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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 THIS
COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN
APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES AND 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 MAYBE 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 SHOULD NOT HA VE 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 LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
3RD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 697-0317
.
COMPLAINT IN MORTGAGE FORECLOSURE
AND NOW, comes the Plaintiff by its attorneys, Louis p, Vitti and Associales, p,c.
and Louis p, Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure
Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the
following:
1, The Plaintiff is a corporation duly authorized to conduct business wilhin
the laws of the Commonwealth of Pennsylvania, having a principal place of business located
at Three Park Plaza, 16th Floor, Irvine, CA 92714,
2, The Defendant(s) is/are individuals with a last known mailing address of
928 Goodyear Road, Gardners PA 17]24, The property address is 928 Goodyear Road,
Gardners, PA 17324 and is the subject of this action.
], On the 11 th day of March, 1996, in consideration of a loan of Fifty Seven
Thousand Eight Hundred and 00/1 00 ($57,800,00) Dollars made by Colonial National Bank,
USA, a CA corporation, to Defendant(s), the said Defendant(s) executed and delivered to
Colonial National Bank, USA, a CA corpora~ion, a "Note" secured by a Mortgage with the
Defendant(s) as mortgagor(s) and Colonial National Bank, USA, as mortgagee, which
mortgage was recorded on the 18th day of March, 1996, in the Office of the Recorder of
Deeds of Cumberland County, in Mortgage Book Volume 1307, page 1133, The . said
,
mortgage is incorporated herein by reference thereto as though the same were set forth fully
at length,
4, The premises secured by the mortgage are:
ALL fRAT 0'.'1'.\%)1 t.nGe at laNl wlth t.he bll1141nII and .
i.'~OY.ftant.1 thl~eon areat.ad lieuat.. p~i.a~11Y n Saut.h Middl.t.on
Townlhip and ~art.ly 1n Dicklnaan '1'ownahip, c~r1&n4 COunt.y,
.Innaylvania, DoYndI4 .nd dla~r~d in acaordanae wit.h a alrtaln
prop.rey survey tor the Iva K. It.arn.r J.t.at.. Dy 30bn a.
Willi..l, prot...lanal Land surv.yor, dat..d S.~te.ber 5, 19'7,
.. tollew.:
..C%WV%NG at. a ~ailro,d apika (aet.) in tha aanter of the ~i&h
Road (L.K. 21030) .t cornar at land. nav or tormerly at aary .,
ae.., t.hanaa by t.he alnterlinl at the a,id Urlan aoad, South
7' dlgTe.. 30 .1n~te' 10 ..~nd. i..t 1'5.70 t.et to e P.X. Hall
r.placed with a railroad .pike at the intar.ection of the
canterlin.. at the .Ild ~l.h Roed end Torvey Raid (1'-1'4)1
than~. by thl a.nt.rline at,thl eald'Torw.y Ra.d, south
1a dlgra.. 52 .inut..a 34 ..aon4a W..t. to.45 t.at. to a point at
Gornlr ot laNl' now or toraerly ct v.rd.l1a s. Cavi., thenc. by
lana. now or toraar1y at Verdell. I. Davi. and't.hrough an iron
pin ..t. 20.00 teet tram the eenterlin. at ..1d Torvay Ro.d,
Worth II 4Iqr.e. 4' minute. 10 ee~and. W..t 152.65 t.et to ·
pi,., th.nce Dy 1.n4a now or tor..rly at Oery .~ ...., Horth 14
d~rae5 23 minut... l' ..cand. BA.t 1aa.&4 t..t~ta a r.ilroAd
.pik. (.ac), the 'lace ot .IGINYING.
COHTllNING 1.,124 .quar. t..~.
5, Subsequent thereto, Colonial National Bank USA, CA corporation, assigned
to the Plaintiff, Bankers Trust Company of California, N,A" the said mortgage, that
assignment being recorded in the Office of the Recorder of Deeds of Cumberland County
and the said assignment is incorporated herein by reference,
6, Said mortgage provides. inter alia:
"that when as soon as the principal debt secured shall become due and
payable, or in case default shall be made in the payment of any installment
of principal and interest, or any monthly payment, keeping and performlUlce
2
by the mortgagor of any of the terms, conditions or covenants of Ihe mortgage
or note, it shall be lawful for mortgagee to bring an Action of Mortgage
Foreclosure, or other proceedings upon the mortgage, of principal debl,
interest and all other recoverable sums, together with attorney's fees,"
7, Since June 15, 1997, the mortgage has been in default by reason, inter alia,
of the failure of the mortgagor(s) to make payments provided for in the said mortgage
(including principal and interesll and, under the terms of the mortgage, the entire principal
sum is due and payable,
8, In accordance with the appropriate Pennsylvania Acts of Assembly and the
Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the
mortgagees intention to foreclose, The appropriate time period has elapsed since the Notice
of Intention to Foreclose has been served upon the mortgagor(s).
9, The amount due on said mortgage is itemized on the attached schedule,
10, Plaintiff does hereby release the personal representative, heir and/or
devisee of the mortgagor(s) from liability for the debt secured by the mortgage,
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number
1147(6), Plaintiff demands judgment for the amount due of Sixty Four Thousand Seven
Hundred Thirty Seven and 04/100 Dollars ($64,737,04) with interest and costs,
Respectfully submitted..
LOUIS p, VITTI & ASSOC., p,c.
I (r-') 1
BY .~(j.J)o(..//V----
Louis P. Vitti, Esquire
,
Atlorn~y for Plaintiff
/
3
VERIFICATION
AND NOW louis p, Vitti verifies that the slalements made in Ihis Complaint
are true and correct 10 the best of his knowledge, information and belief, I understand that
false statemenls herein are made subjecl to the pendlties of 18 Pa,C.S, 4904, relating to
unsworn falsification to authorities,
By virtue of the factlhat the Plaintiff is outside the jurisdiction of the court and
the verification cannot be obtained within the time allowed for the filing of this pleading,
the pleading is submitted by counsel having sufficient knowledge, informalion and belief
based upon the information provided him by the Plaintiff,
I
/ /--- I _---
'-~ ( J Jjf/-'
" , M'" ,
louis p, Vitti
(
Dated: October 22, 1997
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NOTICE OF SHERIFF'S SALE or RIAL ISTATE PURSUANT TO
PENNSYLVANIA RULB or CIVIL PROCEDURE 3129.1
TO, TERRY E. WOLF
LUCY W. WOLF
928 GOODYEAR ROAD
GARDNERS, PA 17324
AND, ALL LIEN HOLDERS
TAKE NOTICE that 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 the Sheriff's Office of Cumberland County, Cumberland
County Courthouse, Carlisle, PA on September 2, 1998 at 10100 A.M., the
following described real estate, of which Terry E, Wolf and Lucy W.
Wolf are owners or reputed owners,
S, Middleton Twp., Cumberland Cty,. PA, HET at a dwg. k/a 928 Goodyear
Rd,. Gardners, PA 17324. Parcel 40-43-2759-005,
The said Writ of Execution has issued on a judgment in the
mortgage foreclosure action of Bankers Trust Company of California,
N.A" et al. vs, Terry E, Wolf and Lucy W. Wolf at 928 Goodyear Road,
Gardners, PA 17324 in the amount of $66,667.09.
Claims against property must be filed at the Office of the Sheriff
before ahove 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 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 specifically of these rights, If you wish to exercise your
rights you must act promptly,
YOU SHOULD TAXB THIS NOTICB AND THB WRIT or BXECUTION TO YOUR
LAWYER AT ONCE. Ir YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO
TO OR TBLEPHONE THB OPFICE SET FORTH BBLOW TO rIND OUT WHERB YOU CAN
GBT LBGAL ADVICB.
CUMBERLAND LAWYER RBFBRRAL SBRVICE
COURT ADMINISTRATOR, 3RD PLOOR
CUMBBRLAND COUNTY COURTHOUSB
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 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 (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.
You may also have the right to have the Sheriff's Sale set aside
if the property is sold for a grossly inadequate price or if there are
defects in the Sheriff's Sale. To exercise this right, you should file
a petition with the Court after the sale and before the Sheriff has
delivered his Deed to the property. The Sheriff will deliver the Deed
if no petition to set aside the sale is filed within ten (lO) days from
the date when the Schedule of Distribution is filed in the Office of
the Sheriff.
(/j]J:;]vw-
Louis P. Vitti, Esquire
Attorney for Plaintiff
916 Fifth Ave.nue
pittsburgh, PA l52l9
(412) 2B1-l725
**THB DBBT COLLBCTOR IS ATTEMPTING TO COLLBCT A DBBT AND ANY
INVORMATION OBTAINED WILL BB USBD FOR THAT PURPOSB.**
,
LEGAL DESCRIPTION
ALL THA~ CZRTAIN ~aat ot land vith the buildl~qa and
i.p~ov.ftent. the~eon ereat.d .ituat. p~la.~11y in Soutb Mldd1.ton
Town.hip .nd p.rtly in Dickinson Townahip. Cu~rland County,
..nn.ylvania. bounda4 and dll~ribad in .caordan~. witb . clrt.in
P~op.rty survey 'or the Iva H. Starner latatl ~y 30hn R.
Willi.... Pro'e,aional Land survayar. dated Sa~t..be~ 5. 19.7.
a. 'allOW':
..GINNING .~ e ~.11re.d .pika (alt) in the cente~ of tnl urian
Road (L.R. 210101 at corner of landl nov or to~arly of aa~y R.
el.m/ thene. by the c.nta~lina of tn. .aid u~i.h Roa4. South
7. de9Tee. 3Q .inut.. 10 ..condl Ell' 155.70 'e.t to . P.X. Hail
r.plac.d with I r.ilro.d Ipikl at the int.r.lctLon ot the
cent.rline. at the ..id Uri.h Roed .nd TOrw.y Ro.d (T-534)/ '
chane. by the c.nterlin. ot,the ..14 'Torw.y Ro.d. South
1. d.gr.e. 52 ainut.. 34 e.aan41 W..t '0.45 ta.~ to . point at
corn.r at landl now or tora.rly at V~rd.ll. s. DavL.; th.ne. by
lands nov Or taraarly at V.~d.lla I. Davi8 an4'thrauqh an iran
pin ..t 20.00 t~t tram tn. cant.rlLn. at ..14 Terwey Road,
No~ .1 4egT'" 4' .!nut.. )0 ..conds W8St 15~.15 t..t to .
pLp., th.n~. by land. noy or tor..rlY ot G.r~ I. ..... Horth 14
dair..s 2~ .in~t.. 18 ..cen4. Zalt 13~.'4 t..t~co a railrold
.pika (..t), the 'llca ot IIOIHVING.
CONTAINING 11.134 .quar' tlat.
HAVING erected thereon a dwelling known as 928
PA 17324.
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Goodyear
Road. Gardners.
BEING the same premises which Wilmer H, Wolf, Jr, and Judy L, Wolf, his
wife. by their Deed dated August 5, 1991 and recorded in the Cumberland
County Recorder of Deeds Office on August 6, 1991 in DBV G35, page 206.
granted and conveyed unto Terry E. Wolf and Lucy W, Wolf, his wife,
PARCEL 40-43-2759-005.
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Rob~rt P Ziegler
I, __u__n__ _ ____ u ___ _ _ __ __ _ u _n _un ____ u_____n__ _h_________n n n_____ __ __ Recorder 01
Deed, in and lor .aid Counly IIIld SlalC do hereby certily lhallhe Sherilr. Deed in which u_n__u_n____
Bankers Trust Co of CA '
u___ __n_Uu___n__u__. _ ,__ _n_____hu_U___ h_________u___uu___u ----------- II Ihe gran:ee
the ,ame haying been wid 10 ",id grantee on Ihe uu_~1UI.____u___u.______UU____h________u_ day of
_u~~_I'.~~!"_b_"~______uu______n_____ _u A, 0" 19_ ?JL..., under and by yirtue or a wril_n____n_n__
_______~~~_c_~~~~_~_____ __ _____ _ __ __.___ __ u ___ __ iuued on lhe _ _ _. ____ __u_~!'5__ __ _n___ _unh____
April 98
day 01 ______________uu____h __ A, D" 19u_. u, oulof lhe Court 01 COOlman Pleas of said County a, of
_________________<,;~yJ.1_______ ____uu_______ u h_h_n____ u____ n__ u__uu___ Tenn, 19_ __ 97
Number _______~2~_8___, at Ihe 'Uil or _ _______Il.'!'!~_e.r:! _!'!-_ct"n'?L 9_Ltl~"- _,!:~~_s_~~~n_ u________n____
____ un _______ m________ _n__ _ __ _ again'L _ _ __ u !~:_'L ~__~ _~Y_~~_!l_ _~~}L ___ u uun un ___ is
duly ",corded in Sherilf. Detd Book No. ____1_8_~__
~w-J
1009
Page uu___u_.._
IN TESTIMONY WHEREOF, I haYe he",unto
~
,et my hand aud .eal 01 said or/ice this ~u_n_ day
of.JZ._ __ ~I,...c______u 1- A,
-;. V-{J-2!!c~h- K- ---------
....... Cumberf1. Ceo"", Cat1IIII. "
... ~ EJPm till fitll....... JlA.2GllI
. -
Bankers Tr Co of California. N.A.
as Custodian and/or Trustee. Assignee
of Colonial National Bank, USA
-vs-
Terry E, And Lucy W, Wolf
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No, 97.5948 Civil Term
Michael E, Barrick, Deputy Sheriff, who being duly sworn according to law, says
on June 29,1998 at 3:03 o'clock P,M, E.D,S,T,. he posted a copy of real Estate Writ Notice
Poster and Description on the property of Terry E, And Lucy W, Wolf located at 928 Goodyear
Road, Gardners, Cumberland County, Pennsylvania, according to law,
Kristin D. Mertz, Deputy Sheriff, who being duly sworn according to law, says on May II,
1998 at 8: 19 P,M,E,D,S,T" she served a copy of Real Estate Writ Notice and Description upon
one of the within named defendants to wit: Terry E, Wolf, by making known unto Lucy W,
Wolf. wife at 928 Goodyear Road, Gardners, Cumberland County, Pennsylvania, its contents and
at the same time handing to her personally the said true and attested copies of the same,
Kristin D, Mertz, Deputy Sheriff, who being duly sworn according to law, says on May II,
1998 at8:19 P,M,E,D,S,T" she served a copy of Real Estate Writ Notice and Description, in the
above entitled action upon one of the within named defendants to wit: Lucy W, Wolf, by handing
to Lucy W, Wolfat 928 Goodyear Road, Gardners, 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 June 29,
1998 at 3:03 o'clock P,M,E,D,S,T" he served a true copy of Real Estate Poster, in the above
entitled action upon one of the within named defendants to wit: Terry E. Wolf, by handing to
Terry Wolf, at 928 Goodyear Road. Gardners, Cumberland County, Pennsylvania, its contents
and at the same time handing to him personally the said true and attested copies of the same,
Michael E, Barrick" Deputy Sheriff who being duly sworn according to law, say on June 29,
1998 at 3:03 o'clock P,M,E,D,S,T.I, he served a true copy of Real Estate Poster. in the above
entitled action upon one of the within named defendants to wit: Lucy W, Wolf, by handing to
Terry Wolf, husband at 928 Goodyear Road, Gardners, Cumberland County, Pennsylvania, its
contents and at the same time handing to him 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 above
Real Estate Writ Notice Poster and Description in the following manner: The sheriff mailed one
of the within named defendants, to wit: Terry E, Wolf a notice of the pendency of the action by
regular mail to his last known address 928 Goodyear Road, Gardners. Pennsylvania, This letter
was mailed under the date of June 30,1998 and never returned to the Sheriffs 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 one of the
within named defendants to wit: Lucy W. Wolfa notice of the pendency of the action by regular
mail to her last known address 928 Goodyear Road, Gacdners. Cumberland County,
Pennsylvania, This letter was mailed under the date of June 30, 1998 and never returned to the
Sherill's Office.
R, Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and
legal notice had been given according to law. exposed the within described premises at publie
,
venue or outcry at the: Court 1I0use:, Carlisle:, Cumberland County, Pe:nnsylvania on Se:pte:mber 2,
1998 at 10:00 A,M, E, D, S, T,. and sold the: same: lor the sum 01'$ (,00 to Attome:y Jill Hoove:r
for Bankers Tr Co of California, NA, as Custodian and/or Trustee:, Assignee: of Colonial National
Bank, USA, its succe:ssors and assigns, It being the: highest bid and the best price received for
the same Bankers Tr Co of California. NA, 3 Park Plaza, Treine, CA, being the: buyer in this
Execution paid SheriffR, Thomas Kline, the sum of$ 792.66. it being Sheriffs Costs,
Sheriffs Costs:
Docketing
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
Law Library
County
Mileage
Certified Mail
Levy
Sure harge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
Poundage
30.00
15,00
15,00
30,00
10,00
.sO
1.00
12,40
3,76
15,00
18,00
267,50
279,75
27,70
25,00
26,50
~
S 792,66 pd by Atty,
9-9-98
Sworn and Subscribed To Before Me
So answers:
,r~~-~~
R, Thomas Kline, Sheriff
This 5~ Day of (j), r.J".
1998, ~I' Q hl<I(J;. .,A~n~
rothonotary
By J1;thA .)lLt-
Real Estate Deputy
~
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NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE or CIVIL PROCEDURE 3129.1
TO: TERRY E, WOLF
LUCY W. WOLF
928 GOODYEAR ROAD
GARDNERS, PA 173J4
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued
out of the Court of Comn~n Pleas of Cumberland County, Pennsylvania and
to the Sheriff of Cumberland County, directed, there will be exposed to
Public Sale in the Sheriff's Office of Cumberland County, Cumberland
County Courthouse, Carlisle, PA on September 2, 1998 at 10.00 A.M., the
following described real estate, of which Terry E, Wolf and Lucy W,
Wolf are owners or reputed owners:
S, Middleton Twp" Cumberland Cty., PA. HET at a dwg. KIa 928 Goodyear
Rd" Gardners, PA 17324, Parcel 40-43-2759-005.
The said Writ of Execution has issued on a judgment in the
mortgage foreclosure action of Bankers Trust Company of Ca~ifornia,
N.A" et al, vs, Terry E, Wolf and Lucy W, Wolf at 928 Goodyear Road,
Gardners, PA 17324 in the amount of $66,667.09.
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) jays from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale
must be filed with the Office of the Sheriff no later than ten (lO)
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 must act promptly,
YOU SHOULD TAXB THIS NOTICE AND THE WRIT OJ' EXECUTION TO YOUR
LAWYER AT ONCB. Ill' YOU DO NOT HAVE A LAWYER OR CANNOT AJ'FORD on, GO
TO OR TELEPHONE THE OIl'FICE SET FORTH BELOW TO FIND OUT WHBRE YOU CAN
GET LEGAL ADVICE.
CUMBBRLAND 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 alleging a valid defense and a
reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriff's $ale 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 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.
You may also have the right to have the Sheriff's Sale set aside
if the property is sold for a grossly inadequate price or if there are
defects in the Sheriff's Sale. To exercise this right, you should file
a petition with the Court after the sale and before the Sheriff has
delivered his Deed to the property. The Sheriff will deliver the Deed
if no petition to set aside the sale is filed within ten (10) days from
the date when the Schedule of Distribution is filed in the Office of
the Sheriff.
L~~'
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
**THB DBBT COLLECTOR IS ATTBMPTING TO COLLBCT A DEBT AND ANY
INFORMATION OBTAINED WILL BB USBD FOR THAT PURPOSE.**
LEGAL DESCRIPTION
ALL THAT CZaTAIK traet ot land with tha buLldlnq. and
1.provaaant. tha~.on araotad .Ltuat. p~1.ari1Y in South Midd1.ton
To~.bip and pa~tly in Dickinson Township, cu~~land County,
p.ftI..ylvania, bounda4 and 4..cribad in acoor~nce with a cartaln
Proparty survay lor tha Iva M. Starnar Istata by John a.
willia.., prola..ional Land Surv.yor, datad S.ptamber 5, 1917,
a. lollow.:
..CIKNIHC at a ral1~o.d .pika Ca.C) in tha can tar at the ~iah
Road CL.R. 21010) at cornar ot land. nov or tora.~ly ot Ga~y a,
D...; thanea by tha eant.~lin. ot tha .aid uriah Road, South
7. dagT.a. 30 .!nute. 10 ._cond. Ea.t 1".70 lelt to . P.~. Hail
raplacad vLth a railroad .pLka at tha Lntar.actLon ot the
eantarlina. ot tha .aid UrLah ~oad a~d Torway Roa~ CT-"4)/ '
thence by the cant.rlina ot,th. aa1d Torway Road, South
1. dagra.a '2 .inute. 24 ..00n4& w..t '0.45 t.at to a point at
oprnar ot land. now or loraarly ot Vard.lla s. DavLa; th.nce by
landS naV o~ toraa~ly ot Va~4alla .. Davi. ano'throuqh an iron
pin ..t 20.00 t~t trom the cant.rlin. ot .ai4 Torway RoaO,
North II 4&gT... 4' .!nut.. fO .aconda w.st 152.IS t..t to a
p1p./ th.nc. by land. now or tor.arlY ot Gary a, e.a., Horth 14
4.qra.. 23 ainut.. 18 ._con4. Ea.~ 123.64 ta.t"to a railroad
.pik_ C..t), the 'lac. of IIGINNIKG. '
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i
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COHT1INIKG 1.,124 .quara t..t.
HAVING erected thereon a dwelling known as 928 Goodyear Road. Gardners,
PA l7324.
BEING the same premises which Wilmer H. Wolf, Jr. and Judy L, Wolf, his
wife, by their Deed dated August 5, 1991 and recorded in the Cumberland
County Recorder of Deeds Office on August 6, 1991 in DBV G35, page 206,
granted and conveyed unto Terry E. Wolf and Lucy W, Wolf, his wife.
PARCEL 40-43-2759-005.
25 Gateway Drive, Suite 107
Mechanicsburg, PA l7055
5, Name and address of every other person who has any record lien
on the property.
Household Realty Corporation
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
6.
interest
affected
Name and address of every other person who has any record
in or record lien on the property and whose interest may be
by the sale.
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7, Name and address
has knowledge who has any
affected by the sale:
of every other person of whom the Plaintiff
interest in the property which may be
Name
Address (Please indicate if this
cannot be reasonably ascertained)
20 Buckthorn Drive
Carlisle, PA 17013
Tax Collector of South
Middleton Twp,
South Middleton Muncipal
Authority (water & sewage)
Court of Common Pleas of
Cumberland County
POB 8
Boiling Springs, PA 17007
Commonwealth of PA -DPW
Domestic Relations Division
One Courthouse Square
Carlisle, PA 17013-3387
P.O, Box 8016
Harrisburg, PA l7105
PA Inheritance Tax Dept.
Bureau of Compliance
Dept. #280946
Harrisburg, PA 17l28-0946
Attn. Susan Dolack
Tenant/Occupant
928 Goodyear Road
Gardners, PA 17324
MAJOR EXEMPTIONS UNDER
PENNSYLVANIA AND FEDERAL LAW
1. $300 statulory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
:l. Most wages and unemployment compensation
4, Social Security benefils
5, Certain retirement funds and accounls
6, Certain veteran and armed forces benefits
7, CerU\i'llnsurance proceeds
8. Such other exempllons as may be provided by law
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WRIT NO,
CIVIL TERM
CLAIM FOR EXEMPTION
To the Sheriff:
I, \he above named defendanl. claim exemption of property from levy, or
attachment:
1, From my personal property in my possession which has been levied
upon,
a) I desire Ihal my $300 statutory exemption be
(] (i) set aside in kind (specify property to be set aside in kind):
(] (1I) paid In cash following the sale of the property levied upon; or
b) I claim the following exemption (specify property and basis of exemption):
2. From my property which is in the possession of a third party, I claim \he
following exemplions:
a, my $300 stalutory exemption: a In cash: a in kind
(specify property):
b, Social Security benefits on deposit in the amount of $
c) other (specify amounl and basis of exemption:
I request a prompt court hearing 10 determine the lWImpllon,
Notice of the hearing should be given to me at
Address
Telephone Number
I verify that the stalements made in this Claim for Exempllon are true and
correct. I understand that false statements herein are made subject to the
penallles of 18 Pa, C.S, ~ 4904 relallng 10 unsworn falslflcallon to authorllles.
Date:
THIS CLAIM TO BE FILED WITH THE
OFFICE OF THE SHERIFF OF CUMBERLAND
COUNTY:
CUMBERLAND COUNTY COURTHOUSE
CARLISLE. PENNSYLVANIA 17013
(717) 240-6390
ORDER OF COURT
AND NOW,
of Civil Procedure 3123.1 (b), a hearing isset for
pursuant \0 Pa. Rule
In Court Room No,
Cumberlsnd County Courthouse, Carlisle, Pennsylvania, The Sheriff of
Cumberlana County shall n011fy Ihe parties of the lime and place for Ihe hearing,
By the Court,
J.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEAL TH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 91-5948 CIVIL 19_
CIVIL ACTION. LAW
TO THE SHERIFF oF____CU_M.B_E_Fl!-_~~~________COUNTY
Tosallslylhedebl.inlereslandcostsdue _.!la~keE_s Tr Co of Californ.ta, NA, as
~u_~to.~_i~~_~~.<1/or Trustee, Assignee of Colonial National Bank, USA PLAINTIFF(S)
lrnm Terry E. and Lucy W. Wolf, 928 Goodyear Rd., Gardners PA 17324.
DEFENDANT(S)
(1) You are directed to levy upon the properly ollhe delendanl(s) and 10 sell Real es tate loca ted at
928 Goodyear Rd., Gardners PA 17324 (See attached Legal Description).
_._---~
(2) You are also directed 10 anach the property 01 Ihe defendanl(s) not levied upon In Ihe possession of
GARNISHEE(S) as follows:
and to not~y the garnlshee(S) that: (a) an attachmenl has been Issued; (b) the gamlshee(s) Is/are enjoined from paying any
debt to or for the account of the defendanl(s) and from delivering any properly of the defendant(s) or otherwise disposing
thereof;
(3) It property 01 Ihe defendant(s) not levied upon an subject 10 anachment is found In Ihe possession of anyone other
Ihan a named garnishee, you are directed to notify hinvherthal he/she has been added as agarnlshee and Is enjoined as above
staled.
Amount Due $66,667.09
Inleresl 3/28/98 - 9/2198 $2,087.61
L.L.
$.50
Any's Comm
Any Paid
Plaintiff Paid
%
Due Prothy
Other Costs
$1. 00
$1047.44
Dale: April 1, 1998
Curtis R. Long
\'\, _ prothOt'a.f' Civil Oivis~n
by: u~Hf'1AL~~~!J
Deputy
REOUESTING PARTY:
Louis P. Vitti, Esquire
Name
916 fifth Avenue
Pittsburgh PA 15219
Plaintiff
Address:
Anorney for:
Telephone:
Supreme Court 10 No
(412) 281-1725
3810
'----"
REAL ESTATE S;\LE No, I
On ~ I, 19't <; the sheriff levied upon the defend:: '
If'llefest In the feal property situated In And1AY1~/J':'J-;-. 7..vr'
Cumberland County, Pa" known and numbuod as:'13~ ~"r~ ~
~ and more fully dascr;b:JrJ on E;;;hibit HAHn:>.:: \,,;':,
r~,: ~tJ119f
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this writ and by this reference incorporated herein.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N.A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
.
I
I
.
:
I
No. 1997-5~48
Enter judgment in Default of an Answer in the amount of
$66,667.09, in favor of the Plaintiff, Bankers Trust Company of
California, N.A., et al., in the above-captioned action, against
the Defendants, Terry B. Wolf and ~ucy W. Wolf, and assess
Plaintiff's damages as follows and/or as calculated in the
Complaint.
Vitti,
for the
The real estate, which is the subject matter of the
Complaint in Default Judgment, is situate in S. Middleton Twp.,
Cumberland Cty., PA, HET at a dwg. k/a 928 Goodyear Rd"
Gardners, PA l7324, Parcel 40-43-27 -005,
VB.
TERRY E. WOLF and LUCY W. WOLF,
his wife,
Defendants.
PRAECIPB VOR DBVAULT JUDGMENT
AND ASSBSSMENT OV DAMAGBS
TO I PROTHONOTARY OF CUMBERLAND COUNTY
Unpaid Principal Balance
$56,446.59
4,l48.96
Interest from 5/15/97-3/27/98
(Plus $l3,1296 per day after 3/27/98)
Late charges (Plus $30.07 per
month from lO/24/97-9/2/98-$270.63)
120.28
Attorney's fee
2,822.33
Escrow Deficit 3,l28.93
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriff's sale)
Total Amount Due
S66.667.09
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N.A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
vs.
No. 1997.5948
TERRY E. WOLF and LUCY W. WOLF,
his wife,
Defendants.
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of
Intention to Take Judgment was mailed to the Defendants, in the
above-captioned case on F'ebruary 24, 1998, giving ten (lO) day
notice that judgment would be entered should no action be taken,
BY:
ITTI & ASSOCIATES, P.C.
~-
Uk) ~
V~tti, Esquire
for Plaintiff
SWORN to and subscribed
before me this 27th day
of March, 1998.
No1Bl1a1Soal
/WI lA, Oonzalel, Notary PullIl<
P1l1Sbur1lh, Allegheny Coullty
My Commlsslon Explrui Aug 11,2000
~lj.
car1fiL m. A1m~~
Notary Public 0
IN THE COURT or COMMON PLEAS or CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF CALIFORNIA.
N A. AS CL'STODlAN AND/OR TRUSTEE.
Assigne:e: of COLONIAL NATIONAL BANK. USA.
Plaintiff.
vs,
No. 1997-'948
TERRY E, WOLF and LUCY W, WOLF. his wife:.
De:fe:ndants,
IMPORTANT NOTICE
TO: Terry E, Wolf
Lucy W, Wolf
928 Goodye:ar Road
Gardne:rs. PA 17324
Date: of Notice:: February 24, 1998
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 MAYBE 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, GO 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. PA 17013
717-697-0317
LOUI
BY: A.A.NC
, p, Viui. Esquire-
Attorne:y for Plainti 1'1'
916 Fifth Ave:nue:
Pittsburgh. PA 15219
.. TIlE DEBT COLLECTOR IS A TIEl\IPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE...
.
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
Louis P. Vitti, Esquire, who, being duly sworn according to law,
deposes and says that he is advised and believes that D~FENDANTS
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's knowledge 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,
/~ ('--1uWJ--
~P~V' ,
s . J.ttJ., EsquJ.re
SWORN to and subscribed
before me this 27th day
of March, 1998.
Nolal1alSeal
Ann M. Goflzale., Notary Public
PlIlIIluIIIh, AileQheny Coonl't
My CommIIaIon Expllll5 Aug. 17, 2000
fl.
OA1.vn rfL ldcYi~
Notary Public
"... ..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
BANKERS TRUST COMPANY OF
CALIFORNIA. N,A,. AS CUSTODIAN
AND/OR TRUSTEE. Assignee of
COLONIAL NATIONAL BANK. USA.
CIVIL DIVISION
NO, 1997-5948
Plaintiff.
PRAECIPE FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
vs,
TERRY E, WOLF and LUCY W, WOLF,
his wife.
Code 140 MORTGAGE FORECLOSURE
Defendants,
Filed on behalf of
Plaintiff
Counsel of record for this
party :
Louis p, Villi. Esquire
PA I.D, #3810
Supreme Court #01072
Louis P. Villi & Assoc,. P,C,
916 Fifth Avenue
Piusburgh, P A 15219
(412) 281-1725
.,
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N.A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
vs,
No. 1997-5948
TERRY E, WOLF and LUCY W, WOLF,
his wife,
Defendants.
PRAKCIP. WOR WRIT OF
ZXZCUTION IN MORTGAG. WORZCLOSUR.
TO. PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and
against the Defendants in the above-captioned matter as follows.
Amount Due
$66,667.09 /
Interest from 3/28/98-9/2/98
Total
2,087.6l
S68.754.70
The real estate, which is the subject matter of the Praecipe
for Writ of Execution is situate in.
S. Middleton Twp., Cumberland Cty., PA. HET at a dwg. k/a 928 Goodyear
Rd" Gardners, PA l7324. Parcel 40-43-2759-005.
&f0!.~
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N.A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
vs.
No. 1997-5948
TERRY E, WOLF and LUCY W. WOLF,
his wife,
Defendants.
AJ'FIDAVIT
I, Louis P. Vitti, do hereby swear that, to the best of my
knowledge, information and belief, the Defendants are the owners of the
real property that the Plaintiff seeks to execute on. That the
Defend2nts' last known address is 928 Goodyear Road, Gardners, PA
17324.
VittJ., Esquire
SWORN TO and subscribed
before me this 27th day
of March, 1998.
Nottv1., Sui
Ann M Goolal.., Notary PublIC
P1llIbu'ljh, AlIlIllh.Oy Coon"
lAy Comm'....n expo... Aug '7. 2(111('
u II.
Cl!M,/m .11CfY112>>v
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N.A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
vs.
No. 1997-5948
TERRY E. WOLF and LUCY W. WOLF,
his wife,
Defendants.
AFFIDAVIT PURSUANT TO RULB 3129.1
Bankers Trust Company of California, N.A., et al., Plaintiff in
the above action, sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the real
property located at 928 Goodyear Road, Gardners, PA 17324,
1. Name and address of Owner(s) or Reputed Owner(s),
Name. Address (Please indicate if this
cannot be reasonably ascertained)
Terry E. Wolf
Lucy W. Wolf
928 Goodyear Road
Gardners, PA 17324
2. Name and address of Defendant(s) in the judgment,
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as #1 above,
3. Name and last known address of every judgrr,ent creditor whose
judgment is a record lien on the real property to be sold,
Name:
Address (Please indicate if this
cannot be reasonably ascertained)
None
4. Name and address of the last recorded holder of every mortgage
of record,
Name
Address (Please indicate if this
cannot be reasonably ascertained)
l564 Fairmont Street
Pittsburgh, PA 15221
American Eagle Developers
TMS Mortgage, Inc.
Suite 100
Sacramento, CA 95215
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 understnnd that false statemen~s herein are made subject to the
penalties of 18 Pa, C,S Section 4904 relating to unsworn falsification
to authorities. ~
uJ;r"
March 27, 1998
Date is P. Vitti, Esquire
Attorney for Plaintiff
SWORN TO and subscribed
before me this 27th day
of March, 1998.
a~,'\H\ pt ~r &J.
Notary Public
NO:;Ulal ::ida!
A/Vl M GOl1la:o. "'ald!)' "JCli";
Pl'ttSburQn. Allegheny CcUf'l:
~ ("..ommIs.sJOO e..ptre. AuQ 17. J())I!
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N,A., AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff,
vs.
No. 1997-5948
TERRY E. WOLF and LUCY W. WOLF,
his wife,
Defendants.
AFJ'IDAVIT
I, Louis P. Vitti, hereby certify that as representative of
Bankers Trust Company of California, N.A., et al., am familiar with the
above-captioned case and various servicing activities related thereto
and that the provisions of the laws of the Commonwealth of Pennsylvania
and specifically, Act 9l of 1983, have been complied with in the above-
captioned case.
Vitti, squire
for Plaintiff
SWORN to and subscribed
before me this 27th day
of March, 1998.
NolastalSeal
AM M Gonzol.., Nl1lory Public
1'1nsbuI1Ih, Allegheny county
loty CommIsslon Expir.1 Aug, '7, 2000
I.
tkwt. m. l:hn ~
Notary Public r
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV~IIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF
CALIFORNIA, N,A" AS CUSTODIAN
AND/OR TRUSTEE, Assignee of
COLONIAL NATIONAL BANK, USA,
Plaintiff ,
vs.
No. 1997-5948
TERRY E, WOLF and LUCY W. WOLF,
his wife,
Defendants.
AlllDAVIT
t. Louis P. Vitti, do hereby swear that, to the best of my
knowledge, information and belief, the Defendants are the owners of the
real property that the Plaintiff seeks to execute on. That the
Defendants' last known address is 928 Goodyear Road, Gardners, PA
l7324,
vitt~ ,
SWORN TO and subscribed
before me this 27th day
of March, 1998.
CL1Vv1/ m - 11~
Notary Public
Nolal1al Seal
/Wl M Gonulo., Notal) PublIC
P1Itsllurgn, AII"llhonr COunl)
t.ly Comm'so'on expuoI Aug '7 ~(l&'~
n aUOn U II.
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Household Realty Corporation
25 Gateway Drive. Suite 107
Mechanicsburg, PA 17055
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 ,
interest
affected
Name and address of every other person who has any record
in or record lien on the property and whose interest may be
by the sale.
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address
has knowledge who has any
affected by the sale.
of every other person of whom the Plaintiff
interest in the property which may be
Name
Address (Please indicate if this
cannot be reasonably ascertained)
20 Buckthorn Drive
Carlisle, PA 17013
Tax Collector of South
Middleton Twp.
South Middleton Muncipal
Authority (water & sewage)
Court of Common pleas of
Cumberland County
POB 8
Boiling Springs, PA 17007
Domestic Relations Division
One Courthouse Square
Carlisle, PA 17013-3387
PA Inheritance Tax Dept.
P.O. Box 8016
Harrisburg, PA 17105
Bureau of Compliance
Dept. #280946
Harrisburg, PA 17128-0946
Attn. Susan Dolack
Commonwealth of PA -DPW
Tenant/Occupant
928 Goodyear 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 l8 Pa. C.S. Section 4904 rela ' 9 to unsworn falsification
to authorities.
April 13 1998
Date
U;p/
Vittl, Esquire
for Plaintiff
SWORN TO and subscribed
before me this l3th day
of April, 1998,
,.....'.. e.... I
'If..' <..4 l']clnUH. N.~iU) tolt6~ .
~..twi''C". '\~~rtt1, Countr
~,"'~."''1'llr,js..J;;)n E.t:",..A"O 17, i'tI,J I
..~: '......, ?"-:;t;'~,''''''f~'W\'rY",,)a....<..;
Notary Public
f
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BANKERS TRUST COMPANY OF CALIFORNIA, I
N,A" AS CUSTODIAN AND/OR TRUSTEE, I
Assignee of COLONIAL NATIONAL BANK USA, I
I
I
I
I
I
I
I
Plaintif f,
No. 1997-5948
vs.
TERRY E, WOLF and LUCY W. WOLF, his
wife,
Defendants.
AFFIDAVIT OF SBRVICE
I, Danielle Lardo, do hereby certify that a Notice of Sale was mailed
and served upon all Lien Holders, by Certificate of Mailing for service in
the above-captioned case on March 30, 193B, March 31, 1998 and April l4,
1998, advising them of the Sheriff's sale of the property at 928 Goodyear
Road, Gardners, PA 17324, on September 2, 1998.
LOUIS P. VITTI & ASSOCIATES, P.C.
BY~~~
Danielle Lardo
SWORN to and subscribed
before me this 19th day
of August, 1998.
V\ IV?
Notary Public
Nolat'a1 Seal
AM '-4, Goo,..... Notary PubliC
Plltsllu"Jh. Allegheny COLI11y
My CommISSlOIl explr.. Aug. 17,2000
CI ro My VI h1 ,,cx.IJ ion 0 otJIldS
I
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PS Fo,m 3& 17, Ma,. 1989
P TA . I , BIIfICATE 0
MAV 8E USED FOA DOMES TIC AND INTERNATIONAL MAil, DOES Nor
PRO\lIOE FO N .POSl'MASTf.R
rg-p;SSOCT.
916 FIFTH AVENUE
PIHS[JURGH;-PA 15219
4
, t.
R.ui.....d'
an. plft:. 01 Oldlnary m'll .dd/.II.d 10:
AMERICAN EAGLE DEVELOPERS
1564 FAIRMONT ST
PGN Po'. 15Ul
PS Form 3817, Mar. 1989
On. pIK' of Ofdtn.,v mill .ddllu.d to
TENANT/OCCUPANT
928 GOODYEAR RD
PS Form 3817. Mar. 1989
A Iti. ,.. /ler. '" l1amp.
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WOLF, T.
WOLF, T.
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WOLF, T.
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WOLF, T.
PS Fo,m 3817, Ma,. 1989
OM pteet of Oldln'ry m'll addre..td to
HOUSEHOLD REALTY CORP
25 GATEWAY DR STE
MIU~HANTr.~RIlRr: PA
........ .....
PS Fo,m 3817, Mar. 1989
WOLF, T.
RouivH flam
P lA AVICE IF F MAIL!
MAY BE USlD fOR DOMESTIC AND INTERNA llONAL MAll, DOES NOT
PROVIDE F S (R
.tamp.
g. .nd
uir. of
curr.nt
an. pMc.ol orOin.,y mall .dd/llued to'
S MIDDLETON MUNICIPAL AUTH
POB 8
BOIIINr, qpVINCS P4 17
PS Fo,m 3817, Mal. 1989
I
I
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or mele' pOllag' and
~::mm"k"f~. .. Ol'(~
f.. A'
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or meta' PO'llgI and
post mar lnqulll ,
PO(' II., 9, "'I
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.l!1!~m\'.!u. . ~!UIFICAU Qf.MAll.ING..__
MAY II USiO fOill DOMfSflC A~O INflHNAflONAL MAIL. DOES NOT
..0VlD. 'mf'S'1',-9lrrf'M"ASSoetA ft.:: --
.O<''''''',~n 916 flfrH AVUJUt
0... Me' 01 Of~mM'I' m..l ,dUllnelllo
COMMONWEALTH OF PA DPW
POB 8016
HUgT~~"RC 1!4l-l.1105
PS FOfm 3817, Ma,. 1989
. f. . I IILjlf.
MAV 8E USED fOR DOMESTIC AND INTEANA lIONAL MAIL. DOES NOT
PROVIDE Fon 'kSUAANCE. POS TMAS TER
."..,.., . :i 1', VI I Irg-ASSOCI L",
916 FIfTH AVENUE
PITTSBURGH, PH5213
?
an. pile. of ordlNr., mid .ddr....d 10
PA I~HERITANCE TAX DEPT
BUREAU OF COMPLIANCE
DiPT 12&0946
HARRISBURG PA 17128 0946
All" ~U~AN uOLACK
PS Fo,m 3817, Mar, 1989
PTAERVIC I F I
MAY 81 USED fOR DOMESTIC AND INTERNA TlQNAl MAil. DOES Nor
PAOVIDI FOR INSURANCE -POSTMASTER
Rtc~~R Flom'
lOUIS i) Vir,;
]1'
"Iii "
14L'1.:d
I' />
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..~E,
~
0nlI piece of Otdm.fy mill .ddt....d 10:
THS MORTGAGE INC
SUITE 100
SACRJdIEIITO ell 95215
PS Form 3817, Mer. 1989
WOLF, T.
....... t.....
WOLF, T.
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It'
WOLF, T.
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