, approximately O.S 1
oriles westwardly of Tbwnship Rnad No. 596
along the centerHnc of WertzviUe Road (S.R.
0944) and South 02 degrees 14 minutes 18
seconds East a distance of 30.06 feet from
centerline of Wertzville Road, to said beglnning
point. The following courses and distances
describe said additional dedicated right-of-way
for Lot No. 2.
1. North M degrees 14 minutes 40 seconds
East a distance of 125.11 feet;
2. Soulh 02.degrees 14 minutes 18 seconds
East a distance cf 5.01 feet
;_.."..,,3,.-,s,outh,,-84 degrees l4 minutes 40 secOllOs- ,
.::,:1-Ve_st.adistanceof125.l1feet;" ,
" 4,...-North.,02, degrce.~ 1.4 minutes 18 second.~'-
"'\V:esLl)."di$t~~'6f"5';0l 'fed 10 tile point of~,
BEGRili'lNG. ..... .
" CO~'TAINING- an area of 0.0143 acres, more or
'less, ""
rMPROVEMENTS- consist of a residential
dwelling. _ . -
BEING PRF.M1SES: 5979 WertzViUe Road,
Enola,PA 17025: '
SOLD as the property oftriciaA. Chicome and
Steve N, Chi~ine.
TAx.?ARCEL NO,: 38.l3-098,.o86.
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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 Ass!. 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~
Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th
day(s) of August 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.
PUBLICATION
COPY
SALE#37
1
Swor
Notarial Seal
T""Y L. Russell. NotaJy Public
City 01 Harrisbulg, Dauphin County
My Corrmission Expires June 6, 2006
Member. Pennsylvania Association Of Notaries
commission expires June 6, 2006
CUMBERlAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Total $
345.48
1.75
347.23
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By....................................................................
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REAL ESTA'llJ1) SALE NO. 37
Writ No, 2000-3895 Civil
First Nationwide Mortgage Corp.
vs,
Tricia A. Chicoine and
Steve N. Chicoine
Atty.: Joseph Goldbeck
ALL TIfAT CERTAIN piece. par-
cel and tract of land located in the
TownsWp of Silver Spring, Cumber- I
land County. Cormnonwealth of Penn- ,
sylvania more particularly bounded I
and described as follows:
BEGINNING at a point on the
southern dedicated right of way line
of Wertzville Road (S,R. 0944). said
point being located and referenced
in an easterly direction from the in-
tersection of the eastern right of way
line of Old Willow Mill Road and the
southern right of way line of
Wertzville Road approximately 800
feet: thence from said point of be-
ginning along the dedicated right of
way of Wertzville Road, North 84
degrees 14 minutes 40 seconds'
East a distance of i25, II feet to a
point; thence along Lot No. 1 (lands
of Kevin P. Culley and Denise C.
Culley). South 02 degrees 14 min-
utes 18 seconds East a distance of
247.07 feet to a point; thence along
the same, South 85 degrees 13 min-
utes 08 seconds West a distance of
125.00 feet to a proposed iron pin:
_ thence along lands now or late of
Samuel L. Gerace and Maty D. Ger-
ace, North 02 degrees 14 minutes
18 seconds West, a distance of
244.94 feet to a point on the south-
ern dedicated right of way line of
Wertzville Road (S.R. 0944) and also
the point of beginning.
SAID tract contains 0.71 acres
to the dedicated right of way and
this being Lot #2 on the Final Sub-
division Plan for Kevin P. Culley and
Denise C. Culley prepared by J. Mi-
chael Brill & Associates, Inc. with a
last revised date of March 15. 1994
and recorded with the Cumberland
Connty Recorder of Deeds Office of
June 10. 1994 in Pian Book 68. Page
33.
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ALL THAT CERTAIN tract of lalld
located along the southern right of
way of S.R. 0944 in the Township
of Silver Spring. Cumberland Coun-
ty. Pennsylvania. shown as addi-
tional dedicated right of way for Lot
No. 2 and depicted on a Final Sub-
division Plan, more particularly
bounded and described as follows:
BEGINNING at a point, approxi-
mately 0.51 miles westwardly of
Township Road No. 596 along the
centerline of Wertzville Road (S.R.
0944) and South 02 degrees 14
minutes 18 seconds East a distance
of 30.06 feet from centerline of
Wertzville Road, to said beginning
point. The following courses and
distanced describe said additional
dedicated right of way for Lot No.
2.
1. North 84 degrees 14 minutes
40 seconds East a distance of
125.11 feet:
2. South 02 degrees 14 minutes
18 seconds East a distance of 5.01
feet:
3. South 84 degrees 14 minutes
40 seconds West a distance of
125.11 feet:
4. North 02 degrees 14 minutes
18 seconds West a distance of 5.01
feet to the point of beginning.
CONTAINING an area of 0.0143
acres, more or less.
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 6979 Wertz-
ville Road. Enola, PA 17025.
SOLD as the property of TRlCIA
A CHICOINE and STEVE N. CHI-
COINE,
TAX PARCEL #38-13-0985-086,
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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, sirtce 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:
JULY 18,25,2003 AUGUST 1,2003
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.
TO AND SUBSCRIBED before me this
1 day of AUGUST,2003
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
"
,. Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000 - Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106-1532
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs,
CIVIL ACTION - LAW
TRICIA A. CHICOINE
STEVB N. CHICOINE
Mortgagor(s) and Record Owner(s)
6979 Wertzville Road
Enola, P A 17025
ACTION OF MORTGAGE FORECLOSURE
No. Q.0-3895
Defendant( s)
PRAECIPE FOR WRIT OF EXECUTION
TO THEPROTJIONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
1210111999 to
07/3112000 at
0.0100%
$94,833.06
(Costs to be added)
GOLDBECK M
BY: JosephA. G
Attorney for PI"
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ALL THAT CERTAIN TRACT OF LAND LOCATED ALONG THE SOUTHERN RIGHT OF
WAR OF S.R. 0944 IN THE TOWNSHIP OF SILVER SPRING, CUMBERLAND COUNTY,
PENNSLYVANIA, SHOWN AS ADDITIONAL DEDICATED RIGHT OF WAY FOR LOT
NO.2 AND DEPICTED ON A FINAL SUBDIVISION PLAN, MORE PARTICULARLY
BOUNDED AND DESCRIBED AS FOLLOWS;
BEGINNING AT A POINT, APPROXIMATELY 0.51 MILES WESTWARDLY OF
TOWNSHIP ROAD NO. 596 ALONG THE CENTERLINE OF WERTZVILLE ROAD, TO
SAID BEGINNING POINT. THE FOLLOWING COURSES AND DISTANCES DESCRIBE
SAID ADDITIONAL DEDICATED RIGHT OF WAY FOR LOT NO.2:
1. NORTH 84 DEGREES 14 MINUTES 40 SECONDS EAST A DISTANCE OF 125.11
FEET;
2. SOUTH 02 DEGREES 14 MINUTES 18 SECONDS EAST A DISTANCE OF 5.01
FEET;
3. SOUTH 84 DEGREES 14 MINUTES 40 SECONDS WEST A DISTANCE OF 125.11
FEET;
4. NORTH 02 DEGREES 14 MINUTES 18 SECONDS WEST A DISTANCE OF 5.01
FEET TO THE POINT OF BEGINNING.
5.
CONTAINING AN AREA OF 0.0143 ACRES, MORE OR LESS.
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USBC PAM - LIVE - V2.5 - Docket Report
Page 1 of4
CREDS, PlnCnfrmd, 341Held, CLAIMS
U.S. Bankruptcy Court
Middle District of Pennsylvania (Harrisburg)
Bankruptcy Petition #: 1:03-bk-05145-MDF
Assigned to: Mary D France
Chapter 13
Voluntary
Asset
Date Filed: 09/02/2003
Steve N Chicoine
6979 WERTZVILLE ROAD
ENOLA, P A 17025
SSN: xxx-xx-0175
Debtor
Tricia A Chicoine
6979 WERTZVILLE ROAD
ENOLA, P A 17025
SSN: xxx-xx-6918
Joint Debtor
Charles J. DeHart, III (frustee)
PO Box 410
Hummelstown, P A 17036
717 566-6097
Trustee
United States Trustee
PO Box 969
Harrisburg, PA 17108
(717) 221-4515
Asst. U.S. Trustee
represented by James K. Jones
7 IRVINE ROW
CARLISLE, PA 17013-3019
717 240-0296
represented by James K. Jones
(See above for address)
Filing Date # Docket Text
09/02/2003 1 Chapter 13 Voluntary Petition. Filing fee due in the amount of$
185.00 Filed by James K. Jones on behalf of Steve N Chicoine,
Tricia A Chicoine. (DB) Modified text on 9/4/2003 (JR). (Entered:
09/03/2003)
09/02/2003 2. Chapter 13 Plan Filed by James K. Jones on behalf of Steve N
Chicoine, Tricia A Chicoine (RE: related document(s)l). (DB)
(Entered: 09/03/2003)
09/02/2003 3 Matrix filed/Creditor List Uploaded Filed by James K. Jones on
behalf of Steve N Chicoine, Tricia A Chicoine (RE: related
I
https://ecf.pamb.uscourts.gov/cgi -binlDktRpt.pl 7229053920883991- L _82_0-1
9/30/04
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USBC PAM - LIVE - V2.5 - Docket Report
Page 2 of 4
document(s)l). (DB) (Entered: 09/03/2003)
09/03/2003 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO
CHANGE. 10/23/2003 at 09:00 AM. (DB) (Entered: 09/03/2003)
09/03/2003 Receipt of Voluntary Petition Filing Fee. Receipt Number Fee
Amount (RE: related document(s)l). (DB) Modified on 9/4/2003
(TH)TO REMOVE RECEIPT INFORMATION. RECEIPT WAS
VOIDED DUE TO UNSIGNED CHECK. (Entered: 09/03/2003)
09/04/2003 Corrective Entry fee not paid, check was unsigned. (DD) (Entered:
09/04/2003)
09/04/2003 4 Order re: filing fee due in the amount of$ 185.00. (RE: related
document(s)l). Fee due on: 9/11/2003. (DD) (Entered: 09/04/2003)
09/05/2003 Receipt of Voluntary Petition Filing Fee. Receipt Number 599437
Fee Amount $ 185.00 (RE: related document(s)l, [4)). (DP) (Entered:
09/05/2003)
09/17/2003 5. Request to BNC - Meeting of Creditors. 341(a) meeting to be held on
10/23/2003 at 10:00 AM Federal Bldg, Trustee Hearing Rm, Rm
1160, 11 th Fl, 228 Walnut St, Harrisburg, P A Proofs of Claims due
by 1/21/2004 (DP) (Entered: 09/17/2003)
09/19/2003 Q BNC Certificate of Mailing. Service Date 09/19/2003. (Related Doc #
5.) (Admin.) (Entered: 09/20/2003)
09/19/2003 1 BNC Certificate of Mailing. Service Date 09/19/2003. (Related Doc #
5.) (Admin.) (Entered: 09/20/2003)
10/24/2003 8 Certification of Trustee that 341 Meeting of Creditors Held Filed by
Charles J DeHart, III. Last day to Object to Plan Confirmation
11/7/2003. (DP) (Entered: 10/27/2003)
10/24/2003 9 Motion for Wage Attachment Order Filed by James K. Jones on
behalf of Steve N Chicoine. (DD) (Entered: 10/28/2003)
10/28/2003 10 Order Granting Motion for Wage Attachment Order (RE: related
document(s)[9]). (DD) (Entered: 10/28/2003)
11/13/2003 11 Order Confirming Chapter 13 Plan (RE: related document(s)2., [8]).
(SP) (Entered: 11/13/2003)
05/03/2004 12 Motion to Sell Real Estate located 6979 Wertzville Road, East
Pennsboro Township, Cumberland County, P A to Gloria M Gates for
I
https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?229053920883991- L _82_0-1
9/30/04
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the sum of $120600.00 (Notice requested) Filed by James K. Jones on
behalf of Steve N Chicoine, Tricia A Chicoine. (SP) (Entered:
05/04/2004)
05/06/2004 13 Notice sent to counsel for mailing fixing answer/objection date (RE:
related document(s)[12] ). (SP) (Entered: 05/06/2004)
05/10/2004 14 Certificate of mailing of notice sent by counsel Filed by James K.
Jones on behalf of Steve N Chicoine, Tricia A Chicoine (RE: related
document(s)[12] ). Objections due by 5/27/2004. (SP) (Entered:
05/11/2004)
05/18/2004 15 Answer Filed by Jay B Jones of Federman and Phelan LLP on behalf
of Citimortgage Inc as Servicer for the Mortgagee of Record (RE:
related document(s)[12] ). (Je) (Entered: 05/18/2004)
OS/24/2004 16 Notice to Parties: (RE: related document(s)[15], [12]). Hearing
scheduled for 6/21/2004 at 09:00 AM at 3rd & Walnut Streets,
Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, P A.
(SP) (Entered: OS/24/2004)
OS/28/2004 17 Amendment to Schedules A and C (requested Certificate of Service)
Filed by James K. Jones on behalf of Steve N Chicoine, Tricia A
Chicoine (RE: related document(s)l). (DD) (Entered: 06/02/2004)
06/16/2004 .lli Motion to Dismiss Case for material default and hearing notice to
parties. Filed by Trustee. Hearing scheduled for 7/8/2004 at 02:00 PM
at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal
Building, Harrisburg, P A. (dehart, II1( ds), Charles) (Entered:
06/16/2004)
06/17/2004 19 E-mail correspondence filed by James K. Jones on behalf of Steve N
Chicoine, Tricia A Chicoine requesting that hearing be cancelled.
Debtor's to withdraw the Motion to Sell. (RE:related document(s)
16 ). (JO) (Entered: 06/21/2004)
06/22/2004 20 Praecipe/Withdrawal Filed by James K. Jones on behalf of Steve N
Chicoine, Tricia A Chicoine (RE: related document(s)[12] ). (CR)
(Entered: 06/23/2004)
06/24/2004 21 Order approving Praecipe/Withdrawal Motion for Sale (RE: related
document(s)[20]). (Attachments: # 1 Certificate of Service) (SP)
(Entered: 06/24/2004)
07/13/2004 22 Stipulation by debtor and Ch. 13 trustee Filed by Trustee (RE: related
document(s)l8.). (Attachments: # 1 Proposed Order)(dehart, II1(ds),
Charles) (Entered: 07/13/2004)
I
https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pJ?229053920883991-L _82_0-1
9/30/04
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07/14/2004 23 Order approving Stipulation (RE: related document(s)22).
(Attachments: # 1 Certificate of Service) (SP) (Entered: 07/14/2004)
07/30/2004 24 Motion for Relief from Stay. Filing fee due in the amount of $
150.00 Filed by Judith Romano ofFedennan & Phelan on behalf of
Citimortgage Inc as Servicer for the Mortgagee of Record . (SP)
(Entered: 07/30/2004)
07/30/2004 Receipt of Motion for Relief from Stay Filing Fee. Receipt Number
611565 Fee Amount $ 150 (RE: related document(s)[24]). (SP)
(Entered: 07/30/2004)
07/30/2004 25 Order (RE: related document(s)[24] ). Answers are due on:
8/14/2004. Hearing scheduled for 9/1/2004 at 09:00 AM at 3rd &
Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building,
Harrisburg, PA. (SP) (Entered: 07/30/2004)
08/05/2004 26 Certificate of Service Filed by Judith Romano of Fedennan & Phelan
on behalf of Citimortgage 1nc as Servicer for the Mortgagee of
Record (RE: related document(s)[24], [25]). (CA) (Entered:
08/05/2004)
08/26/2004 27 Order Granting Motion for Relief from Stay (RE: related document( s)
[24] ). (Attachments: # 1 Certificate of Service) (SP) (Entered:
08/26/2004)
I PACER Service Center I
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I 09/30/200410:48:16 I
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Report Criteria: 99999999 Term: y Links: n
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https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl 7229053920883991- L _82_0-1
9/30/04
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Goldbeck McOifferty & McKeever
.BY: Jcrseph A. Goldbeck, Jr.
AttorneyI.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
TRICIA A. CHICOINE
STEVE N. CHICOINE
(Mortgagor(s) and Record Owner(s))
6979 Wertzville Road
Enola, P A 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr.,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information conceming the real
property located at:
6979 Wertzville Road
Enola, PA 17025
I.Name and address ofOwner(s) or Reputed Owner(s):
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, P A 17013
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P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record Uen on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected. by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, P A 17025
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOLDBECK Mc
BY; Joseph A. Go
Attorney for Plain .
DATED: St;ptember 30. 2004
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attomey I.D.#16132
Suite 5000- Mellon Independence Center
70 I Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMM:ON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. CmCOINE
STEVE N. CmCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Eno1a, P A 17025
Term
No. 00-3895
Defendant( s
TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TIDS NOTICE IS SENT TO YOU IN All' ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, TRICIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you,
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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00-3895
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 below 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 NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may f'md
out the price bid price by calling the Sheriff of 717-240-6390.
2. You maybe 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 the Sheriff of717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriff's Sale. This schednle 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 Sheriffwitbin ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
inunediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000- Mellon Independence Center
70 I Market Street
Philadelphia, PA 19106
215-627-1322
Attomey for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CNIL ACTION - LAW
vs.
TRICIA A. CmCOINE
STEVE N. CmCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defendant( s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PRpPERTY
TO: CHICOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take innnediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
,~- ''''''''''. .~-',-
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00-3895
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 below 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 NOT 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 price by calling the Sheriff of 717 -240-6390.
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 the Sheriff 0017-240-6390.
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 aright 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 briog 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 thirty (30) days from the date of the
Sheriff's 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 schedule of distribution is filed.
7, You may also have other rights and defenses, or ways of getting your house 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, P A 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfY the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORP.,
Plaintiff (s)
From TRICIA A. CmCOINE AND STEVE N. CmCOINE
(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 notif'y the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debtto 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 notif'y himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $94,833.06
Interest FROM 12/1/99 TO 7/31/00 AT 0.0100%
Arty's Comm %
Arty Paid $2,314.93
Plaintiff Paid
Date: OCTOBER 5, 2004
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Protho:d;
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p . '7lZ "-'lA/V oJ
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SmTE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ill No. 16132
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GOLDBECK McCAFFERTY & McKEEVBR
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16l32
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attome for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-10 11
Gaithersburg, MD 20898-9481
FN-0084
03/02/2005
$94,833.06
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
TRICIA A. CHICOINE
STEVE N. CHICOINE
Mortgagor(s) and
Record Owner(s)
Tenn
No. 00-3895
6979 Wertzville Road
Enola, PA 17025
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was. made bY:. 1. .J.. lJ -<. . .' (J (' 0
~t- s~rwo.. ~ o(] I@ ~t D'l~<JbrW. ~ ~e 1J
K Personal Servlce by the Shenffs 0 lce/ . . . , '.: d .l L Ji). .
M Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ,It, C ttJ/
( ) Certified mail by Sheriffs Office. mW.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record . I
(proof of mailing attached).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment
attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified
Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S
Section 4904.
7:LIoD JlIfi 'is..1 "t1tiL 7$.e
TO: CHICOINE, STEVE N.
STEVE N. CHICOINE
6979 We1izville Road
Enola, P A 17025
SENDER:
GOLDBECK MCCAFFERTY & MCKEEVER
September 30, 2004
REFERENCE: I FN-0084
03/02/05 - Cumberland
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service POST.MA'RidR.D~i1Ii;
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Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
...-----,....--"----_..~----"-----~._."--_...,._.--"--"----.~--"- -_._~.~-~-~-~~...-~-"._....~-.-,,--~.-..-_...._-_.._,,-~.-~~--,,--~.
7160 ~:01 ~6~838il!7 1713
~'i':'
TO: CHICOINE, STEVE N.
STEVE N.CHICOINE
5 N. Locust Point Rd.
Mechanicsburg, P A 17050
SENDER: GOLDBECK MCCAFFERTY & MCKEEVER
November 9, 2004
REFERENCE:
I FN-0084
03/02/05 - Cumberland
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
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GOLDBECK MCCAFFERTY & MCKEEVER
September 30, 2004
REFERENCE: I FN-0084
03/02/05 - Cumberland
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CHICOINE, TRlClA A,
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
I'
SENDER:
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provicfsd
Do Not Use for International Mall
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attomey for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIIE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. CmCOINE
STEVE N. CmCOINE
. Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE FORECLOSURE
Tenn
No. 00-3895
6979 Wertzville Road
Enola, P A 17025
Defendant( s)
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, by its attomey, Joseph A. Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, P A 17025
l.Name and address ofOwner(s) or Reputed Owner(s):
TRICIA A. CmCOINE
6979 Wertzville Road
Enola, PA 17025
STEVB N. CmCOINE
5 N. Locust Point Rd.
Mechanicsburg, P A 17050
2. Name and address ofDefendant(s) in the judgment:
TRICIA A. CmCOINE
6979 Wertzville Road
Enola, PA 17025
STEVB N. CHICOINE
5 N. Locust Point Rd.
Mechanicsburg, P A 17050
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3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
UMLIC VP LLC
P.O. BOX 471827
CHARLOTTE, NC 28247
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, P A 17025
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: February 4, 2005
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First Nationwide Mortgage Corp.
VS
Tricia A. Chicoine and Steve N. Chicoine
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-3895 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per instructions from Attorney Joseph Goldbeck.
Sheriff s Costs:
Docketing
Surcharge
Poundage
Levy
Advertising
Mileage
Posting Handbills
Share of Bills
Law Joumal
Patriot News
Postpone Sale
Certified Mail
Prothonotary
30.00
30.00
13.75
15.00
15.00
28.12
15.00
30.73
200.30
287.56
20.00
14.78
1.00
$ 701.24
This ftf 0. day of ~
2005, A.D. ~-<- Q,
Prothonotary
So Answers:
-r-;;?? -A< ~~
,_ Jf1R. Thomas Kline, Shlriff
~
,
BY .
Real Est
Sworn and subscribed to before me
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Goldbeck Mcoifferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
vs.
CIVIL ACTION - LAW
TRICIA A. CHICOINE
STEVE N. CHICOINE
(Mortgagor(s) and Record Owner(s))
6979 Wertzville Road
Eno1a, P A 17025
ACTION OF MORTGAGE FORECLOSURE
Defendant( s)
No. 00-3895
AFFIDAVIT PURSUANT TO RULE 3129
FIRST NATIONWIDE MORTGAGE CORP., Plaintiff in the above action, hy its attorney, Joseph A. Goldbeck, Jr.,
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:
6979 Wertzville Road
Enola, P A 17025
I.Name and address ofOwner(s) or Reputed Owner(s):
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, PA 17025
STEVB N. CHICOINE
6979 Wertzville Road
Enola, PA 17025
2, Name and address ofDefendant(s) in the judgment:
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
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,.
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iI'
,
P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
GREENTREE CONSUMER DISCOUNT CO.
3401 Hartzdale Drive
Suite 132
Camp Hill, PA 17011
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected. by the sale.
TENANTS/OCCUPANTS
6979 Wertzville Road
Enola, P A 17025
(attach separate sheet if more space is needed)
1 verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
GOWBECK Mc
BY: JosephA. Go
Attorney for Plain .
DATED: September 30. 2004
~.,----
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(
00-3895
GOLDBECK McCAFFERTY & McKEEVER
.BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attomey for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRICIA A. CmCOINE
STEVE N. CmCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00-3895
Defenclant( s
TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, TRICIA A.
TRICIA A. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriff's Sale on
Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
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00-3895
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 below 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 NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may frod
out the price bid price by calling the Sheriff of7l7-240-6390.
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 the Sheriff 0017-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 thirty (30) days from the date of the
Sheriff's Sale. This schednle 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
inunediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
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00-3895
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, P A 19106
215-627-1322
Attorney for Plaintiff
FIRST NATIONWIDE MORTGAGE CORP.
P.O. Box 9481
Mail Code 22-528-1011
Gaithersburg, MD 20898-9481
IN TIlE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
vs.
TRlCIA A. CmCOINE
STEVE N. CmCOINE
Mortgagor(s) and Record Owner(s)
ACTION OF MORTGAGE
FORECLOSURE
6979 Wertzville Road
Enola, P A 17025
Term
No. 00~3895
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CHICOINE, STEVE N.
STEVE N. CHICOINE
6979 Wertzville Road
Enola, P A 17025
Your house at 6979 Wertzville Road, Enola, P A 17025 is scheduled to be sold at Sheriff's Sale on
Wednesday, March 02,2005, at 10:00 AM, in Connnissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $94,833.06 obtained by FIRST NATIONWIDE MORTGAGE CORP. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take inunediate action:
1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORP., the back
.payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322 .
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
"
--.
"" ..;",-_
00-3895
3. You may also be able to stop the sale through other legal proceedings,
You may need an attomey to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
Ev icN lJ< THE SHERIii'F'S SALE DOES NOT TAKE PLACE.
I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price hid price by calling the Sheriff of717-240-6390.
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 fmd
out if this has happened, you may call the Sheriff 0017-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
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 f1!ed by the Sheriff thirty (30) days from the date of the
Sheriff's Sale. This schednle 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
~,-,
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ALL THAT CERTAIN TRACT OF LAND LOCATED ALONG THE SOUTHERN RIGHT OF
WAR OF S.R. 0944 IN THE TOWNSHIP OF SILVER SPRING, CUMBERLAND COUNTY,
PENNSLYVANIA, SHOWN AS ADDITIONAL DEDICATED RIGHT OF WAY FOR LOT
NO.2 AND DEPICTED ON A FINAL SUBDIVISION PLAN, MORE PARTICULARLY
BOUNDED AND DESCRIBED AS FOLLOWS;
BEGINNING AT A POINT, APPROXIMATELY 0.51 MILES WESTWARDLY OF
TOWNSHIP ROAD NO. 596 ALONG THE CENTERLINE OF WERTZVILLE ROAD, TO
SAID BEGINNING POINT. THE FOLLOWING COURSES AND DISTANCES DESCRIBE
SAID ADDITIONAL DEDICATED RIGHT OF WAY FOR LOT NO.2:
1. NORTH 84 DEGREES 14 MINUTES 40 SECONDS EAST A DISTANCE OF 125.11
FEET;
2. SOUTH 02 DEGREES 14 MINUTES 18 SECONDS EAST A DISTANCE OF 5.01
FEET;
3. SOUTH 84 DEGREES 14 MINUTES 40 SECONDS WEST A DISTANCE OF 125.11
FEET;
4. NORTH .02 DEGREES 14 MINUTES 18 SECONDS WEST A DISTANCE OF 5.01
FEET TO THE POINT OF BEGINNING.
5.
CONTAINING AN AREA OF 0.0143 ACRES, MORE OR LESS.
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WRIT OF EXECTJT.ION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 00-3895 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORP.,
Plaintiff (s)
From TRICIA A. CIDCOINE AND STEVE N. CIDCOINE
(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) 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 $94,833.06
Interest FROM 12/1/99 TO 7131/00 AT 0.0100%
Atty's Comm %
Atty Paid $2,314.93
Plaintiff Paid
Date: OCTOBER 5, 2004
LL
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
---
proth02 p ~
Rv: 0-,. II. . "'AA-'~
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK. JR., ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SillTE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPIDA, PA 19106-1532
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ill No. 16132
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Real Estate Sale #03
On November 19,2004 the Sherifflevied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA
Known and numbered as 6979 Wertzville Rd.,
Enola, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: November 19,2004
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REAL ESTATE SALE No.ro'-
Writ No. 2000-3895
Civil Term
First Nationwide
Mortgage Corporation
Vs
Tricla A. Cl1licoine and
Steve N; Chicoine
AIty: Jo""p~ Goldbeck
DESCRIPTION
ALL THAT CElITMN lIact of land located
along the..Southem Rigbt-of-Way of SR 0944 in
the Township of Silver Spring. Cum-berland
County, - Pennsylvania, shown as :niditional
: .,: dedicated Right-of-Way for Lot No. 2 and
I, ,', depicted on a final Subdivt~ion Plan, lllOIe par-
j li/:u1arly bOlmded and described as follows:
. BEGINNING at a point. approximately 0.51
miles west-wardly of Township Road No. 596
along the centerline of Wertzville Road. to said
Beginning Point. The following ooun;es: aad di.s-
tmccs describe said additional dedicated Right-
. cit-WayforLotNo.2:
t North 84 degrees 14 minute&40 seoonds East
a d1Stance of 125.11 ~t;
2..South 02 ~ 14.t$utes 18 seconds East
a distance of 5.01 teet;
3..south 84 degrees 14 minutes 40 seconds West
.a:distanceofl25.11 feet~ .
4. North 02 degrees 14 minutes 18 seconds West
a, distance of 5.01 teet 10 the point of
BEGINNING.
... 'CO~'TAININGanareaofO.0143 acres,more
<)rless.,
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark, being duly sworn according to law, deposes and says:
That he is the Accounts Receivable Manager 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 The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday! Metro editions which appeared on the 18th and 25th day(s) of January and the
1st day(s) of February 2005. 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. /
/'7 (/
//
I I
'it
......................................................j........................................
PUBLICATION
COpy
S ALE #3
Sworn to and subscribed before m
,
NOTARIAL
Terry L. Russell, No .
Oly of Harrisburg, Dauphin Cou1!llfl Y PUBLIC
My Commission expires n expires June 6, 2006
Member. PennsylvanlaA:JJsoelationo( Notaries
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO.
For publishing the notice or publication attached
hereto on the above stated dates
287.56
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
circulation, hereby acknowledge receipt ofthe aforesaid notice and publication costs and certifies that the same have
been duly paid.
By........................................................m.........
REAL ES'l'A\1l'E S_ NO. 8
Writ No. 2000-3$95 Civil
First Nationwide Mortgage Corp.
vs.
Tricia A Chicoine and
Steve N. Chicoine
Atty.: Joseph Goldbeck
ALL THAT CERTAIN tract of land
located along the southern right of
war of S.R 0944 In the Township of
Sliver Spring, Cumberland County.
Pennsylvania, shown as additional
dedicated rlght of way for Lot No.2
and depicted on a Final Subdivision
Plan. more particularly bounded and
described as follows;
BEGINNING at a point. approxi-
mately 0.51 miles westwardly of
Township Road No. 596 along the
centerline ofWertzville Road. to said
beginning point. The following
COUrses and - distances describe said
additional dedlcaled righl of way for
Lot No.2:
1. North 84 degrees 14 minutes
40 seconds East a distance of 125-
.11 feet;
2. South 02 degrees 14 minutes
18 seconds East a distance of 5.01
feet:
3. South 84 degrees 14 minutes
40 seconds West a distance of 125-
.11 feet:
4. North 02 degrees 14 minutes
18 ~econds West a distance of 5.01
feet to the polnl of beginning.
5. CONTAINING an area of 0.0143
acres, more or less.
~ '
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.l784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor ofthe Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
VIZ:
January 14, 21, 28, 2005
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.
S TO AND SUBSCRIBED before me this
28 day of January. 2005
~JOTAt1if~ SEAL
~I LOIS E. S\\~YDER, NotODI Public
I ,,- J
"-'."__;:.,~~ 'C ~,. '.,"" 1 ""
~ Vd,k"" uo,O, CUI"bdl:ma \;ounty
fl [:~!':dres Iv1arch 5, 2005 "
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