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PRAECIPE FOR WRn OF EXECUTION. (MONEY JUDGMENTS)
P.I.C.P. 3101 to 3149
GREAT VALLEY SAVINGS BANK,
SYcgg~&er iR Intor9bt te CeAtr31
Pa. Savings Association,
PlaiRtiff
IN THE COURT OF CONNON PLEAS OF~mN
COUNTY, PENNSYLVANIA
CUMBERLAND
Writ No, Te.. 19
..
No. 97-529 CIVIL TERM Te.. 191Z.
,52,074.86
$ 2,041.48
AmOUnl due
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
[nctctlC _.
uelenaants
Auy'. Comm.
I
,
ond CoOII
TO TlfE PROTHONOTARY OF SAID roURT: ISSUE WRIT OF EXECUTION IN TlfE ABOVE NATTER,
Cumberland
(I) Direc,ed 10 rhe Sheriff 0/ Couney, Pennsylnni";
Bernard C. Wilder, Sr., and Paula J. Wilder,
(2) oaoino,
9119 South ~pssner Road, Suite l02, Houston,
13514 Cree!<Sprinqs, lIouston, TX 77083-l83?
Esquire
TX 77074; and at
Dc/endlnl(l);
(3) Ind oa"in",
Glmishec{I);
(~) Indindesrhiswri, Bernard C. IHlder, Sr., and Paula J. Wilder, Esquire,
(0) oa"inll
9119 South G0ssnel' Road, Suite 102, Houston, 'I'X 77074; and
l1C;14 ('t-pnk sr1-;nCr:;. Ilnll~t'nn. 'rx 770R1 lR12.Dtfendllnt(I)lnd
(b) "a"inll
Glmiohec{I).
.. a iii pendenl "a"in", rhe reol propcrey 0/ rhe dc/endonl(l) io the nome 0/ che GlmisheC<I)" .lollowl:
(Specilicolly delcribe p,ope"y Ind no'e ony Ipeci/ic direcrion '0 Sheril/) Fumilh ~ copi.. /or re:of coco.. lery)
. ,'.
P1Cc1Sf.: see .1ttiH.:'hpd (';.:l1ii>it.
(1) EU'mp(jon h.. (not) been ..ind.
DIled '.
. 1'1 , 'r::: h 'I
.~~~.l.~I~~~;u!.-'_'_ ~~I_~tt) I. ~!-'.i~_, .!~:~~J.:..
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I.
The aforesaid tract
thereon, is reputedly owned
Paula J. Wilder, solely.
Claims against the property must be filed with the Office of
the Sheriff before the above sale date. Claims to proceeds must be
made with the Office of the Sheriff before distribution.
of land, with improvements erected
by the said Bernard C. Wilder, Sr., and
Notice is further given to all parties in interest of said
claim that a schedule of proposed distribution will be filed by the
Sheriff of Cumberland County on or about January 2, 1998.
Distribution will be made in accordance with the said schedule
unless exceptions are filed thereto within ten (10) days
thereafter.
Attached hereto is a copy of the Writ of Execution. It has
been issued because there is a judgment against Defendants, Bernard
C. Wilder, Sr., and Paula J. Wilder. It will cause the property
above identified to be held or taken to pay the judgment.
Defendants Bernard C. Wilder, Sr., and Paula J. Wilder, may have
legal rights to prevent the property from being taken. A lawyer
can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
THOMAS E. CHEFFINS, COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriff's Sale and
the loss of your property. In order to exercise those rights
prompt action on your part is necessary. A lawyer may be able to
help you.
You may have the right to prevent or delay the Sheriff's Sale
by filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection you might have within twenty (20)
days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment
opened if you promptly file a petition with the Court alleging a
valid defense and a reasonable excuse for failing to file the
defense on time. If the judgment is opened, the Sheriff's Sale
GREAT VALLEY SAVINGS BANK,
Successor in Interest to
Central Pennsylvania Savings
Association,
Plaintiff
v.
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
Defendants
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
: NO. q 7 - j~2 if CIVIL TERM
I
I CIVIL ACTION - LAW
I
I
I
I
I
COMPLAINT
AND NOW, comes the Plaintiff, Great Valley Savings Bank,
Successor in Interest to Central Pennsylvan~a Savings Association,
by and through its attorneys, Caldwell & Kearns, and does file the
following Complaint against Defendants, Bernard C. Wilder, Sr., and
Paula J. Wilder, stating in support thereof the following:
1. Plaintiff Great Valley Savings Bank is a Pennsylvania
bank and trust company duly incorporated and existing under the
laws of the Commonwealth of Pennsylvania, with its principal place
of business located at 210 North Fifth Street, Reading, Berks
County, Pennsylvania 19063. Plaintiff Fulton Bank is the servicing
agent for Great Valley Savings Bank with regard to real estate
located in Cumberland County, Pennsylvania.
2. Defendants, Bernard C. Wilder, Sr., and Paula J. Wilder,
both adult individuals whose last-known address is: 13514 Creek
Springs, Houston, Texas 77083-1832.
3. Plaintiff, by merger, did acquire and succeed to the
interest and assets of Central Pennsylvania Savings Association,
1
formerly a Pennsylvania banking corporation, or about October 1,
1994. As stated, Fulton Bank is the servicing agent for Great
Valley Savings Bank with regard to real estate located in
Cumberland County.
4. On or about February 8, 1991, in consideration of a loan
of $49,200.00 made by Central Pennsylvania Savings Association to
will D. Tate, said Will D. Tate did execute and deliver to Central
Pennsylvania Savings Association a written Adjustable Rate Note, a
true and correct copy of which is attached hereto and marked
Exhibit "A" and made a part hereof by reference thereto.
5. The said Note did obligate the said Will D. Tate to pay
the sum of $49,200.00 at the annual interest rate of eight and one-
half (8.5%) percent, which may vary after March, 1994, as more
specifically provided in Paragraph 4 of the said Adjustable Rate
Note. Said payments would continue until the obligation were fully
paid, principal and all accrued interest, which would occur on or
about March 1, 2021.
6. The said Will D. Tate did die on or about December 3,
1992.
7. In conjunction with said Adjustable Rate Note, the said
Will D. Tate, now deceased, did give, grant and deliver to Great
Valley Savings Bank, formerly Central Pennsylvania Savings
Association, a certain Mortgage encumbering Unit No. 6 of Willow
Crossing Condominiums, located in South Middletown Township,
Cumberland County, Pennsylvania, also being known as 426 Dogwood
2
Court. A true and correct copy of said Mortgage dated February 8,
1991, and recorded in and for the Office of the Recorder of Deeds
of Cumberland County on February 15, 1991, in Mortgage Book 1003,
Page 218, is attached hereto and marked Exhibit "B" and made a part
hereof by reference thereto.
8. The said estate of Will D. Tate did grant and convey the
subject property to one Kenneth E. West by Deed dated January 4,
1994, a true and correct copy of which is attached hereto, marked
Exhibit "c' and made a part hereof by reference thereto. It is
noted that in conjunction with said conveyance, the said Kenneth E.
West did accept by assignment the subject Adjustable Rate Note.
9. Thereafter, on or about January 19, 1994, the said
Kenneth E. West did grant and convey the subj ect property to
Defendants, Bernard C. Wilder, Sr., and Paula J. Wilder. A true
and correct copy of said executed Deed is attached hereto, marked
Exhibit "D" and made a part hereof by reference thereto.
10. Pursuant to said conveyance, the said Cefendants, Bernard
C. Wilder, Sr., and Paula J. Wilder, did agree to an Assumption
Agreement of the said Adjustable Rate Note and agreed to a specific
payment schedule therein to include payments to cure arrearages.
A true and correct copy of said Assumption Agreement and Addendum
is attached hereto, marked Exhibit "E" and made a part hereof by
reference thereto.
11. The said Defendants did fail to tender the monthly
payment due on April I, 1996, and did thereafter fail to make the
3
regular payments due through December 1, 1996, although a payment
was made on April 22, 1996, which was credited to the March, 1996
payment.
12. As so provided in the Adjustable Rate Note, all of the
said debt is now due and payable as demanded by Plaintiff, Great
Valley Savings Bank.
13. Defendants, Bernard C. Wilder, Sr., and Paula J. Wilder,
are therefore in default of said obligation to Great Valley Savings
Bank in the principal amount of $46,772 .12, accrued interest
through December 23, 1996, of $2,794.42, a negative escrow account
as provided in the loan instruments of $130.74, and late charges
and collection expense of $146.72, for a total due as of December
23, 1996, of $49,844.00. In addition, after that date, interest
accrues at a per diem figure of $9.42 per day.
14. Plaintiff has demanded payment of the aforesaid
obligation by Defendants, but Defendants have failed and/or refused
to pay said sum or any further portions thereof.
15. Pursuant to Act No.6, Fulton Bank, Servicing Agent for
Plaintiff, Great Valley Savings Bank, did give to said Defendants
Notice of Intention to Foreclose Mortgage pursuant to legal action
upon the Adjustable Rate Note as required by law. A true and
correct copy of said Notices dated August 16, 1996, are attached
hereto, collectively marked Exhibit "F" and made a part hereof by
reference thereto.
4
16. As provided in the loan documents, a reasonable
attorney's fee of $1,500.00 is also demanded.
WHEREFORE, Plaintiff Great Valley Savings Bank, Successor in
Interest to Central Pennsylvania Savings Association, demands
judgment against Defendants Bernard C. Wilder, Sr., and Paula J.
Wilder, in the amount of $51,344.00, plus accrued interest from
December 23, 1996, continuing collection costs, continuing escrow
payments and costs of suit.
Respectfully submitced,
CALDWELL\, & ~KEARNS
By: ,
Ja~es . Clippi ger, Esquire
Attorn y I.D. # 7159
Attorney for Plalntiff
Great Valley Savings Bank
3631 North Front Street
Harrisburg, PA 17110
(717) 232 -7661
<,
Dated: January _,'-.J, 1997
2053L
82243-1
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Exhibit A
GREAT VALLEY SAVINGS BANK, !i IN THE COURT OF COMMON PLEAS
Successor in Interest to !i CUMBERLAND COUNTY,
Central Pennsylvania Savings PENNSYLVANIA
Association, !i
Plaintiff
!i No. 97-529 CIVIL TERM
!i
V.
BERNARD C. WILDER, SR., AND !i
PAULA J. HILDER, !i
Defendants !i CIVIL ACTION - LAW
ANSWER
Bonard Carl Wilder, Defendant, and Paula J. Wilder, Defendant,
file their Answer, stating the following:
l. General Denial
Defendants generally deny the allegations in plaintiff's
complaint and state that each and every item of plaintiff's
complaint are not just or true.
2. Prayer
Defendants pray that Plaintiff take nothing and that
Defendants be granted all relief requested in this Answer.
Defendants pray for general relief.
Respectfully submitted,
'--
Bonard Carl
l35l4 Creek Springs
Houston, Texas 77083
Telephone: (28l) 495-1798
Facsimile: (7l3) 272-8955
A :Wilder. 2
Page 1 of 2
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GREAT VALLEY SAVINGS BANK,
Successor in Interest to
Central Pennsylvania Savings
Association,
Plaintiff
v.
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
Defendants
,~
~
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 97-529 CIVIL TERM
I
I CIVIL ACTION - LAW
I
I
I
I
I
.~
COMMONWEALTH OF PENNSYLVANIA:
AFFIDAVIT OF SERVICE
COUNTY OF DAUPHIN
ss
Personally appeared before me, a Notary Public in and for said
County and State, JAMES R. CLIPPINGER, ESQUIRE, who deposes and
says that on July 7, 1997, he mailed a true and correct copy of the
attached Notice of Default via United States, First Class mail,
postage prepaid, served upon Defendants, Paula J. Wilder, and
Bernard C. Wilder, Sr., at 9119 South Gessner Road, Suite 102,
Houston, Texas 77074. A copy of said notice is attached.
Sworn to and subscribed to
befOr'v.mej this 1 ~ day
of t" , 1997.
iACt, C. 1!"(lW
N(;Itary Public
84348-1
2053L
NOTARI.~l SEAL
TillY C. KOlUS, Notar)' Put!lc
Harrisburg, Oauphln Countt
My Commission expires Nov. 28, 2000
J~~'~~~-
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GREAT VALLEY SAVINGS BANK,
Successor in Interest to
Central Pennsylvania Savings
Association,
Plaintiff
v.
, IN THE COURT OF COMMON PLEAS
, CUMBERLAND COUNTY, PENNSYLVANIA
I
, NO. 97-529 CIVIL TERM
,
, CIVIL ACTION - LAW
I
,
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
Defendants
IMPORTANT NOTICE
TO: Defendants, Bernard C. Wilder, Sr., and
Paula J. Wilder.
DATE OF NOTICE: July 7, 1997
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. 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 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:
THOMAS E. CHEFFINS, COURT ADMINISTRATOR
One Courthouse Square, 4th Floor
Carlisle, PA 17013
(717) 240-6200
CALDWEL
& KEARNS,
t--
Esquire
Dated: July 7, 1997
84348-1
2053L
By:
James
Attorney'
3631 No Front Street
Harrisburg, PA 17110-1533
(717) 232-7661
Attorneys for Plaintiff
TO: Defendants, Bernard C. Wilder, Sr., and
Paula J. Wilder.
FECHA DE NOTICIA: July 7, 1997
NOTICTA IMPORTANT~
USTED NO HA COMPLIDO CON EL AVISO ANTERIOR PORQUE HA FALTADO
EN TOMAR MEDIDAS REQUERIDAS RESPECTQ A ESTE CASO. SI USED NO ACTUA
DENTRO DE DIEZ (10) DIAS DESDE LE FECHA DE ESTA NOTICIA, ES POSIBLE
QUE EN FALLO SERIA REGISTRADO CONTRA USTED SIN UNA AUOIENCIA Y
USTED PODRIA PERDER SU PROPIEDAD 0 OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. DEBE
LLEVAR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE
ABOGADO 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VAYA
o LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONnE USTED
PUEDE OBTENER LA AUYDA LEGAL.
THOMAs E. CHEFFINS, COURT ADMINISTRATOR
One Courthouse Square, 4th Floor
Carlisle, PA 17013
(717) 240-6200
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ALL THAT CERTAIN Unit, being Unit No.6 (the "Unit"), of willow
Crossing, A Condominium, located in South Middleton Township,
Cumberland County, Pennsylvania, which unit is designated in
the Declaration of Condominium of willow Crossing, A
Condominium (the "Declaration of Condominium") and Declaration
Plats and Plans as recorded in the Recorder I s Office of
Cumberland County in Miscellaneous Book 386, Page 889 and Plan
Book 61, Page 62 and First Amendment to Declaration of
Condominium for Willow Crossing, A Condominium (the First
Amendment to Declaration of Condominium) and Declaration Plats
and Plan as recorded in the Recorder of Deeds of Cumberland
County in Miscellaneous Book 388, Page 412 and Plan Book 61,
Page 97.
TOGETHER with an undivided 2.50% interest in Common Elements
as more particularly set forth in the aforesaid Declaration of
Condominium and Declaration Plats and Plans.
TOGETHER with the right to use the limited common elements
applicable to the Unit being conveyed herein, pursuant to the
Declaration of Condominium and Declaration Plats and Plans.
BEING known as 426 Dogwood Court.
SAID property bearing Cumberland County Tax Parcel No.40-22-
0485-070.
BEING the same premises which KENNETH E. WEST by deed dated
January 19, 1994, and recorded January 28, 1994, in and for
the Office of Recorder of Deeds of Cumberland County in Deed
Book T, Volume 36, Page 1022, granted and conveyed unto
BERNARD C. WILDER, SR., and PAULA J. WILDER, Defendants
herein.
EXHIBIT "A"
92301-1
205353
GREAT VALLEY SAVINGS BANK,
Successor in Interest to
Central Pennsylvania Savings
Association,
Plaintiff
v.
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
Defendants
, IN THE COURT OF COMMON PLEAS
, CUMBERLAND COUNTY, PENNSYLVANIA
t
t
t
I NO. 97-529 CIVIL TERM
t CIVIL ACTION - LAW
t
I
t IN MORTGAGE FORECLOSURE
t
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
TO: Bernard C. Wilder, Sr. and
Paula J. Wilder
9119 South Gessner Road, Suite 102
Houston, TX 77074, and also
13514 Creek Springs,
Houston, TX 77083-1832
Lien Creditors of Record as Identified on the
Accompanying Affidavit Pursuant to Rule 3129
PLEASE BE ADVISED that the sale of the parcel of real estate
with the improvements erected thereon known as Unit No.6, Willow
Crossing, known as 426 Dogwood Court, Carlisle, Cumberland County,
pennsyl vania 17013, which improved parcel of real estate was
conveyed to Defendants Bernard C. Wilder, Sr., and Paula J. Wilder,
by deed dated February 8, 1991, and thereafter conveyed February 8,
1991, unto Bernard C. Wilder, Sr., and Paula J. Wilder, will be
held on December 3, 1997, under the auspices of the Sheriff of
Cumberland County, Cumberland County Courthouse, One Courthouse
Square, Carlisle, Pennsylvania, at 10:00 a.m. A complete copy of
the further legal description of said real estate is attached
hereto as Exhibit "A",
The aforesaid sale is being held on the judgment of Great
Valley Savings Bank v. Bernard C, Wilder, Sr., and Paula J. Wilder,
and the United States of America indexed to No. 97-529 Civil Term,
in the Court of Common Pleas of Cumberland County, said judgment
being in the principal amount of $52,074.86, together with interest
in the amount of $2,041. 48, with additional accrued interest
thereafter at a per diem figure of $6.46 per day.
The aforesaid tract
thereon, is reputedly owned
Paula J. Wilder, solely.
Claims against the property must be filed with the Office of
the Sheriff before the above sale date. Claims to proceeds must be
made with the Office of the Sheriff before distribution.
of land, with improvements erected
by the said Bernard C. Wilder, Sr., and
Notice is further given to all parties in interest of said
claim that a schedule of proposed distribution will be filed by the
Sheriff of Cumberland County on or about January 2, 1998.
Distribution will be made in accordance with the said schedule
unless exceptions are filed thereto within ten (10) days
thereafter.
Attached hereto is a copy of the Writ of Execution. It has
been issued because there is a judgment against Defendants, Bernard
C. Wilder, Sr., and Paula J. Wilder. It will cause the property
above identified to be held or taken to pay the judgment.
Defendants Bernard C. Wilder, Sr., and Paula J. Wilder, may have
legal rights to prevent the property from being taken. A lawyer
can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
THOMAS E. CHEFFINS, COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriff's Sale and
the loss of your property. In order to exercise those rights
prompt action on your part is necessary. A lawyer may be able to
help you.
You may have the right to prevent or delay the Sheriff's Sale
by filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection you might have within twenty (20)
days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment
opened if you promptly file a petition with the Court alleging a
valid defense and a reasonable excuse for failing to file the
defense on time. If the judgment is opened, the Sheriff's Sale
Great Valley Savings Bank
vs
Bernard C. Wilder Sr, and Paula J. Wilder
In the Court of Common Pleas of
Cumberland County. Pennsylvania
Writ No. 97-529 Civil Term
Steve Whisler, Deputy Sherin: who being duly sworn according to law, says on October 2.
1997 at 8:47 o'clock A.M., E,D.S.T., he posted the property of Bernard C. Wilder Sr. and
Paula J. Wilder at 426 Dogwood Court, Carlisle, Cumberland County, Pennsylvania with copies
of Real Estate Writ, Notice, Poster and Description according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served
Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed the
within named defendant, to wit: Bernard C. Wilder Sr. a notice of the pendency of the action by
certified mail marked DELIVERY ONL Y TO ADDRESSEE, at his last known address 01'9110
Gessner Road Suite 102, Houston Texas 77074. This letter was mailed under the date of
September 29, 1997 and was returned to the Sheriff Omce marked RETURN REFUSED.
Letter is hereto attached unopened.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says tht he served Real
Estate Writ Notice Poster a nd description in the following manner. The Sheriff mailed the
within named defendant, to wit: Bernard COo Wilder Sr a notiee of the pendency of the action by
regular mail to his last known address at 9119 Gessner Road Suite 102, Houston Texas 77074,
This letter was mailed under the date of October 3, 1997 and was never returned to the SheriIT's
Omce.
R, Thomas Kline, Sheriff, who being duly sworn aceoriding to law, says that. he served Real
Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed the
within named defendant, to wit: Paula J. Wilder a notice of the pendency of the action by
certified mail marked DELIVERY ONLY TO ADDRESSEE. at her last known address 01'9119
Gessner Road, Suite 102. Houston, Texas 77074, This letter was mailed under the date of
September 29, 1997 and on October 2, 1997 and the return receipt card signed by Paula J,
Wilder, Return receipt card is hereto attached.
R. Thomas Kline, Sherin: who being duly sworn according to law, says that he served Real
Estate Writ, Notice Poster and Description in the following manner: The Sheriff mailed the
within named defendant, to wit: Paula J. Wilder a notice of the pendency of the action by regular
mail to her last known address at911 Gessner Road Suite 102 Houston, Texas 77074. This letter
was mailed under the date of October 3, 1997 and was never returned to the SheriIT's omce.
R. Thomas Kline. Sherin: who being duly sworn according to law, say that aner due and legal
notice had been given according to law, exposed the within deseribed premises at public venue or
out cry at Court House. Cumberland County, Pennsylvania on December 10, 1997 at 10:00
o'clock E.S.T., and sold the same for the sum 01'$ 1,00 to Attorney James Clippinger for Fulton
Bank. One Penn Square, Lancaster, Pennsylvania, its successor and assigns. It being the highest
bid and best price quoted lor the same. Fulton Bank its successors and assigns at One Penn
Square, Lancaster, Pennsylvania paid to sheriffR. Thomas Kline the sum 01'$ 700.27, it being
poundage etc. Sherin"s Costs listed below.
Sheritrs Costs::
Docketing
Poundage
30.00
13.73
GREAT VALLEY SAVINGS BANK,
Successor in Interest to
Central Pennsylvania Savings
Association,
Plaintiff
t IN THE COURT OF COMMON PLEAS
t CUMBERLAND COUNTY, PENNSYLVANIA
I
t
t
t NO. 97-529 CIVIL TERM
t CIVIL ACTION - LAW
t
v.
BERNARD C. WILDER, SR., and
PAULA J. WILDER,
Defendants
t IN MORTGAGE FORECLOSURE
I
t
AFFIDAVIT PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF DAUPHIN
SS
Great Valley Savings Bank, Successor in InteLest to Central
Pennsylvania Savings Association, Plaintiff in the above mortgage
foreclosure action, sets forth as of the date of the Praecipe for
the Writ of Execution was filed the following information
concerning one parcel of improved real estate located at Unit No.
6 of Willow Crossing, a condominium, known as 426 Dogwood Court,
South Middleton Township, Carlisle, Cumberland County, Pennsylvania
17013.
1. The real estate as above identified to be sold at
Sheriff's Sale is described in Exhibit "A" attached hereto.
2. The names of the owners or reputed owners are Bernard C.
Wilder, Sr., and Paula J. Wilder, whose last known addresses are
9119 South Gessner Road, Suite 102, Houston, Texas 77074; and 13514
Creek Springs, Houston, Texas 77083-1832.
The aforesaid tract
thereon, is reputedly owned
Paula J. Wilder, solely.
Claims against the property must be filed with the Office of
the Sheriff before the above sale date. Claims to proceeds must be
made with the Office of the Sheriff before distribution.
of land, with improvements erected
by the 3aid Bernard C. Wilder, Sr., and
Notice is further given to all parties in interest of said
claim that a schedule of proposed distribution will be filed by the
Sheriff of Cumberland County on or about January r, 1998.
Distribution will be made in accordance with the said schedule
unless exceptions are filed thereto within ten (10) days
thereafter.
Attached hereto is a copy of the Writ of Execution. It has
been issued because there is a judgment against Defendants, Bernard
C. Wilder, Sr., and Paula J. Wilder. It will cause the property
above identified to be held or taken to pay the judgment,
Defendants Bernard C. Wilder, Sr., and Paula J. Wilder, may have
legal rights to prevent the property from being taken. A lawyer
can advise you more specifically of these rights. If you wish to
exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
THOMAS E. CHEFFINS, COURT ADMINISTRATOR
ONE COURTHOUSE SQUARE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
You may have legal rights to prevent the Sheriff's Sale and
the loss of your property. In order to exercise those rights
prompt action on your part is necessary. A lawyer may be able to
help you.
You may have the right to prevent or delay the Sheriff's Sale
by filing, before the sale occurs, a petition to open or strike the
judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the
Court any defense or objection you might have within twenty (20)
days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment
opened if you promptly file a petition with the Court alleging a
valid defense and a reasonable excuse for failing to file the
defense on time, If the judgment is opened, the Sheriff's Sale
NOV.
OCT.
OCT.
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t;l)mplctt! t:fJ\'I!ra~l~ of Punnsylvama 's Third Largest
. " ! I and ~llJst Profitable ~larket
, ,
~ 61 I I CUMB020 OCT b NOV 1997 _
7, I
, CU:-lBERLA:iD CO SHERIFFS OFFICE
, 8' i
COURT HOUSE
I 9! I CARLISLE, PA 17013
, ,
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All ,\llvertl,Hn~ rece,\'ed ;ubJect to appro,'al by Publi;her.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No 587, Anorovod Mav 18 1929
Commonwealth of Penneylvanla, County of Dauphin) II
FrankJ. Epler being duly sworn according to low, deposes and says:
That he Is the Controller 01 THE PATRIOT.NEWS CO., a corporetlon orgenlzed and existing under the laws of the
Commonweelth 01 Pennsylvania, with Its principal office snd place of business at 612 to 616 Market Street, In the
City 01 Harrisburg, County 01 Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT.NEWS end THE
SUNDAY PATRIOT.NEWS newspapers 01 generel circulation, printed and published et 612 to 616 Merket Street, In
the City, County and Stata aforesaid; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS ware established
March 4th, 1854, and September 16th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which Is securely ettached hereto Is exactly ae printed end published In
their regulsr dally and/or Sunday and Metro editlonslissues which appeared on the 21st and 28th day(s) of October
and the 4th day of November 1997. That neither he nor said Company Is Interested In the subject matter of said
printed notice or advertising, and that 011 of tha allegations of this statement as to the time, place and character 01
publication are lrue; and
That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this
statement on behalf of The Patrlot.News Co. aforesaid by virtue and pursuant to a rasolutlon unanimously passed and
adopted severally by the stockholders and board of directors 01 the ssld Company and subsequently duly racorded In
the office for the Recording of Deeds in and for sold County of Dauphin In Mlscallaneous Book "M",
Volume 14, Page 317. _ ,. - :L.....~.4 ?;(:
Cs~or~ ::~~eier;e~~~~~~4th -;a~-~~~~;mtllr-~;;;- A.D.
NoI",,~1 ~",al p...ll >;/0/ :I.~/ /7/7 ,,~/C
Tefry l. Ru..sen. Nota 1.1"- ,., './ . l'~_~<"
H":'.~ ~:~r.;nJun. 6,1990 NARY PUBLIC
hlyCo~ .. sslon expIres June 6. 1998
/oIeIltlIII,noo......--
CUMBERLAND COUNTY SHERIFFS OFFICE
roJRTHOUSE
CARLISLE, PA. 17013
PUBLICATION
COPY
SALE #34
Statement of .\dvertlslng Cost$
To THE PATRIOT.NEWS CO., Dr,
For publishing the notice or publication attached hereto
on the above stated dates $
Probating same (1) Notary Fee(s) $
Total $
195,30
1,00
196,30
Publisher'S Receipt for Advertising Cost
THE PATRIOT.NEWS CO., publisher of THE PATRIOT.NEWS end THE SUNDAY PATRIOT.NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notico and publication costs and cortlffos that the sarno have
been duly paid.
THE PATRIOT.NEWS CO.
By....,..........,.....,...........,..........,.........,........,....