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NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
>>ENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO:
MYERL E. SEIBERT, JR.
225 PINE GROVE ROAD
Gardners, PA 17324
PATRICIA ANN SEIBERT
418 FIRST STREET
CARLISLE, PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE ::hat by virtue of the above Writ of Execution
issued out of the Court of Common Pleas of Cumberland County,
Pennsylvania and to the Sheriff of Cumberland County, directed,
there will be exposed to Public Sale in Cumberland County
Courthouse, Carlisle, PAon June 3,1998 at 10:00
A, M., the following described real estate, of which Myerl E,
Seibert, Jr. and patricia Ann Seibert are owners or reputed owners:
Dickinson Twp, Cumberland Cty, PA. "Plan of Lots at Toland. PBV 3,
Pg, 68. Lot #15, HET a dwg, k/a 225 Pine Grove Rd., Gardners, PA
17324. Parcel No, 08-38-2172-015.
The said Writ of Execution has issued on a judgment in the
mortgage f~reclosure action of ContiMortgage Corporation, et al.
ve. Myerl E. Seibert, Jr, and patricia Ann Seibert at No.: 1997-
04848 P in the amollnt of $65,529.56.
Claims against property must be filed at the Office of th.
Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff
before the sale date,
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thlrty (301 days from sale date,
Except Lonn to DLnt~Lbution O~ a Petition to Set Aside the Sale
-
must be filed with the Office of the Sheriff no later than ten (10)
days from the date when Schedule of Distribution is filed in the
Off.ice of the Sheriff.
Attached hereto is a copy of the Writ of Execution, It has
been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may
have legal rights to prevent your 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 NOTICR 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 OF1l'ICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL ADVICE.
CUMBERLAND LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR - 3RD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 697-031"
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 p~rt 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 in 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'lI Sale
would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if
the Sheriff has not made a v~lid return of service of the Complaint
and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise
this right, you would have to file a petition to strike the
judgment.
You may also have the right to petition the Court to stay or
delay the execution and the Sheriff's Sale if you can show a defect
in the Writ of Execution or service or demonstrate any other legal
or equitable rlght,
5. Name and address of every other person who has any record
lien on the property:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None.
6. 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:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None.
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the s~le:
Tax Collector of
Dickinson Twp.
Address (Please indicate if this
cannot be reasonably ascertained)
1044 Pine Road
Carlisle, PA 17013
Name
Commonwealth of PA -DPW P.O. Box 8016
Harrisburg, PA 17105
PA Inheritance Tax Dept. Bureau of Compliance
Dept. 11280946
Harrisburg, PA 17128-0946
Attn: Susan Dolack
Tenant/Occupant 225 Pine Grove Road
Gardners. PA 17324
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.
December 17. 1997
Date
/
Lo P.
Attorney
v..w:r
Vitt . Esquir.e--
for Plaintiff
SWORN TO and subscribed
before me this 17th day
of /;c.emb:Jn 1997 vi.. /"
LeX tv II /.-~ I d?:0--~
Notary i?ubi. ic '
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1147(6), Plaintiff demands Judgment for the amount due of Sixty Four Thousand Three
' .
Hundred Seven and 10/100 Dollars ($64,307.10) with Interest and costs.
Respectfully submilled,
I.
LOUIS P. VITTI & ASSOC., P.C.
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'BY , 1,lit1 I t.;..V
Louis Fy. vHtI, Esquire
(1l0~~Y for Plaintiff
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IN THE COUR'I' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONTIMORTGAGE CORPORATION, As~ignee of
AMERICAN MORTGAGE REDUCTION, INC.,
Plaintiff,
VIS.
No., 1997-04848P
MYERL E. SEIBERT, JR. and
PATRICIA ANN SEIBERT, his wife,
Defendants.
IMPORTANT NOTICE
TO: PATRICIA ANN SEIBERT
418 FIRST STREET
CARLISLE, PA 17013
Date of Notice: November 19, 1997
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 YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 30 TO OR TELEPHONE THE
FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP: CUMBERLAND LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR - 3RD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, fA 17013
TELIIPHONE: (717) 697 - 0317
"
LOU€. V [TTI,.& ..l.\.SSO P . C.
BY: ;4, /./ .~ ...
Louis P. va t , Esqui e}-':,:
Attorney for plaintiff
916 Fifth Avenue
Pittsburgh. PA L5219
.. THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND AJIIY
INfORMATION OBTAINED WILL BE USED FOR THAT PURPOSE...
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, ss:
COUNTY OF CUMBERLAND
BEFORE me, the undersigned authority, personally appeared
LOllis P. Vitti, Esquire, who, being duly sworn according to law,
deposes and says that he is advised and believes that DEFENDANT(S)
is/are not presently in the active military service of the United
States of America and not members of the Army of the United States,
United States Navy, the Marine Corps, or the Coast Guard, and not
officers of the Public Health Service detailed by proper authority
for duty with the Army or Navy; nor engaged in any active military
service or duty with any military or naval units covered by the
Soldiers and Sailors Civil Relief Act of 1940 and designated
therein as military service, and to the best of this affiant I s
knowledge is/are not enlisted in military service covered by said
act, and that the averments herein set forth, insofar as they are
within his knowledge, are correct, and true; and insofar as they
are based on information received from others, are true and correct
as he verily believes.
This Affidavit is made under the provisions of the Soldiers
and Sailors Civil Relief Act of 1940.
---r--'~~-~~~~~_________
LOU~~~tti, Esquire
SWORN to And subscribed
1
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MUllllJlil V'~lln..ylv<l lid I~ lid"uLI.II '01 '\liJI~U~
of De,Cembe,r, 1997';>/. {"J
IlJC'lt-- IJJ ~( jo 2!.~.::-
Notary Publi.c ,/1
before me this 17th day
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must be filed with the Office of the Sheriff no later than ten (10)
days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
Attached hereto is a copy of the Writ of Execution. It has
been issued because there is a judgment against you. It may cause
your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A
lawyer can advise you more speci f ically of these rights. I f 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 APFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL ADVICE,
CUMBERLAND LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR - 3RD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 697-0317
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 in you promptly file a petition with the Court allegi.ng a
valid defense artd a reasonable excuse for failing to file the
defense on time. If the judgment is opened, the Sheriff's Sale
would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if
the Sheriff has not made a valid return of service of the Complaint
and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise
this right, you would have to file a petition to strike the
judgment.
You may also have the right to petition the Court to stay or
delay the execut ion and the Sherif f' s Sale if you can show a defect
in the Writ of Execution or service or demonstrate any other legal
or equitable right,
IN THE_ ....()~I:_(~I':-'::OMr-!:)~U'!:lj\:; ,'Ili ('1 J~Ull:H[,\t-;1J ,', )1j~r~'{!_,_!,ENN~;YI.vAN IA
c r..V1(1)[\{ I S ~N
p.~~~~l.I;'~,!~_ WI~Y.r.!)F _1::<I:!:t1'l'[()~
vs.
MYERL E. SEIBERT, JR. and
PATRICIA ANN SEIBERT, his wife
Confessed Judgment
( X) other
'lle No. 1997-04848
AtnJunt Due E.8,24B,eg I..~, t~9. 5~ ""-
Interest 6/4/98-12/9/98 3,0~3.22
Atty's Ccmn
Costs
Capt ion:
mm'IOORTGAGE CORPORATION, As signee
of AMERICAN ~RTGAGE REDUCIlON, INC,
ro THE PRCmiO~ARY OF THE SAW COURT:
The wxIersigned hereby certifies that the below does not anSB out of 11 retail
installrrent sale, contract, or account based on a confession of Judgnent, but if it does,
it is based on the appropriate or; ginal proceedJ.ng filed pursuant to Act 7 of 1966 as
arrended: and for real property pursuant to Act 6 of 1974 as arrended.
Issue writ of execution 1n the above IT'dtter to the Sheriff of Cumberland
County, for debt., iptere!l.,\: and c~t=\ ~'C the p~1l0w1ng descnbed property of the
defendant(2.1 D1cklnsonlwp, G.un r a ty, . "Plan of lots at Toland, PBV 3,
pg. 68. lot #15. BET a dwg, k/a/ 225 Pine Grove Road, Gardners, PA 17324
Parcel No, 08-38-2172-015,
PRAEX:IPE fOR ATI'ADt1ENl' EXm11'ICfi
Issue writ of attacl'vrent to the Shenft of County, for debt,
interest and costs, as above, dJ.rectlng dttachment agalnst the above-named garnishee(5) for
the followiJlg property (if real estate, supply SlX coples of the description: supply four
copies of lengthy personalty llStl
and all other property of the defendant( s J Ln the possession, custody or control of the
sald garn1shee(s).
__( lncllcate) Index tl'us wrlt agalnsr. the garmshee(s} as a 115 pendens against
re41 estate of the defendant(sl descnbed Ln the attached ~b . G- ~ ',",
DATE: ';) ',JG. - I 1'6 SLqndr.llre:__, ~A _ _ UJ#' 'I'il
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NOTICB O. SHBRI..'S SALB O. RBAL BSTATB
PURSUANT TO
RULB or CIVIL PROCBDURB 3129,1
TO, MYERL E. SEIBERT, JR,
225 PINE GROVE ROAD
GARDNERS, PA 17324
PATRICIA ANN SEIBERT
418 FIRST STREET
CARLSISLE, PA 17013
AND, ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued
out of the Court of Common Pleas of Allegheny County, Pennsylvania and
to the Sheriff of Allegheny County, directed, there will be exposed to
Public Sale in
GOLD ROOM
ROOM 410 COURTHOUSB
PITTSBURGH, PBNNSYLVANIA 15219
on December 9, 1998 at 10,00 A.M. the following described real estate,
of which Myerl E.Seibert, Jr. and patricia Ann Seibert are owners or
reputed owners,
Dickinson Twp, Cumberland Cty, PA .
pg. 68. Lot #15. HET a dwg. k/a
17324. Parcel No. 08-38-2172-015.
"plan of Lots at Toland. PBV 3,
225 pine Grove Rd., Gardners, PA
The said Writ of Execution has issued on a judgment in the
mortgage foreclosure action of ContiMortgage Corporation, it al. vs.
Myerl E. Seibert, Jr. and patricia Ann Seibert at No, 1997-04848 in
the amount of $68,240.00.
Claims against property must be filed at the Office of the Sheriff
before above sale date,
Claims to proceeds must be made with the Office of the Sheriff
before the sale date.
Schedule of Distribution will be filed with the Office of the
Sheriff no later than thirty (30) days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale
must be filed with the Office of the Sh~riff no later than ten (10)
days from the date when Schedule of Distribution is filed in the Office
of the Sheriff,
Attached hereto is a copy of the Writ of Execution, It has been issued
because there is a judgment against you, It may cause your property to
be held or taken to pay the judgment, You may have legal rights to
prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights you
ml.lst act promptly.
YOU SHOULD TAKB THIS NOTICB AND THB WRIT Of BXBCUTION TO YOUR
LAWYER AT ONCB. IF YOU DO NOT HAVE A LAWYBR OR CANNOT AfFORD ONB, GO
TO OR TBLBPHONB THB OFFICE SET FORTH BELO~1 TO FIND OUT WHBRB YOU CAN
GBT LBGAL ADVICB,
LAWYER REF1RRAL SBRVICE
THB ALLBGHBNY COUNTY BAR ASSOCIATION
920 CITY-COUNTY BUILDING
PITTSBURGH, PENNSYLVANIA 15219
TBLBPHONB. (412) 261-0518
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 in 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 would ordinarily be delayed
pending a trial of the issue of whether the ~laintiff has a valid claim
to foreclose the Mortgage.
You may also have l'.he right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events. To exercise this right, you
would have to file a petition to strike the judgment.
You may also have the right to petition the Court to stay or delay
the execution and the Sheriff's Sale if you can show a defect in the
Writ of Execution or service or demonstrate any other legal or
equitable right,
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Attached hereto is a copy of the Writ of Execution. It has been issued
because there is a judgment against you. It may cause your propert'l to
be held or taken to pay the judgment. You may ha'le legal rights te'
pre'lent your property from being taken. A lawyer can advise :leu ,"ere
specifically of these rights, If you wish to exercise your rights :leu
ml,lst act promptljl'.
YOU SHOULD TA~E 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 TELl PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL ADVICE.
LAWYER REFERRAL SERVICE
THE ALLEGHENY COUNTY BAR ASSOCIATION
920 CITY-COUNTY BUILDING
PITTSBURGH, PENNSYLVANIA 15219
TELEPHONF.. (412) 261-0518
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 b~ 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 cr 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 t'lIenty ,20 days
af ter service of the Complaint for Mortgage Foreclosure and Neti( e : c
Defend, you may have the right to have the judgment opened in yr,u
promptly file a petition with the Court alleging a valid defense and d
reasonable excuse for failing to file the defense on time, If the
judgment is opened, the Sheriff's Sale would ordinarily be delayed
pending a trial of the issue of whether the plaintiff has a valid ~laim
to foreclose the Mortgage.
'lou may also have the right to have the judgment ~tricken if :::e
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty '20. days
after service or in certain other events. To exercise this right, you
would have to file a petition to strike the judgment.
'lou may also have the right to petition the Court to stay or delay
the execution and the Sheriff's Sale if you can show a defect in the
Writ of Execution or service or demonstrate any other legal or
ea.uitable right.
nill-~I8.nm:AnhQf. . AlLlNO..
MAV I. USIO flOA DQMur", AND IN TlRNA T10NAli MAIL, 0015 Nor
PfIlOVIDI liaR INSURANt. POS TMAS TiM
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SEIBERT
NOV 23 1998;
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONTlMORTGAGE CORPORATION, Assignee:
of AMERICAN MORTGAGE REDUCTION, INC.,:
Plaintiff,
vs,
No, 1997-04648
MYERL E, SEIBERT, JR, and PATRICIA ANN
SEIBERT, his wlfl!,
Defendants.
ORDER OF COURT
AND NOW, lo-wlt, this ~ 3 M..day of --=z::t <l\I'(.,..J.,..v
, 1998, it Is hereby
Ordered, Adjudged and Decreed that substantial compliance has been accomplished under Rules
400 and 403 el. seq" and 3129,1 and 3129,2, el. seq., with respect to the Defendants and all
lienholders, Plaintiff shall direct a copy of this Order upon Defendants and upon all lienholders by
regular mail with less than a thirty (30) day notice, Sale shall not be advertised again and the
Sheriff is directed to sell the within properly at the regularly scheduled sale or at any date to which
it is continued.
BY THE COURT:
I~I &"...&<d. t. ~ t.
'.1
Conti mortgage Corporation, Assignee
of American Reduction. Inc.
-vs-
Meryl E, Seibert, Jr. and Patricia Ann
Seibert
In the Court of Common Pleas of
Cumberland Couonty. Pennsylvania
No 97.4848 Civil Term
Kathy J. Clarke. Deputy Sherin' who being duly sworn according to law, says on October 8,
1998 at 6:55 o'clock P,M, E,[), S, T.. she posted a copy of Real Estatc Writ Notice Poster and
Description on the pl'llperty located at 225 Pine Grove Road, Gardners. Cumberland County,
Pennsylvania according to law,
R, Thomas Kline, Sherifl',who being duly sworn according to law. says he made diligent
search and inquiry for the within named dclendantto wit: Myerl E, Seibert. but was unable to
locate him in his balilwick, He therefore returns Real Estate Writ Notice Poster and Description
NOT FOUND as hl defendant Meryl E, Seibert,
Michael E. Bal'rick, Deputy Sheriff, who being duly sworn according to law, says on October
8, 1998 at 4:00 o'clock P,M, E,[).S:r. he served a true copy of Real Estate Writ Notice Poster
and Description, in the above entitled action upon one ofthc within named defendants to wit:
Patricia Ann Seibert. by handing to Patricia Siebert at 418 First Street. Carlisle, Cumberland
County. Pennsylvania. its contents and at the same time handing to her personally the said true
and attested copies of the same,
R, Thomas Kline, Sheriff: who being duly sworn according to law says he served the within
Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a
notice of the pendency of the action by regular mail to one of the within named defendants to
wit: Patricia Ann Siebert at her last known address 418 First Street, Carlisle Pennsylvania, This
letter was mailed under the date ofOctobcl' 27, 1998 and never returned to the Sheriffs Office,
R, Thomas Kline, Sheriff: who being duly sworn according to law. says he served the within
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 thc within named defendants to wit: Myerl
E,Seibert by Certified Mail Return Receipt Requested. Restricted Delivery. Deliver to Addressee
Only to his last known address 406 Lincoln Street. Carlisle. Pennsylvania, This letter was mailed
under the date of November 4, 1998, and returned to the Sheriff s Office on November 23, 1998
with reason checked UNCLAIMED.
R, Thomas Kline, Sheriff who being duly sworn according to law, says he served the within
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: Meryl Seibert
by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to
his last known address 225 Pine Grovc Road. Gardners, Pa, This letter was mailed under the date
of November 4,1998 and never returned to the Sheriffs Oflice.
R, Thomas Kline. Sheriff: who being duly sworn according to law. says he served the within
Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a
n(":~~ vfthe pendency of the action to one of the within named defendants Meryl Seibert by
'egular mail to his last known address 225 Pine Grove Road, Oardners. Pennsylvania. This letter
wa.s mailed under the date of November 4. 1998 and never returned 10 the Sheriffs Office.
R, Thomas Kline. Sheriff. who being duly sworn according to law, says aller due and ICIla!
notice had been given according to law. exposed the within described premises at public venue
Attached hereto is a copy of the Writ of Execution. It has been issued
because there is a judgment against you. It may cause your property to
be held or taken to pay the judgment. You may have legal rights to
prevent your 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. IV YOU DO NOT HAVE A LAWYER OR CANNOT AVfORD ONE. GO
TO OR TELEPHONE THE OfFICE SET fORTH BELOW TO VIND OUT WHERE YOU CAN
GEf LEGAL ADVICE.
LAWYER REVERRAL SERVICE
THE AL~EGHENY COUNTY BAR ASSOCIATION
920 CITY-COUNTY BUILDING
PITTSBURGH, PENNSYLVANIA 15219
TELEPHONE, (412) 261.,0518
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 che right to have the judgment opened in 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 would ordinarily be delayed
pending a trial of the issue of whether the Plaintiff has a valid claim
to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the
Sheriff has not made a valid return of service of the Complaint and
Notice to Defend or if the judgment was entered before twenty 120, days
after service or in certain other events. To exercise this right, you
would have to file a petition to strike the ,judgment.
You may also have the right to petition ~he Court to stay or delay
the execution and the Sheriff's Sale if you can show a defect in the
Writ of Execution or service or demonstrate any other legal or
equitable right.