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Home My WebLink About98-00672 ~ ~ \' ~ ~ " ~ cS ~i ~ , !..J . tI " ~ . (i :: .~ -...( J J "'ts '3 L ~ III ~ ....... / ;, ~ / i! c:j / ~:}t~ ".''4 ;,:';~ ":,~>$, ):;; . ~~D,~ ',?/ ~~~ ;;w ':t;t ';;'>~ ."iI. \,ty '~ ~,:'i .;:,1~~ ':;,"/l? ';:J~~ ~ :>'j . ~ A";-,! "i~(~;: ::, ~;'j ';;'~~q~ ;'~>:, ~ \. ~ l-\ ..... . ":l .... ~ ~ t-- " , Clo ()-, 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COMMERCE BANK/ HARRISBURG N.A. 100 SENATE AVENUE CAMP HILL. PA 17011 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 so 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 so indicate) NONE 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: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 DOMESTIC RELATIONS OF CUMBERLAND COUNTY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOSUE SOUARE CARLISLE. PA 17013 DOMESTIC RELATIONS OF BUCKS COUNTY 30 EAST COURT STREET DOYLESTOWN, PA 18901 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. Auaust 13. 1999 DATE '1--1uML ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~d ~ l!" ![Z ~ II l ~ ~ For Accountable Mall "tJ en ~ ,Ill ;I ~ ~ .:i! i ~ .... ~ '" ~ N I~ al la if " 0 3 I: c !l i n 0 3 1 3: .!l ... 1 Ii -~ 5' ... 0 ~ lD !: '0 !!. a '0 .. " ~ ~ .. :' 'if ~ II> 3 .. !!. ~ s' ~' '" \l' " 6' ! u~~.~ l ~8h~i~ J 01lil!~~ ili 'U~ !~~~lH ~f~~IKl hfl"'aS" 21lil'r9.i in~!j3 11[~~8111. hh~~i I~aiH L~~'l! 2.~-<ailll Hl ~~ ~ lnil~ ~ '8l!l.. i 3 -." 1:" ~S'~: "[ ~ ~ \~';):'oi",:,::",~:.? ,.~~'?i:~:'~:~.=,;:::=::~1 : Q~ /~. (.."....--.,.----:..... iiiC I::~;. ''''~', ":-: ,d 1.: ~ ,~" :;1':-;- 29.~' :<'.\ .'.. , -. W"'" . .1_ ".., .,... ~'1' .. /' ~ ,", L.l.,..... "" ,i .. ". ," . , . ',,', ' I .0 (] .:: : fl '.....,e.r::./:,.,?:'j" :: Mt 1_.._____. Jh~UI I I I I I I ~ o '" ~ i51~f i!l , a. .. co -.j U1 .... C1l '" N ~ t:l M ~ z~ FJ ~~ Ul ""-P>1 :T C " .... 0 0> ... " 0>"'''- 0... .. " "1 ..." .. ... 0. :Tn.. ..... ... .. " " . ".. .. " "'''' :>. 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POSTAL SEnVIC' CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDr FOR INSURANCE POSTMASTER Received From: DMK R~DIHMbER Two-PenltGentef-Plaza. /:J !' .' \;;\ Philadelphia, PA 1Q10 ~ f} }~) On., pil!CIl 01 oullnarv mall adlJroSlod to: \0..\ g'ffi ./~/ != SUSQUEBANC LEASE COMPANY ~'~b. ~~~~~!" 2rmRt\r..J, ;)l,lUl\KJ:. ~C"'l $~gnEi~ MANHEIM, PA 170\\ ~~ -ill~~ ~ ... ~~il .......Q ~.;: ~~ '9~....,. g, "," ~ ,If~w.;: j . ,!J7:. '\v..,. .. J-;. ....'t.P ,,:, .' C::-"l' ,.,\ aza\~ ~"" .l,::l ~<,_.."" ~,. . !i:; '.0. "'~::.g-E::FJ. ~~ ~C'") .:.~ o PS Form 3817. Mor, 1989 V,S, POSTAL S'AVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE cOR INSURANCE POSTMASTER Receil/ed From: DMK RE.IlEIHLEK FEDERMA~ AN Suite 900 Philadel hi r One piece of ordinary mail add/oased tQ: COUNTRYWIDE HOME LOANS, -oquo L~uAGY UK1V~ .BJ\NO. TX -rr.;C? <\ . INC PS Form 3817. Mor, 1989 V,S, POSTAL S'AVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, ODES NOT PROVIDE FOR INSURANCE-POSTMASTER f",.." Receil/ed F,om: . I," '.g II~'\~'" raa~~' \ r',\ Suite 900 '.~ (~.. l ;;,) Two Penn ce(\~~/,::" Phi/adelohia, P "HlHW' DMK One piece 01 ordinary mail addressed 10: DOMESTIC RELATIONS OF :nn;A:ST GUURT STR~ET QQYLESTOWN. FA 18901 BUCKS COUNTY PS Form 3817. Mor, 1989 ..". '!r '" c Iii !2 v, ~O~::;~' ~gnc~ - oCl_ VJ CD ... ... (C ~ ~ .... ... ~l!,;;'i ;;:"'.: "', Nt.' " ..-,. 'r lib o ~~ l;l~ w. gC'") .:.~ o ~ !2 ~ ~O~::;~' NO - . onCl~ _ oCl_ l:ii ill:;! ... in ~ -< IT1 l'- ru Lr1 .-'I ru IT1 l'- IT" 0. ll(Jumj } nrC[IPr SCRVlC( "",IA'lr .. - - - '-' -- -- -- -_. --. -- --. - - -. - -.- -- - - - - -,- ',r ,If''';!lll t'r ~1'..fJlf ,:r"llfr"" 'HT11fi'4I1F.:t,r! SENT TO: I(llolt 1'(J',IAl,t 4110 'rr~. I..U L l l. "OT 'ORIN rnli...T10,...... ...... ~UK~N J. U'lX~~A 4JJ I.'Ot'W\i\ (;ilul\Ch KOAil (;/iJ'l1' lilLI., l.'.i 11U11 PS FORM 3800 US Postal Service Receipt for Certified Mall CHS -- ------- - - ~- ---.---------- ru l'- ru RE;TURN } ~ECEIPf SERVICE ".J-;l~j[ -......:...._----~~----- Il(STf;:r:;TEOCELI',EIl( cERTmO'H.,IETlJmll"lrC;[:PT s_ Lr1 .-'I ru IT1 l'- IT" 0. SENT TO: tOT.4\. PCSTAUE AI.D FEES UII ""I;" _ NOT FOR INfEA"'.AnOt'A" MolIL :,'fi4d.J::Y ~1 !JC:l~1L~k. .JK. ..JJ I'VPl.AI\ CIlU"Cil i\UAD l.~1P HILL, l.'A 17011 PS FORM 3800 US Postal Service Receipt for Certified Mail CdS '-.->--- -,- - --.-- - --- --.-.-- --- i ~~~-"~I~'~=~:'--~~y,. ,.'. -~~-~--'f~~J::o~=~iO(~~~feej:1 Ii PrInt )OJr t\lIme &Dj 8ddrou on the re\oerHO of thII f9nn 10 thai we can return wi card. , ~:= ;h~ form to the front of the mai~. or on tho back If SJ*8 doe, not PMmIt. . ~estricted Delivery . : ~ ~'nl.;";'..."" will omw'lo ......he "'...,;... - "'" ~"!' do'. _. Consult postmaster for fee. I 't~ '.:::!~;;:=' '.', , ~;~;' :::.:~ 2i, 273 ", I: 'CWiuu.t~(I'A 11011 J' ':' -<~; . }~. )( CERTIFIED ,I r. I i I I I I I I J " 79 5, Recel\'ed 8y: (Print Name) a. Addressee's Address PS RM B 11 ,December 1994 QlS I II ,I' II l\il II I J ' I' r 'II II t II \ \ ,~Orn~~\'r ~~tu~~ ~ficelpt 1\ I I o .. ~ Ii ~I 15.. ~~ ~ ~ lr f i! 12 ~ o -'uj ~'" wi!! ..0 ofi l!;z ~~' a: a: w. Ile, ~r WI ~l ~ i i! COUNTRYWIDE HOME LOANS, INC. IF/K/A COUNTRYWIDE FUNDING CORP.) . . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VB. STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER NO. 98-672 CIV1.L AMENDED AFFIDAVIT PURSUANT TO (Affidavit No. RULE 3129 1) COUNTRYWIDE HOME LOANS. INC. (F/K/A COUNTRYWIDE FUNDING QQ~, Plaintiff in the above action, by its attorney I FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the writ of Execution was filed the following information concerning the real property located at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) STANLEY M. DEIMLER. JR, 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 LAUREN J. DEIMLER 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) FULTON BANK P.O. BOX 432 EAST PETERSBURG, PA 17520 COUNTRYWIDE HOME LOANS, INC. 6400 LEGACY DRIVE PLANO, TX SUSOUEBANC LEASE COMPANY 2 MARKET SOUARE MANHEIM. PA BOROUGH OF WORMLEYSBURG 20 MARKET STREET WORMLEYSBURG. PA 17042 '~ (') \0 0 C \D -il ;?'" r.. -n C;-1 c= ::-) GJr.l C;., f;i:!l ...:..:u ,;..,;:; -,.~-, N -,- en :-<0 U\ :"? ;:$;';'" ~i::i ~~ 9(J "" :!::fj c...n ~-.,J.:-:>> ;:~{-, Zrn ~..c: r;:> C> ?3 :;-l .::> 55 "' -< " ., FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - suite 900 Philadelphia, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) 6400 LEGACY DRIVE PLANO, TX 75024-3632 VB. STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION . . : NO. 98-672 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against STANLEY M. DEIMLER, JR. AND LAUREN J. DEIMLER, Defendant(s) for failure to file an Answer to Plaintiff's 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 - 1/1/98-4/28/98 TOTAL $93,769.13 2,330.50 $96,099.63 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given io occord""ce with Role m." copy ot[:\, ~.Jl JA.-tv-W-- FRAN FEDERMA, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: jV\() 1 j 5~111 }QQ'6 FEDERMAN AND PHELAN FRANK FEDERMAN, ESQUIRE Identification No. 12248 ATTORNEY FOR PLAINTIFF Two Penn Center Plaza suite 900 Philadelphia, PA 19102-1799 12151 563-7000 COUNTRYWIDE HOME LOANS, INC, (F/K/A COUNTRYWIDE FUNDING CORPORATION) COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY STANLEY M, DEIMLER, JR. LAUREN J. DEIMLER No. 98-672-CIVIL Defendant(s) TO: STANLEY M. DEIMLER, JR. 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 DATE OF NOTICE: MARCH 25. 1998 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. IMPORTANT NOTICE You are in default because you have failed 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: Cumberland county Court Administator 4th Floor Cumberland county Courthouse Carlisle, PA 17013 (717)240-6200 ~~ ~ FRAN FEDERMA~ ESQUIRE Attorney for Plaintiff FEDERMAN AND PHELAN FRANK FEDERMAN, ESQUIRE Identification No, 12248 ATTORNEY FOR PLAINTIFF TWo Penn Center Plaza suite 900 philadelphia, PA 19102-1799 1215l 563-7000 COUNTRYWIDE HOME LOANS, INC, (F/K/A COUNTRYWIDE FUNDING CORPORATION) COURT OF COMMON PLEAS plaintiff CIVIL DIVISION vs, CUMBERLAND COUNTY STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER No. 98-672-CIVIL Defendant(s) TO: LAUREN J. DE IMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 DATE OF NOTICE: MARCH 25. 1998 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. IMPORTANT NOTICE You are in default because you have failed 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: Cumberland county Court Administator 4th Floor Cumberland County courthouse Carlisle, PA 17013 (717)240-6200 ~l \)~ . FRANK FEDERMAN, ESQUIRE Attorney for plaintiff I' I.. I " I, : } I [ ; .Ef ! \ . I ~. , t, ~ p f 'J:I ~ i:I- (') .0 0 .... c w -" , ~ ~ ~':: :::: ...t +- b -or;; :.~ T rnr., -, .,i::rJ f1- ~ %:1.1 1 ,'OF;:; 9S fl -D -''''1.;'' t;~.,=.. <J1 "6 ;z: '-) CO 9j -.- :r!( 8 r::c~ ~. .. ~11 fJl P: 0 ?~(") -,' (J~~ ~.r) 4,~ rn ~ ~;.;c: 9? ~ -,.. -.~... -a :"l w :b -< -< VI ~ - (n _. .0 clJ 'l " , r , -, '" .r- bi- t:i. t:i i:.< .~ <I >:> Oz . z : :- ~ cr.< ,... . . <> . 0 i : t- e:: '" '" c:; ~~ ~ .. ..... ... ... ... -. 0 'co -,.. ,~ E E ~ c.:r. Jt.l C,J' ',' l!;l ZZ t:l .. i!l~ ><'" .- ~ ~ i OZ : :: -::Q t:: ; ra i .c. ~! -- r::. III fa: .c 0 o~ OU : .. C,J... .. i~ ! ... .. I ~z ~~ _ 0 i:::. qO ~i . c::r::. ~" ~ ~8 In ~ .. : e I I> .. :-S c::r,. ., Oe .- . I"lf&l 0- ~l~ ~ 82: o. .. I"l - 0 =~ ~B . ~:a ~I . I :a: , "- Ii . ~ : - , E=:t:l ~< U 1 ci ci ci ZCO i:l ::: z Z Z _:li: .... < .. ;;. ;:) Be ":> 2 - - u ::- ~ I - ~ ":> ":> < " , , I, ir ~ 'I I" \~ M: , I ,,' , (? ~ ~ i " \ . I ~I , ' . 'i"'" k, ) l' 1 J CJl 0 0 0 r t? r 0- CL c <:; ~ ~ ~. (") cD r;, * r,. c: C~ :-~... -" -wi':: -;. ;-;J .J:. Q,lrt: :i:'. .p m - (::f.';' _.;: '1'1~ ()l (-j ~.. I .om 0 ()1 8 :',0'''',. CJ1 ' ']:1 0 ,::.:t:i i',O (I "'. ... <,.... ::;: -"-"Ii ~;~ c:\ 6:., ""R- co', ,....c- '?? ont -? j ~ w :;! ~ -< 1 , ! : ~ , , ~ [ , 01 c;- ~ U"I o 6 -1 JU .~' FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 suite 900 TWo Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION VB. . . STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER : NO. 98-672 CIVIL 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 STANLEY M. DEIMLER, JR. is over 18 years of age and resides at 433 POPLAR CHURCH ROAD, CAMP HILL, PA 17011. (c) that defendant LAUREN J. DEIMLER is over 18 years of age, and resides at 433 POPLAR CHURCH ROAD, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~E~~ Attorney for Plaintiff C':l lD 0 F; c:> " :!:: -t "."tli :.;.. T Wrc! -. ii;fn ~~;~ J 'TJm t.n s~6 r-.. ~ ) ::On ~)~ :11 ~ ~ ~ ,4)_D '~.:r, :.;'0 .....~r-! <<;? Om ;~r~ :;;! ,"';", ,'V ~ =< \.0 ("') ID 0 ~ c.o -Il ,- ::':: --< -on, -,.. ::;:n OJU'I ::.&: ' f-' ;2(;" I -';~ (":.,.;: (.Ji ,', ~c .":.l i ~ n. : 1: :~3 ~;n :J.: ~'~(j t.:'=O OJ om :Pc ., ~ ~ N :.0 '0 '-< ."' ... COUNTRYWIDE HOME LOANS, INC IF/K/A COUNTRYWIDE FUNDING CORP.) : CUMBERLAND COUNTY COURT OF COMMON PLEAS VB. . . CIVIL DIVISION STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER NO. 98-672 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 April 28, 1998 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 433 POPLAR CHURCH ROAD. CAMP HILL, PA 17011, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 2. 1998 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle. PA 17013, to enforce the court judgment of $96.099.63 obtained by COUNTRYWIDE HOME LOANS. INC IFIKIA COUNTRYWIDE FUNDING CORP.) (the mortgagee) against you. 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: 1. 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: t2151 563-7000. 2. 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- be sold calling If the Sheriff's Sale to the highest bidder. 12151 563-7000. is not stopped, your property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (215) 563-7000. 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 Sheriff on 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 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 COURT ADMINISTRATOR 4th floor Cumberland County Courthouse (717) 240-6200 n \/) 0 C CSJ -n :.:.. ;r: -4 "Tli;; :.... -r: '"T1 OJr~. .-< " 1--~ ~....'- 1 'rqh=1 ';;"1' ;.)0 ulJ:' Vi ':'t? -<Ii' ." r-'~: :7: -:J ." .:~ ... 1.',:0 i:-~(i ~. ".0 ~;~~ Cf! '.;)m ::~ .~ N 'l~ ~ :.0 \0 -< .. \ I j L. . , ',~ Ii (") \.0 0 c: c.'U -- -" ,,- ~ -0(."(1 :::1 n11-;-j :~. i~'i:n Z:;:t -: r- -"''5' I -om uJ ~; Ul :XJO -< ~'_. ''>6 ~c; p ,:-~ :l:":r, :J.:: :}4"=a t2C) f) C') ....cAe.: 9? om z :s;!- ~ oj, :.0 0 -;; r ;:- Countrywide Home Loans, Inc. F/K/A Countrywide Funding Corp, ) -vs- Stanley M. Deimler and Lauren J. Deimler In the Court of Common Pleas of Cumberland County, Pennsylvania No. 98-672 civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing Law Library County Surcharge Service Postpone sale POundage Share of Bills Sworn and Subscribed To Before Me This .)II ty Day o~ 1998, A.D. Q.,..... Q. fh.u11-l'1^# Prothonotary 30.00 .50 1.00 18.00 27.90 20.00 2.51 27.91 $ 127.82 Advance costs 1000.00 Sheriff's Costs 127.82 $ 872.18 Refund to atty 6-24-98 So answers: -.~a/ .Y# 1.... ,?;I~'??::'.<.iC -1':. ~ R. Thomas Kline,' Sheriff By .jJaL~.JRa:tt; Deputy Sheriff ., t~1l I" \... . .' , \: DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Wormleysburg, County of Cumberland, and State of Permsylvania, bounded and described as follows, to wit: BEGINNING at a point on the North side of Poplar Church Road, which point is located South 53 degrees 30 minutes East along the North side of Poplar Church Road, a distance of three hundred thirty (330) feet from the intersection of the extension of the North side of Poplar Church Road with the extension of the West side of Hillside Drive as they appear on the Plan of Lots of Section "B" of Riverview; THENCE along the North side of Poplar Church Road, South 53 degrees 30 minutes East, a distance of eighty (80) feet to a point; THENCE through the center of Lot No.2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred forty-two and eight one- hundredths (142.08) feet to a point on the dividing line between Lots Nos. 2 and 17 on said Plan; THENCE along the line dividing Lots Nos. 2 and 3 from Lot No. 17 on said Plan, North 53 degrees 30 minutes East, a distance of eighty (80) feet to a point, THENCE through Lot No.3 on said Plan, South 36 degrees 30 minutes East, a distance of one hundred forty-two and eight one- hundredths (142.08) feet to a point on the North side of Poplar Church Road. the place of BEGINNING. BEING the Eastern thirty-five (35) feet of Lot No, 2 and the Western forty-tive (45) feet of Lot No. 3 on the Plan of Lots of Section "B", Riverview, which Plan is recorded in the Cumberland County Recorder's Office in Plan Book 10, Page 21. H.-\ VING THEREON ERECTED a brick and frame dwelling house numbered 433 Poplar Church Road, Camp Hill, Permsylvania. - ~AX PARCEL NUMBER: 47-19-1590-008 1 T~TLE TO SAID PREMISES IS VESTED IN Stanley M. Deimler, Jr. and Lauren J Deimler his ;tfe by Deed from Darma J. Blais, Executrix of the Last Will and Testament of Joan 'Gail Kort~ ated 12/14/94 recorded 12/16/94 in Deed Book 116 Page 303. r COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. 'to . . CIVIL DIVISION STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER . . NO. 98-672 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY April 28, 1998 TO: STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 2, 1998 at 10:00 a.m. in the cumberland county courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96,099.63 obtained by COUNTRYWIDE HOME LOANS, INC IFIKIA COUNTRYWIDE FUNDING CORP.) (the mortgagee) against you. 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: t215) 563-7000. 2. 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. 1. 3. You may also be able to stop the sale through other legal proceedings. J " f ;';:' ,. , 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. be sold calling 2. sale if of your If the Sheriff's Sale to the highest bidder. (215\ 563-7000. You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. is not stopped, your property will You may find out the price bid by 3. The sale will go through only Sheriff the full amount due in the sale, happened, you may call (215) 563-7000. if the buyer pays the To find out if this has 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 Sheriff on 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 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 COURT ADMINISTRATOR 4th floor Cumberland county Courthouse (717) 240-6200 ; '., , DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Worrnleysburg, County of Cumberland. and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the North side of Poplar Church Road, which point is located South 53 degrees 30 minutes East along the North side of Poplar Church Road. a distance of three hundred thirty (330) feet from the intersection of the extension of the North side of Poplar Church Road with the extension of the West side of Hillside Drive as they appear on the Plan of Lots of Section "B" of Riverview; THENCE along the North side of Poplar Church Road. South 53 degrees 30 minutes East, a distance of eighty (80) feet to a point: THENCE through the center of Lot No, 2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred forty-two and eight one- hundredths (l~2.08) feet to a point on the dividing line between Lots Nos. 2 and 17 on said Plan: THENCE along the line dividing Lots Nos. 2 and 3 from Lot No. 17 on said Plan, North 53 degrees 30 minutes East. a distance of eighty (3D) feet to a point. THENCE through Lot No.3 on said Plan. South 36 degrees 30 minutes East. a distance of one hundred forty-two and eight one- hundredths (1~2.03) feet to a point on the North side of Poplar Church Road. the place of BEGINNING, BEING the Eastern thirty-five (35) feet of Lot No, 2 and the Western forty-tive H5) feet of Lot No. 3 on the Plan of Lots of Section "B", Riverview, which Plan is recorded in the Cumberland COUnty Recorder's Office in Plan Book 10, Page 21. HA VING THEREON ERECTED a brick and frame dwelling house numbered ~33 Poplar Church Road, Camp Hill. Pennsylvania, T-\X PARCEL NUMBER: 47-19-1590-008 l ~:ieLE TO SAID PREMISES ISYESTED!N Stanley M. Deimler, Jr. and Lauren J. Deimler, his by Deed from Danna J. BlaIS, Executnx of the Last Will and Testament of Joan Gail Korte dated 12/1~/94 recorded 12/16/94 in Deed Book 116 Page 303. r ~' COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION VB. . . STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER : NO. 98-672 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. II COUNTRYWIDE HOME LOANS. INC tF/K/A COUNTRYWIDE FUNDING CORP.l, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 433 POPLAR CHURCH ROAD, CAMP HILL. PA 17011. 1. Name and address of owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) STANLEY M. DEIHLER. JR. 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 LAUREN J. DEIHLER 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) FULTON BANK P.O. BOX 432 EAST PETERSBURG. PA 17520 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOIVN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COMMERCE BANKI HARRISBURG N.A. 100 SENATE AVENUE CAMP HILL. PA 17011 ,; ... 5, Name and address of every other person who has any record lien on the property: liAM./;; LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) limm 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: tlAr:rn LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 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: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 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. April 28, 1998 DATE ~'\ , \' i ...,c-.l\ I! ,L. C I c..."y..-'l FRA K FEDERMAN, ESQUIRE Attorney for Plaintiff WRIT OF EXECUTION and/or AlTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 98-672 CIVILJf\tTenn CIVIL ACTION. LAW TO THE SHERIFF OF Cumberland COUNTY: To sallsfy the debt, Interest and costs due -CQun~iClne In,.'ns. Inc. (F/K/A Countrywide Fundinq Corp. ) PLAINTlFF(S) from Stanley M. Deimler. Jr. and Lauren J. Deimler DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell please see 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 notijy the garnlshee(s) that: (a) an attachment has been issued; (b) the garnlshee(s) Is/are 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 anyoneother 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. 1 , I I , , Amount Due S96.099.63 Interest 4/29/98 to Sale (il S15.79 Per Diem Atty's Comm % Atty Paid $11 7.30 Plaintiff Paid LL $.50 Due Prothy $1. 00 Other Costs , . , Date: Mav 5. 1998 CUrtis R. Lonq Prothonotary, Civil Division by: L ~r... J) '01 N1l!U)1CJi)n I~ Deputy REQUESTING PARTY: Federman and Phelan Name Frank Federman. Esq. Address: T\o.u Penn Center Plaza. Suite 900 Philadelphia. PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court 10 No, 12248 \ " STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } SS, Robert P Ziegler I, __________________ ___on h ______________ ___n___n_n__ _n_____n__ ___________ Recorder of Deeds in and for said Count)' and State do hereb)' certify that the Sberiff's Deed in which ________________ Countrywide Hm Loans lnc aka Countrywide Fund Corp _____________n____________ _____________________ _____00_____________________________ t. the grantee 7th the same having been sold to said grantee on the --------------------_____________________n____ da)' of JUne ,,,, 00 ___n___nnn_nn_____________________ A. D., 19__0000__' under and by virtue of a writ______________ execution 15th ------------------------------__________________i~uedonthe_____________________________________ December 99 . day of _______________________00_ A. D., i!f.._____, out of the Court of Cornman Pleas of saId Count). as of civil 98 --- _____nn_n___ __ ___On - - - _" __ __on _ __ _ _ _ _ n_ __ __ n_ _ _ _ __ n_n_ __n n __ __ n __ _ Tenn, t 9_ 00 ____ 672 Countrywide Hm Lns INc aka Countrywide FUnd Corp ~umber______________,atthesuitof _______________________________________________________________ STanley M Deimler Jr & Lauren J -.------ ------ -- ---------- -- --- --...... against_ -- __ _____......... __ __... ___...... __ __ __ ____... ___ __ ______ __ __ ___ is 224 424 duly recorded in Sherilrs Deed Book ~o. __________00' Page _nn___n__. , . \ , I I , , I~ TESTIl\IO~Y WHEREOF, I have hereunto set my hand and seal of said olfiee this __{!Q_____ day of ___J"f(~~____________________ A. D., ffJ_gp-f?~ ~//~;~;;j;;~io;.d.' Recorder 01 o..ds. Cumberl,nd Counly. Codis!e. PA My Commis~on Expires the rim Mond.y ot Jln. 2002 f L , I " ....;~ Countrywide Home Lonns, Inc. In the Court of Common Picas of F/K/A Countrywide Funding Corp. Cumberlnnd County, Pcnnsylvnnin -vs- No. 98-672 Civil Stanley M. Deimler, Jr nnd Lnuren J. Deimler Shawn Harrison Deputy Sherin: who being duly sworn necording to luw. snys on January 4, 2000 at 7:03 o'clock P.M. EDST, he posted a copy ofl~eal Estate Writ Notice Poster and Description in the above entitled action on the property of Stnnley Dcimler Jr. and Lauren Deimler loeatcd at 433 Poplar Church Road, Cnmp Hill, Cumberland County, Pennsylvania according to law. Harold J. Wcary Deputy Sheriff who being duly sworn according to law, says on January 19.2000 at 10:24 o'clock A.M. EDST he served a true copy of Real estate Writ Notice Poster and Description in thc above entitlcd netion upon onc of the within named defendants to wit: Stanley M. Deimlcr Jr., by making known unto Stanley Deimler at 101lA Markct Strect, Lemoync, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Shawn Harrison, Deputy Shcriff, who being duly sworn according to law, says on January 4, 2000 at 4:38 o'clock A.M, EDST, he servcd a true copy of Real Estatc Writ Notice Poster and Dcscription in the above entitlcd action upon one of the wihtin named defendant sot wit: Laurcn J. Deimler by making known unto Dennis Renshaw adult residing at 118 Beard Road, Enola, Cumbcrland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attestcd copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Noticc Poster and Dcscription in the following manner: The Sheriff mailed a notiec of the pcndency ofthc action to one of the within named dcfendants to wit: Stanely M. Deimler, Jr by regular mail to his last known address IOIIA Market Street, Lemoyne, Pennsylvania. This letter was mailed under the date of January 20, 2000 and nevcr returned to thc Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manncr: The Sheriffmailcd a notice of the pendcncy ofthc action to onc ofthc wihtin named defendants to wit: Lauren J. Deimlcr by regular mail to her last known address 118 Beard Road, Enola, Pennsylvania. This letter was mail cd under the date of January 20, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says that afte due and legal notice had bcen given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on June 7, 2000 at 10:00 o'clock A.M. ED ST. And sold thc same for the sum of $ 1.00 to Attorney Dale Shughart for Countrywide Home Loans, Inc. ( FIK/A Countrywide Funding Corporation). It bcing the highest bid and best price quoted for the same Countrywide Home Loans, Inc. being the buyer in this exceution paid to SheriffR. Thomas Kline the sum of $ 97 I ,09 it being costs. Sherilfs Costs: Docketing Poundage Posting Bills Acknowledging Deed Auctioneer County Mileage Certified Mall Levy Surcharge Postpone sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 30.00 19.04 15.00 30.00 10.00 1.00 27.90 3.33 15.00 24.00 20.00 404.90 279.34 25.08 25.00 26,50 $ 971.09 Pd By Atty 6/20/00 Sworn and Subscribed To before Mc This .:l I.v- Day of Cf.1t 2000, A.D. (14(" _ a. nwt...-. ~hdnotary *. ?~~ R. Thomas Kline, Sheriff By4i;h..~g Real Estate eputy ~ /vr 311.l!Il ,. rrJ C/<... ..) f 9 f'l ~. 918 9i '"' ; COUNTRYWIDE HOME LOANS, nrc. (F/K/A COUNTRYWIDE FUNDING CORP,) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION va. STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER NO. 98-672 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS. INC. (F/K/A COUNTRYWIDE FUNDING CORP.) , plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011. 1. Name and address of Owner(s) or reputed Owner(s) : NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) STANLEY M. DEIMLER. JR. 25 SOUTH 32ND STREET CAMP HILL. PA 17011 118 BEARD ROAD ENOLA. PA 17025 LAUREN J. DE IMLER 2. Name and address of Defendant (5) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please 50 indicate) FULTON BANK P.O. BOX 432 EAST PETERSBURG. PA 17520 COUNTRYWIDE HOME LOANS. INC. 6400 LEGACY DRIVE PLANO, TX SUSOUEBANC LEASE COMPANY 2 MARKET SOUARE MANHEIM. PA BOROUGH OF WORMLEYSBURG 20 MARKET STREET WORMLEYSBURG. PA 17042 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COMMERCE BANK/ HARRISBURG N.A. 100 SENATE AVENUE CAMP HILL. PA 17011 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 so 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 so indicate) NONE 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: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained. please so indicate) TENANT/OCCUPANT 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 13 NORTH HANOVER STREET CARLISLE. PA 17013 DOMESTIC RELATIONS OF CUMBERLAND COUNTY DOMESTIC RELATIONS OF BUCKS COUNTY 30 EAST COURT STREET DOYLESTOWN. PA 18901 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. December 10. 1999 DATE . h,,~. ..... . ~....,:;.r I 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. be sold calling If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stopped, your property will You may find out the price bid by 2 . sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only if the buyer pays the Sheriff the 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 proposed schedule of distribution of the money bid for your house will be prepared by the sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The 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 filing of the proposed schedule. 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 , , . \ \ i DESCRlPTtON ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Wonnleysburg, County of Cumberland. and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a poin! on the North side of Poplar Church Road, which point is located South 53 degrees 30 minutes East along the North side of Poplar Church Road, a distance of three hundred thirty (330) feet from the intersection of the extension of the North side of Poplar Church Road with the extension of the West side of Hillside Drive as they appe:u on the Plan of Lots of Se~tion "B" of Riverview; THE1':CE along the North side of Poplar Church Road. South 53 degrees 30 minutes East, a distance of eighty (SO) feet to a poim: THENCE lhrough the center of Lot ;":0, 2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred fOrlv-two and eight one- - . - hundredths (l~:!.OS) feet to a poim on the dividing line between Lots Nos. 2 and I i on said Plan: THENCE along the line dividing Lots Nos. 2 and 3 from Lot No, 17 on said Plan. North 53 degrees 30 minutes East, a distance of eight:; (SOl feet to a point. THE:'-:CE through Lot 1':0, 3 on said Plan. South 36 degrees 30 minutes East. a distance of one hundred forty-two and eight one- hundredths (l-:':!.OS) feet to a poim on the North side of Poplar Church Road, the place of BEGINNING, BEING the Eastern thirty-five (35) feet of Lot No, 2 and the Western forty-the (~5'1 feel of LO! No. 3 on the Plan of Lots of Section "B", Riverview, which Plan is re~orded in the Cumberl:md Coumy Recorder's Oetke in Plan Book 10, Page 21. HA VING THEREON ERECTED a brick and frame dwelling house numbered ~33 Poplar Church Road, Camp Hill. Pennsylvania. TAX PARCEL NlJ~(BER: 4i-19-1590-00S TITLE TO SAID PRE~lISES IS VESTED N Stanley M. Deirnler. Jr. and Lauren 1. Deimler, his wife by Deed from Danna J, Blais, Executri:< of the Last \ViIl and Test:unem of Joan Gail Korte dated 12/1~/9~ recorded 1:!/1619~ in Deed Book 116 Page 303. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approvcd May 16, 1929), p. L.1784 STATE OF PENNSYLVANIA : 55. COUNTY OF CUMBERLAND : Roger M. Morgenthnl, Esquire, Editor of the Cumberland Law Journal, ofthe 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 the said County, and that the printcd notice or publication attached hereto is exactly the same as was printed in the reglllar editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 21,28, FEBRUARY 4. 2000 Affiant further deposes that he is authorized to verify this statement by the Camberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter oflhe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. -&3 :2??!~~ Writ No. 98-672 Clvtl Countrywtde Home Loans. Inc, IF IKI A Countrywtde funding Corp,) vs. Stanley M. Delmler. Jr.. Lauren J. Delmler Atty.: Frank Federman DESCRlPl10N ALL THAT CERTAIN piece or par- cel ofland, situate In the Borough of Wormleysburg, County of Cumber- I d and State of Pennsylvania. \ :o':,~ded and described as follows, 10 I wit: i BEOlNNING at a point on the i Norlh side of ~opl~r ~,I!u~.h ~o".? SWORN TO AND SUBSCRIBED before me this ~day of FEBRUARY. 2000 NOTMIAL S 'AL LOIS E, SNroE~. Nclory ""blie . CanjtJ., fooro. Curt\b<tnantl County, PA 1 :IV ("r.':mi~$ioll c).pir., Ih,J,fl:h.s, '200' i '.... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ret No, 587. RnDmund MQU t6. 1929 Commonw'llIh 01 P.nnlylvlnll, Counly 01 Oluphln) I. F~nkJ. Epler being duly sworn according to law, deposes and says: Thai he's the Controllsr 01 THE PATRIOT-NEWS CO., a corporation organized and existing under the law. 01 Ih. Commonwealth 01 Psnnsylvanla, with lIB principal ofl/ce and place 01 business at 812 10 818 Markst Str..t, In th. City of Harrisburg, County 01 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 Markel Slr..I, In the City, County and Stale aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were ..Iabll.h.d March 4th, 1854, and September 18th, 1949, reapecllvely, and all have been continuously published ever alnc.; That the printed notice or publication which Is securely attached hsreto /s exactly as printed and publlahed In their regular dally and/or Sunday and Metro edltlonBlisauss which appeared on the 25th day of January and the la' and 8th day(s) 01 February 2000. That nslther he nor said Company Is Interested In Ihe subject mattsr of aald printed notlcs or advsrtlslng, and that all of the allsgatlons of this statement as to the time, place and charaoter 01 publicatIon are true; and That he has personal knOWledge 01 the lacts aforesaid and Is duly authorized and 9mpowered to verify thla statement on behalf of Th9 Patrlot-Naws Co. aforesaid by virtue and pursuant to a reaolutlon unanimously pa..ed Ind adopted severally by the stockholders and board of directors of ths 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. / ~ PUBLICATION ..4L COpy SALEI43 c \ , I , , . ....- ~ " i;;;!'IaA"!8TATa8AU!'~,;'P':" I ',':t.;I.~:Jf<~J1~b' Writ No.' 11472;1~'~:,'l;l:~;lj"~: :.I~'\~~~',~l.t~:~'.v/~'!J ClvUT.... '.: :~~~;.:~;~~~(,lf'\<~..;( p )";:CoUE" . deHomeLolln.;". 'H..<:tno" . '''-ii-Ide''',,1 $"":"~,I,.~,...;!, . I~' !1"r~..;,.,J~~:::~ l ~", .)~.. ,,,;: l'~ urkI n , .., . '.',,-,"", , .~.~.1(""'l,*":I~'~''',,,,,- I,~"-l"~;~',,, i ~:,~;n-: \~;"\'~k'h if .l~. '\_~J~.~'!;.-.~,,'r: ;_' ',:' -',~, I i~,'\';;-~;~' 8....,; .1 De"r.'''~.i.:'.~;,:".:_ t- "''''';''.' .U" a ......mlef,...."., "" " .',;:'r-..,..,....... . ...... ""_.'!'/'/",; :":~.:t{i~-,~~#,~ n~~.~._I'~l8I'I:;"l:~,,:, t n ~!~)~[;~;'Pt4-::I'." ':1'~t~I'>,Wg~,~..\.(J'.',...: '.::.;,,"'; i ~;~i.(;\IZ;pp<~g~'(:;:i'?iNi'I' ''';"",;ALI;,:mAT"c:::~A.INi'plece.or, I ~p'r:cel of",nd;sltualeln the llol)l~gh'i :: lI.fy"Wormleysburg.{,lCCounIY"i' of" fi,C"mbertan dji','and! ",S 1.lej>o!..... 1< l'erliialil.v.nla; bou"ded and described,_ Nolarlal Seal Terry L. Russell, Notary Public Han15burg. DauphIn COunty My Commission EKplres June 6. 2002 P Ivanla Association of NdlIlf.,ommlsalon explrss June 8, 2002 Member, ennsy ...-,.-.. CUIv'BERlAND COUNTY SHERIFFS OFFICE c:x:.:llJfffiOJ CARLISLE, PA. 17013 Stalemenl of Advertlslna Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Feels) Total $ $ S 277.84 1.50 279.34 Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general clrculallon, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the aame have been duly paid. THE PATRIOT-NEWS CO, By.................................................................... REA.L :::ST AE Sf.L::: J-JQ S 1 ,000,00 Ad-:;mc: Com Paid 12 I 1 7 / 99 Arr::. Assessed VaJuation S B690. 00 \v"RITNO, 9B-672 Civil 43 Frank Federman Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. VS Stanley M. Deim1er, Jr and Lauren J. Deim1er 433 Po1par Church Road Camp Hill, PA RE.A.L DEBT ~'TEREST 5/5/9B-3/1/00 15.BO per diem A TT' S FEES 'WRIT COSTS ATTY ESCRo\V LATE CHARGE SHEF1FF"S COSTS Docke:ing Poundage Pos'dng Bill! Adve::ising Acknowledging Ded ..~..uctioce~r La'w Librw::- Co unry lvfile:!ze . Ce:1 )'l~il Le-,:: , Poslpone S.ue Surcharg~ $ 96,099.63 10, 522/BO + 1.548.40 1.172,75 30,00 19.04 15.00 15.00 30,00 10.00 1.00 27.90 3.33 15.00 20.00 24.00 Le~al Se:u-.-:h ...\..D\'ERTISi::G: La'.\' JOUr.i:J.! Patriel Shore of Bills Distribution of F,oce~:!s She:-iff s D~~d5 404.90 2~~',b~ 25.00 26.50 STA\.lPS Pa. Timisfe:: T:1:-: Tw'j) or Boro Transfer T:lx TAXES Sewer & Refuse 1,300.22 ': ~- , ~.: 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1/97 through 1/1/98 (Per Diem $19,75) Attorney's Fees Cumulative Late Charges 12/14/94 to 1/1/98 Cost of Suit and Title Search $84,794.38 3,653.75 4,239,00 276.48 550,00 Subtotal 93,513,61 Escrow Credit Deficit 0.00 255.52 Subtotal 255.52 TOTAL $93,769.13 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 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. WHEREFORE, PLAINTIFF demands Judgment against the Defendant(s) in the sum of $93,769.13, together with interest from 1/1/98 at the rate of $19.75 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. ~ :::r- ,_A~ "T ~ct'&vv"""'-- Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for plaintiff ~ '"' VERIFICATION Ili.abeth Blue hereby states that he/she is Assistant Vice- President of countrywide Home Loans, Inc. mortqaqe servicinq aqent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foreqoinq civil Action in Hortqaqe Poreclosure are true and correct to the best of his/her Itnovledqe, information and belief. The undersiqned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relatinq to unsworn falsification to authorities. DATE: /- .3(}. <;f . \ , I { , '.'. j" .'."-' D ,~:) 0 ~~ UJ I I "Tl '- ';} c: r.! r- e- '1 ;1.;.,;., i:: :::!iE! ...:: , (!,' , \ :S ~~: ~. .::. I: ; -,., :J "r. '~.~ '.. -11 " , " , ' ~ ;=~) ~n. (- ) :~) :.l'n .~.... ~;; ~_' ".1 -. ~ I " ~o -< ~ ~ tJ . ~ l1t III 0 U III ~ ~ M~ H ~~ . ~ M 'tl Gl . ~~ r.1 Z P':~~ Q Q 0 ~Gl . ~ - - III III ~ ~~ ~ 4-1 . ..:lNGl CD f!;llll U ..:lo..Q '" Hr-- '" a:rn ~ ~~ :.: M >t M Z~ -r.1 ~P':: fH! fol61 - Ofol U ~o ~ ~~ !i1tl 0] ~ - J.l Ql ... HQ ...'" -~ Ql E-< I.: . r.1 E2~ E-<o ~ H ... III Q . rz. > ~ E:~ ~fijp, H ~ . :> ~O :Sfij ='~ H Ou E-< _ Gl U . Ot: III~~ ~~ ~ tJ~ ~;g N ~:il~ r-- H ~ ~ \0 N 8~ - Ma~ I III U CD .. '" folfol ~ III fol 'tl i:~ ~ Ql ~lll~ ..:l ~ o 'tl . 'M ~ ~u ~ rz. IIICD~ IllM NM :.: r.1 .. Q rn H rn ~ Ql J.l 'tl ~ 'tl ~ 0 U '". - -. .\ , \ I / DESCRIPTION ALL TaA T CERTAIN p;"" " "re,; of ;''''. ,;""" 10 ", BO"".h of Wonnl'y"",. C,"o~ of Cumb~rland, and Slale of P~nnsylvania, bounded and d~scribed as follows, 10 Wil: BEGINNING al a poine on the Norlh sid~ of Poplar Church Road, which poine is loc:lled Soulh 53 degrees 30 minules Easl along th~ NOrth side of Poplar Church Road, a dislance of lhree hundred lhircy (330) feel from the ineerseclion of lhe e.xlension of lh~ Norch sid~ of Poplar Church Road with lhe eXlension of lh~ Wesl sid~ of HiIlside Drive as they appear on lh~ Plan of LOIs of Seclion "B" of Riven'iew; THENCE along th~ Norlh sid~ of Poplar Church Road. Soulh 53 degrees 30 minules Easl, a dislance of eighlY (80) feel 10 a poine: THENCE lhrough lh~ ceneei of LOl No, 2 on said Plan, Norlh 36 deerees 30 minules Wesl, a dislance of one hundred forcv-lwO and eiehl one- - . - hundredlhs (142.08) feel 10 a poine on lhe dividing line between lOIS Nos. 2 and 17 on said Plan: THENCE along th~ line dividing lOIS Nos. 2 and 3 from Lot No, 17 on said Plan, Norlh 53 degrees 30 minules Easl, a dislance of eighty (SO) feel 10 a paine, THENCE lhrough LOl NO.3 on said Plan, Soulh 36 degrees 30 minules Easl. a dislance of one hundred forcY-lwo and eighl one- hundredlhs (142,08) feet 10 a poine on lhe North side of Poplar Church Road, lhe place of BEGINNING. BEING lhe EaSlern lhircy-fi~'e (35) feet of LOl No, 2 and lhe \Veslern fOrty-th'e (~5i feet of lOI No. 3 " 'h, p,,, 0'- Lo" of S"d" .. B'. Ri"~i,w. whi'h p,,, " =0<'" ;0 'h, C,mb'd", C,"O" Recorder's Of lice in Plan BOOk 10. Page 2!, HA VI:-iG THEREON ERECTED a brick and frame dweliim! house numbered ~33 Poplar ChUrch Road, Camp Hili, Pennsylvania. _ TAX PARCEL NUMBER: 47-19-1590-008 TITLE TO SAID PREMISES ;5 VESTED 'N SooJ" M. Deiml". J,. ,,' L,,,,, J. DeimJ". hi, wit, by Ceo, from D,,,, J. B"a. E."""" of '" L~, Will ,,' T~""", of Jo" G'il Ko", dated 12/14/94 recorded 12/16/94 in Deed BOOk l!6 Page 303, . - () f.'.~ P/': //.1; I" -c .(\ iV', 1\ .' I .'~' I~; i " , \ i" \ it~ ;-'j'< .1' ;'1 !f :.-[ 0:) "" :-, " _ "'1.1.1'" c_': .' ~ . ~.,.;, ",j(:J ':::1 -- r ..~. -,:1[:J :'.J '. ;:!1- ". I:'~ ,~) ..... "Jill (b :::'1 ':'r~ ~..-~ Uj {oJ "1 ''':> 't: V '-, ,. :;. ~~ ) . :(~ ~. ~~i ~ :-- ~ -- -- .Q ~ ~ '4 _ I>t" l>J .. '" ... :-<","'-.0 . '" ~ ..-..t') ~ '" au,' ,7'\ .~ ~ . t ., $ "- " , , . c '& 1 ~ ...t:'" .,:"",1:) 'ea~~ rR ~ ll( '" ..., " -<: ~ f \\ ., COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER NO. 98-672 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS. INC. (F/K/A COUNTRYWIDE FUNDING CORP.) , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ" sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011. 1. Name and address of Owner(s) or reputed Owner(s) : NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) STANLEY M. DEIMLER. JR. 25 SOUTH 32ND STREET CAMP HILL. PA 17011 118 BEARD ROAD ENOLA. PA 17025 LAUREN J. DE IMLER 2, Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3, Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) FULTON BANK P.O. BOX 432 EAST PETERSBURG. PA 17520 COUNTRYWIDE HOME LOANS. INC. 6400 LEGACY DRIVE PLANO. TX SUSQUEBANC LEASE COMPANY 2 MARKET SOUARE MANHEIM. PA BOROUGH OF WORMLEYSBURG 20 MARKET STREET WORMLEYSBURG. PA 17042 . . 4, Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COMMERCE BANK/ HARRISBURG N.A. 100 SENATE AVENUE CAMP HILL, PA 17011 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 so 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 so indicate) NONE 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: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 13 NORTH HANOVER STREET CARLISLE, PA 17013 30 EAST COURT STREET DOYLESTOWN. PA 18901 DOMESTIC RELATIONS OF CUMBERLAND COUNTY DOMESTIC RELATIONS OF BUCKS COUNTY 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. December 10. 1999 DATE ~~~ F K FEDER , ESQUIRE -. A torney for Plaintiff ~ ~ q 0 './) 0 c: U) ''II :'l i c::J 'T~ r,'"j rq 1-: ....~] ;TJ :~:.: i .''"1.:''1'1 Uj : en .. f""1 ~~ , r :':~ ..:i ~-) J- " Co" '," , '. . ;..;,2 (~ ....-. ~"~ =,;,.J C'" rn ;," :-j . -'! " 10 .. - ^ COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER NO. 98-672 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY December 10, 1999 TO: STANLEY M. DEIMLER, JR. 25 SOUTH 32ND STREET CAMP HILL, PA 17011 LAUREN J. DEIMLER 118 BEARD ROAD ENOLA, PA 17025 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 **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, 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 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriff's Sale on MARCH 1. 2000 at 10:00 a.m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96.099.63 obtained by COUNTRYWIDE HOME LOANS. INC. IF/K/A COUNTRYWIDE FUNDING CORP.) (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take inunediate action: 1. 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. 2. 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. l. be sold calling If the Sheriff's Sale to the highest bidder, (215) 563-7000, is not stopped, your property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property, 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (717) 240-6390, if the buyer pays the To find out if this has 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale, The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office, The 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 filing of the proposed schedule, I , , I I I l ,~ i! 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 \, " , . , , , , I:....,. . \ \ i DESCRIPTION ALL THAT CERTAIN piece or parcel of land, siruate in the Borough of Wormleysburg, County of Cumberland, and Slale of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the North side of Poplar Church Road, which point is located South 53 degrees 30 minutes Easl along the North side of Poplar Church Road, a distance of three hundred lhirty (330) feet from the intersection of the extension of the North side of Poplar Church Road Wilh the extension of lhe West side of Hillside Drive as they appear on lhe Plan of lots of Section "B" of Riverview; THENCE along the North side of Poplar Church Road, South 53 deg~ees 30 minules East, a distance of eighty (80) feel to a point: THE:--iCE lhrough lhe center of LOl No.2 on said Plan, Norlh 36 degrees 30 minules Wesl, a distance of one hundred forty-two and eight one- hundredlhs (142.08) feel to a point on lhe dividing line between LOIS Nos. 2 and 17 on said Plan: THENCE a10n!! lhe line dividine lots Nos. 2 and 3 from lOI No. 17 on said Plan. North 53 degrees 30 min-utes East, a disla~ce of eighlY (SO) feel to a point. THENCE lhrough lOI No.3 on said Plan, South 36 deerees 30 minules Easl. a distance of one hundred forlv-two and eiehl one- - . - hundredths (142.08) feet to a point on the North side of Poplar Church Road. the place of BEGI:-lNING, BEING lhe E:mern lhirty-fi~'e (35) feet of LOl No, 2 and the \Vestern forty-the (~5', feet of lOI No. 3 on lhe Plan of Lots of Section "B", Riverview, which Plan is recorded in lhe Cumberland Couney Recorder's Oflice in Plan Book 10. Page 2l. HA VI:--iG THEREON ERECTED a brick and frame dwelling house numbered 433 Poplar Church Road, Camp Hill, Pennsyl~'ania. TAX PARCEL :-lUMBER: 47-19-1590-00S TITLE TO SAID PRE:-.rrSES IS VESTED IN Stanley M. Deimler, Jr. and lauren J. Deim1er, his wife by Deed from Danna J, Blais, Executrix of the lasl \\iill and Testamem of Joan Gail Korte daled 12/14/94 recorded 12/16/94 in Deed Book 116 Page 303, . .",' n l.o n . . c u J -, \ ::--:1 ..,,\ . ~.....-, -.."T'\ 1:'] . (-') "Ib ; ,;C? , ," " .:~'!{;i). 1< ::~ -. , . , .., ~ {-) .rn :.:? (') , , :':"1 " ~O "- , 0 :..~ , " , . COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) . . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : : VS. . . STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER . . NO. 98-672 CIVIL' AFFIDAVIT PURSUANT TO RULE 3129 IAttidavit No. II COUNTRYWIDE HOME LOANS. INC IF/K/A COUNTRYWIDE FUNDING CORP.l, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the praecipe for the writ of Execution was filed the following information concerning the real property located at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011. 1. Name and address of owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) STANLEY M. DEIMLER. JR. 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 LAUREN J. DEIMLER 433 POPLAR CHURCH ROAD CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the jUdgment: NAME LAST KNOWN ADDRESS, (if address cannot be reasonably ascertairied, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) FULTON BANK P.O. BOX 432 EAST PETERSBURG. PA 17520 ," '. .r . . '. , . COUNTRYWIDE HOME LOANS, INC (F/K/A COUNTRYWIDE FUNDING CORP.) : CUMBERLAND COUNTY COURT OF COMMON PLEAS . . VS. : CIVIL DIVISION STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER . . : NO. 98-672 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY June 15, 1999 TO: STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 433 POPLAR CHURCH ROAD. CAMP HILL. PA 17011, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 1, 1999 at 10:00 a.m. in the Cumberland county Courthouse, South Hanover street, Carlisle, PA 17013, to enforce the court judgment of $96.099.63 obtained by COUNTRYWIDE HOME LOANS. INC IFIKIA COUNTRYWIDE FUNDING CORP.l (the mortgagee) against you. NOTICE OF OWNER'S RIGHT~ YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's sale, you must take immediate action: 1. 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: 1215l 563-7000. 2. 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 HAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling 2. sale if of your If the Sheriff's Sale to the highest bidder. (215) 563-7000. You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. is not stopped, your property will You may find out the price bid by 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (215) 563-7000. if the buyer pays the To find out if this has 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 Sheriff on 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 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 COURT ADMINISTRATOR 4th floor Cumberland County Courthouse (717) 240-6200 . 'l DESCRIPTION ALL THAT CERTAIN piece or parcel of land, siruate in the Borough of Wormleysburg, County of Cumberland, and Slale of Pennsvlvania, bounded and described as follows, to wit: BEGINNING al a poine on lhe Norch side of Poplar Church Road, which poine is localed South 53 degrees 30 minutes East along the Norch side of Poplar Church Road. a distance of three hundred thirty (330) feet from the ineerseclion of lhe extension of lhe Norch side of Poplar Church Road Wilh the extension of lhe West side of Hillside Drive as they appear on the Plan of lots of Section "B" of Riven'iew; THENCE along the Norch side of Poplar Church Road, South 53 degrees 30 rninules East, a distance of eighty (80) feet 10 a point: THENCE lhrough the ceneer of LOl No, 2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred farcy-two and eighl one- hundredths (142.08) feel 10 a paine on the dividing line between lOIS Nos. 2 and 17 on said Plan: THENCE along the line dividing lOIS Nos. 2 and 3 from LOl No. 17 on said Plan. Norch 53 degrees 30 minutes East, a distance of eighlY (80) feet to a poinl, THENCE lhrough LOl No. 3 on said Plan, South 36 degrees 30 minules East. a distance of one hundred forty-two and eight one- hundredths (142.08) feet to a poine on the Norch side of Poplar Church Road, lhe place of BEGINNING. BEING the Eastern thircy-five (35) feet of Loe No, 2 and lhe Western farcy-five (45) feet of Lot No. 3 on the Plan of Loes of Section "B", Riverview, which Plan is recorded in the Cumberland Couney Recorder's Office in Plan Book 10, Page 21. HA VING THEREON ERECTED a brick and frame dwelling house numbered 433 Poplar Church Road, Camp Hill, Pennsylvania. ~AX PARCEL NUMBER: 47-19-1590-00S ~ T~TLE TO SAID PREMISES IS VESTED IN Stanley M. Deimler, Jr. and lauren J Deim1er his ;lfe by Deed from Danna J. Blais, Execulrix of the Last Will and Testamene of Joan 'Gail Kort~ aled 12/14/94 recorded 12/16/94 in Deed Book 116 Paoe 30~ " ,). f r ,~'", r-r'1-j\TC (',1\1 F r'~[i ~<b r""l~1 I" j:' / ~ dt\l__!. '" ~\L .~ (..'\.1 ." ... I.np J~ 1'*91 th;: sl':oriff it:'lilj,;j lJprm llle defenaanlli Illiams! in lJ'!l) real prO~3rfy :.H!Ja((!(~ in &/~.~ CumlJerlilnd Caur,ly. Pa" klil).,vil .~Ild flUiIlUer&:J as: -~,Le~CZ4~~.L~ c:v, c:u:u = GE) IInJ /!,. /1 I," '/JA . "'J,' ,',..",'.' (',"'.. '~i\':'i'''I't.'',.: l"" E"'III'hl'! "Jl" ("""(} ""1""" ~./,~. ':'...~ '.I..It:, ~Jllj .....,...., ...,.... I, ".,;.) r\ '" r~ ~i this 'o':ri! ,11;'1 (/1 ii'lis r:JI.~i(lilC(: iilCOrpl}f2t:Jd l1~rejn. ~dri~ ~~L~....L'9J____ , , ~'.. '.' 'r ,; ,:J '1ft" t""''-'R...L'E-......Ii&LI' 'No" "21' "'.':~,: ~.:/:,,('. 5I't .''''Ii -, . ':':';",' ';, ;..";-..:~.{~:,,:;~~=,~~-;;;:~::~,.,) '."',1,, Countrt*IdI HomILaIn.( .,.1.: ~. "'-",,'-.,," "'11)\;) ~i'rl ',,4,, ',' '}o."'" ," """"~'" L,.;;.' :': .,~~"h"i- i/~"'~ ~-i"l'" I,i~~~i~,t'>~(~-i:~::~ '~\'-':V {~,,1 ~&,'~;; itWJ,u;qrvI r~ tt/_;,;~ ~.?,:;', {~~ ~'\t;::~,~ :,~\,,;,SlIn/Iy ""llIlmllr,Jr. ~nCI.'.',:" ;.'~,';'-D.; ;.::.f:i' Llu.....J.- Dtfm., ~,: ~): j;j;:~<~,:-~ ,.t I; ":ii'IAIty: Fratlk I'IdIrmIn,;e;..,/!:, "',<':',' _ ",'-, DESCRIPTION ',t!,fLj1:'i~~;\J" . ALL THAT CERTAIN pfaceOr parctlOl , land, 'f IlluIla,\ln ..tha':, Borough)' of,' ,Worrniiyeburg, County 01 Cumballaiid; and ~ , Stale ',oIt Pilnnlyty8nlaii boundad;;and' desCribed as folloWs, to wtt::'::':.'~'t"',:'.\:\;"Ji~'\~; ,.?, BEGINNING'at.apolnt,on.lhe;NorIh, ; IIde of. Poplar,Church Roacl;whlch:polntl8; : located SoutII 53,cllgr-.30 IIlInu* EaIl, "a/ona IhalNorlh,IIde<ol;Popla/:Church; '. Roaa.; a' dIsta!108 .:of.thrae: hundllld .lI1lrty I \ (330)'ifaal', from', the ,'Inlafaacllon :01 : Iha i '. menaIon'lO/('1ha 'NorIh ',aldt::oI !'Popl"; i Church.,Road;w!th:Iha'extenalon;of ,thai ~,w.t Ilde 'of Hillside DrIv8 as lhay' appea,! j ori'thell'lan"of; Lola ',of: SeCtIon: :'8',; 01' 1 RNaIvIaW:" ' . THENCE afo!1g tha North aide 0/' !F.cIGliK,Chun:h floaci.~ll3cl!1l11W,30" lI/lllilWEIi~,..' dIitInce'Of:iral!I918OlJill) 'loiam:t;,THENCE ......."'Iihi'_.\ll, 'LOl',\ ,oit'IBlcUltlri;,''''''''. ~'i:!8""'. f30~ , ",WaoI;Ya;"dIaWIc>>~ol:OiIai .~. --'10 ty two'''8''nd'"el\Jht-~....-", '. ... ,;",' r .'.~ ,...._~ ~:''''''~'', ~ '.'. :l142.OB)'raet IO'apOlntonthei )dlvIdlria-... batweei1,LotI Noa.2andl1on i "aaId Piln:THENCE aloIlg'thelfntcllvldlllil" ~t:oCI'Noe!2 and 3 from Lot No,'.17.Qn NIICl1 1 PIa!\'North 'll3deg,_'30ml...a'EiIl.'a' (cllalancerpl;,ilghly~ (60) ,leal,loia"ipOlnl;i ~THENCe.th(OUg/1;Lol NO. 3 on.8IId:"*!,, 1"llouIl~..digiae8; 3Oiml~-1 EaIl;!a,,' '~dlitai1i:a'Dl Cna htIldllld .. .,-twolncl, elghl1 \Ona-hunClr8ilthaJl42.OB)'fa8t 10 a 'point on i ; IhaIaceNorthol BEIldeGIN': 'NINGI'ol!'~':ChI ,,~~:,~,;~jl '-: P ,," .,fY-; "h;;~Ji"}{I!:i~_~~',il'-;; :>; ;..j!iBEING,lha Eaatem,IhIfly-ftoM(35)leali t, of Lot No, 2 and lha Weatem forty.lMi(45) ,; ,feet 01, Lot No. 3 on lI1a: Plan of Loti; of ; fSecUoll:,.;'a;, .,RIvarvIew"whlch', PIal1~Ia.: : rllCOIdlid'lln:\; the;;Cumberland ;':~1 "2R,~(e'~, )~;,~n.,~JO.i,"""1 \;,,:; kAVI~ 1iiERE6N'EREoTEilt'~1 rand fra!Il8: ctNelllng house.oumtJnd433' &I'opla,:'-.: Church '''" Road,';..'Camp,';: Hili; j ".baA =,' ""';':':""':''-\'''''-~:'', ',..'ri""l,~,'."""~~"~'.'.lJ ..,,....,, . :,' ,,~',:, '.:' .....!- ,0 ,...,,,,,, ~"", 11;:1. ;~CEIi'iNUMtieFt;47:;ip:ljO.; :,OO8~',;~;Af-i~)'i.~~t- l::,\, l\:: 1':;'~~ :.:3~} ~1,t:tX> ;'~~~".1 'i' ,'"TlTLE,;,.Tt'"t SAID :;,PREMISES:~,IS, NESTED I.N ,~M:, Defmler; 'Jr:aild'j ,Lauren, \1;: Dll,",*. . ,his, wile, by '.DacId ',110;, iDanna;;), BlaIa;e.a.tifxollli8:1.aat WIlt i and Teatamenl of Joan Gall Korle dIlted 121,' ('1411141wCon1ed12l1ll194In DaldBook 118; L~~ ~~".5:~:~1~;!~':! :i'~,~j ;1 i~~:t} :(~(:l:_;:~~~~~~~; .' . ' ?\ l. " \ ': I~ M: , I I I r ~ '. " i ~;,ti\'>.::. '. .~ i ',.~ / i I'. ',"' . ". " \. 1- '" ......, , ",i~: 1 . J rr'., I I ! >J\ , . ~ H" I I \ I r I I I I \ I I r ". - " j , j i ( I i' I 11 il: if' \,:'1, 'I," il': ! ; , , I I , . \ ''tI I " " I I, "if ... , ,'" "- lI: ,- I ~ .-- ..., , , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587. AODrDued May 16.1929 Commonwealth 01 Pennsylvania, County 01 Dauphin) ss AfichsB/Afor,ow being duty sworn according to tow, deposes and says: That he Is the Asslstanl Controllar of THE PATRIOT.NEWS CO" a corporallon organized and exlsllng under the laws ollhe Commonwealth of Pennsylvania, with lIs principal office and place of business al 812 10 818 Markel Streel, In the City of Harrisburg, County of Dauphin, Stale 01 Pennsylvania, owner and publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS newspapers of general clrculallon, printed and published at 812 to 818 Market Street, In the City, County and Slate aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 18th, 1949, respecllvely, and all have been conllnuously published ever since; That the prlnled nollce or publication which Is securely attached hereto Is exactly as printed and published In their regular dally and/or Sunday and Metro edlllonslissues which appeared on the 27th day(s) 01 July and the 3rd and 10th day(s) of August 1999. That neither he nor said Company Is Interested In the subject matter of said printed nollce or advertising, and that all 01 the allegallons of this statemenl as 10 the lime, place and character of publica lion are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verily this statement on behalf of The Patrlot,News Co. aforesaid by virtue and pursuant to a resolullon unanimously passed and adopted severally by the slockholders and board of directors of the said Company and subsequently duly recorded in the office for the Rocording of Deeds in and for said Count~ of Dau hin In Miscellaneous Book "M", V~~1~P~e~~ - PUBLICATION COpy SALE #28 CUMBERLAND COUNTY SHERIFFS OFACE COURTHOUSE CARLISLE, PA. 17013 Statement of Advertlsina Costs To THE PATRIOT-NEWS CO" Dr. For publishing tne notice or publica lion attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Tolal $ 378.14 1.50 377.64 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 nollce and pubncallon costs and certllles that the same have been duly paid. THE PATRIOT-NEWS CO. By.................................................................... . . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Aet No. 587, approved May 16, 1929), P. L,1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberlund Law Joumul, of the County and State aforesaid, being duly swom, uecording to law, deposes und says that the Cumberland Law JounmI, a legal periodieal published in the Borough of Carlisle in the County and State aforesaid, was established Januury 2, 1952, und designated by the local courts as the ortieiallegal periodical for the publication of all legal notices, and hus, sinee January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attach cd hereto is exaetly the same as was printed in the regular cditions and issues of the said Cumberland Law Joumal on the following dales, viz: JULY 23, 3D, AUGUST 6, 1999 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true, REAL ESTATE SALE NO, 28 Wnl No. 08,672 Civil Countrywide flame Loans. Inc. vs. Slanley M. Delllller. Jr. and L..'1urcn J. Delmlcr Ally.: Fronk Federmall DESCRIPTION ALL nlAT CERTAIN piece or par. eel ofland, situate In lhe Borough of Wormleysburg. County of Cumber. land. and State of Pennsylvania. bounded and described as follows. 10 Wit: BEGINNING at a point 011 the Nonh side of Poplar Church Road. which point Is located Soulh 53 de- grees 30 mJnules East along the Nonh side of Poplar Church Road. a dlslanee of lhree hundred lhlrty (330) feel from Ille IntersecUon of the extension of the North side of Poplnr Church Road wllh the extension of the West side of Hillside Dnve as they appear on the Plan of Lois of Secuon ; "B" of Rlvervlew: THENCE along the North side of Poplar Church Road, South 53 degrees 30 minutes East. a dlslance of eighty (80) feet to a polnl: 1llENCE lhrough the center of Lot No.2 on &11d Plan. North 36 degrees 30 mJnules West. a distance of one hundred forty,two and eIght one, hundredlhs 042.081 feel 10 a polnl on the (IIvlclln~ line between l.ots Nos. 2 alltl 17 on said Plan: TIII-:NCE nlol1~ the lIue dlvldln~ (.ots Nos. 2 and 3 rrum Lot No. 17011 said Plan, North 53 de~rees:m minutes East. it distance or eighty (BO) reel In n pOint. TIIENCE through Lot No.3 on said j Plan. Soulh 36 de~n~es 30 minutes Enst. n ~lslnnl"C or one hundred rurty. '/Yf?/L--- Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this --G.-day of AUGUST. 1999 J' L' '-,;' J: 0 ' ( / IJ .~ ~. /.( / .I1.(,rUA~ NOTARIAL SEAL 1OI5 !, SN~DER. Nolory Public Corlitle Bor<>, Cumb.rland County. PA My Commiuion bpir., Marth.5, 2001 ~ , '. (14~ 'I;~'" . -... :i ,t. p , ';'. , .. " ) . -..,.' , " .\1.1. TllAr Lt:I\T./~II; IJj~Ll: lJl ~.u- rei oflanrt. sltl1:ltc 111 the Anrou(!h of WorllllcyslJurg, COllllty of CUllluer- land. nnd Slale of Pennsylvania. bounded and described as follows. to WlI: BEGINNING nl n point on the North side of Poplnr Church Rand. whleh point Is locnled South 53 de, grccs 30 minutes East along the North side of Poplar Church Road. a distance of three hundred thirty (330) feet fromlhe Inlerscellon oflhe extension of the North side of Poplar Church Road with the extension of (he West side of J IlIIsldc Drive as they appear 011 the Plnl1 of l.ols of Sccllon I "II" of Illvervlew: TI mNCE nlonA Ihe Nor1h RUle of Poplar Church Hnacl. South 5:J dcltrccs ao minutes I~nsl. n ..-~ cllslnlll'c nrcllthty (801 feci to n pullll: I"'JlI~NCI~ Ihrntl,Lth the (:(~l1h'r of J.n( Nu, 2 uti ~Ulld I'lulI. Nurth :10 dl',l.tft.C's :10 1I11J1l1h!N Wcst. 11 cll!-tll1lu'(~ of Olll' Jlllluln'f1 rurly.lwn urnl t~llthl lJIll'- I hlllldn'(lIhs fI,12,081 ft'l'l In n pUll It _I. 011 tile dlVldJlIg IUle between Lots Nos. 2 nnd 17 on said Plnn: TIIENCE nlong Ihe line dividing Lots Nos, 2 nnd 3 from LoI No. 17 on snld Plan. North 53 dCArces 30 minutes East. a dlslanee of eIghty (80) feet to n point. '! TI1ENCE Ihrough Lot No, 3 on said Ii Plnn. Soulh 36 degree! 30 mlnules " Ensl. n distance of one hundred forty, two and eight one,hundredlhs (142. .08) fret 10 n point on the North side of Poplnr Church Road. the plnce of BEGINNING. BEING Ihe Eastern thirty. five (35) feel of Lot No. 2 nnd the Western forty. five (45) feet of LoI No.3 011 Ihe Plan of Lots of Section "B-, Rlvervlcw, which Plnn Is recorded In the CUItl~ berland County Recorder's omce In Plan Book 10. Page 21. HAVING TIIEREON ERECTED n brick Rnd frame dwelltng house numbered 433 Poplar Church Road, Camp Hili. Pennsylvanln. TAX PARCEL NUMBER: 47-19, 1590,008. TITLE TO SAm PREMISES IS VESTED IN Stanley M. Delmler. Jr. and Lauren J, Dclmler, his wife by Deed from DannaJ, Blais, Executrix of the Lost Will and Teslamenl of Joan Gon Korte doled 12/14/94 rr.. corded 12/16/94 In Deed Book 116 Page 303. (......../~ A ~., J /~ viol /-1 d~L<.A ..-" HOT"RfAtSEAL 1Ol6 E. SNYDEW, Noto'Y Public Corlltlo Iloro, Cumb.rland County, PA My Commiufon bpi,.. March.5. 2001 ~--"., , '"' ~ r I';' , " .. '" _of\. ,>.. 'o>r '.. ';~ " I, j..<-: ... ",. '. \ ;n~~ " "::J'"'tP-1 ,. j , J..JI\ , " :''1'' fl i 1 ~,;. .....Ijo...,:;..1.,'t'!.,i\ .',:' ..-.......J..~:..,,"'"'" .~: ,1 .' ~ , -.;:;' ~", -.~ ..1 ',.,.' . ''00.:. ~!""',.'1 , ;:\ . ~< ~~ ''5'''.. .... " ,. . ~ .:. " . '. 'l':-e-_' . .,' iO'~< 1-, k, ! ,14, .)l. ,,: .. ., I \. f"" .' ',> " " ~ .,'\> !i " ~! 'I. ,;(-."," '.... .t' , I " . .... i' ....~ :. .. '"' SENDER: _Chick box Ilnghtrf )QIrecpren..tricted~. . PI1nt )OIl' NIne am atnu on the ,..... of IhiI form 10 thai M can ntturn this card IOlOU- . AItKh IhiI kwm 10 iN front of ttw 1Nll1piec., Of on 1M b<<k if apace does not ,*mrl . The Return ~ ....... ahow to vwt'cm the artldt was doIMtred n the drale deIIYMed. 3. reaa tit I olso wish 10 "",elve the following ~es (for on exlro fee): !if'Reslrlcted Delivery ',:' Consult poslmaste, 10' fee. 40. ArIlcle Numbe, l P 974 231 626. I 4b, Service Type - . )( CERTIFIED j' I , 7. OOle of Deliver 1/- tiD - 8. Addressee's Address LAtl~N:J.' IlIIi.a.U... 113 ;iUIUl ROAD r.l/oIX,'"" 17025 " ,.. Domestic Return Receipt ./ ) ,\ \ j 8 ;-0 "'T:[i~ ~~:U zc- C/J r. , .~# ~c -;:: zG ;:; l.-) c: ~ \ . i \ .' \~ l' C) C) ,- ~'!.. "1. .,- Q '" ::;.1 - i;:g ':I" ")\,,-:J :~:~J (LJ ...!-r. , '..'):n '.'(':1 5"'1 ~ :0 -< OJ -n ;:l; W N ..... [>2) .g;J t" .1, , FEDERMAN AND PHELAN by. Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS VB. STANLEY M, DE IMLER , JR. LAUREN J. DE IMLER CIVIL DIVISION NO. 98-672 CIVIL PRAECIPE FOR RULE TO SHOW CAUSE TO THE PROTHONOTARY: Kindly enter a Rule upon STANLEY 14. OEIMLER, JR. LAUREN J. DEIMLER, Oefendant(s) to show cause why the attached Order for Reassessment of Damages should not be entered. ~(] Lisa D. Blankenburg, Esquire Attorney for Plaintiff ,--..~-~-:-,:.;...... , . FEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 /215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VB. STANLEY M. DEIMLER, JR. LAUREN J. DEIMLBR NO. 98-672 CIVIL RULB AND NOW, this l 0 fb, day of F4 r... 2J 1 ZOOO , a Rule is entered upon STANLEY M. DEIMLER, JR. LAUREN J. DEIMLER, Defendant(s) to show cause why the attached Order for Reassessment of Damages should not be entered. w--;t~ ,,,' 2.0 d;> ,oS J Su \.l t 2.,,- RULE RETURNABLE t>I.~ duy v( . BY THE COURT: {dto 'J. ~/ ~~ J -/'1-00 RKS . '. ,"-!' ~'\'\ !~,I ". '.... ),: r::" .' - :-:~":!:8 l ,~: :,:~ ::.1 'I ,~~;j ;~;J ), ~ . i. . ., :'~. ~: f ) COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY COURT or COMMON PLEAS FEDERMAN AND PHELAN bYl Lisa D. Blankenburg, Esquire Atty. 1.0. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF vs, STANLEY M, DE IMLER , JR. LAUREN J. DE IMLER CIVIL DIVISION I 1 I ,I NO. 98-672 CIVIL ORDER ANO NOW, this day of , the ~ Prothonotary is ORDERED to reassess the damages in this case as follows: Principal Balance Interest Amount 7/1/97 through 3/1/00 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Inspections/Other Appraisal Fees Escrow Credit Deficit 84,794,38 18,659,12 1,053,78 4,239.00 1,946,50 1,900.13 332.50 0.00 ,\ , I 0.00 5,395.77 i > , TOTAL $118,321.18 Plus interest per diem from 3/1/00 through Date of Sale at six (6%) percent. NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS AND COMMISSION ARE NOT INCLUDEO IN THE ABOVE FIGURES. BY THE COURT: J. 1 stayed, and Defendant(s) have been given credit for any payments that have been made since the judgment, if any. follows: The amount of damages should now read as Principal Balance Interest Amount 7/1/97 through 3/1/00 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Inspections/Other Appraisal Fees Escrow Credit Deficit 84,794.38 18,659.12 1,053,78 4,239.00 1,946,50 1,900.13 332.50 0.00 0.00 5,395,77 TOTAL $118,321.18 5. Under the terms of the mortgage, Plaintiff is entitled to inclusion of the figures set forth in paragraph four in the amount of judgment against the Defendant(s). WHEREFORE, Plaintiff respectfully requests this Honorable Court issue an Order to the Prothonotary to reassess ~ Lisa D. Blankenburg, Attorney for Plaintif -2 - j ,. '"' FEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. STANLEY M, DEIMLER, JR. LAUREN J, DE IMLER CIVIL DIVISION NO. 98-672 CIVIL BRIEF OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. BACKGROUND OF CASE Plaintiff and Oefendant (s) entered into a Promissory Note and Mortgage Agreement, wherein Defendant (s) agreed to pay Plaintiff principal, interest, late charges, real estate taxes, hazard insurance premiums and mortgage insurance premiums as said monies became due. In turn, Plaintiff's Note was secured by a mortgage on the subject premises. The Mortgage Agreement indicates that in the event Defendant(s) defaults, Plaintiff may pay any necessary obligations in order to protect its collateral, the Bubject premises. In the case sub judicia. Defendant (s) failed to abide by the Mortgage Agreement by failing to tender numerous, promised monthly mortgage payments. Accordingly, after Plaintiff determined that Defendant (s) were not going to cure the default and bring the loan current, Plaintiff commenced a Mortgage ForecloBure Action. Judgment was subsequently entered by the Court, and the subject property is scheduled for Sheriff's Sale. \ , I i I I, h f l I' i ,\ , ,: ,..',~...' .""~..-. necouoe of the exceoolve perlod of tlme between the inltiotlon of the Mo,otgoge Foreelooure Action, the entry of Judgment ond the She.-!H's Sole dote, damageD aD prcviouoly iloocoocd by the Court are outdated and muot be incre,loed to include current intereot, real estate taxeD, inourancc premiumo, and other expenoes which Plointlff hoo been obllgoted to poy under the Mortgoge Agreement in order to protect Ita Interest. II. ARGUMENT FOR REASSESSMENT OF DAMAGES The Pennoylvanla Rules of civil Procedure are silent with respect to the iSDue of Reaosessment of Damages; however, Rule 1037 provideo, lithe Prothonotary shall assess damages for the amount which Plaintiff is entitled if it is a sum certain or which can be made certain by computation.,." In the instant case, the amount to which Plaintiff is entitled is readily calculated by review of the Mortgage Agreement, which is of record, together with the Complaint which specifically lists the items chargeable, Clearly, if Rule 1037 gives the Prothonotary the right to assess damages for the amount to which Plaintiff is entitled as set forth in the Complaint, the Court has similar power to reassess damages at a later date. In addition, Rule 1037(a) provides that the Court, on motion of a party, may enter an appropriate judgment against a party upon default or admission. If the Court has the power to enter judgment, it certainly has the power to do a lesser act, to wit, reassess damages. . It io oettled law In Pennoyl'lanla that the Court may exercloe ito equitable powero to control the enforccment of a judgment and to grant any relief until that judgment lo oatiofled. 20 P.I,.E., Judgmcnto Sec. 191. See aloo, SteRhenoon v. Butto, 187 Pa.Super 55, 59, 1-12 A.2d 319, 321 (1958); Cha,",-,,- Home Mort.9!!ge corporatlc;m of._t.he,'p.o,!Lthw,,,s,t.y. fl.ooej. 537 A.2d 22, 201 (Pa.Super 1988) . In Chase Home Mortlli'.9~, the Court otated that where a judgment has been assessed following defendant's failure to flle a responsive pleading in a mortgage foreclosure action, a mortgagee "... could properly move the court to amend the judgment to add addItional sums due by virtue if the mortgage's failure to comply with the terms of the mortgage agreement..." Id. at 201, Because a judgment in mortgage foreclosure is strictly in ~, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. See Meco Reality Company v. Burns, oIlol Pa. 0195, 200 A.2d 335 (1971) . Plaintiff submits that if Plaintiff went to sale without reassessing damages, and if there was competitive bidding for the subject premises, Plaintiff would suffer irreparable harm in that it would not be able to recoup monies it paid to protect its interest. Conversely, a reassessment of damages will not be detrimental whatsoever to Defendant (s) as it imputes no personal liability. The Supreme Court of pennsylvania found in the Landau v. Western Pa. Nat. Bank case that the debt owed on a mortgage changeD ilnd Cilll be expected to chilngc from dilY to day, beciluoe Weotern pennoyl van 1,1 Illuot poly expenoeo for the property In order to protect i to collateral. 445 Pa. 117, 282 A.2d 335 (1971). Becauoe a Illortgage lien io not extinguiohed until the debt 10 paid, Plaintiff Illuot protect lto collateral up until the date of oale, See !l.~ck!!lmL.y....-,\I.tCl()!E!...:r.r.lIl!J:....~P-,-, 332 Pol, 545, 2 A.2d 826 (1939). Therefore, Plaintiff reopectfulljl oubmlto that if the enforcement of ito righto are delayed by legal proceedingo and enforcement of ito judgment, and ouch delayo require the mortgagee to expend additional sumo pursuant to the Mortgage, then said expenses become part of the mortgagee's lien and should be included in said judgment. As the Court indicated in FNMA v. Jefferson, an unreported case a copy of which is attached hereto, since the charges enumerated in Plaintiff's Motion for Reaosessment of Damages were incurred pursuant to the Mortgage Agreement, and the mortgage had not yet been paid, said charges should be included in Plaintiff's judgment amount. May Term, 1986, No. 2359 (CCP PHILA. 1986). III. CONCLUSION Plaintiff respectfully requests this Honorable Court grant its petition to Reassess Damages. Plaintiff respectfully submits that it has acted in good faith in maintaining the property in accordance with the Mortgage, and in reliance on said instrument ... .. .. '. I ,~ .. . .......C-'I -- .., f'(" :J. I,.: i " . ~ -, ~.... ... ~ ,I' . . . , -" " /,'J-..?3/,S n::J::il,,", N^':':C~!,'..:, HC?':G..\:;;: AS see :;,= ION " V5. . JOS!?!1 JEFI:::....SOl'l anc ROS:! JE!F::'''lSON, hilt \..:~fe .. ..- I. ........ 1 ~:,\ ..2J ' r.CU~':" O!7 C::H.~MOI-f P!.I~;\S I'H::'~.:ll;:"l'lI:iI CO,l::/'~'t C:V:~.rRlA~ O:V:S!ON " . 1",^':I -:::R:1.' L982: I:,. " ",;, NO, ::359 O?,::::::t ~C OP!:HOt~ HRz.rE, J. ,;... r~;;; Iqllti, ANC NON, t.~ is '. 7' day o! upcn ccns!de:ation o~ ~l~!n~if~, Fedc:al Na:ion~l Mc=~;aqa . ..... . Associa:ion's pet.ition for Reeons1dera:ion ~une 1'::0 T~ne cf t.his Cou::-t's Order o~ ~overn~er 7. L911S and ..he Ans'...er ::h"r~':o of O~!cncant~~ Jesc?h ~e==e=scn and Rcsie ~e=:e:sor., i~ is h ~ 'ORD~~~C d O-~~--o 'F'l ' ere_y .,..:uo.:.n :._...:.:..:.s _ o. Oh'S; I 1) Said ?~~~~on 1s GR~~T!D: 0'.... I -;:;\: ::;:! 2) .;.:~~i ('~... _=t: 's 0 :de= of r:ovcr..be r i I 19 as!.:; .,......,. r.,..' .-'..., ~...,... c,'," . ,,".\\ RZV~:tSE:!) aild _ lai:\':.ifft' k MC':..!.o~..:o= ReaS"sess~Qnt.'o~ Da:nac;o5 ).$ ,,(",'" ,.~.~oJ "\ -... . 4 \:,;,." ~ .." . ~'\,\',). 'Y(,~ 3) Ju~~;t: is h~rcrj; lnc:ca:llid :'0 SG,141..7t. .' '. GiU..'lTEO : aec~u~s(: Pl~!.n~i=: was rCG,,;irec. ~o ac~~~pt cur:c.:nt mort;:!agc payments upon the f.iling of .Oe~t!:lcan..s I b.:.n!;ru?l:/:Y . . , pet1~lob and in fact did so, it is necossa=y :0 rQnss(!s~ 'C.he i!.r:ount 0: dal'llar;a,S tha.~ initially we:e ~ssess~d ~:~Q= jucq:nClot by dCl:au1t was' cntc:'oc i:'l ::01s 2oc::.10n. . llccaUSA Dc:cncan~s have no~ ~c=ut~d the spcci:ic ~~cunts clcimcc - 1 - '. Ii " .~ FEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. CUMBBRLAND COUNTY COURT OF COMMON PLEAS vs. STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER CIVIL DIVISION NO. 98-672 CIVIL AFFIDAVIT OF SERVICE Lisa D. Blankenburg, Esquire, hereby certifies that a copy of Plaintiff's Petition for Reassessment of Damages have been sent to the individuals indicated below on Februarv 2, 2000. STANLEY M. DEIMLER. JR. 25 SOUTH 32ND STREET CAMP HILL, PA 17011 AND LAUREN J. DE IMLER 118 BEARD ROAD ENOLA, PA 17025 ~- DATE: February 2, 2000 Lisa D. Blankenburg, Es Attorney for Plaintiff I ,~ ,"' FEB 1 02000(1!7 FEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDB HoME LOANS, INC. ctlMIlBRLAND COUNTY COURT OP COMMON PLBAS vs, STANLBY M, DBIMLBR, JR, LAURIlN J. DBIMLBR CIVIL DIVISION No. 98-672 CIVIL ORDBR AND NOW, this day of , the Prothonotary is ORDERED to reassess the damages in this case as follows: Principal Balance Interest Amount 7/1/97 through 3/1/00 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Inspections/Other Appraisal Fees Escrow Credit Deficit 84,794,38 18,659.12 1,053.78 4,239.00 1,946.50 1,900.13 332.50 0.00 0.00 5,395.77 TOTAL $118,321.18 Plus interest per diem from 3/1/00 through Date of Sale at six (6%) percent. NOTE: THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS AND COMMISSION ARE NOT INCLUDED IN THE ABOVE FIGURES. BY THE COURT: J. FEB 1 0 2000 #'7 FEDERMAN AND PHELAN by, Lisa D. Blankenburg. Esquire Atty. I,D. No, 78020 Two Penn Center Plaza. Suite 900 Philadelphia. PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS. INC. CUMBERLAND COUNTY vs. STANLEY M. DEIMLER. JR. LAUREN J. DEIMLER .....,' L,.. COURT, OF, COMMON PLEAS . ,'- ;.}...- 1, :, '.i ,j .' '.' ;. .' , . . AJ','ijPIVIL D;tVIS.ION , I-'L~oj)t~~~i~HJ ici~IL PLAINTIFF'S PETITION FOR REASSESSMENT OF DAMAGES Plaintiff, by its Attorney, Lisa D. Blankenburg, EsqUire, moves the Court to direct the Prothonotary to reassess the damages in this matter, and in support thereof avers the following: 0 pL\~LAN Nf\.N '-, 1. This is an acti'fIEOGf\~E.r'I"\tt.F\)~'{osure . ATiQR l'r~UqN entcced MAY S. 1998 1n th,,"; amcfilhptf.l\ro.lI99.S.. 2. A Sheri~\:'(~~~\le of the "mortgaged premises was J~hp6ri';d:'or,~'ti1yed \'i) \ ,-\",. for the fol ~!'l1h\~9\ ,!~a:sbns: <:;,t,\>. ",\ ,\", , petit~''''''';L\'l,itlge the entry of jUdgment in this action. The latest bankruptcy .... :<,;1' .n",' _" '\' -<\\J '.' ,#99-03~4iRJW was filed on AUGUST 31. 1999. y automatic stay by Order of Court dated DECEMBER 8, 1999, fiJ-::~hich . Judgment. was \!, ',' ' ,1' '", The Defendant (s) have filed three (3) bankruptcy Plaintiff obtained relief from the 2000. 3. The mortgaged premises are listed for Sheriff's Sale on MARCH 1, 4. Additional sums have been incurred or expended on Defendant (s) , behalf during the time the sale was postponed or FED 1 0 2000W FEDERMAN AND PHELAN by, Lisa D. Blankenburg. Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 InS) 563-7000 ATTORNEY FOR PLAINTIFF . COUNTRYWIDE HOME.;tici~s, INC. .-) ":JY ,.\ 1'~~.\0'~ .\;.';.\ ,,~;?~d \' '\'0' 0" ~'\~~-18~:' ST~~~~.(..~BI'MLER, JR. LAUREN'u~\DEIMLER CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIT'IDliV'JiSI~N~ _ r-, rq.;'. {\ !\,' ,\i'.l) 1 . .-..... .. r:l:.DL~l'l','\I.\~. ~ I'll ,- :'ljPV ;'('; \ !:Np'..\r98~67.~~fIVIL I~- ',,_ - c'r' (i1"":ll\,";\' I ,I ;. ~ \ _ . - II I .... I \ . \' Lt....... ~; ~ ... i.'tfr~ AFF~?~c..~ OF SERVICE ~\\) CJ(S ~:~ ~ ~\\-Y.. 'V>~~ Lisa D, BlankenbU~~~~Y..~erebY certifies that a copy of Plaintiff's pet~~~~~=assessment of Damages have been sent to the individuals indicated below on Februarv 2. 2000. STANLEY M. DEIMLER. JR. 25 SOUTH 32ND STREET CAMP HILL, PA 17011 AND LAUREN J. DEIMLER U8 BEARD ROAD ENOLA, PA 17025 DATE: February 2, .......<~("~~_: 2000\";;'" "H ' , " .;' l, , . "'."' , ~ '.., ,......' \ ~ Lisa D. Blankenburg, Es Attorney for Plaintiff " g. ~ ." ,~ . . \ _ . _ _-::::""11-. _ -- - -- " l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COUNTRYWODE HOME LOANS, INC. (F/KJA COUNTRYWIDE FUNDING CORP.) Plaintiff CIVIL DIVISION No. 98-672 CIVIL vs. STANLEY M. DEIMLER, JR. LAUREN J. DE IMLER Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for COUNTRYWIDE HOME LOANS. INC. (F/KJA COUNTRYWIDE FUNDING CORP.), hereby verify that on DECEMBER 13. 1999 and JANUARY 31. 2000, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded Iienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on DECEMBER 13, 1999 and JANUARY 21. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. ') I , I I i r ) ( j ~ \~ ( ! ~'1~71~_ /FRANKIFEDERMAN, ESQUIRE , Attorney for Plaintiff 'I I, 'I' '.\ 1/ ,'I ,i Date: Februarv 28. 2000 i,. , -I , " i"~ . " i "~ '"' ", ...- ! , . I I I I J! , ,.1 ,. .. I: '. , ....:' '. '--~".'.1 , ' , U ... I ',..,-'-:.."./,..';/.;1'. ,.J". .h:..:..:~:.' , I~ I .,. '," '. ". / -j', ' ,;") ,'. 'f':..! /' :." "" : ",1 ~~-'~;;~~ ~ :~! j~,.;,'" \ -. ":::~" ........ ';" ",:-" .~ -. ":..:-.':....-" '- ~ ..~.....i'.; ""j'l / - ...{r "'. ....... 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Belt 278 RICHLAND, PA 17087 PS Form 3817. Mar. 1989 J U,S, POSTAL SERV'CE CERTIFICATE OF MAILING MAY DE USED FOR DOMEsnc AND INTERNATIONAL MAIL, ODES NOT PROVIDE FOR INSURANCE-POSTMASTER ,,- 1 ,\ I II ,. " " Received From: . I I f "" ,I' ~-i . --j~' J:\~% ':~ ~F.nF.RMAN ANn PHFTAN TWO PENN CENTER PLAZA. SUITE 900 PlIILAIlELPIlIA. PA 191BZ One plecl 01 ordinary mall addreued 10: ;11',.:': iI' :,,~ ,;:) ~~~:'~~.>';\,; :. 'j;;,"-:-:i". ,:.".::(,.1. '\ 'l.: ;"..c.\ . :f~. ;~,~ ~) ..', 7' \ I' ,jJi'".!.:;.;../ . J CLTPPER MAGAZINE. TNC. 1650 MANHEIM PIKE LAlICJ.STCR. FA 17601 PS Fo.m 3817. Mar, 1989 ~ ~ I' I'" ~ ), :1 ~ i 'f \1 \ 'I SENDER: . Check boA 01 "Ohl il you r~ire Re.'ricled Oelivety. . Print your name ard add,.,n on lhe nwetM oIlhis form 10 ttull wo can relurn this cord "".u . Attach IhIa lorm to lhelront of the IT\IIllp<<e, or on the back II &PaCe does nol peflTlll. . Thlt Return Receipt WlII shoW 10 whom the ~icJe Will delivered and lhe dale dellwntd. 3. rtle ressed 10: I also wish to receive the lellowing ,",vices (for on extra fe [i( Restricted Delivery Consult postmaster for fee. 4a. Article Number l P 974 231 626, 4b. Sarvic. Typo I.AUll"",,:...t.., DUMl.Foll ' ' '113~Rn ROAD F.::OLI/l'A 170~5 " )( CERTIFIED 0':' 7. Date of Deliver. _ lit; tJ1J 8. Addressee's Address Domestic Return Receipt . r 1 J t: ,~; ::tJ' .Jl nJ .Jl ..., m nJ :r l'- IT' c.. ,'--"- , , 1 ~ lI[tlJlHj .lr(~t'PI ':plv'~r } 'A'.I POSTMARK OR DAlE ..I """'r(''''I'',lr,, T"I'f:-"f,;"'c,Il',r.l I'" l~.' ,'''' ';. A',I.: HI , SENT TO ., , ;',C'i' US Postal Service Receipt for Certified Mail PS FORM 3800 .- - .__'._'H___ - - U1 nJ .Jl "" m nJ RETumj RECEIPT 'iER'/ICE } ,...)..,r"'''E POSTMARK OR DATE ~(..!r;"'='FO CEll'/EIl'( ([RT'N:orrc ,PET'JIl..,fiEt:E',PT SENT TO: fOr"'I.:>r;SUli(.lt!C'fts N I I, ... ... ~t YI NOT FORtNT!RtlAnONAL 1,4",1. ~I. ~ :r l'- IT' c.. '\ '. . . . ., .'') '~dt;.... 3 p.~. ;:i':~: ..... OJ.'. 1::)1,1 '::., :1' d, PS FORM ~800 US Postal Service Receipt for Certified Mail c::J "" IT' "" m nJ RETUR" } RECEIPT SERVICE :><)<';',lm POSTMARK OR DATE QE'nPIC'roc[u...tn" r.rllTI"EOFEC-fl[TljllllIlECE'pr :" SENT TO: T:;I.1.\. ,,-;~rAGE AI.e ~EE':' ,. u " ~ VI Nor FOR INTElltU,nONAL "'Atl ~r. _ ~I :.)',::'\.::.':::: i'.. :~:.~~ lo,j':L, ...1'. :r l'- IT' .\ ~ w~ ';.t' j:' . ':~'_' :', ..~ l";~'.-_\J .' -:,1 c.. PS FORM 3800 US Postal Service Receipt for Certified Mail :'~:: C;':E~[ P. U'~." ':;~: e ~ ~ !l! z ... ~ .. 0 ... I:i a: ... " CJ Iji . 'I it ~ Ii It :! ; 1 ~ - , f ( > , . ~ < ~ . , , , :: u. c. C ~ ii: u. c c. C ... I:i " u. '" ~ >= V' U. ~ ~ a: ~ g li: :! ,I. (') <::> !::: !J ~ <::> -..,- :1: ~H' ::.. 'TI _ :xl ::0 ' ;fp~'" ;.q :Si , f~2:~' , - !C"; ~ 0. ;$8 i~~ is? ,v. ~ 6" .. en ~ - -.; j FEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 COUNTRYWIDB HOMB LOANS, INC, ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLBAS VB. STANLBY M. DEIMLBR, JR, LAURBN J. DB IMLER CIVIL DIVISION NO, 98-672 CIVIL AND NOW, this lsfl ORDER Vl1.u '-~ , '2...000, upon consideration of day of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED that the Rule entered upon Defendant (s) shall be and is hereby made absolute and Plaintiff's petition is GRANTED and it is further ORDERED that the prothonotary reassess the damages in this case as follows, Principal Balance Interest Amount 6/1/97 through 3/1/00 Late Charges Legal fees Cost of Suit and Title Sheriff's Sale Costs Inspections/Other Appraisal Fees Escrow Credit Deficit 84,794.38 18,659.12 1,053.78 4,239.00 1,946.50 1,900.13 332,50 0.00 0.00 5,395.77 TOTAL $118,321.18 Plus interest per diem from 3/1/00 through Date of Sale at six (6%) percent. NOTE, THE ABOVE FIGURE IS NOT A PAY OFF - SHERIFF'S SALE COSTS AND COMMISSION ARE NOT INCLUDEO IN THE ABOVE FIGURES. ~~;l;t:, .. " ':;:,. if: h.'; ,'.~\ ", I ~ " ,~ ~ -:. , '. . (f!J;-- , . .., . ': EXHIBIT A , FEDERMAN AND PHELAN byr Lisa D. Blankenburg, Esquire Atty. I.D. No. 78020 Two Penn Center Plaza, Suite 900 Philadelphia, PA 191~2-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. STANLEY M. DEIMLER, JR, LAUREN J. DE IMLER CIVIL DIVISION NO. 98-672 CIVIL CERTIFICATION OF SERVICE I, Lisa D. Blankenburg, Esquire, hereby certify that a copy of the Rule Returnable Date of March 6. 2000 and a copy of Plaintiff's Petition for it Reassessment of Damages have been sent to the individuals indicated below on Februarv 16, 2000. STANLEY M. DEIMLER, JR. LAUREN J. DUMLER 433 POPLAR CHtIRCH ROAD CAMP HILL, PA 17011 ~ VJ t ) \ , I Lisa D. Blankenburg, Esquire Attorney for Plaintiff Date: February 16, 2000 { , r, I' I /,,{ :<4' ':.,' ( , ..,.: ,-.' VERIFICATION Lisa D, Blankenburg, Esquire, hereby states that she is the attorney for Plaintiff in this action, that she is authorized to take this affidavit, and that the statements made in the foregoing Motion to Make Rule Absolute are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S, 54904 relating to unsworn falsification to authorities. DATE: March 7, 2000 ~ 0- uJJ Lisa D, Blankenburg, Esquire Attorney for Plaintiff \ , I ! ~ ~',- ,. ;;, r . ~: .') !I PEDERMAN AND PHELAN bYI Lisa D. Blankenburg, Esquire Atty. I.D, No. 78020 Two Penn Center Plaza, suite 900 philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC, CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. STANLEY M. DEIMLER, JR, LAUREN J, DE IMLER CIVIL DIVISION NO, 98-672 CIVIL CERTIFICATION OF SERVICE !, Lisa D. Blankenburg, Esquire, hereby certify that a copy of the Motion to Make Rule Absolute has been sent to the individuals indicated below on March 7, 2000. STANLEY M. DEIMLER, JR. LAUREN J. DUMLER 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 ~ rJ idJ~ Lisa D. Blankenburg, Esquire Attorney for Plaintiff Date: March 7, 2000 ".,." , , PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 COUNTRYWIDE HOKE LOANS. INC. IN THE COURT OF COKHON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA , : , ! vs. NO. ..9.8~.6l J.. .CJ.YJ..j.. . .. .... TERM, 19..... STAHLEY M. DEIMLER, JR. LAUREN J. DEIMLER PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) To the Director of the Office of: Issue writ of Execution in the above matter: bount Due $.96,Q~~63....... Interest from 4/29/98 TO SALE $............... @ $15.79 PER DIEM (+ costs) ..JwJj.~ Attorney for Plaintiff(s) Note: Please attach description of property. , r " :~I , , " ( ~ . . . Q Q Q . . . Ill! ..: ~ . . lIo 0": :I: .~ .,. .,. .,. H 0 . CO ... ... ... ~~ ~ .~ foo~ . rz. .. .. .. roll> Clrol . lIo e e e ..:!..:l UIll . ~ Ili>< rolCl rE< .. II II CO Il<CO .:z; foo E< foo ~~ rolO .H . ..:l J'. Ul tJ lIoU '..:l ~ Orol '111 0 III . U .. fooO . III >< . , ~ra. . 0 lIoE< rIl Illl ~rol . ra. 0:1: ~ ., . cl . . C!J \...O~ E<O ~~tl 1lllCl; a:u i OC!J c:,;~ 'iJ cl ra.foo OQ III ~O U~ ~J rolO .foo 11I:Il . E< rol..:! lol l'l H~ , 'lCl; I . =a: ii U ~ E<rol rol III ~ :I::Il ~cl 111 .. . U Q Ill! . . . ..:l 0 ~ 0 ~ . :z: :z: ra. D 0.0 0 c.: '-" 'r' ;::"' '-- -,' l)r~: ~2 :1~ :!J 1J.1L; .Ilj=""_ ':.i /- ~..' -.-,P1 :;-~C" en ~:'JI=' :.- (fJ._ : I":'; .!.. ..< ~~. ..-ie} r:::~,:, -0 '-:'~: :;~ ~~~~ -'- '~)(.} 1:--;>> ;..,~ ITl ::4 ~ N ~ eJl -< ,;:4 .....~ DESCRlP1'ION ALL THAT CERTAIN piece or parcel of land, siruace in the Borough of Wormleysburg, County of Cumberland. and Slale of Pennsylvania, bounded and described as follows. to wit: BEGINNING at a point on the North side of Poplar Church Road. which point is 10caled South 53 degrees 30 minutes East along the Norch side of Poplar Church Road, a distance of three hundred thirty (330) feet from the intersection of the extension of lhe North side of Poplar Church Road with the extension of lhe West side of Hillside Drive as they appear on lhe Plan of LOIS of Section "B" of Riverview; THENCE along the North side of Poplar Church Road, South 53 degrees 30 minules East, a distance of eighlY (80) feet to a point: THENCE through lhe center of Lot No, 2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred forty-two and eight one- hundredths (142.08) feet 10 a point on the dividing line between LOIS Nos. 2 and 17 on said Plan; THENCE along lhe line dividing Loes Nos. 2 and 3 from Lot No. 17 on said Plan, North 53 degrees 30 minUles East, a distance of eighty (80) feel to a point. THENCE through lot No.3 on said Plan. South 36 degrees 30 minutes East, a distance of one hundred forty-two and eight one- hundredths (142.08) feet to a point on lhe North side of Poplar Church Road. the place of BEGINNING, BEING the Eastern thirty-five (35) feet of loe No, 2 and lhe Western forty-five (45) feet of LOl No. 3 on lhe Plan of LOIS of Section "B". Riverview, which Plan is recorded in lhe Cumberland County Recorder's Office in Plan Book 10. Page 21. HA VING THEREON ERECTED a brick and frame dwelling house numbered 433 Poplar Church Road. Camp Hill, Pennsylvania. ~AX PARCEL NUMBER: 47-19-1590-008 . \ T~TLE TO SAID PREMISES IS VESTED IN Stanley M. Deirn1er, Jr. and Lauren J Deim1er his ::~:dbi2~Ie4e/d94from Ddannd a12J/'16B/19ais,. Executrix of the Last Will and Testament of Joan 'Gail Korc~ recor e 4 In Deed Book 116 Page 303. r p~~ FV ~ .,0,J) \ -SL 'u., _I'-... ....... I.N (,..\., 2;--0- . ~ .- \ ... ~~ C> I:'; .\~ \'..I ~ ~ ?3\~ ~ , . ~ ..... . 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Name and address of the last recorded holder of every mortgage of record: l:!Al:rn LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COMMERCE BANK/ HARRISBURG N.A. 100 SENATE AVENUE CAMP HILL, PA 17011 5. Name and address of every other person who has any record lien on the property: ~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so 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 so indicate) CUMBERLAND COUNTY DOMESTIC RELATIONS DEPARTMENT CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SOUARE CARLILSE, PA 17013 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: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 433 POPLAR CHURCH ROAD CAMP HILL, PA 17011 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. l (\ June 15. 1999 q)'M,^/,^ffi ~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ (') '0 0 c: u::> -- ~f1 wnfu ,- ~IJ <= C!; rr I ::::: '1;1~'] ~ "'! Z~. . ~'ii1 ~.> 0-. u!? c;: tJ ' , :::? :;~IC' p : 1: :f~ ~-.. (") .~;~ ";:('; Sj;Cl ~ Cirn L: ';'- ;-l II :3 I'" 51 -. (11 -~ D 1.0 0 c: l.D "T' ~ '- "-I 'TJ CO :: ~- :..- RrJ mc;:' , lip.. Z_:J ....,n1 .".C' :!.J'y en :. 0'> ~% =:1 CJ r:' C') -0 'C-r. ~ ::::: b~ zQ ..,~ ~ 0<"_4 .:::::0 Q ;J>c: ,~ Z ,"", ~ ~ (}1 . 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 HAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. " 1. be sold calling 2. sale if of your If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stopped, your property will You may find out the price bid by You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (215) 563-7000. 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 Sheriff on This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (~easons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after 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 COURT ADMINISTRATOR 4th floor Cumberland county Courthouse (717) 240-6200 DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the Borough of Wormley~burg, County of Cumberland, and Slale of Pennsvlvania, bounded and described as follows, 10 wit: , . BEGINNI>lG at a paine on the North side of Poplar Church Road, which poine is localed South 53 degrees 30 minutes East along lhe North side of Poplar Church Road, a dis[ance of three hundred thirty (330) feet from the intersection of lhe extension of lhe North side of Poplar Church Road with the extension of lhe West side of Hillside Drive as they appear on [he Plan of lots of Se~tion "B" of Riverview; THENCE along the Nolth side of Poplar Church Road, South 53 degrees 30 minutes East, a distance of eighlY (80) feet to a point: THENCE lhrough the center of Lot No, 2 on said Plan, North 36 degrees 30 minutes West, a distance of one hundred forty-twO and eight one- hundredlhs (1~2.08) feel to a poine on the dividing line between lots Nos. 2 and 17 on said Plan: THENCE along lhe line dividing lOIS Nos, 2 and 3 from LOl No, 17 on said Plan, Norch 53 degrees 30 minules East, a distance of eighty (SO) feel to a point, THENCE lhrough lot No.3 on said Plan, South 36 degrees 30 minutes East, a distance of one hundred folty-twO and eighl one- hundredlhs (142.08) feet to a paine on the Nolth side of Poplar Church Road, lhe place of BEGINNING, BEING the Eastern [hilty-five (35) feet of Lot No, 2 and the Western farcy-five (~5) feet of LOl No. 3 on [he Plan of LOIS of Section "B". Riverview, which Plan is re~orded in lhe Cumberland County Recorder's Office in Plan Book 10, Page 21. HA VING THEREON ERECTED a brick and frame dwellin2 house numbered 433 Poplar Church Road, C:lmp Hill. Pennsylvania. - ~AX PARCEL NUMBER: 47-19-1590-008 ~~TlE TO SAID PREMISES IS .VESTED IN Slanley M. Deimler, Jr. and Lauren 1. Deim1er, his \ d tfedbY Deed from Danna J. BlaiS, Executrix of the Last Will and Testament of ;oan Gail Korte ale 12/14/94 recorded 12/16/94 in Deed Book 116 Page 303, . r