Loading...
HomeMy WebLinkAbout03-0380FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL1NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, STE. 150 HORSHAM, PA 19044 Plaintiff MATTHEW J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043-182 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DWISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attomey and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:168784304 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, STE. 150 HORSHAM, PA 19044 The name(s) and last known address(es) of the Defendant(s) are: MATTHEW J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043-182 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 4/8/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1535, Page 25. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2002 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 08/01/2002 through 01/22/2003 (Per Diem $15.77) Attomey's Fees Cumulative Late Charges 04/08/1999 to 01/01/2003 Cost of Suit and Title Search Subtotal $79,394.70 2,759.75 1,250.00 85.56 $ 550.00 $ 84,040.01 Escrow Credit 0.00 Deficit 293.65 Subtotal $ 293.65 TOTAL $ 84,333.66 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event cfa third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 84,333.66, together with interest from 01/22/2003 at the rate of $15.77 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. By: /s/Francis S. Hallinfin' FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff .~r.T TI-IAT CER.TAII'4 lot 0r tract of'k~nd slate ~ ~e Borough o~Lcmo~e. C~bcrland Cotm~.~e~ylv~a. more p~icu]arly bo~ded an~ descried as follo~, to wit: ~~ at a po~t ot~ ~e no,hem line of Bosler Avenue. at t[~e dis~nc~ of seven,- five (75) feet m~ed ~ an e~terly direction ~om the no~c~t comer of Bosler Avenue and N~ ~tr~t, o? ~e l~e of ~t No. 1]1 on ~ henna,er meDtioned Pl~ off Lo(s; ~ence in a no~l~erly 'direc~on alon~ d~e l~c of said Lei Ho. 13l one hundred H~ (150) feet to a fi~een Foot alley; dtencc ~ an e~terly direction along said H~cen foot allcy ~il~-five (35) feet to a point on fire l~e of~t No. 129 on s~d hereina~er mentioned Plan; ~cncc iz] a southerly dircctlon along ~c l~e ofsaid Lot No. 129 one hundred ~ (150) feet to a po~t on the no~em l~c of Bosler Avenue. then~ in a we~erIy direction along the nm=hem line oe Bosler Avenue thi~-avc 05) feet to a polnh dee place ~E~G Lot ~; 13~ Section "E", PI~ No. I of ~veaon, ~ ~co,'ded b= Deed Book "J", Volume 4, Page 40, m me ~mberland Coun~ Rccorder's ~G ther~n erected a single ~o sto~ dwelling house, No. g35 Boslcr Avenue, Lemon.e, Pe~syJv~ia. . 5E~O ~e same premises which ~[omas ~ted ~ nua~ 24. 1997, ~d r~orded Februa~ 3, 1997 ~ ~c O~ce of thc Recorder of Deeds in nad for Cmbcrl~d CounW, Pc~sylv~ia, granted ~d conveycd ~to Nrat~ew X. Redmond and Brenda L. Redmond, Graters hcmln. P~SES B[IN~: 835 BOSL~ A~. VERIFICATION FRANCIS S. HALLINAxN', ESQUIRE hereby states that he is attorney for Plaintiffin this matter, that Plaintiffis outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to Unsworn falsification to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-00380 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPOP~ATION VS REDMOND MATTHEW J BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon REDMOND MATTHEW J the DEFENDANT , at 0902:00 HOURS, on the 28th day of January , 2003 at 835 BOSLER AVENUE LEMOYNE, PA 17043 by handing to MATTHEW REDMOND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 39.04 Sworn and Subscribed to before me this ~57 day of /.~. ~(A--~ ~ .~00~ A.D. ~ z~.P.~Ot h~n~t ary ~/ So Answers: R. Thomas Kline 01/29/2003 By: 2 D~ep ~y ~ / Sheriff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 Plaintiff, MATTHEW J. REDMOND Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-380CV PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against MATTHEW J. REDMOND, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 1/23/03 to 3/4/03 TOTAL $84,333.66 $ 646.57 $84,980.23 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~I~aNK' FE~~, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATflD.(( , / PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215) 56~-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff vs. MATTHEW J. REDMOND Defendant(s) TO: MATTF~-~N J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043 : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY DATE OF NOTICE: FEBRUARY 19, 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE 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: CI_J'MBE~CO~ CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman~, Es~qu'ire Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 Plaintiff, MATTHEW J. REDMOND Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-380CV VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant MATTHEW J. REDMOND is over 18 years of age and resides at, 835 BOSLER AVENUE, LEMOYNE, PA 17043-182. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~~ FE~DERMAN, ESQUIRE l~ttomey for~Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PlfflLADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION Plaintiff, MATTHEW J. REDMOND Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-380CV CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. / FRANI~ F~DERMAN~-ESQUIRE ~Attomey for Plaintiff pRAECIPE FOR WRIT OF EXECUTION ' (MORTGAGE FORECLOSURE) p.R.C.P. 3180-3183 GMAC MORTGAGE cORPOI~TION Plaintiff, MATTHEW g. REDMOND Defendant(s)- : No. 03-380CV TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 3/5/03 to 6/11/03 (per diem -$13.97) TOTAL $ 84,980.23 $ 1,383.03 and Costs $ 86,363.26 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. AIL THAT CERTAIN lot or trac~ of i~nd siluate in th~ Borough of Lemoyne, Cumberland County, Pennsylvania, more particularly botmded and dea~bed as follows, to wit: BEGINNING at a point on the northern line of Boaler Avenue, at the distance of seventy- five (75) fcct measured in an easterly direction from the nonhenst comer of Bonier Avenue and Ninth Sh~-t, on the line of Lot No. 131 on thc hereinafter mentioned Plan of Lots; thence in a northerly direction along the line ofsaid Lot No. 131 one hundred fifty (150) feet to a fifteen foot alley; thence in an easterly direction along ~aid fii~en foot alley thirty-five (35) f~ to a point on the line of l,ot No. 129 on said hereinafter mentioned plan; 0~ence in a aourtherly direction along the line of said Lot No. 129 one hundred fifty (150) feet to a point on the northern line of Bosler Avenue; thence ia a weanea'ly dite~on along the northern line of Boslc'r Avenue thirty-five 0:5) feet to a point, the place of BEGINNING. BEING Lot No. 130, Se~ion "E", Plan No. I of Rivetmn, as recorded in Deed Book "/", Volume 4, Page 40, in the Cumberland County Recorder'$ Office. HAVING thereon ean:ct~ a sing, lc two story dwcllin8 house, No. 835 Bosler Avenue, Lcmoyne, Pennsylvania. TAX PARCEL#: 12-22-0824-042 BEING the same premises that Matthew J. Redmond and Brenda L. Redmond, by it's deed dated 3/9/1999 and recorded in the Office of Recorder of Deeds in and for Cumberland County, Pennsylvania on 4/19/1999 in Deed Book Volume 197, Page 753, granted and conveyed unto Matthew J. Redmond, Grantor herein. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-380 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION Plaintiff (s) From MATTHEW J. REDMOND, 835 BOSLER AVE., LEMOYNE PA 17043. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 835 BOSLER AVE., LEMOYNE PA 17043 (SEE ATTACHED LEGAL (2) of DESCRIPTION). You are also directed to attach the property of the defendant(s) not levied upon in the possession GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $84,980.23 Interest 3/5/03 TO 6/11/03 ~ $13.97 per diem Atty's Comm % Atty Paid $121.04 Plaintiff Paid Date: MARCH 4, 2003 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN ESQUIRE Address: 1617 JFK BLVD, SUITE 1400 L.L. $.50 $1,383.03 Due Prothy $1.00 Other Costs CURTIS R. LONG ProthonOtary ONE PENN CENTER ~ SUBURBAN STATION PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 GMAC MORTGAGE CORPORATION Plaintiff, ¥o MATTHEW J. REDMOND Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-380CV AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~835 BOSLER AVENUE~ LEMOYNE, PA 17043-182. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MATTHEW J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043-182 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRENDA L. REDMOND 6110 SPRINGFORED DRIVE APT F-10 HARRISBURG, PA 17101 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 835 BOSLER AVENUE LEMOYNE, PA 17043-182 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. February 26, 2003. ~qK FEDEI~M~, ESQUIRE DATE ~ttorney for Plaintiff GM_AC MORTGAGE CORPORATION Plaintiff, V. MATTlCtEW J. REDMOND Defendant(s). TO: MATTHEW J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043-182 CUMBERLAND COUNTY No. 03-380CV February 26, 2003 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTE. ** Your house (real estate) at ~ 835 BOSLER AVENUE~ LEMOYNE~ PA 17043-182~ is scheduled to be sold at the Sheriff's Sale on JUNE 11~ 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $84~980.23 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 AI.L THAT CERTAIn/1o~ or tract of land situat~ in the Borough of Lemoyne, Cumberland County, pennsylvania, more particu_ I_~y bounded and described as follows, to wit: BEGINNING at a point on the nonhero ~ of Bosler Avenue, at ti~ distance of seventy- five (75) f~ measured in an eas~ly direction from th, northeast ~omer of Bosl~ Avenue and Ninth Street, on the linc of Lot No. 131 on the hereinafter mentioned Plan of Lots; thence in a northerly direction along thc line of said Lot 1~1o. 131 one hundred fifty (150) feet to a fifteen foot alle~ thence in an easterly direction along said fifteen foot alley thirty-five (3~) fr~ to a point on the line of Lot No. 129 on ~aid hereinafter mentioned Plan; thence in a sourtherly direction along the line of said Lot No. 129 one hundred fifty (IS0) f~t to a point on the northern line of Bosler Avenue; thence in a westerly direction along the norflm~ line of Bosler Avenue thi~y-five DS) feet to a point, the place of B]~G~G. BEINO Lot No. 130, S~/on "E", Plan No. i of Riverton, as recorded in Dg~d Book Volume 4, Page 40, in ~hc Cumberland County Rccorder'$ Office. HAVING ther~m exc~ a single two story dwcllin8 house, No. 835 Bosler Avenue, Lcmoyne, Pennsylvania. TAX PARCEL#: 12-22-0824-042 BEING the same premises that Matthew J. Redmond and Brenda L. Redmond, by it's deed dated 3/9/1999 and recorded in the Office of Recorder of Deeds in and for Cumberland County, Pennsylvania on 4/19/1999 in Deed Book Volume 197, Page 753, granted and conveyed unto Matthew J. Redmond, Grantor herein. Real Estate Sale # 621 On March 14, 2003 the sheriff'levied upon the defendant's interest in the real property situated in Borough of Lemoyne, Cumberland County, PA known and numbered as 835 Bosler Ave., Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2003 Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-380 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION Plaintiff (s) From MATTHEW J. REDMOND, 835 BOSLER AVE., LEMOYNE PA 17043. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 835 BOSLER AVE., LEMOYNE PA 17043 (SEE ATTACHED LEGAL DESCRIPTION) · (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; · · ' dant s not levied upon an subject to attachment ~s found m the posses~s)o.n (3) If property of the defen ( ! ' ed notify him/her that he/she has been added as a of anyone other than a named garnishee, you are drrect__ to _ garnishee and is enjoined as above stated. Amount Due $84,980.23 Interest 3/5/03 TO 6/11/03 ~ $!3.97 per diem Atty's Corem % Arty Paid $121.04 Plaintiff Paid Date: MARCH 4, 2003 (Seal) REQUESTING PARTY: Name FRANK FEDERMAN ESQUIRE Address: 1617 JFK BLVD, SUITE 1400 L.L. $.50 $1,383.03 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothon~ary By: ~ ONE PENN CENTER ~ SUBURBAN STATION PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 GMAC Mortgage Corporation VS Mathew J. Redmond In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-380 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Levy 15.00 Poundage 1.33 $ 67.83 paid by attorney 03/25/03 Sworn and subscribed to before me This ~ ~ 2003, A.D. Prothonotary Real Estate Deputy GMAC MORTGAGE CORPORATION~ Plaintiff, v. MATTHi~W J. REDMOND Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : NO. 03-380CV SHERiF '$ *~ffidavit GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~835 BOSLER AVENUE~ LEMOYNE PA 17043-182. . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MATTHEW J. REDMOND 835 BOSLER AVENUE LEMOYNE, PA 17043-182 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Nanle None Last Known Address (if address cannot be reasonably ascertained, please indicate) 5.' Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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. Nanle BRENDA L. REDMOND Last Known Address (if address cannot be reasonably ascertained, please indicate) 6110 SPRINGFORED DRIVE APT F-10 HARRISBURG, PA 17101 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: Naxne Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 835 BOSLER AVENUE LEMOYNE, PA 17043-182 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 26, 2003 DATE t Attorney for Plaintiff coRFOBATION GMAC MORTGAGE plaintiff, REDMOND : Defendant(s)- : cuMBERLAND coIY~TY No. 03-380C¥ February 26, 2003 TO: MATTHEW J' REDMOND 835 BosLER AvENUE LEMOYNE, PA 17043'152 PREVIOUSLY RECEIVED A DISCHARGE IN **THIS FIRM IS A DEBT cOLLECTOR ATTEMPTING TO cOLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE uSED FOR THAT puRPOSE. IF YOU HAVE BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 835 BosLER AvENUE. LEMOYNIS. PA X7043-1.82 ,is_. L at 10:00 a.m. m the Cumberland {county scheduled to be sold at the Sheriffs Sale on ~nforce the court iudgrnent of ~ against you. In the event the (the mortgagee)south with P a.R.C.P., Rule 3129. Courthouse, Hanover Street, Carlisle, PA 17013, to obtained by GMAC MORTGAGE cORPORATION sale is continued, an announcement wtll be made at said sale in compliance NOTICE OF oWNER'S RIGHTS YOU MAY BE ABLE TO pREVENT THIS SHERIFF'S sALE_ To prevent this Sheriffs Sale, you must take i_mmediate aetion~ 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charge costs and reasonable attorney's fees due. To find out how much you must pay, you nq call: ~ 2. You may be able to stop the sale by filing a petition asking the Court to strike or ope judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. Yot~ r~ay need an att you w~ll have ofstoo.;.~ .,_ orn.ey to assert ~ u,- ,'~"-~ tne Sale t~ .... .yo --g:,nts. The · ~'~ nOt~ce on page SOoner you COntact one, the more ~--~_~_GGHTS E two on how to obtain an attorney.) chance ~TILL BE ABLE TO SA V~ E YOUR PRO~PERTy ~AND YOU ~HA 1. /fthe Sheriffs Sale is not Stopped, find out the pr/ce bid by ca/lEg ~yo. ur property will be sold to the h/ghest bidder. You may 2. You may be able to petition the Court to set as/de the sale /nadequate COmpared to the value of YOur property, if the bid pr/ce was grossly 3. The sa/e will go through on/y if the buyer pays the Sheriff the full find out if this has happened, you may call (717) 240-6390. amount due/n the sale. To 4. If the amount due from the BUyer is not property as if the sale never happened, pa/d to the Sheriff, you will rema/n the OWner of the 5. You have the right to remain in the property until the full amount due is pa/d to the Sher/ff and the Sher/ffg/ves a deed to the buyer. At that time, the buyer may br/ng legal proceedings to er/ct you. 6. You may be entitled to a share distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. Th/s of the money wh/ch was paid for your house. A schedule of Schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule un/ess except/ohs (reasons why the proposed distribution is Wrong) are filed with the Sher/ffwith/n ten (I0) days alter the distribution is filed. 7. You may a/so have other fights and defenses, or Ways of getting your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN (;ET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND ATTORNEy REFERRAL COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 99o. 1o8 ~ereio. ~e 197. ' ~ot , oy it,~ / ' 't'~ge 753, PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE GMAC MORTGAGE CORPORATION MATTHEW J. REDMOND SERVE MATTHEW J. REDMOND AT 835 BOSLER AVENUE LEMOYNE, PA 17043-182 CUMBERLAND COUNTY PJT No. 03-380CV ACCT. #.168784304 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 3, 2003 £~SE~RVED~, ~ d ' "~Q~ ~,ox_~k'g4ql~efendant, onthe /~' ~/~'dayof ,~Ol'-~,; ,200_~ Served and made known to at&/Cff'-,o,clock:m.,at _C~...~,~- :C~['~?~'~ /~Vc~ ~-Q~4c~/lk..~'k' ,Co~onwealth of Pemylvaffia, in the m~er deschbed below: ~ Defendant personally se~ed. ~ Adult hmly member wi~ whom Defendant(s) reside(s). Relations~p is ~ Aduk in ch~ge of Defend~t(s)'s residence who reused to give rome or relationship. ~ ManageffClerk of place of lodg~g in which Defend~t(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: , ,[ ~ ~ ~.~ Description: Age ~J~ Height,9~/ Weight /~/'c~ Race ~Sex ~ O~er ~C~ I, ~C'~k~ d~ c.~tac~mpetenta~u~t~be~g~u~ys~macc~r~ingt~a~ep~sean~statethat~pers~m~y~an~e~ a ~e and co~ect copy of the Notice of Sheriffs Sale ~ ~e ~er as set fo~ hereto, issue ' ' ~.~., ~.. · e address indicated above. Sworn to and subscribf~ before me this / ~ ~y PLEA~TTEMPT SE~ICE AT LEAST 3 TIMES. INDICATE DATES~TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200__, at o'clock __.m., Defendant NOT FOUND because: __ Moved __ Unknown__ No Answer __ Vacant 1st Attempt: / / Time: : 2na Attempt: / / Time: : 3rd Attempt: / / Time: : Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE CORPORATION VS. MATTHEW J. REDMOND CIVIL ACTION CIVIL DIVISION NO. 03-380CV AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attomey for GMAC MORTGAGE CORPORATION hereby verify that on June 9~ 2003 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: August 1, 2003 FEfiEV MAN, ESQUn Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Ziezler, Recorder of Deeds in and for said County and State do hereby certify that the SherifFs Deed in which GMAC MTG Corp is the grantee the same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ Execution issued on the 9th day of June, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 380, at the suit of GMAC MtgCorp against Matthew J Redmond is duly recorded in Sheriff's Deed Book No. 259, Page 2128. 1N TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this o?~_} -~ day of , A.D. 2003 ~ ~J ~~~ecorder of Deeds GMAC Mortgage Corporation VS Matthew J. Redmond In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003~380 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 07, 2003 at 3:59 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Matthew $. Redmond, by making known unto Matthew Redmond, at 835 Bosler Ave., Lemoyne, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the sanae. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 09, 2003 at 4:37 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Matthew Redmond located at 835 Bosler Ave., Lemoyne, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Matthew J. Redmond, by regular mail to his last known address of 835 Bosler Ave., Lemoyne, PA 17043. This letter was mailed under the date of July 11, 2003 and never returned to the Sheriffs Office. R. Thomas KIine, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for GMAC Mortgage Corporation. It being the highest bid and best price received for the same, GMAC Mortgage Corporation of 500 Enterprise Road, Suite 150, Horsham, PA 19044, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $807.60. SherifPs Costs: Docketing $30.00 Poundage 15.84 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 23.46 Levy 15.00 Surcharge 20.00 Law Journal 274.70 Patriot News 263.20 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriffs Deed 40.50 $ 807.60 Sworn and subscribed to before me So Answers: This J0 ~dayof ~R. Thomas Kline, Sheriff 2003, A.D. Real Estat/uDeputy Real Estate Sale # 56 On June 12, 2003 the sherifflevied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA known and numbered as 835 Bosler Ave., Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 12, 2003 Real Estat~ Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mamh 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. A L E ff56 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 261.45 $ 1.75 $ 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in {he said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE 8ALE NO. 56 Writ No. 2003-380 Civil GMAC Mortgage Corporation vs. Matthew J. Redmond Atty.: Frank Federman ALL THAT CERTAIN lot or tract of lalld situate in the Borough of LemoyIle, Cumberland County. Pennsylvania, more particularly bounded and described as follows, to w/t: BEGINNING at a point on the northern line of Bosler Avenue, at the distance of seventy-five {75) feet measured in an easterly direction from the northeast corner of Bosler Avenue and Ninth Street, on the line of Lot No. 131 on the hereinafter mentioned plan of Lots: thence tn a northerly direction along the line of said Lot No. 131 one hundred fifty {150) feet to a fifteen foot alley; thence in an easterly direction along said fifteen foot alley thirty-five {35) feet to a point on the line of Lot No. 129 on said hereinafter mentioned Plan; thence in a sou$herly direc tion along the line of said Lot No. 129 one hundred fifty (150) feet to a point on the northera line of Bosler Avenue; thence in a westerly direc- tion along the northern line of Bosler Avenue thirty-five {35] feet to a point, the place of BEGINNING. BEING Lot No. 130, Section Plan No. 1 of Rlverton. as recorded in Deed Book 'J". Volume 4, Page 40, in the Cumberland County Re- corder's Office. HAVING thereon erected a single two story dwelling house, No. 835 Bosler Avenue, Lemoyne. Pennsyl- TO AND SUBSCRIBED before me this day of AUGUST, 2003 lO~ E. ~.IY, ~,~R, Nota,"y Pub~ measured in an easterly direction from the northeast corner of Bosler Avenue and Ninth Street, on the line of Lot No. 131 on the hereinafter mentioned Plan of Lots: thence In a northerly direction along the line of said Lot No. 131 one hundred fifty (150) feet to a fifteen foot alley; thence in an easterly direction along said fifteen foot alley thirty five feet to a point on the line of Lot No. 129 on said hereinafter mentioned Plan; thence in a southerly direc tion along the fine of said LOt No. 129 one hundred fifty (150) feet to a point on the northern line of Bosler Avenue; thence in a westerly direc~ tlon along the northern line of Bosler Avenue thirty-five (35) feet to a point, the place of BEGINNING. BEING Lot No. 130, Section Plan No. 1 of Riverton, as recorded in Deed Book 'd". Volume 4, Page 40. in the Cumberlmud County Re- HAVING thereon erected a single two story dwelling house, No. 835 Bosler Avenue, bemoyne. Pennsyl- TAX PARCEL//: 12-22-0824 042. BEING the same premises that Matthew d. Redmond and Brenda L. Redmond, by its deed dated 3/ 9/1999 and recorded in the Office of Recorder of Deeds in and for Cumberland County. Pennsylvania on 4/19/1999 in Deed Book Vol- ume 197, Page 753. granted and conveyed unto Matthew J. Red- mond, Grantor herein.