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FLEET MORTGAGE CORPORATION
f/k/. FLBET REAL BSTATB
FUNDING CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
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NO.
Q1. 'J"I'/) C'u..d ~-
LOUIS S. BOGDEN and
SANDRA L. BOGDEN,
DEPENDANTS
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
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 have been served. To defend against
the aforementioned claims, a written appearance stating your defenses and
objections must be entered and filed in writing by you, the defendant, or by
an attorney. You are warned that if you fail to take action against these
claims, the court may proceed without you and a judgement for any money
claimed in the complaint or for any other claim required by the plaintiff
may be entered against you by the court without further notice. You may
lose money, property or orher rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
Court Administrator, Cumberland County Courthouse
Carlisle, Pa. 17013 -- (717) 240-6200
NOTICIA
Le han demand ado a usted en la corte. Si usted quiere defenderse de
estas damandas expuastas en las paginas siguientes, usted tiene viente (20)
dias de plazo al partir de la fecha de la demanda y la notificacion. Usted
debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar
en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en
contra de su peruona. Sea avisado que si usted no se defiende, la corte
tomara med:i.das y puede entrar una orden contra usted sin previo aviso 0
notificacion Y por cualquier queja 0 alivio que es pedido en la petici~n de
demanda. Usted puede perder dinero 0 sUS propiedades 0 otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. S1 NO TIENNE ABOGAD 0 SI
NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAMi
POR TELEFONE A LA OFICINA CUYA D1RECC10N SE ENCUENTRA ESCRIDA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASS1STENC1A LEGAL:
CUMBERLAND COUNTY
Court Administrator, Cumberland County Courthouse
Carlisle, Pa. 17013 -- (717) 240-6200
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FLEET MORTGAGE CORPORATION
f/k/a FLEET REhL ESTATE
FUNDING CORPORATION,
PLAINTIFF
IN THB COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO.
LOUIS S. BOGDBN and
SANDRA L. BOGDEN,
DEFENDANTS
CIVIL ACTION - LAW
MORTGAGB FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, lS U.S.C. 51601:
The undersigned attorney is attempting to
collect a debt owed to the Plaintiff, and ~ny
information obtained will be used for that
purpose. The amount of the debt is stated in
this Complaint. Plaintiff is the creditor to
whom the debt is owed. Unless the Debtor,
within thirty (30) days after your receipt of
this notice disputes the validity of the
aforesaid debt or any portion thereof owing
to the Plaintiff, the undersi'3ned attorney
will assume that said debt is valid. If the
Debtor notifies the undersigned attorney in
writing within the said thirty (30) day
period that the aforesaid debt, or any
portion thereof, is disputed, the undersigned
attorney shall obtain written verification of
the said debt from the Plaintiff and mail
same to Debtor. Upon written request by
Debtor to the undersigned attorney within
said thirty (30) day period, the undersigned
attorney will provide debtor with the name
and address of the original creditor if
different from the current creditor.
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PURCELL, KRUG &. HALLER
Leon P. Haller, Esquire
l7l9 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #lS700
Attorney for Plaintiff
Commonwealth. Said Mortgage is attached hereto and made a part
hereof as Exhibit "B".
5. The land subject to the Mortgage is: 2021 HARVARD AVE,
CAMP HILL, PA 17011 and is more particularly described in
Exhibit "C" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on April 1,
1997 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $
76,B09.70
(b) Interest at $17.62 per day
from 3/1/97 to 10/13/97
(based on contract rate of 8.375%)
3,982.12
(c) Accumulated Late Charges
and Late charges at $29.78
per month for 7 months
208.46
(d) Escrow Deficit
2,37B.96
(e) 5% Attorney's Commission
3,B40.49
$ 87,219.73*
*Together with interest at the per diem rate noted in (b) above
after October 13, 1997 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
B. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and sailors Relief Act of 1940, as
amended.
10. Plaintiff has Complied with the procedures required by
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and defendant has either failed to
meet the time limitations as set forth therein or has been
determined by the Housing Finance Agency not to qualify for
assistance.
WHEREFORE, Plaintiff demands judgment in mot'tgage
fot'eclosure "IN REM" for the aforementioned total amount due
togethet' with intet'est at the rate of 8.375\ ($17.62 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and fot'
foreclosure and sale of the property within described.
PURC~'. KRUG. HA~L,ER
By , . (OJ\ j !o..!:.U,,--
Leon P Hall
Attorney for Plaintiff
I.D. 1115700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234 -4178
Y~IUEICATION
I, Annette Blazek, as the Assistant Secretary of the servicing agent of the
Plaintiff corporation within named do hereby verify that I am authorized to and do
make this verification on behalf of the Plaintiff corporation and the facts set forth in
the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statement therein are made subject to
the penalties of 18 Pa. c.s. 4904 relating to unsworn falsification to authorities.
Date:~
~~
Annette Blazek
Assistant Secretary
FLEET MORTGAGE CORPORATION f/k/a
FLEET REAL ESTATE FUNDING CO~PORATION
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FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY OF THE WITHIN COUNTYI
Please enter JUDGMENT "in rem" in favor of the Plaintiff and
against Defendants LOUIS S. BOGDEN AND SANDRA L. BOGDEN for failure
to plead to the above action within twenty (20) days from date of
service of the Complaint, and assess Plaintiff's damages as
follows:
Unpaid principal balance
Interest
(Per diem of $17.62
from 3/1/97 to 10/13/97)
Accumulated late charges and
Late charges
($29.78 per month to 10/97)
Escrow Deficit
5% Attorney's Commission
$76,809.70
$ 3,982.12
TOTAL
$ 208.46
$ 2,378.96
$ 3.840.49
$87,219.73**
** Together with additional interest at the
above from 10/13/97, based on the contract
and costs to the date of Sheriff's Sale.
per diem rate indicated
rat and other charges
By
~LER
Leon P. aller PA I.D. #15700
l7l9 North Front Street
Harrisburg, PA l7l02
(717) 234-4178
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FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SAND~' L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
TO THE PROTHONOTARY.
Issue Writ of Execution in the above matter on the real estate
located at 2021 HARVARD AVENUE, CAMP HILL, PA as follows:
Amount due pursuant to Judgment
$ 87,219.73
Interest
(Per diem of $17.62 from
10/13/97 TO 6/3/98)
$ 4,105.46
Late Charges at $29.78
(10/97 to 6/98)
$ 238.24
$ 1.500.00
Escrow deficit
TOTAL WRIT
$ 93,063.43**
.. Together with any additional interest, charges and costs to the
date of Sheriff's Sale.
By
.ft-
LEON P. HALLER I.D. #15700
ATTORNEY FOR PLAINTIFF
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Dated: March 6, 1998
Attached is a description of the real estate.
'.
,
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Cumberland County, Pennsylvania, bounded and described
as follows:
BEGINNING at a pOint of the South side of Harvard Avenue
(sixty feet wide) at the dividing line between Lots Noe. 167 an!
168, Section 0 in the hereinafter mentioned Plan ot Lots; thenc
along aald dividing line South seven (7) degrees twelve (12
minutes Eaat one hundred torty-tlve (145) teet to Lot No. 145
Section 0; thance along said Lot No. 145 Section 0, South eighty
two (82) degrees forty-eight (40) minutes West sixty-four anp'
eighty-tive hundredths (64.85) teet to the Eastern line ot Sout~
21st Street; thence along the Eastern line of South 21st Street
North nine (9) degrees seven (7) minutes West one hundred twenty-
nine and fitty-seven hundredthe (129.57) feet to a point; thence
along a curve to the right having a radius ot tltteen (15) teet, an
arc distance of twenty-tour and seven hundredths (24.07) feet to a.
point on the Southern iine of Harvard Avenue; thence along the
Southern line ot Harvard Avenue North eighty-two (82) degrees
tortt-elght (48) minutes East, tlrty-tour and two tenths (54.2)
teet to a point, the place ot BEGINNING.
BEING Lot No. 168, Section 0 in the Plan ot College Park as
recorded in the Cumberland County Recorder's Office in Plan Book 4
Page lOB.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, Pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August 18, 1993 in
Cumberland County Deed Rook L 36, Page 1168 granted and conveyed
unto Louis S. Bogden and Sandra L. Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
01-22-0536-163
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5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
6.
intere.t
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
UNKNOWN
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any inter..t in the property which
may be affected by the sale:
TENANTS IF ANY ...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made su ject
to the penalties of 18 PA C.S. Section 4904 relating to sworn
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug &. Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 6, 1998
I
FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said
Commonwealth and County, LBON P. HALLER, ESQUIRB who' being duly
sworn according to law deposes and states that the Defendant(s)
above named are not in the Military or Naval Service nor are they
engaged in any way which would bring them within the Soldiers and
Sailors Relief Act of 1940, as amended.
Sworn to and subsyribed :
before me this 6~~~Y:
of /Jltl" VI. 19 <'('I :
~ ~fj. ".k'- <<t:::a,1'(/.
o ry PubIi .
,
, ESQUIRE
NOTARIAL SEAl
MARYLAND It FERRETTI. Nola1y Public
Lower Paxlon Twp. Dauphin County
My Commission Ujlkes Aug. 8, 1998
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FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS,
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
CBRTIPICATE OP SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on JANUARY 7, 199B I served the Ten Day
Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
~~
Leon P. Haller PA I.D.
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
By
#15700
March 6, 1998
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FLEET MORTGAGE CORPORATION
llk/a FLEET REAL ESTATE
FUNDING CORPORATION,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
PLAINTIFF
va.
NO. 91-5995 Civil
LOUIS S. BOGDEN and
SANDRA L. BOGDEN,
De lendants
CIVIL ACTION LAW
IN MORTGAGE FORECLOSURE
IMPORTANT IlO'l'IC1l
TO:
LOUIS S. BOGDEN
Delendant
2021 Harvard Avenue
Camp Hill, PA 11011
SANDRA L. BOGDEN
Defendant
2021 Harvard Avenue
Camp Hill, PA 11011
DATE OF NOTICE:
January 1, 1998
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS
NOTICE IS SENT TO YOU IN ~ ATTEMPT TO COLLECT THE INDEBTEDNESS
REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APpEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10)
DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD
TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Lawyer Referral Service
Court Administrator
cumberland County Courthouse
Carliele PA 11013
(111) 240-6200
n P. Haller
.0.#15100
Attorney for plaintiff
co.'
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FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDLNG CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALB OF REAL ESTATE
PURSOANT TO
PENNSYLVANIA ROLB OF CIVIL PROCEDURE 3129
TAKB NOTICEa
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: JUNE 3, 1998
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania l70l3
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consist ing of a statement of the measured
boundaries of tbe property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SE~ DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
2021 HARVARD AVENUE
CAMP HILL
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 97 5995 CIVIL
is:
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHllDULB OF DISTRIBUTION, being a list of the persons and/oI'
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to bank. that hold mortgage.
and municipalities that are owed taxe.) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will. in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPBRTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. I f you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADV:CE,
cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE I
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILBD BEFORE THB SHERIFF'S DBBD IS DELIVERBD.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Cumberland County, Pennsylvania, bounded and described
as follows:
BEGINNING at a point at tha South alda ot Harvard Avenue
(.IKty teet wide) at the dividing line betwean Lota Noa. 167 an1
168, Section D In the herelnatter mentioned Plan at Lot.; thenc
along aald dividing Une South uven (7) deguu twelve (12
mlnutaa Eaat one hundred torty-t1ve (145) taet to Lot No. 145
Section D; thence along aald Lot No. 145 Section D, South elghtyr
two (82) deguu torty-elght (4 8) mlnutea Wen ahty- tour en/l'
elghty-tlve hundredths (64.85) taet to the Eaatern line ot Sout~
Hat Street; thence along the En tern line at South H.t Street
North nine (9) degrees .even (7) minute. We.t one hundred twenty-
nine and tltty-seven hundredths (129.57) teet to a point; thence
along a curve to the right having a radius ot tltteen (15) taet, an
arc distance ot twenty-tour and seven hundredth. (24.07) teat to au
point on the Southern line ot Harvard Avenue; thence along tha
Southern Une ot Harvard Avenue North eighty-two (82) degreu
torty-elght (48) minute. East, tHty-tour and two tenths (54.2)
teet to a point, the place ot BEGINNING.
BEING Lot No. 168, Section D In the Plan ot College Park a.
recorded In the Cumberland County Recorder'. Ottlce In Plan Book 4
Page 108.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, Pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August l8, 1993 in
Cumberland County Deed Book L 36, Page 1168 granted and conveyed
unto Louis S. Bogden and Sandra L. Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
01-22-0536-163
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SHERIFF'S RETURN - REGULAR
CASE NO, 1997-1B~99~ P
CO""ONWEALTH OF PENNSYLVANIA I
COUNTY OF CU"BERLANO
FLEET "ORTGAGE CORPORATION
VS.
BOGDEN LOUIS S ET AL
. Sheri~f or Deputy Sheri~f of
being duly .worn according
"ORT FORE wa. .erved
WESLEY COOK
CU"BERLAND County, Penn.ylvania, who
to law. ..y., the within CO"PLAINT -
upon BOGDEN SANDRA L
de~endant, at 18~IB,1B1B HOURS, on the ~ d.y o~ Hove.ber
1921 .t 21821 HARVARD AVENUE
CA"P HILL. PA 171811
County, P.nn.ylv.ni., by h.nding to SANDRA BOGDEN
a true .nd .tt..ted copy I)f the CO"PLAINT - "ORT FORE
togeth.r with HOT~CE
and .t the .... ti.e directing ~ attention to the ccntent. ther.o~.
the
. CU"BERLAHD
Sheri~~'. Co.t.,
Docketing
Service
Affid.vit
Surch.rge
So .nawer.,
'-<27' ~
-T ~~~'.(~
R. Thoe.. JU1ne, .r;
pURCELL KRUG & HALLER
""":~7 $~.; ef/
u y er1:f:f
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6.1818
.1818
.1818
2.1818
.8.00
Sworn and aubacribed to before .e
thi. '? ~ d.y o~ ,1.-tlu.uYu_-,
19 91 A.D.
C} u C 1J,1.Jlt...- ~'
n t"ro~nono~.ry
.
.
SHERIFF'S RETURN - REGULAR
CASE NO, 199'7-0~99~ P
CO""ONWEALTH OF PENNSYLVANIA,
COUNTY OF CU"BERLAND
FLEET "ORTGAGE COR?ORATION
VS.
BOGDEN LOUIS S ET AL
WESLEY COOK
CU"BERLAND County, PennBylv.ni., who
to l.w, ..y., the within CO"PLAINT -
. Sheriff or Deputy Sh.riff of
being duly .worn .ccording
"ORT FORE w.. .erved
upon BOGDEN LOUIS 5
def.nd.nt, .t 18~0,00 HOURS, on the ~ d.y of November
19~ at 2021 HARVARD AVENUE
CAftP HILL. PA 17011
County, Penn.ylvania, by handing to SANDRA
a true .nd atte.t.d copy of the COftPLAINT
together with NOTICE
and at the .... time directing Her attention to the content. thereof.
the
.
.CUftBERLAND
BOGDEN. WIFE OF DEFT.
- ftORT FORE
.
.
.
Sheriff'. COBtB'
Docketing
Service
Affid.vit
Surch.rge
18.00 So annpw& ,." / ~
9 34 -- ....~~;.J.rz'"~..c::' ~~
. Of
.00
2.00 H. Thom.. K11ne, 5 er
.~~.~~ r~'~~7~:9~RU~~,~R ~~
Jl~%%
F
Sworn .nd .ub.cribed to before me
this i~ day of 71..'1-"'......k.-
19 '11 A.D.
\ I, / '- r. nt..ll.-- I hT., .
~, lfrot.honotary -7 I
rLEET MORTGAGE CORPORATION
f/k/a rLEET REAL ESTATB
rUNDING CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PBNNSYLVANIA
VS.
NO. 91.-)'/fi s' [~.J 1,-,-
LOUIS S. BOGDEN and
SANDRA L. BOGDEN,
DEPENDANTS
CIVIL ACTION - LAN
MORTGAGB rOREcLOSURE
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 have been served. To defend against
the aforementioned claims, a written appearance stating your defenses and
objections must be entered and filed in writing by you, the defendant, or by
an attorney. You are warned that if you fail to take action against these
claims, the court may proceed without you and a judgement for any money
claimed in the complaint or for any other claim required by the plaintiff
may be entered against you by the court without further notice. You may
lose money, property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 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.
CUMBBRLAND COUNTY
Court Administrator, Cumberland County Courthouse
Carlisle, Pa. 17013 -- (717) 240-6200
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse de
estas damandas expuastas en las paginas siguientes, usted tiene viente (20)
dias de plazo al partir de la fecha de la demanda y la notificacion. Usted
debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar
en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en
contra de su persona. Sea avisado que si usted no se defiende, la corte
tomara medidas y puede entrar una orden contra usted sin previo aviso 0
notificacion y por cualquier queja 0 alivio que es pedido en la peticion de
demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENNE ABooAD 0 SI
NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME
POR TELEFONE A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRIDA ABAJO PARA
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL:
CUMBERLAND COUNTY
Court Administrator, Cumberland County Courthouse
Carlisle, Pa. 17013 -- (717) 240-6200
FLEET MORTGAGE CORPORATION
tiki_ FLEET REAL BSTATB
FUNDING CORPORATION,
PLAINTIFF
IN THB COURT OF COMMON PLEAS
CUMBBRLAND COUNTY, PENNSYLVANIA
VS.
NO.
LOUIS S. BOGDEN and
SANDRA L. BOGDEN,
DBFBNllANTS
CIVIL ACTION - LAN
MORTGAGB FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 51601:
The undersigned attorney is attempting to
collect a debt owed to the Plaintiff, and any
information obtained will be used for that
purpose. The amount of the debt is stated in
this Complaint. Plaintiff is the creditor to
whom the debt is owed. Unless the Debtor,
within thirty (30) days after your receipt of
this notice disputes the validity of the
aforesaid debt or any portion thereof owing
to the Plaintiff, the undersigned attorney
will assume that said debt is valid. If the
Debtor notifies the undersigned attorney in
writing within the said thirty (30) day
period that the aforesaid debt, or any
portion thereof, is disputed, the undersigned
attorney shall obtain written verification of
the said debt from the Plaintiff and mail
same to Debtor. Upon written request by
Debtor to the undersigned attorney within
said thirty (30) day period, the undersigned
attorney will provide debtor with the name
and address of the original creditor if
different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney rD n15700
Attorney for Plaintiff
Commonwealth. said Mortgage is attached hereto and made a part
hermof as Exhibit "B".
5. The land subject to the Mortgage is: 2021 HARVARD AVE,
CAMP HILL, PA 17011 and is more particularly described in
Exhibit .C. attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on April 1,
1997 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $
76,80~.70
(b) Interest at $17.62 per day
from 3/1/97 to 10/13/97
(based on contract rate of 8.375%)
3,982.12
(c) Accumulated Late Charges
and Late charges at $29.78
per month for 7 months
208.46
(d) Escrow Deficit
2,37S.96
(e) 5% Attorney's Commission
3,840.49
$ 87,219.73*
*Together with interest at the per diem rate noted in (b) above
after October 13, 1997 and other charges and costs to date of
Sheriff's Sale.
.. ."!' ."
' "'A ~&:; -.' - -
, ..,.:'
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the soldiers and Sailors Relief Act of 1940, as
amended.
10. Plaintiff has Complied with the procedures required by
Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage
Assistance Payments Program) and defendant has either failed to
meet the time limitations as set forth therein or has been
determined by the Housing Finance Agency not to qualify for
assistance.
, iI
. 1"
WHEREFORE, Plaintiff demands judgment in mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 8.375% ($17.62 per diem),
together with other charges and costs including ~scrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
KRUG & HALLER
By
Leon P Hall
Attorney for Plaintiff
I.D. 1115700
1719 N. Front StrEet
Harrisburg, Pa. 17102
(717) 234-4l78
. f:&..,-
TRUE copy FROM REOORD
! f' T a;,tlmony wMraof, I here II'*' lit ffP/ IlInd
.' "~ [1,6 ;J~.dI of said Coun at Carlllle. PI.
t:&- 'J
't;~~ .1?C;~~ t ~~~ ~~?
. I '
PI othollOlaIY
V~RIFICA liON
I, Annette Blazek, as the Assistant Secretary of the servicing agent of the
Plaintiff corporation within named do hereby verify that I am authorized to and do
make this verification on behalf of the Plaintiff corporation and the facts set forth in
the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statement therein are made subject to
the penalties of 18 Pa. c.s. 4904 relating to unsworn falsification to authorities.
Date:~_
~
Annette Blazek
Assistant Secretary
FLEET MORTGAGE CORPORATION f/k/a
FLEE~ REAL ESTATE FUNDING CORPORATION
.
,
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OF~I~;r '1~' :~H'I~!FF
(',', "
OCT 30 7 57 nH '97
\'. I.
PUj};;', VAil/A
II
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.
,
. ,
FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I have deposited in the U.S. Mails at
Harrisburg, Pennsylvania on "Q,/iqI Q'i' , a true and correct
copy of the Notice of Sale of Real Estate pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders of record by
regular first class mail (Certificate of Mailing form in compliance
with U.S. Postal Form 3817 is attached he~eto as evidence), and
also to the Defendants by Certified Mail, which mailing receipts
are attached. Service addresses are as follows:
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
r. .... J
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(.) ~'"
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Thomas B. Hamm, Jr. /
340 North 28th Street
Camp Hill, PA 17011
""
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
~
By
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
PURCELL, KRUG . HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102
(717) 234-4178
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 170ll
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
NOTICB IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached
hereto.
YOU ARB FURTHER NOTIFIED that the lien
real estate will be divested by the sale
opportunity to protect your interest, if
said Sheriff's Sale.
YOU ARB HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached Notice of Sale.
~
you hold a 'inst the said
/'ou have an
notified of
By:
Leon P. Haller PA I.D.15700
Attorney for Plaintiff
FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP,,:
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ZSTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICEI
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: JUNE 3, 1998
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner'S Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania l70l3
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
2021 HARVARD AVENUE
CAMP HILL
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 97 5995 CIVIL
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OP DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgag..
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
except~ons to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OP THE TIME AND PLACE OP THE SALE OP
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. 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 PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OPPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET
PREE LEGAL ADVICEs
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE AREs
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
Re: Fleet vs. Bogden
Cumberland Sale 6/3/98
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Postmark:
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA l7102
Postage:
One piece of ordinary mail addressed to:
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Postmark:
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In cOmDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
mail
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Postmark:
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Fleet MOrtgage Corporation
F/K/A Fleet Real Estate Funding
Corp.
-vs-
Louis S. Bogden and Sandra L. Bogen
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 97-5995 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law,
says this writ is returned STAYED.
Sheriff's Costs:
Docketing
pos t ing Bills
Advertising
Law Library
County
Mileage
Certified Mail
Levy
Postpone sale
Surcharge
Law Journal
Patriot News
Share of Bills
Poundage
30.00
15.00
15,00
,50
l.OO
l8.60
3.66
15.00
20.00
18.00
290.00
263.85
35.18
14.52
740.31 pd. by atty 6-3-98
$
Advance payment
Refund to Atty
lOOO.OO
259.69
Sworn and Subscribed To Before Me
This J" ~ Day of C)............
1998. A.D. n,...-<- O. /J,ktu~ ~J:;'
~, I
Prothonotary
So answ;;;;, ~ ~
r~)-.:..,-t:-r-'h ~
R. Thomas Kline, Sheriff
By ~iuh_ J.L/L.
eal Estate Deputy
FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP.,:
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 5995 CIVIL
VS.
LOUIS S. BOODEN AND
SANDRA L. BOGDEN,
DEFENDANTS
IN MORTOAGE FORECLOSURE
NOTICE OP SHERIPP'S SALB OP REAL EDTATE
PURSUANT TO
PENNSYLVANIA RULB OP CIVIL PROCEDURE 3129
TAXB NOTICB I
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: JUNE 3, 1998
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THB PROPBRTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
202l HARVARD AVENUE
CAMP HILL
CUMBBRLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 97 5995 CIVIL
is:
THE NAME(S) OP THE OWNER(SI OR REPUTED OWNERS of this property
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OP DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
dist ribut ion of the proceeds of sale in accordance wi th this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OP THE SALE OP
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you mor~ specifically of these
rights. I f you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE AREI
1. You may file a petition with the Court of Common pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BB FILBD BBFORB THB SHBRIFF'S DBBD IS DBLIVBRBD.
3. A petition or petitions raising the legal issues or rights
ment ioned in the preceding paragraphs must be presented to the
Court of Common pleas of th~ within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired. such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County COllrthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
l7l9 North Front Street
Harrisburg, PA 17102
(717) 234-4178
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Cumberland County, Pennsylvania, bounded and described
as follows:
BEGINNING At A polnt ot the South slde ot HArvArd IIvenue
(SlKty teet wlde) At the dlvldlng llne between Lots Nos. 167 AnI
168, Sectlon 0 ln the herelnAtter mentloned Plan ot Lots; thenc
Along IAld dlvldlng 11ne South leven (7) degrees twelve (1:l
mlnutes EAlt one hundred torty-Uve (145) teet to Lot No. 145
Sectlon 0; thence along sald Lot No. 145 Sectlon 0, South alghty
two (8:l) degrees torty-elght (40) mlnutu West shty-tour ani!"
elghty-tlve hundredths (64.85) tset to the EAstern llne ot Sout~
:lIst Street; thence Along the Eastern 11ne ot South :lIst Street
North nlne (9) degrees seven (71 mlnutes West one hundred twenty-
nln~ and t1tty-seven hundredths (129.57) feet to A polnt; thence
Along A curve to the rlght havlng a rad1us ot tltteen (15) teet, An
Arc dlstance ot twenty-tour and seven hundredths (24.071 test to A.
polnt on the Southern line ot Harvard IIvenue; thence along the
Southern line ot HarvArd IIvenue North elghty-two (82) degrees
torty-elght (48) mlnutes East, tUt.y-tour and two tenths (54.:l1
teet to a polnt, the place ot BEGINNING.
BEING Lot No. 168, Sectlon 0 ln the Plan ot College Park AS
recorded 1n the CumberlAnd County Recorder's Ottlce ln Plan Book 4
Page 108.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August 1B, 1993 in
Cumberland County Deed Book L 36, Page 1168 granted and conveyed
unto Louis S. Bogden and Sandra L. 9ogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
01-22-0536-163
PARCEL:
,
FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANT A
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
APFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 2021 Harvard Avenue, Camp Hill, PAl
1. Name and address of the Owner(s) or Reputed Owner(s):
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 1701l
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA l7011
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO~ 97-5995 _CIVIL teL.Ierm
CIVIL ACTION. LAW
TO THE SHERIFF OF __OJrnboirland_____COUNTY:
To salisfy the debt. inlerest end costs due Jle.et M:Jrtqaqe COrJXJration F/K/A Fleet Real
Estate F\Jndinq Corp. PLAINTlFF(S)
from__Ipu:i,.s S. Bogden and Sandra L. Bogden, 2021 Harvard Avenue, Camp Hill, PA 17011
DEFENDANT(S)
(1) You are dlreCled to levy upon the property of the defendant(s) and to sell please see leoal
descr; ption~_~__~ __
(2) You are also directed to attach the property of Ihe defendant(s) not levied upon In the possession of
GARNISHEE(SI as follows:
and to not~y the garnishee(s) that: (a) an attachment has been Issued; (b) the garnlshee(s) islare enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(sl or otherwise disposing
thereof;
(31 If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee. you are directed to notify hinvherthat he/she has been added as a garnishee and Is enjoined as above
stated~
Date: March 11. 1998
71 00
r,...tF> o,...rgPH Elt 529.78 (1O/97 to
6/98) 5238.74
Escrow deficit - $1,500.00
/I~-'l.~~
-t--'-pro:=l!,f1,vil DV""
~a-v\." P '-n;lrn-Mur-
( Depuly
L.L
Due Prothy
Other Costs
$.50
Amount Due $87,219.73 _________~~~_
Per diem of $17.62 from 10/13/97
Interest t.e-613/9S) $4T~--
Atty's Comm %
Atty Paid $lnQ.10
Plaintiff Paid
REQUESTING PARTY:
Name [.pon P. HElller. EHQ.
Address: 171 q North Front Street
H~rr; c:;h11rg PA 171 OJ
Attorney tor: PI ...inti ff
Telephone: 717-?14-417R
Supreme Court ID No~ 1 'i70D--________
~.
FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
Bankruptcy Dismissal
- ~~
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1::\11'0) SnTES IIANKRl'I'rn' COI:R'/'
MIIJDLI': DISTRICT OF PE:'>INSYI.VANIA
INIl.E:
BOGDEN.toUlS S,
CASE NO. 9lJ.01718RJW.l
CHAPTER 13
BOGDEN. SANDRA L.
Demonsl
NOTICE TO CREDITORS AND ornER PARTIES IN INTEREST
Notice is hereby given that the Coun has entered an Order dated December 14,1999 DISMISSING
the above-captioned case upon Trustee's Motion to Dismiss.
"
DATE: December 14. 1999
CIerIt. U.S. BankroplCY Court
228 WALNlTI'STREET
P.O. BOX 908
HARRISBURG. PA 17108.Q9OJ1
VAN.87
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FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP.,:
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
APPIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 2021 Harvard Avenue, Camp Hill, PAl
1. Name and address of the Owner(s) or Reputed Owner(s):
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
2. Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
5. Name and address of every other person who has any record
.
.'
lien on the property:
UNKNOWN
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
UNKNOWN
7. Name and address of every other person of whom the
plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS IF ANY...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17108-0845
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, 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. ~
L:on P. Halle~.
Purcell, Krug & Haller
l719 North Front Street
Harrisburg, PA l7l02
(7171 234-4178
1H5700
DATE: March 3, 2000
.f:!"
('
"
~LEET MORTGAGE CORPORATION F/K/A,
?:'EE7 R::AL C:S:'.=-.TE FL~JD!NG CORP. I :
PLA:::TIFF
IN THE COURT OF COMMON PLEAS
:':UNBE?:NTC C:t-:::-y, PE:-r.--!SYLVANIA
CIVIL ACTION - ~W
VS.
I..ours s. BOGDE:: ..~ND
SANDRA c.. Bom::=:::-!,
DEFEN:lANTS
NO. 9""'1 - 5S>?5 ,::-'/IL
IN MORTGAGE FOR2CLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICEI
Th3~ the S~eriff's Sale of Real Property (real estate) will be
he:':!:
DA::=::: WEDNESDAY, JUNE 7, 2000
TI~IE: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania l7013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
202l HARVARD AVENUE
CAMP HILL
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 97 5995 CIVIL
THE NAME(SI OF THE OWNER(SI OR REPUTED OWNERS of this property
is:
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OF DISTRIBUTION, being a list of ::!:e pers()ns M1d/or
govern~e~~al or corpcrate entlties or agencies bei~g entitled to
t-ecei.,e '03rt "'?" the croceeds of the sale recei.;-:d and t.o be
disbursed by the Sher::'f (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff ~f t::is c~u:;,:y thirty (30) d3YS af':.er the sale and
distdc'.:::::1 .. tho: oroceeds of sale inac:ordanco: 'lJtth this
sche.:\ule 'II::':'. :n :1::. be made unless someor.e cbJe::ts b, filing
ex:eptl:~s to :: w1th:n ten (10) days of the date 1t is filed.
I~:crmation about the Schedule of Distributicn may be obtained
from the Sheriff of the Court of Common Pleas. of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your propelty [rom being
taken away. A lawyer can advise you more specifically of these
rights. . I f you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, pennsylvania 17013
717-249-3166
Legal Services, Inc.
a Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARRI
I. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
E:~' a ;:'-:S3~~" ~:1a.jeq'.la~e price or for other ;:r:.per cause. Thi3
pe~itic~ MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. .; pet::.:.or. or petitions raising CL':e le'~3.: i.ssues ~r !'"igr.':s
me~:lo~~i in :~e preceding paragra~hs ~ust t~ p!'"esentei t~ t~e
c-:,~~.t c: :.:>mrr,cr: Pleas of the 'lIIithin County. 7:-.e pe~iti;:r: must be
served ;:~ ~he a~torney for the creditor or on ~he creditor before
p!:-:=sent;t: :,:)n ': = the court and a p!'"oposed :>rc-=!'" Or' rule must ce
ae:achei ~o ene petition.
If a spe=~fic return date is desired. s'.Ich date must be
cb~ained :rom the Court Administrator's Office - Civil Division, of
the ~ith~~ Cour:~y Courthouse, before a presenta~ion of the petition
to t:he Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & ~~LLER
Attorneys for Plaintiff
1719 North Front: Street
Harrisburg, PA 17:02
(717) 234-4178
.
..
,
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Ca~p Hill, Cumberland County, pennsylvania, bounded and described
as :ol1ows:
BEGINNING at a point at the South side at Harvard Avenue
(sixty teet wide) at the dividing line between Lots Nos. 161 ant
168, Section 0 In the hereinafter mentioned Plan at Lots; thenc
along said dividing line South seven (7) degrees twelve (12
minutes East one hundred torty-tlve (145) teet to Lot No. 145
Sectlon 01 thence along said Lot No. 145 Section 0, South elghtyr
two (82) degrees torty-elght (40) minutes West alxty-tour anl1'
elghty-tlve hundredths (64.85) teet to the Eastern line ot SoutH
21st Streetl thence along the Eastern line at South 21st Street
North nine (9) degrees seven (7) minutes West one hundred twenty-
nine and tHty-seven hundredths (129.57) teet to a polntl thence
along a curve to the right having a radius at tHteen (15) teet, an
arc dlstance at twenty-tour and seven hundredths (24.07) teet to a.
point on the Southern line at Harvard Avenuel thence along the
Southern llne at Harvatd Avenue North eighty-two (82) degrees
torty-elght (48) minutes East, tUty-tour and two tenths (54.2)
teet to a point, the place ot BEGINNING.
BEING Lot No. 168, Section 0 In the Plan at College Park as
recorded In the Cumberland County Recorder's Ottlce In Plan Book 4
Page lOa.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, Pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August 18, 1993 in
cumberland County Deed Book L ~6, Page 1168 grantect and conveyed
unto Louis S. Bogden and sandra L. Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
01-22-0536-163
,
..
.
Noles: If real properly, supply six copies of description including improvements and an original and copy of
aHidavit of ownership (PaR.C.P. No. 3129).
If lengthy personally list, supply four copies 01 list.
To index writ, lile separate praecipe with writ.
i\
.
.
.
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Curr~erland County, pennsylvania, bounded and described
as follows:
BEGINNING at a point ot the South side ot Harvard Avenue
(sixty teet wide) et the dividing line between Lots Nos. 167 anf
168, Section 0 in the hereinatter mentioned Plan ot Lots; thenc
410ng said dividing line South seven (7) degrees twelve (12
minutes East one hundred torty-Uve (145) teet to Lot. No. 145
Sect.ion 0; t.hence along said Lot. No. 145 Sectiort 0, Sout.h eight.Yr
two (82) degrees torty-eight (40) minutes West sixty-tour anp'
ei9hty-tive hundredths (64.851 teet. to the Eastern line ot Sout.~
21.t. Street; thence along the Ea.tern line ot South 2l.t. Street
North nine (9) degree. seven (7) minute. West one hundred twenty-
nine and tHty-oeven hundredths (129.57) teet to a point; thence
along a curve to the right having a radlu. ot tlfteen (15) feet, an
arc distance of twenty-four end seven hundredths (24.07) feet to au
point on the Southern line ot Harvard Avenue; thence along the
Southern line of Itarvard Avenue North eighty-two (82) degrees
forty-eight (48) minutes East, fHty-four and two tenths (54.2)
teet to a point, the place of BEGINNING.
BEING Lot No. l6B, Section 0 In the Plan ot College Park as
recorded in t.he Cumberland County Recorder's Ottice in Plan Book 4
Page 108.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, Pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August 18, 1993 in
Cumberland County Deed Book L S6, Page 1168 granted and conveyed
unto Louis S. Bogden and Sandra L. ,Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
01-22-0536-l63
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LAW OFFICES
PURCELL, KRUG AND HALLER
1711) NORTlII'RONT STREET
HARRISllllRli, PENNSYLVANIA 17102.2Jl}!
TELEPHONE (717) 2J4~417K
I'ORH'LOSlJRE DEP'f. FAX (717l2J4~1206
JOSEPH Nl5SliY 11910.19821
ANTHONY DISANTO
all COUNSlL
HERSHIY
10Q9 GOVERNOR ROAD
17171 53J.l116
NOTICE TOI
Louia S. Bogden
2021 Harvard Avenue
Camp Hill. FA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill. PA 17011
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, FA 17011
Eleanor J. Hamm
340 North 28th Street
Camp Hill, FA 170~1
DOHBSTIC RBLATIONS OFFICB
CUMBBRLAND COUNTY COURTHOUSB
HIGH AND HANOVBR STRBBTS
CARLISLE FA ~70~3
Stephen J. Dzuranin, Esquire
508 North Second Street
Harriaburg, FA ~7108-0845
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached
hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said
real estate will be divested by the sale and that eu have an
opportunity to protect your interest, if any, ~~~notified of
said Sheriff's Sale. ~~
By:
Leon P. Haller PA I.D.15700
Attorney for plaintiff
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OP DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitlec to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgage.
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be octained
from the Sheriff of the Court of Common Pleas of the within County
at the courthouse address specified herein.
THIS PAPER IS A NOTICE OP THE TIME AND PLACE OP THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. 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 PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OPPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICEI
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE AREI
I. You may file a petition with the Court of Common pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sherif f' s Sale YOll may file a peti t ion with the
Court of Common pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE PILED BE PORE THE SHERIPF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
ment ioned in the preceding paragraphs must be presented to the
Court of Common pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(7171 234-4178
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Cumberland County, pennsylvania, bounded and described
as follows:
BEGINNING at a point of the South elde of Harvard Avenue
(.lxty feet wide) at the dividing line between Lots Nos. 161 anI
168, Section 0 In the hereinafter mentioned Plan of Lots; thenc
along said dividIng line South seven (1) degrees twelve (H
minutes East one hundred forty-flvfl (145) teet to Lot No. 145
SectIon 0; thence along sold Lot No. 115 Section 0, South eighty
two (82) degrees torty-el9ht (40) minutes West shty-four anFf
eighty-fIve hundredths (64.85) teet to tho Eastern line of Sout~
21st Street; thence along the Eastern line of South 21st Street
North nine (9) degrees seven (1) minutes West one hundred twenty-
nine and fifty-seven hundredths (129.57) teet to a point; thence
along a curve to the right havIng a radius of fltteen (15) feet, an
arc distance of twenty-tour and seven hundredths (24.07) feet to..
point on the Southern line of Harvard Avenue; thence a!~ong the
Southern line ot Harvard Avenue North eighty-two (02 j degre..
forty-eight (48) minutes East. fifty-four and two tenths (54.21
feet to a point, the place of BEGINNING.
BEING Lot No. 168, Section 0 in the Plan ot College Park ..
recorded in the Cumbarland County Recorder's Otfice In Plan Book 4
Page 108.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, Pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August 18, 1993 in
Cumberland County Deed Book L 36, Page 116B granted and conveyed
unto Louis S. Bogden and Sandra L. Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOODEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
01-22-0536-163
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US Palla! SlIfVlco
Receipt for Certified Mall
Prf:J ,",-,,0..,:' Coverage Provided.
o '. -.1tW\na1 Mad (Se. ffWflfSe)
r SANDRA I
r 2011 HAR~~~gDEN
CAMP HILL P AVENUE
A 17011
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Recelptfor Certified Mall
No Insurance Coverage ProvMJed.
Do not use tor Inlematk>nal Mail (5" reve,,,)
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p 2021 HARVAR
CAMP HILL PAD AVENUE
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Re: Fleet/Bogden
Cumberland County Saie 6/7/00
U. S. POSTAL SERVICE
CERTIFICATE OP MAILING
(In compliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of Ordinry mail
Louis S. Bogden
2021 Harvard Avenu
Camp Hill, PA 1701
addressed to:
Postmarkl
u. S. POSTAL SERVICE
CERTIPICATE OF MAILING
(In compliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Sandra L. Bogden
2C21 Harvard Avenue
Camp Hill, PA 17011
Postmark:
.
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In compliance with Postal Service Form 38771
Received from:
Pur~ell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
Postmark:
. ~:::..... -':~-::- :~~ :
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U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
Postmark:
U. S. POSTAL SERVICB
CBRTIFICATE OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH k~D HANOVER STREETS
CARLISLE PA 17013
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In cOmDliance with Postal Service Porm 38771
/
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17108-0845
Postmark:
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FLEET NORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP.,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTIO~ - LAW
V5.
LOUIS S. BOGDEN AND
SANDRA L. EOGDEN.
DEFENDANTS
Ne. 97 - 5j~? CIVIL
IN ~IORTGAGE :ORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its a~torneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 2021 Harvard Avenue, Camp Hill, PAl
1. Name and address of the Owner(s) or ReFuted Owner(s):
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
.
4. Name and address of last recorded holder of everymortgag.
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
Thomas B. Hamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 17011
5. Name and address of every other person who has any recor4
lien GI: ::~~ pl'.:pe::ty:
UNKNOWN
". :;~\1117. ,:',:1 c\jh~"3;3 of e'/ery other per3cr. '.~;:o has any record
interest ~n ~he pr~perty and whose interest may be affected by the
;3:l>~;
UNKNOWN
7. Name ar.d addt-ess of every other person of whom the
?l:untl:: h:lS :':r.:>'..:led':Je who has any interest in :;-.e property which
may be a:fected by the sale:
TE~;.~ITS IE" A.'JY ...
;:;C:-:;::ST:: ?E:.AT::NS OFFICE
CUMaERLA.~~ COUNTY COURTHOUSE
HI':;H AN: :iANOVE" STREETS
CAR~ISLE?A 17J:3
Stephen :. Dzuranin. Esquire
50B North Second Street
Harrisburg, PA 17108-0845
(In the preceding information, where addresses could not be
reasonably ascertained. the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best vf my personal knowledge, 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.
,
~
Leon P. Haller- PA 1.0. #15700
purcell, Krug & Haller
l719 North Front Street
Harrisburg, PA 17102
(7171 234-4178
DATE: March 3, 2000
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LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OF DISTRIBUTION, beinq ,) llst ':JE ':he persons and/or
~'J'..~t'nn~~~:31 :~ 2~rpcr3te entlt18s 2r aJ~~:ies teing en~itled to
r-:-:~i'll= ":':lrt: ..,..: ':he t)roceeds of th~ 93lo:: r,;,c~lved :\nd to be
d!2::'.:rse:l bi' :~:e Sher~{f (for example, to banks that hold mortgages
and municipalities that are owed taxes) '/Jill be filed by the
Sh~::,iff =,f ':>.:':3 COU:1':Y thirty (30) daiS :\fr;~r the sale and
di.;::rll':"_::lon ~~ the proceeds of s:\le In 3.c::c,:n:dance 'Nith this
sc;:-::-j...~:~ ',':i1':", :.:: :i;: I be m,~dt~ unleas s~~:ecr.e cbje.::,:s by fillr.g
~X=~ptl:~a tc :: ~ltr.:n ten (10) days of the d3te it is filed.
In:=~~mat~:r. about the Schedule of Distdbutlon mai' be obtained
fr=m the Sher~:: of the Court of Common Plea~ of the w~thin County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may ha~e legal rights to prevent your property from being
taken awaY. 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 PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET PORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE AREI
I. You may file a petition with the Court of Common pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
~
Court of Common Pleas of the within County to Bet aside the sale
for a grossly inadequ~te price or :or other prop~r calIse. This
petlticm MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVF.RED.
3. A petlcion or petitions ralsing the legal issues or rights
mentioned in c~e preceding paragraphs must be pres~nted to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
,~ttached to the peti.tion.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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UNITED STATES BANKRUI"fCY COURT
MIDDI.E D1STRI(.'T Qt. pt.:NNSYI.VANIA
INRE:
BOODEN. LOUIS S
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CASE NO. 00.01454RJW.l
CHAPl'ER 13
BOODEN. SANDRA L
Deblor(l)
NOTICE TO CREDITORS AND OTHER PARTIES IN INTEREST
Notice is hereby given that the Court has entered an Order dated December 20. 2001 DISMISSING
the above-captioned case due to:
'I'ru3tec's Motion to Dismiss Case filed on November 8. 200 I.
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DA11!: December 20. 2001
C1crk, U.s. SInlaupccy COI.It
:m WALNUt' STREET
P.O. BOX 908
HARRISBURG. PA 171ll84J08
VAN-87
013114
.
FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP.,:
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
,:^NDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 2021 Harvard Avenue, Camp Hill, PAl
1. Name and address of the Owner(s) or Reputed Owner(s):
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 1701l
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
2. Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
Borough of Camp Hill
2145 Walnut Street
Camp Hill, PA 17011
[h)11I1 L. Snyder, Esquire
Penn National Insurance Tower
2 North 2nd Street - 7th Floor
Harrisburg, PA 17101
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
.~
TII""kl"; B. ILillllll, Jr.
;.10 North 28th StI~eet
CdllV Hill, PA 17011
Eleanor J. Hamm
140 North 28th Street
Camp Hill, PA 17011
'i. Name and address of every other person who has any record
lien l)l1 the property: UNKNOWN
.,.
interest
sdle:
Name and address of every other person who has any ~ecord
in the property and whose interest may be affect:ed by the
UNKNOWN
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale: TENANTS IF ANY ...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17108-0845
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, 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
'.1""0"'00 '0 .u'hor"'.,. ~
Leont'. Haller PA I. .-#15700
purcell, Krug & Haller
1719 North Front Street
Har~isburg, PA 17102
(717) 234-4178
DATE: March 12, 2002
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LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OP DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
recei ve part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OP
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. I f you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICEI
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE AREI
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense dgainst the person or company that has entered judgment
dqainst you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
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FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP.,:
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
SANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
RBTURN OF UERVICE
I hereby certify that I have deposited in the U. S. Mails at
H,HTisburg, Pennsylvania on 4-o'z- O"Z-, a true and correct copy of
the Notice of sale of Real Estate pursuant to PA R.C.P. 3129.1 to the
D~fendants herein and all 1ienholders of record by regular first class
mail (Certificate of Mailing form in compliance with U.S. Postal Form
3817 is attached hereto as evidence). and also to the Defendants by
Certified Mail. Service addresses are as follows:
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hil1, PA 17011
Borough of Camp Hill
21.5 Walnut Street
Camp Hill, PA 17011
Donn L. Snyder, Esquire
Penn National Insurance Tower
2 North 2nd Street - 7th Floor
Harrisburg, PA 17101
Thomas B. Hamm, Jr.
3.0 North 28th Street
Camp Hill, PA 17011
Eleanor J. Hamm
3.0 North 28th Street
Camp Hill, PA 17011
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Stephen J. Dzuranin. Esquire
508 North Second Street
Harrisburg, PA 17108-0845
'y /-
PURC2t~ KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg. PA 17102
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
'Jovenlmental or corporate entities or agencies being entitled to
n,cei ve part of the proceeds of the sale received and to be
cllsbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
di:Jt:!:ibution of the proceeds of sale in accordance with this
sch".dule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
[nformation about the Schedule of Distribution may be obtained
h'om the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. 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 PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICEI
cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania l7013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE AREI
1. You may file a petition with the Court of Common pleas of
'.he within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
"':I,lin:Jt you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
I...,: Fleet v. Bogden
I:llmbedand 6/5/02
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comDliance with po.tal Service Porm 38771
Received from:
purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Postmark:
U. S. POSTAL SERVICB
CERTIPICATB OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Postmark:
U. S. POSTAL SERVICE
CERTIPICATE OP MAILING
(In comDliance with Postal Service Porm 38771
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressee
Borough of Camp Hill
2145 Walnut Street
Camp Hill, PA 1"1011
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U. S. POSTAL SERVICE
CERTIPICATE OF MAILING
(In comDliance with Postal Service Form 38771
r~f,ceived from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In comDliance with Postal Service Porm 38771
Received fT.om:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17108-0845
Postmark:
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FLEET MORTGAGE CORPORATION F/K/A:
FLEET REAL ESTATE FUNDING CORP.,:
PLAINTIFF
VS.
LOUIS S. BOGDEN AND
S^NDRA L. BOGDEN,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
AFPIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 2021 Harvard Avenue, Camp Hill, PAl
1. Name and address of the Owner(s) or Reputed Owner(s):
Louis S. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
Sandra L. Bogden
2021 Harvard Avenue
Camp Hill, PA 17011
2. Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
Borough of Camp Hill
2145 walnut Street
Camp Hill, PA 17011
Dann L. Snyder, Esquire
Penn National Insurance Tower
2 North 2nd Street - 7th Floor
Harrisburg, PA 17101
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW 1 :
~
.
Thomas B. flamm, Jr.
340 North 28th Street
Camp Hill, PA 17011
Eleanor J. Hamm
340 North 28th Street
Camp Hill, PA 1701l
5. Name and address of every other person who has any record
lien on the property: UNKNOWN
6.
interest
sale:
Name and address of
in the property and
UNKNOWN
every other person who has any record
whose interest may be affected by the
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale: TENANTS IF ANY...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17108-0845
(In the preceding information, where addresses could not be
. . reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, 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
fa'.ific,"o" '0 ,"'hor"'o.. .... .~
Leon"1>.~. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 12, 2002
,
FLEET MORTGAGE CORPORATION F/K/A: IN THE COURT OF COMMON PLEAS
FLEET REAL ESTATE FUNDING CORP,,: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
CIVIL ACTION - LAW
VS.
LOUIS S. BOGDEN AND
flANDRA L. BOGDEN,
DEFENDANTS
NO. 97 - 5995 CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OP SHERIPF'S SALE OP REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OP CIVIL PROCEDURE 3129
TAKE NOTICEI
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: WEDNESDAY, JUNE 5, 2002
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner'S Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
202l HARVARD AVENUE
CAMP HILL
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 97 5995 CIVIL
THE NAME(SI OF THE OWNER(S) OR REPUTED OWNERS of this property
l' (C' .
~ .
LOUIS S. BOGDEN AND SANDRA L. BOGDEN
A SCHEDULE OP DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgage.
and municipalities that are owed taxe.1 will be filed by the
Sheriff of this County thirty (30) days after the sale and
dist ribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the schedule of Distribution may be obtained
from the Sheriff of the Court of Common pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OP THE TIME AND PLACE OP THE SALE OP
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
t.,lken away. 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 PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFPICE SET FORTH BELOW TO PIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICEI
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE AREI
1. You may file a petition with the Court of Common pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
d'Ylinst you. You may also file an petition with the same Court if
you dre aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
COlll-t of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petitIon MUST BB PILED BE PORE THB SHERIPF'S DEED IS DELIVERBD.
3. A petition or petitions raising the legal issues or rights
ment ioned in the preceding paragraphs must be presented to the
COllrt of Common Pleas of the within County. The petition must be
:IPrved on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
I f a specific return date is desired, such date must be
obtained from the Court Administrator's Office - civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4l78
.
ALL THAT CERTAIN piece or parcel of land situate in the Borough of
Camp Hill, Cumberland County, Pennsylvania, bounded and described
as follows:
BEGINNING at a polnt ot th. South ald. ot Harvard Avenue
(SlKty t..t wld.) at th. dlvldlng 11n. betwe.n Lots Nos. 167 an!
168, S.ctlon 0 In the h.relnatt.r mentlon.d Plan ot Lots; th.nc
along .ald dlviding 11n. South ..v.n (7) d.gre.s t....lv. (l~
minut.s East on. hundr.d torty-tlv. (1451 tut to Lot NO. 145
Section 0; thence alon9 said Lot No. 145 S.ction 0, South eighty
two (821 d.grees torty-elght (40) mlnutes West slxty-tour anj:(
.ighty-tive hundredths (64.851 t..t to the Ea.t.rn I1ne at Sout~
~lst Street; th.nce along the Eastern line at South ~lst Street
North nln. (9) degr..s seven (71 mlnut.. West one hundred twenty-
nlne and titty-s.ven hundredths (129.571 t.et to a polnt; thence
along a curve to the rlght havlng a radlus ot tltteen (151 teet, an
arc dlstance ot twenty-tour and seven hundredths (24.071 t.et to a.
polnt on the Southern 11ne ot Harvard Avenu.; thence along the
Southern 11ne ot Harvard Avenue North elghty-two (82) degrees
torty-e1ght (48) mlnutes East, tHty-tour and two tenths (54.~1
teet to a point, the place ot BEGINNING.
BEING Lot No. 168, Section 0 1n the Pien ot College Park as
recorded 1n the Cumberland County Recorder's Otfice in Plan Book 4
Page 108.
HAVING THEREON ERECTED a two story single brick dwelling known as
2021 Harvard Avenue, Camp Hill, pennsylvania.
BEING THE SAME PREMISES WHICH Thomas B. Hamm, Jr. and Eleanor J.
Hamm by deed dated August 9, 1993 and recorded August lB, 1993 in
Cumberland County Deed Book L 36, Page 116B granted and conveyed
unto Louis S. Bogden and Sandra L. Bogden.
TO BE SOLD AS THE PROPERTY OF LOUIS S. BOGDEN AND SANDRA L. BOGDEN
UNDER CUMBERLAND COUNTY JUDGMENT NO. 97 5995 CIVIL.
PARCEL:
Ol-22-0536-163
WRIT OF EXUVrlON ond/or '\TT'\CH~IENT
COMMONWEALTH OF PENl'SYLV ASIA!
COUNTY OF CUMBERLAND)
St) 97-S99S Chll
CIVIL AniON - LAW
TO TIlE SHERIFI' OF CllMBERL,\);U COl)NTY,
To salisfy Ihe debl. inlerestand co<ls due .~LU:T MORTGAGE CORPORATION I"/KlA .'LEET
REAL ESTATE .'UNUlNG CORP. PLANTlHIS)
From LOUIS S. BOGUEN ANU SANURA L BOCmEN
(I) You are directed 10 levy upon the propcrly of Ihe delendalll(s) and 10 sell SEE LEGAl.
DESCRIPTION OF PROPERTY
(2) You a.e also directed toa"ach Ihe properly oflhe defendanl(s) nOllevied upon in Ihe possession
of
GARNISIIEE(S) as follows:
and to notify th. gamishee(s) lhat: (alan attachment has been issued; (b) the gamisbc:e(sl is enjoined from
paying any debito or fur rhe account of the defendam (s) and from delivering any properly oflhe defendant
(s) or otherwise disposing thereof;
(3) Ifproperl)' of the defendant(sl not levied upon an subject 10 al!achmenl is found in:he possession
of anyone othe. Ihan a named gamishec. you are directed 10 nobfy himlhe. lbat he/she has been added as a
garnishee and is enjoined as above stated.
Amounl DueS87,1I9.73
J..J..
lnterest (PER U1El\J TO 517.61 TO 6/5/011 513,169.79
AUy's Conun 0/0
Due Prothy 51.00
Other Custs LATE CHARGES AT 519.78
(TO 6/011 51,378.31
ESCROW DEFICIT 55,534.17
Ally Paid 51,741.35
Plaintiff Paid
Date: MARCH 13,1001
CURTIS R. LONG
Prothonolary. Civil Division
By:
'1"~t.L rJ6/~, /}J
REQUESTING PARTY:
Name LEON P. HALLER, ESQ.
Add.e..: 1719 N. FRONT ST.
HARlUSBURG, PA 17101
Attorney fur: PLAINTIFF
Telephone: 717.134-4178
Supreme COUrl ID No, 15700
Real Estate Sale #52
On March 14,2002 the sheriff levied upon the
defendant's interest in the real property situated in
Camp Hill Borough, Cumberland County, PA known
and numbered as 2021 Harvard Road, Camp Hill,
and more fully described on Exhibit "AIt filed with
this writ and by this reference incorporated herein.
Date: March 14,2002
By: Jor/,.(/ SWti-{ h
Real Estate Deputy
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Unde. M No, 587, Approved May 16, 1929
Commonwealth 01 Pennsylvania, County of Dauphin) sa
Frank J. Epler being duly sworn according to law, deposes and says:
That he Is the Controlle. of The Pat.lot News Co., a corpo.ation o.ganlzed and existing under the laws of the
Commonwealth of Pennsylvania, with Its principal oHice and place 01 business at 812 to 818 Ma.kel Street, In the
Clly of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publlshe. of The Patrlot.News end..Ilul
Sundav Pat.iot.News newspapers of sene.al circulation, printed and published at 812 to 818 Market Street, in the
City, County and Slate afo.esaid; that The Patriot. News and The Sunday Patriot. News we.e established March 4th,
1854, and Septembe. 18th. 1949, .espectively, and all have been continuously published eve. since;
That the p.inted notice or publication which is securely altached he.elo Is exactly ss p.lnted and published In
their .egular dally and/or Sundayl Met.o editions which appea.ed on the 23.d and 30th day(s) of Ap.1I 2002 and the
7th day(s) of May 2002, That nellher he no. said Company Is interested In the subject melte. of said printed notice
o. advertising, and that all 01 the allegations 01 this statement as to the time, place and cha.acte. 01 publication a.e
true; and
That he has personal knowledge 01 the lacts afo.esald and is duly autho.lzed and empol,e.ed to verify this
statement on behalf of The Patriot. News Co, afo.esald by virtue and pu.suant to a .esolution unanimously passed and
adopted severally by the stockholde.s and board 01 dl.ecto.s of the said Company and subsequently duly .eco.ded in
the oHice for the Reco.ding of Deeds In and for said County of Dauphin In Miscellaneous Book "M".
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SA L E '52 NolaolalSU1' > .1' L~ ~A
T..ry L, RUII,_, Nof.1ry PUblic NO RY PUBLIC
Harrisburg, OaupNn CO~.mly
MV CCHM\lSlIOn Expires June 6. 20U2
MtmOIr, PennSylVania AsIocaaUOn of Notant.
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
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My commission expires June 8. 2002
Statement of Advertising Costs
To THE PATR;OT-NEWS CO" D..
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Probating same Notary Fee(s)
Total
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