The URL can be used to link to this page

Home My WebLink About97-06063 ~. ~ oJ ~ ~ b u 0- iI., f: ~ J " . i CORNERSTONE FEDERAL CREDIT UNION, Succeseor in Interest to the United Telephone Employeee' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 Civil Term Plaintiff v CYNTHIA L. QUIGLEY, Defendant IN MORTGAGE FORECLOSURE PRABCIPB: TO THE PROTHONOTARY: Please reinstate the Christophe C. Houston, Esquire Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 Date: ,>tlf(.,fj I I ii ;., .. ~ ..:J ~ LUQ c;, g~ U.... E?1 :r- .0>: gr.; D~ Is: 0\ ~~ - ~~ c;: ~'! Q:: F ~ IJ1 x: ~ ClCI -..l:O 0' ~ CORNERSTONE FEDERAL CREDIT UNION, Successor in Interest to The United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintif f v CYNTHIA L. QUIGLEY, Defendant IN MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of the above-captioned Plaintiff. Date: 3-/~-9'T Joh ily, s Attorney or Plaint ff Saidis, Shuff & Masland 26 West High Street Carlisle, PA 17013 717-243-6222 Please enter my appearance e Plaintiff in the above- captioned matter. l!/~(H Date: Christophe C. Houston, Esquire 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 ~ % ...::J ~~ t 0. t5 ..... ;;; ,... ~. c:)~ 0 Q\ :':Ijj 8: ~~ u:Ll...: cr- "1 ~ c:c lli E t's CO :s 0\ U LAW omces SAIDIS, GUIDO, SHUFF" MASLAND 16 W. HIOH STREET 1109 MARKET STUET CARUSLI!, PA 17013 CAMPiI1LL. PA 11011 POON8(111}14).6111 PHONE (117) 737.]0105 CIllITlI'lED COPY: . . '" '_"".-~;~"'i ;",'C'.__'^__~N. ~ .- -, , . , i , , , I . ;!' . \ , I , ~- ..~~~--:-..~.\~~ -. 7~' ~~!.f'c CORNERSTONE FEDERAL IN THE COURT OF COMMON PLEAS OF CREDIT UNION, Successor in CUMBERLAND COUNTY, PENNSYLVANIA Interest to The United Telephone Employees' Federal: Credit Union, Plaintiff v. NO. q7- t-OtAJ CUtJ~~ CYNTHIA L. QUIGLEY Defendant IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims s~t forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your def~nses or objections to the claims set forth against you. You are warned that if you fail to do so the case may pr.oceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 SAlDIS, GUIDO, SHUFF " MASLAND 26 W. Hiah S..... Carli"le. PA Joh eily, Esquir Att n for Plaintiff SAIDIS, GUIDO, SHUFF & MASLAND 26 West High Street Carlisle, PA 17013 (717) 243-6222 CORNERSTONE FEDERAL IN THE COURT OF COMMON PLEAS OF CREDIT UNION, Successor in CUMBERLAND COUNTY, PENNSYLVANIA Interest to The United Telephone Employees' Federal: Credit Union, Plaintiff v. NO. q...,- <.POCc3 CYNTHIA L. QUIGLEY Defendant IN MORTGAGE FORECLOSURE COMPLAINT AND NOW, comes the Plaintiff, Cornerstone Federal Credit Union, Successor in Interest to The United Telephone Employees' Federal Credit Union by and through its attorneys Saidis, Guido, Shuff & Masland and respectfully avers the following: 1. The Plaintiff is Cornerstone Federal Credit Union, Successor in Interest to The United Telephone Employees' Federal Credit Union, doing business at P.O. Box 1181, 5 East Gate Drive, Carlisle, PA 17013. 2. The Defend&nt is Cynthia L. Quigley, an adult individual residing at 81 East Main Street, Newville, Cumberland County, PA and the true owner of the mortgaged premises. 3. The Plaintiff brings this action to foreclose on a SAIDIS, GUIDO. SHUFF " MASLAND 26 w. Hiab SItUI Carlisle,PA Mortgage by and between the Plaintiff and the Defendant dated September 18, 1991 in the principal amount of Thirty-eight Thou~and Nine Hundred Seventy-one and 35/100 ($38,971.35) Dollars; a copy of said Mortgage is attached hereto and made a part hereof marked as Exhibit "A" and recorded in Cumberland County Recorder of Deeds Office in Mortgage Book 1047, Page SAIDIS. GUIDO. SHUFF " MAS LAND 26 W. Hiah SItUI Carlisle. PA 1119. 4. Said Mortgage is and contains a lien against all that certain tract of land situate in the Borough of Newville, County of Cumberland, Commonwealth of Pennsylvania, known as 81 East Main Street, Newville, PA 17241; a legal description is more fully described in the attached Exhibit "A". 5. Pursuant to the terms of said Mortgage, the Plaintiff advanced to the Defendant the sum of Thirty-eight Thousand Nine Hundred Seventy-one and 35/100 ($38,971.35) Dollars. 6. The Defendants defaulted under the terms of said loan by failing to make the monthly payment of $529.14 for the month of February, 1997, and subsequent monthly installments. 7. The Plaintiff has given to the Defendant a written Notice of Intention to Foreclose on said Mortgage as required by law under the Act 6, dated August 28, 1997; a copy of said Notice is attached hereto and made a part hereof marked as Exhibit "B". 8. The Plaintiff has given to the Defendants a written Notice of Homeowners' Emergency Mortgage Assistance Act of 1983, the Act 91, dated August 28, 1997; a copy of said Notice is attached hereto and made a part hereof marked as Exhibit liCit. 9. To the best knowledge, information and belief of the Plaintiff, the Defendant has not availed herself to the protection of the Homeowners' Emergency Assistance. 10. The amounts due and owing under the terms of said Mortgage are as follows: , i Ii ]! ,I Ii :1 :1 A. Principal Balance: $27,006.07 B. Interest @ 10.75\ until 10/31/97 1,313.88 E. Attorney Collection Fee: 1.350.00 $29,669.95 WHEREFORE, the Plaintiff prays Your Honorable Court to enter a judgment in favor of the Plaintiff and against the Defendant in the amount of Twenty-nine Thousand Six Hundred Sixty-nine and 95/100 plus interest at 10.75\, plus costs and sale and foreclosure of the mortgaged premises. Respectfully submitted, SAIDIS, GUIDO, SHUFF. & MASLAND Dated: /0.;2'1-9:;' eily Esquire 26. st 19h Street Carlisle, PA 17013 (717) 243-6222 Attorney for the Plaintiff SAlOIS, GUIDO, SHUFF '" MASLAND 26 W. Hlah SItU! Carlisle, PA \, / THIS MORTGAGE midi Ihis ...~.~.~.~..... dlY ol ....~.~P.~.~.'!'.~.~.~.................. 19..~.~.... b.tw..n................................ Cynthia l. Quigley, single person 81 E. Mein St., Newville, PA 17241 .............................................................................. of ................................................................................ /ldd,.,,) . Morts.sor. .nd United Telephone Carlisle, Pennsylvania 17013 " " I" (1 ./:>..1.- (-'dr I~ \, ~', //Jj 1'"/1 /"?t'.' " MORTGAGE bPl~;:~~;i...;:~d~~~l..c~~dit..ii~i~~.:.........p.:ii.:..ii~x 1181. . IVITNESSETH l11at Morrsasor hu .x.cuI.d and delivered 10 the MorrS.s.e . note or olher obllsalion on thl. ~ale In lhe \ . lum of 3 ..J.\l...nl..:lii........ wllh Inleresl th.reon .t l11e rate Ip.clnod ther.ln and requlrlns tho performanco o( alllho I;.'m.. co;.nanlllnd cond'tlon. Ih.r.ln contaln.d. III of which are m.d. . parr hereof .nd Incorporared horeln by refer. ence: and as d.ldlnce o( ,aid Indebledon. o( MOrllasor to Mortl'I.', ,nd .. secority (or p.ymool a' ."id n',,, or "Ihcr ""lip lIon whh Inlerell and mlendfns. to b. le,ally bound hereby, MOrll,sor doe. hereby grant and convey unlo .\Iurll.goo. . ~lIlhaf ceruln piece o( I.nd whh the Impro.emonll thereon erocled Ihual. In Ih. cily or lawn o( ....NllWv.iJ.J.e........... .................................................. County of.......J;Jj(l)tll'lr.J.l\mt............ and Slate o( PA known Ind Id.nllned .. . more parllcularly 81 E. Main St., Town of Newville, County Of Cumberlend, PA 17241 See ATTACHED as dmrlbed In dud In name(.) of .....(:.Y.I).~!)J1..h.....g\!~.[[tg.Y.,...~A!')!It!!..p.!!r.~.~D.................................................. darod .........J/.~{.~?.............................. and recorded In book .. ...~.?~............... Pag... .....Ui!.~......... .. IOIOlhor Ylllh all bulldlngs.lmpro.oment.. rights of way. right. and privil'le.. heredllam.nll and .ppurlonance.. .nd Ih. re""lon.. remalnd.rs. renll, wues and prOnlllhereof. MOrlg'lor co..nanll .nd WI".nlS Ih.1 MOrlgagor has full (.e Ilmple litle to premlln .bove dncribld.lexcepl a. olherwlse IpeclOcally dllcloled In wrillns to Morlg.gee). Ihal Morlg.gor will pay Ihe full deb I 01 required by sold nore or olher obllgallon; lhat the bulldlnSS on the preml.e. shall b. kepI Inlured 'gall1l1 IUI. by Ilre .nd other casU.lly (or benelll of Mortgagee in .mounll ..lllf.ClOry 10 Mortgagee. wilh standard Mortgagee c1au.e; and Morlg.sor will pay any lax. 31111I. menl. municipal Of other sovernmenlOl charge. Including w.ter and lewer renll charged 10 laid premi.e.. and will dell.er to Morlgage. recelplI therefor Immedlalely upon demand. If Mort,a,or f.il. to pny any In'I.lIm.nt of princlp.1 .nd/or Inlere.1 required by sold nOle or olh.. oblil!lllion. when rhe \alll~ \halll'all dll~ rh~ un raid b:1J:Jnl.:! IJi' "..iLl debt \hJII h-=t.:ulT1c tlu~ ;.lf1d r;Jyabl~ at rhe option of MlJrrg:lgee. as provided In ,he nule or olher oblig:Ulon. to Ih. ""'enl permitled by law. 'f MOllgagee retoln. an 3Itorney 10 In.Ulure .cUon on sold nolt or other obllg3l10n or .n acUon of foreclo.ure on lhi. mOrlg'ge. MOllgagor .hall P'Y. In .ddillon 10 the principal. InlereSl. and CO.l.. . reason.ble OftorneY'1 fee; and if a luda. menl I. entered In fovor of MOIIg.ge. .gainSl MOllgagor In sold .uil and MOllgage. Ihere.fter Issue.. Wril of E..cutlun or olher .ppropriale writ. Mortgagor waives all right. .nd benenlS under any 3nd .1I13w. or rul.s of th. COUrl now or here. after in erfeCI. granUng or p.rmllllng .ny exemplion or .l.y of execution 3gainll the rnorlg3ged premi.e. or any olh.. properly whatsoe.er. and lUch Judgment Ih.1I beal IntereSl alth. maximum legal rale untlllhe full ~mounl of Ihe ~Ibl i. actually paid to Mortg3gee. The word "Mollga~." Ihall be construed to Include IUctmon and asslgnl of Mortgagee. and lhe word "Morlgagor" shall b. conSlrued 10 Includ. the respecUve heln. ..eculors. admlnl.trOfoll, ,ucce"ors 3nd assigns of MOIIgagor. If Ih..e i. more Ih.n on. pally named herein as a Mortgagor. the word "Morlgagor." whene.er occurring. .hall be deemed .nd t.k.n to be Ihe plural; and all covenants. walven. wan.nlS. promise.. and rel...e. by and lh. ohllg:lllon. or lIabillUe. imposed "pon. MOllgagor under thJ. mortgage and the afore.ald nole or olher obllg:ulon .hall bind Ihem joinlly 3n~ .ever3l1y. Its. his. her. and their. and each of Ih.lr re.pectlve heirs, exetuton. admlnl.lralon. ,ucce"ors and as.lgn.. IN WITNESS WHEREOF. and In lending 10 be legally bound hereby. MOrll3gor has he..unlo .el h.nd 3nd .e.llh. day and year nrsl abo.e wrimn. \VlT~ESS OR ATTEST: , J' . ,.. ., "..,,: J.:"" oj,... .:..J..C !... i..... :/.... ..'::!.!Lr..!1..:::..fa;.u..u...... ............................................................................ i . , I " , { 1';./ '/ , I' I t I "I ,,,,, (". (SEAL) .... C;rrthi~"i::'; iiG'i!]'i~.y.l.:........!..i.'................ .... ...... .................... ............... ..... ................ ........1 SEAL) .........................................................................ISEAL) ........ .................................................................... .....................................................u..................... :........................................................................ISIAl.l "'O~M 000 Ot lSl . boOK: I 04 i 1'~G.d J IU Exhibit "A" / r: CORNERSTONE r l' rI {' rill (' ,Ifemlx', iJ/lI/ded r f' rI i I II 11 . .\I'/7';('e based i 4') Il r.o. Bnx 1181, 5 Ea~1 Gale OriVl', Ca"i~le. f'A 171111 Telcllhone (717) 2-I~.I6(, I r AX (717) H'/1I2ll8 August 28, 1997 Ms. Cynthia L. Quigley 81 E. Main street Newville, PA 17241 kOTICB 01 i>>t*NTioH TO rOR!ctoSB kOR~QAQB The mortgage held by Cornerstone Federal Credit Union (hereinafter we, us or ours) on your property located at 81 E. MAIN STREET, NEWVILLE, PENNSYLVANIA 17241 is in serious default in the amount of $3,549.68 because you have not made the monthly payments of $529.14 for six months because of personal reasons. No other charges have accrued on this account as of this date. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $3,549.68 made up of $3,549.68 in regular monthly mortgage payments. You mar cure this default within thirty (30) days of the date of th s letter, by paying to us the above amount of $3,549.68, plus any additional monthly payments and charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check, or moner order, and made at 5 East Gate Drive, P.o. Box 1181, Carl sle, PA 17013. If you do not cure the default within thirty (30) days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will bd considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within thirty (30) days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the sheriff to payoff the mortgage debt. If we refer your case to our attorners, but you cure the default before they begin legal proceed ngs against you, you will still have to pay the reasonable attorney's fees actually incurred, uf to $50.00. However, if legal proceedings are started aga nst you, you will have to pay reasonable attorner's fees even if they are over $50.00. Attorneys fees w 11 be added to whatever you owe us which may also include our reasonable costs. If you cure the default within the thirty-day period, you will not be required to pay attorney's fees. MrMnrR ~.\VINr;~ "rrrJtINr~ rF/lrR^,1 y IN~IIRrrl HI ~In/l,nnn IIV Till NMIONAL tRr/lIlIINION A/lMINlqRAJlClN Exhibit "B" .----..-----..-..-- -2- We may also sue you personally for the unpaid principal and all other sums due under the mortgage. If you have hot cured the default within the thirty-day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anr time up to one hour before the Sheriff's foreclosure sa e. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then clue, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a sheriff's sale could be held would be apprOXimately March, 1998. A notice of the date of the sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You mar find out at any time exactly what the requir.d.pa~eht ~i 1 be by calling U~ at the followitllj IlUtMldl': I , (111) ~4!lill11!l1. '1'hi4~aY1ildHt InUst be in cash, cashier's chsck, certified cheCk, or mone~ order and made payable to us at the address stated above. YoU should realiZe that a sheriff's sale will end your ownership of the mortga~ed property arid your ri~ht to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit coUld be started to evict you. You have additional rights to help protect your interest in the property; You have the right to sell the property to obtain money to par off the mortgage debt, or to borrow money fro~ another lend ng institution to paYoff this debt. (You may have the right to sell or transfer the property SUbject to the mort~age to a buyer or trahsferee who will aesume the mortgage debt, provided that all the outstandin~ payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements under the mortgage are satiSfied). Contact us to determine Under what circumstances this right might exist. You have the right to have this default cured by any third party acting on your behalf. If you cure the default, the mortgage will be restored ttlthd '41i11'"pcs!t:()/,.,U' it I1tl detault had OCCUrrEld. However, you are'not'ehtitled to this right to CUre your default more than thriA times in any caleridar year. ~/.I'7~ David G. Keffer Manager ./ ~ CORNERSTONE F t' II l' , ,1 I C r (' d ill' II I " II ,Ifember fiJl/llded - Sl'I7'ice !Jt/sed r.o. Box llHl. 5 E,1<1 Gale Driw. (arlisl", PA \70\1 rell'phonl' (71 71 201'/.1661 rAX (7\7) 2-").8108 IMPORTANT' NOTICB OF HOMEOWNBRS' BMBRGENCY MORTGAGB ASSISTANCB ACT OF 1983 PLEASE READ TillS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS. Date. August 28, 1997 RB. Account No.1 795-0. TOI cynthia L. Quigley FROM. corneratone Faderal Credit Union "Your mortgage is in serious default" because you have failed to pay promptly installments of principal and interest, as required, for a pericd of at least sixty (60) days. The total amount of the delinquency is $3,549.68. That sum includes the following: $ 2,471.89 $ 1,077.79 $ -0- - Principal - Interest - Other Charges "You may be eligible for financial assistance that will prevent foreclosure" on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act' tsl 1983 (tho hAct'I). You may be eligible for emergency temporary assistance if your default has been caused by circumstances berond your control, and if you meet the eligibilitr requ rements of the Act as determined by the Pennsylvan a Ilousing Finance Agency. "Please read all of the Notice. It contains an explanation of your rights." Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you (have the right to) must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. .. MEMBER SAVINGS ACCOUNTS fEllERALL Y INSURED TO Sloo.ono RY filE N^,IONAL CREIJIT UNION AIJMINI~'RATlON Exhibit "c" -2- If you attend a facs-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of that meeting_ The name, address and telephone number of our representative iel David G. Keffer, Manager 5 East Gate Drive P_ O. Box 1181 carlisle, PA 17013 (717)249-2923 <.Th. nlMs and'add~181,~t a desi~nated consUmer oredit ooun.eliHq agehcY!sl . consumer Credit Counseling 2000 Linglestown Road, suite 203 Harrisburg, PA 17111 (717)541-1757 tt is only hece~sarr to schedule one face-to-face meeting. You should adv se this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after rour face-to-face meeting, you have the right to apPlr for f nancial assistance from the Homeowners' Emergenoy Ass stancs Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Consumer Credit Counseling the designated consumer credit counseling agency listed above. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agencr' "Your application i' i,mua1o.bel'.(J.led orl'Pcstmarked, within th rty (30) days of your '. tatili.t:t1Alllco ml!l8tift(lI"' . , (YOU must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agency listed above). The Pennsylvania Housing Finance Agency is located at: 2102 North Front street P. O. Box 8029 Harrisburg, PA 17105 Telephone No: (717)780-3800 or 1-800-342-2397 (toll free) , , -3- An application for assistance may be obtained from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. "It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately" and you will forefeit your eligibility for assistance. Available funds for emergency mortgage assistance are very limited. Ther will be disbursed by the Agency under the eligibility cr teria established by the Act. "It is extremely important that your application is accurate and complete in every respect." (The counseling agency will help you to fill out the application.) The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front street, Harrisburg, PA 17105. Telephone No. (717)780-3800 or 1-800-342-2397 (toll free number). You have already received another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Very truly yours, ~~.i(~ David G. Keffer Manager ~~. 0; : .- .' , : I-' j Iii"'i ~ ~lo -.......: - . jE . . . i-o ...$TRf J~~~.~ .... . --- :..: . ri . . , '"" . ~ ~ ~ . ~~ ~ ~~ ~ .' ., ~J ~ ~~ C\ IV) ~ ~ ~\ I. r CORNERSTONE FEDERAL CREDIT UNION, Successor in Inte~est to The United : Telephone Employeed' Federal: credit Union, Plaintif f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-6063 civil Term CYNTHIA L. QUIGLEY Defendant IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Please reinstate the above-captioned Complaint. SAIDIS, GUIDO, SEUFF " MAS LAND 26 W. Hiah SItU! Clllisle,PA ... >- ('oj '>- cr; U": F;: ~~ N :;1.:t ':.1;.\,_ ,- . :It: '~.::: -('., ~ ;,. "-. ":,2:i 1...- C' 0 ~ ~' ~I? f.? .;:. M __I..:. IT!~, ~t: ;;'i (....l '.,lll.l .1. u/ {Q~ 1-" = .... u. r- :;; (;.1 0'\ U ill ..,t':[ ~i' it"ti:LlL~Vf\~I::\: . >: i :~hLA ~~~, . _:. ___L~:_~_JEht.'-h-.~~;::t;.LL_ 1.:11'-': A.....L.______ :~.:J'~bi...._JU...J..1~______., .~h~__'.rlfi.. 'Wh,J b,.'j.ng ,ju1l z'IIurn ac:cordlf.j Jo/, J'i..:.;, '.l,'3t h~' r!\...ldt? ~ 'JlJ.l'\.)\:nt, ;:'';.;';',jrr~h ,Jnd -lnqU.lf'l 10t- th~ '1Iltt.lfi j.-'1.-'i\j:Hj~.. t'.' -";1 t.: _UI..ll_l,LE'i C'{llTHIA L ... LJ IH\dltl.;' 1,0 i<JI:;J,"wf? --11~_ 1r1 his biJillWick. ~I~ ther~1()r0 [-~tu~rl~ ,,' ,:'LU-_A! fiT MI~'f(r FijP,E n" 'f i,____.__._____ ~_'_~_._:l;_. ..!-; t~(. t.h~ ....It.hlrl lidmo;:.j d~l.f~.r:jiJClt ','- --" ~';:.Jl:T!l.Li_ L .:---;:'..... H'\:;_.J1El'JLAT THE F:['_;1C'EtI<:E_llEn_1'UUTILc; AliE ~1:. '.',. 'n' _:~',:"':""_l :;~_\l_T_ .~'J.-U~_-E..EF~Ij'::E~ Tt--f AU'3..WEE THE L'QCiFL .~ (' ~, , _') ~r"'WL'~~~ ft. ~r:r;:r7~ -.- ,).,'..:rrr------ ..t." . k t~' ~ 1 f1':;1 l,'~~. Di...:.1 1 -t. -:..\ ~_~ . ..' '.~I ..~\. ,-~0 .\':'!.. I"'''' 'I ii,_1(: .:-.rr.-,::--:::- '~(\ri.j!_. UUIL<j ,-,HUFF ~ ;,J~:,' i ':f:';':' 1.1,'.'1 '1'1 ll\_~t\.i..' I 'J J .i Z,.. ..:,; ,_ : -l b.;;,..; ,~ ''':' ;: ._' 1 l' ~':" ,:, ':;' J_,..,.{. 1,;/ 0! U"'!__I_ 'Il ;" : n'--::-J~r.c;r'r~r-~A . l '_/.Il.(i". I. / SHERIFF'S RETURN - REGULAR CASE NO. 1997-06063 P COKKONWEALTH OF PENNSYLVANIA I COUNTY OF CUKBERLAND CORNERSTONE FEDERAL CREDIT VS. QUIGLEY CYNTHIA L DAWN L. KELL . Sheriff or Deputy Sheriff of CUKBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COKPLAINT - KORT FORE was served upon QUIGLEY CYNTHIA L the defendant, at 14~1100 HOURS, on the ~ day of Karch 19~ at 81 EAST KAIN STREET NEWVILLE. PA 17241 .CUKBERLAND County, Pennsylvania, by handing to CYNTHIA QUIGLEY . true and att.sted copy of the COKPLAINT - KORT FORE together with NOTICE and at the same time directing ~ attention to the contents thereof. . . . Sheriff's Costs. Docketing Service Affidavit Surcharge 18.00 7.44 .00 6.00 So answ.r~ -~4...;- ~ I ..-:;-~~ ~ R. Thomas Kl1n, er f; .31.44 cHRISTOPHER 03/27/1998 by C. HOUSTON C. 11 ~\1l':'):6 ~. l~tL Deputy I> er1%f Sworn and subscribed to before me this .2/ ~ day of 7)1." LJ.-/ 19 Yf A. D. \-..f.,t~ Vr ~I_ft-' #' , rot ano ary , CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff CIVIL ACTION -LAW v CYNTHIA L. QUIGLEY, Defendant ACTION OF MORTGAGE FORECLOSURE RBTURN OP SERVICE POR SBRVICB OP NOTICB OF SHBRIPP'S BALB OF REAL PROPERTY PURSUANT TO P~SYLVANiA RULB OP CIVIL PROCEDURE 3129.2 I, Christopher C. Houston, Esquire, certify that I served Notice of Sheriff's Sale of Real Property pursuant to Pa.R.C.P. 3129.2 by first class mail, postage prepaid, on May 8, 1998, with copies of Certificates of Mailing attached hereto, on the following: Cumberland County Tax Claim Bureau Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Christop er C. Houston, Esquire Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 Sworn and subscribed to before me this ~ day of y, 1998. Notary J , 4.J - .... .-'.--.- c.........r .1 ......c-,.'A My ,. . ................. t& .. 1 U... POITAL I'''VIC' CEIlTIPICATI Of MAILING Christopher C. Houston, Esquire 52 West Pomfret Street Carlisle. PA 17013 Ell ,........,,-; ,:",'rl,nUII .;;;.:i7I,.-:.;:-, coo:' l ON ,... of ....., mM ..,...., to Cumberland County Tax Claim Buresu Cumberlsnd Co. Courthouse/One Courthouss Sq. Csrlisle. PA 17013 ........- II UlIO 11I011 DOMIITIC AND INTIllINATIONA" ".11.. 0011 HOT ",OYIDI 'OflIIHlURANCI -I'OIUlIAaTUI ~:?:1~ Sill t1 GPO: 1977-15o-Ul II ) .I { l " l'- 0' I:: ,~. I , " , ; , , ( ,. L ~ ) ;,,l.... - " e: J U ~,~ ,) -n I . ',j" .~ '.' -', (.;--/ .,.-,.;,-",,-.;.' ~ : " tE&1~~:)~:~;o\~:~~;C_ " . " .' "Y" .." ,,", -' "'QJ I_J8lC.tIDUI'fON " ;:It:E,'~~,":'''=: , ",..:c.","'''' <c.;:';' ";, !""', ,0 ._1'1.~1-81t7O MX:71N41-t11O ;~&;;:?y<::;~~~}~t~;,\~~?",~ ' . .:~'- ':'",:- ,.- ".""-";' ',:,1 .. .-~ ,.,-1: '-,,'; ',1, , -~' .,', '-'-'....' . I I ~...- -' ...:...;;.....-~-~ \ \ :--..- '.~ ;;,,"-...:..::.- -. - -....- CORNERSTONE FEDERAL CREDIT UNION, Successor.s in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff v CYNTHIA L. QUIGLEY, Defendant IN MORTGAGE FORECLOSURE PRABCIPB TO THE PROTHONOTARY: Please enter judgment against the Defendant, Cynthia L. Quigley, in the above-captioned matter for failure to file within the required time an Answer to a Complaint which contained a Notice to Defend. Written notice of intention to file this Praecipe was mailed in accordance with Pa.R.C.P. 237.1 by first class mail to the Defendant, copies of which are attached to this Praecipe. Enter judgment for $29,979.48 plus interest costs. Date: ~k1h1 f , Christophe C. Houston, Esquire Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 . .,.. .:r iT.; c: (;: ." ~ ~ .. "J n ..:l , );;; I.U'4:_ c ') ~..: >", -.... "'.';,.. 'j:ct tt:r l.l... TJ;:j Yo: (/, ' ..(} E2' ('-...i :1 ;.~_ '. "j:O .Jl1 ~ ': t u.. -, 'I.. ;', '0- f" ... -f. .... en ~') 0 0' 0 CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff v CYNTHIA L. QUIGLEY, Defendant Defendant I IN MORTGAGE FORECLOSURE . . '. TO: Cynthia L. Quigley c/o Robert Quigley 803 Factory Street Carlisle, PA 17013 Cynthia L. Quigley 81 East Main Street Newville, PA 17241 DATE OF NOTICE: April 16, 1998 :IMPORTANT HOTrCB YOU ARB IN DBFAULT BECAUSB YOU HAVE FAILBD TO TAI<E ACTION REQUIRED 0' YOU IN TIllS CASB. UNLBSS YOU ACT WITHIN TEN (10) DAYS FROM THE DATi!: OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSB YOUR PROPBRTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE nlls NOTICE TO A LAWYBR AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONB TIlE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBBRLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, pA 1701] n~~ Christopher C. Houston, Esquire Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 ., 717-241-5970 , " t.'~ ~.: , - fJ'C' ( ..,:; p...:( C);~ , I ~:,i,' L:: : I. LL c.J ..:s' e: .cz ,c .~. ~) -)'~ "i: (l4 . , _C. ..,..__l ~;., (-.3 -:!",,; Cl '" r.' ,.' .:.. ":) 0' , 'J '-i~ ....-... :~ d CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff v CYNTHIA L. QUIGLEY, Defendant IN MORTGAGE FORECLOSURE CBRTIPICATB or SBRVICE I, Christopher C. Houston, Esquire, do hereby certify that I served a Notice of Default by first class mail, postage prepaid, on April 16, 1998, directed to the following: Cynthia L. Quigley c/o Robert Quigley 803 Factory Street Carlisle, PA 17013 Cynthia L. Quigley 81 East Main Street Newville, PA 17241 Christoph r C. Houston, Esquire Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 Sworn and subscribed to before me this ~rh day of April, 1998. ~U\A..,..l _J.-A<"U.l.-' Notary Pub1--!c -- _.......-,- ~_- ~~'A .,- . --...- ~ '=t c: >- ~ .~ 0"- W' i':: ..; c;.; .0 ~ ~ ,.. .." :::c: "lit:" .. "- c.,.;-' ~7 ...J _ t' .'. ..... -- . .'} :".~ ~ 'I[) .. ~." L_ ~ ~.,:) , . '}-', C' a. -a. t>C> -;. li1 c-.. c:' . J '"..- ~ .:::::' ... .:..,.: .::w: ;- t... "-';.0 ~ CJ u ... .::'.0. .- I.l~ ~ ~ ~ L: to' ~j ~ <11 U <:J at I r I nr Tn COURT or COMMON PLaA9 or cmm..'.a.un COUH'l'Y. PDlHSYLVAlfIA. CIVIL DIVIBIOII Plaintiff I FILE NO. 97,6063 CIVIL TERM I Amount Due $29.979.48 Intereat from ~/29/98 at S7.9~~ Der day Atty's Com Costs CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, v CYNTHIA L. QUIGLEY, Defendant TO THE PROTHONOTARY OF THE SAID COURT, The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAlCIPI FOR IXlCOTIOII Issue writ of executian in the above matter to the Sheriff of cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 81 East Main Str@@t. N@wville. Cumberland County. PA 17241 PRAlCIPI FOR ATT~rRVWNT IXBCOTIOH Issue writ of attachment to the Sheriff of County, for debt, interest and costs. as above, directing attachment against the above,named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of said garnisheefs) . _____lIndicate) Index this writ against the garnisheefs) as a lis pendens against real estate of the defendantfs) describ~ed e attached exhibit. DATE, t' /.., ~t5 Signature,__ J-+-P- Print Name: Christooher C. Houston. Esauire Address: 52 W@st pomtret Street Carlisle. PA 170123 Attorney for: Plaintiff Telephone: 717-241-5970 Supreme Court 1.0. No.: 36502 . (/ .,. (") ~ iT~ I.r. "-l. .. - , :...:' , , . I'J - S'. , -:~j v l ': , r-- .- I L' ;;"-,j ".-_1 ;c-: !~ L:.... ~ ,. :i:: ~) I.. c,., U '-' cr> t- ~ ....) ~ ~ ~ ~ ~ ~ 1"=11 t.; cJri. t);: ~ ~ 1; ~ r-I () 0 () 00 ~o (";) (no~~~~^ ~~ In ~ ;=;,., .~ ~ ....,...,. "' ..... ~ .~ t:!3-.< I 1 Oa () , '" CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff CIVIL ACTION - LAW v CYNTHIA L. QUIGLEY, Defendant ACTION OF MORTGAGE FORECLOSURE AJrIDAVIT PURSUANT TO RULS 3129.1 (Affidavit No. 11 CORNBRSTONB FSDSRAL CRBDIT UNION, Succ...or. in Int.r..t to the Unit.d Te1.phon. Employ...' F.deral Credit Union, Plaintiff in the above action, by its attorney, Christopher C. Houston, Esquire, sets forth as of the date of the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 81 BAST MAIN STREET, NEWVILLE, CUMBERLAND COUNTY, PA 17241. 1. Name and address of Owner(s) or reputed Owner(s): NAME: LAST KNOWN ADDRESS cannot be reasonably please so indicate) (if address ascertained, CYNTHIA L. QUIGLEY 81 BAST MAIN STREET NEWVILLE, PA 17241 c/o ROBERT QUIGLEY 803 FACTORY STREET CARLISLB, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME: LAST KNOWN ADDRESS cannot be reasonably please so indicate) (if address ascertained, Same all above. 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: HA.MIi; LAST KNOWN ADDRESS cannot be reasonably please so indicate) Non.. (if address ascertained, 4. Name and address of the last recorded holder of every mortgage of record: HA.MIi; LAST KNOWN ADDRESS cannot be reasonably please so indicate) None. (i f address ascertained, 5. Name and address of every other person who has any record lien on the property: NA.l!1:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) ( if address ascertained, CUMBBRLAND COUNTY TAX CLAIM BURIAU CUMBERLAND COUNTY COURTHOUSB ONE COURTHOUSE SQUARB CARLISLE, PA 17013 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: NA.l!1:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) Non. ( if address ascertained, 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAMJ:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) (i f address ascertained, NON!:. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. (/1ii8 ~oo.'on. '.qui<< Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 Sworn and subscribed to before me this ~ day of -1JlA,"", , 1998. J .~~ d ~~ Notary publi -- --....... -,- __'" . ......-,.'A ., - .. ...... ..... l' .. >- C'l ,. if' u. !-: ..' .=:: 1 . , Ci' 11.1:-, (.); ) R - -" ....J S~,:. L [::. ~I: ~ ~_. r \ - i'- :.:.. .- u. e-: , p' U 0' U . CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff CIVIL ACTION - LAW v CYNTHIA L. QUIGLEY, Defendant ACTION OF MORTGAGE FORECLOSURE NOTICE OF SHERrFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.2 TAKB NOTICEI That the Sheriff's Sale of Real Property (Real Estate) will be held on September 2, 1998, in the COMMISSIONERS' HEARING ROOM, 2M FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 A.M., prevailing local time. 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: 81 East Main Street Newville. Cumberland County. Pennsvlvania 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed to: 97-6063 Civil Term in Cumberland County. Pennsylvania THE NAME (S) OF n:E OWNER (S) OR REPUTED OWNER (S) OF TH IS PROPERTY IS: Cynthia L. Ouialey A SCHEDULE OF 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 within thirty (30) days after the sale and distribution of the proceeds of sale in accordar.ce 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 Cumberland County, Cumberland County Courthouse, Carlisle, Pennsylvania 17013 (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OR 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. 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 ADVICS: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with Court of Common Pleas of Cumberland 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 a 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 Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 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 Cumberland County at one of the Court's regularly scheduled Business Court sessions. The petition must be served on the attorney for the creditor or on the creditor at least two (2) business days 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. R. THOMAS KLINE, SHERIFF PROPERTY nBSCRIPTZOH ALL that certain tract of land with the improvements thereon erected, situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Main Street; on the East by Lot No. 42 on General Plan of said Borough; now or formerly owned by John Mayberry; on the North by Cove Alley; and on the West by property now or formerly of George A. Plough. Containing 30 feet in front on said East Main Street, and extending 180 feet in depth to said Alley; and having thereon erected a two and one-half story stone dwelling house and necessary outbuildings. BEING the same premises which Betty A. Quigley and Robert G. Quigley, husband and wife, by Deed dated January 8, 1992, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book L, Volume 35, Page 1195, granted and conveyed unto Cynthia L. Quigley. HAVING THEREON ERECTED a residential dwelling known and numbered as 81 East Main Street, Newville, Cumberland County, Pennsylvania. BEING known as Tax Parcel No. 27-20-1756-077. SEIZED and taken in execution by the Sher.iff of Cumberland County to be sold as the property of Cynthia L. Quigley, Mortgagor and real owner, under Judgment No. 97-6063 in the Court of Common Pleas of Cumberland County, Pennsylvania. * ..... -"1' -- (r; ". " r-" t, ' . ::;, , :' ,'. " C/. ,~. 'T " , . . ... ::&.. t, .~--- .::5 C; en Cornerstone Federal Credit Union Successor in Intrest to The United Telephone Employees Federal Credit Union In the Court of Common Pleas of Cumberland County. Pennsylvania No. 97-6063 Civil Term -vs- Cynthia L. Quigley R. Thomas Kline. Sheriff who being duly sworn according to l3w, says this writ is returned ST^~ED. Sheriff's Costs: Docketing posting Bills Advertising Law Library County Mileage Certified Mail Levy Pas tpone sale Surcharge Law Journal Patriot News Share of Bills Poundage 30.00 15.00 15.00 .50 1.00 10.54 3.76 15.00 20.00 12.00 226.25 216.15 27.91 11.87 604.98 pd by atty 9-3-98 $ So ;~~~~ R. Thomas Kline, Sheriff Sworn and Subscribed To Before Me a. "\ This I~ - Day of vi "r;.. I.~ (~\ . , 1998. ^.D.~~....., C Il..j;:,.... ..._ I Prothonotary I 1L9fi'.' Byjj,t;;~~ Jkt4 Depu ty Sheriff Real Estate Deputy ~(t> \. CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 97-6063 CIVIL TERM Plaintiff CIVIL ACTION - LAW v CYNTHIA L. QUIGLEY, Defendant ACTION OF MORTGAGE FORECLOSURE HOT~CE 0. SKRR~..'S SALE 0. REAL PROPERTY PURSUANT TO PBNHSYLVAHrA RULE 0. Crv~L PROCEDURE 3129.2 TAXI!: HOT~CBI That the Sheriff's Sale of Real Property (Real Estate) will be held on September 2, 1998, in the COMMISSIONERS' HEARING ROOM, 2M FLOOR, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA, at 10:00 A.M., prevailing local time. 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: 81 East Main Street Newville. Cumberland Countv. Pennsylvania 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed to: 97-6063 Civil Term in Cumberland Countv. Pennsylvania THE NAME (S) OF THE OWNER (S) OR REPUTED OWNER (S) OF THIS PROPERTY IS: ~nthia L. Oui9ley A SCHEDULE OF 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 within 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 Distributi~n may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Cumberland County Courthouse, Carlisle, Pennsylvania 17013 (717) 240-6390. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SAI.P. OR 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. 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 O~ TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with Court of Common Pleas of Cumberland County to opon the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a 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 Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 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 Cumberland County at one of the Court's regularly scheduled Business Court sessions. The petition must be servoed on the attorney for the creditor or on the creditor at least two (2) business days 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, before presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. R. THOMAS KLINE, SHERIFF " ,/ ~ >- I 1 PROPERTY DBSCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Main Street; on the East by Lot No. 42 on General Plan of said Borough; now or formerly owned by John Mayberry; on the North by Cove Alley; and on the West by property now or formerly of George A. Plough. Containing 30 feet in front on said East Main Street, and extending 180 feet in depth to said Alley; and having thereon erected a two and one-half story stone dwelling house and necessary outbuildings. BEING the same premises which Betty A. Quigley and Robert G. Quigley, husband and wife, by Deed dated January 8, 1992, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book L, Volume 35,. Page 1195, granted and conveyed unto Cynthia L. Quigley. HAVING THEREON ERECTED a residential dwelling known and numbered as 81 East Main Street, Newville, Cumberland County, Pennsylvania. BEING known as Tax Parcel No. 27-20-1756-077. SEIZED and taken in execution by the Sheriff of Cumberland County to be sold as the property of Cynthia L. Quigley, Mortgagor and real owner, under Judgment No. 97-6063 in the Court of Common Pleas of Cumberland County, Pennsylvania. CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLNND COUNTY, PENNSYLVANIA NO. 97-6063 CIVIL TERM Plaintiff I CIVIL ACTION - LAW v CYNTHIA L. QUIGLEY, Defendant ACTION OF MORTGAGE FORECLOSL~E AP~IDAVIT PURSUANT TO RULB 3129.1 (Affidavit No. 11 CORNBRSTONB ~EDERAL CRBDIT UNION, Successors in Interest to the united Telephone Employees' rederal Credit union, Plaintiff in the above action, by its attorney, Christopher C. Houston, Esquire, sets forth as of the date of the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 81 BAST MAIN STREET, NEWVILLE, CUMBERLAND COUNTY, PA 17241. 1. Name and address of Owner(s) or reputed Owner(s) : ~ LAST KNOWN ADDRESS cannot be reasonably please so indicate) (if address ascertained, CYNTHIA L. QUIGLBY 81 BAST MAIN STREET NEWVILLE, PA 17241 clo ROBERT QUIGLEY 803 ~ACTORY STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: ~ LAST KNOWN ADDRESS cannot be reasonably please so indicate) (if address ascertained, Same as above. 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: w.MJ:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) Non.. (if address ascertained, 4. Name and address of the last recorded holder of every mortgage of record: w.MJ:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) Non.. (if address ascertained, 5. Name and address of every other person who has any record 1 ien on the property: w.MJ:: LAST KNOWN ADDRESS cannot be reasonably please so indicate) (if address ascertained, CUMBBRLAND COUNTY TAX CLAIM BUREAU CUMBERI~ COUNTY COURTHOUSB ONE COURTHOUSB SQUARB CARLISLE, PA 17013 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: llAl:m LAST KNOWN ADDRESS cannot be reasonably please so indicat.e) NONE. (if address ascertained, 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: PROPERTY DBSCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in the Borough of Newville, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Main Street; on the East by Lot No. 42 on General Plan of said Borough; now or formerly owned by John Mayberry; on the North by Cove Alley; and on the West by property now or formerly of George A. Plough. Containing 30 feet in front on said East Main Street, and extending 180 feet in depth to said Alley; and having thereon erected a two and one-half story stone dwelling house and necessary outbuildings. BEING the same premises which Betty A. Quigley and Robert G. Quigley, husband and wife, by Deed dated January 8, 1992, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book L, Volume 35,.page 1195, granted and conveyed unto Cynthia L. Quigley. HAVING THEREON ERECTED a residential dwelling known and numbered as 81 East Main Street, Newville, Cumberland County, Pennsylvania. BEING known as Tax Parcel No. 27-20-1756-077. SEIZED and taken in execution by the Sheriff of Cumberland County to be sold as the property of Cynthia L. Quigley, Mortgagor and real owner, under Judgment No. 97-6063 in the Court of Common Pleas of Cumberland County, Pennsylvania. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 97-6063 CIVIL to' Term CIVIL ACTION. LAW TO THE SHERIFF OF _____Q.lnM.land___._COUNTY: To salisfy the debt. interest and cosls due ~!'lerstone Federal Credit Union Succ~ssors in Interest .._.._to t~ United Telephon~ Employees' Federal Credit Union PLAINTIFF(S) from___Cynthia L. Q.Jigley, 81 East M3in Street, Newville, Cunberland County, PA 17241 (1) You are directed to levy upon the properly of the defendanl(S) and to sell DEFENDANT(S) please see leqal description (2) You are also directed to allach the property of the defendant(s) nollevled upon In the possession of GARNISHEE(S) as follows: and to noldy the gamlshee(s) that: (a) an allachment has been Issued; (b) ths gamlshee(s) Is/are enjoined from paying any debt to or for the account 01 the defendant(s) and from delivering any property of the defendant(s) or otherwl~e disposing lhereof; (3) If property of the defendant(s) not levied upon an subjecllo allachment Is found in the possession 01 anyone other Ihan a named garnishee. you are directed to notify hlrTVherthal he/she has been added as a garnishee and Is enjoined as above staled. Amount Due $29,979.48 S 'in $1.00 % l.l. Due Prothy Olher Cosls Interest ft"'" d/?Q/QA "t 57 Q'id [J"r i1"y Ally's Comm Ally Paid Plainliff Paid $138.32 Date: May 7 , 199B Curtis R. Long Prolhonolary, Civil Division b~ An-..... _ 2. r...nJ.n/Uu/ ~ Deputy REQUESTING P \RTY: Name Christopher C. Houston, Esq. Address: 52 \~est Pomfret Street Carlisle, PA 17013 Morney for: Plaintiff Telephone: 717-241-5970 Supreme Court 10 No. 36502 ... CORNERSTONE FEDERAL CREDIT UNION, Successors in Interest to the United Telephone Employees' Federal Credit Union, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff NO, 97-6063 CIVIL TERM v CYNTHIA L. QUIGLEY, Defendant PRABCIPE TO SETTLE AND DISCONTINUB TO THE PROTHONOTARY: Please mark the above-captioned judgment matter settled, paid in full and discontinued. Christo her C. Houston, Esquire Attorne for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 Date: )1J.~/11 cc: John Oszustowicz, Esquire Jacqueline M. Verney, Esquire . (, N C-.J r.' a'":. ~ en cn 1': .--: .--l.:\' I ~.; l" ~ '~, ~.:.~ ~~ ,',;; 1-:::--;: .:.1l.1I ;..:~ WoO :.i u '" ,v: ~ ... Cl 1.1-1--. 0' n-C- r.--f ~\: ~-- ft" _l .... ~ c;.. ;'C ..0: \/ (, "