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HomeMy WebLinkAbout98-00782 ~ ~ ~ It' ~ . ~ (S 4) "'- II { ~ J ~ .{ ,? .3 ~ , } ~ ~ :J o 'CJ ',.if ) " \ , ( : ~ I {~I ( 'j , - ~ : ~ I '-.J - ~ <.l ~ ;1 /' I I " ~l ~I . i ~i ~. . ~I I . . ~ :,- - .:.=:=-""'" - - ..... FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORPORATION) 6400 LEGACY DRIVE PLANO, TX 75024 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff NO. 90'- 7tL (I, ~~~ v. CUMBERLAND COUNTY WILLIAM H. WALKER 339 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249 3166 l'.L I J G6fU-U.c.uu ';'~ '.... 1. Plaintiff is COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORPORATION) 6400 LEGACY DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are WILLIAM H. WALKER 339 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 7/29/92 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1080, Page 182. By Assignment of Mortgage dated 8/19/92 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 431, Page 1020. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 9/1/97 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. i , , I" (t \ ii" 1 : I. . I' I '> /' J I ti I ". 6. The following amounts are due on the mortgage: Principal Balance Interest 8/1/97 through 2/1/98 (Per Diem $13.59) Attorney's Fees Cumulative Late Charges 7/29/92 to 2/1/98 Cost of suit and Title Search $66,122.16 2,465.37 3,306.00 119.40 550.00 Subtotal 72,562.93 Escrow Credit Deficit TOTAL 99.60 Q.,J!Q (99.601 $72,463.33 Subtotal 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 corne 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 $72,463.33, together with interest from 2/1/98 at the rate of $13.59 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. 1- :-:;-r-A.~'7 ~\...v~'- /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DESCRIPTION ALL THAT CERTAIN tract of land situate in the Township of Hopewell, County of Cumberland. and Commonwealth of Pennsylvania, more fully bounded and described as follows, to wit: BEGINNING at a point on the Western right-of-way line of Township Route 696, at corner of lands now or formerly of Ernest E. Maley; thence by said right-of-way. on a curve to the left having a radius of 400 feet an arc distance of 68.11 feet to a point; thence continuing by same South 15 degrees 34 minutes 20 seconds East. a distance of 96.34 feet to a point: thence by same on a curve to the right having a radius of 1570 feet. an arc distance of 62.26 feet to a point at the Northwest corner of the intersection of Township Route 696 and Township Route 315: thence by Township Route 315. on a curve to the left having a radius of 325 feet and a distance of 94.84 feet to a point: thence by the Northern right-of-way line of Township Route 315. South 85 degrees 28 minutes 00 seconds West. 68.28 feet to a point. a corner common to Lots Nos. I and 2 on Subdivision Plan of Gary D. Reihart. Trustee. dated August 3. 1973. and recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 24. Page 117; thence by Lot No.2. 1':orth 04 degrees 32 minutes 00 seconds West 187.25 feet to a point. on line of lands now or formerly of Ernest E. Maley; thence by said lands now or formerly of Maley. North 75 degrees 17 minutes 51 seconJs East 147.57 feet to a point. on the Western right-of-way line of Township Route 696. the place of BEGINNING. , HA VING thereon erected a single-family dwelling house known and numbered as One Dead End Lane. Shippensburg, Pennsylvania. 17257. J BEING all of Lot No. I as shown on the preliminary Subdivision Plan for Gary D. Reihart. Trustee. recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle. Pennsylvania. in Plan Book 24, Page 117. CONTAINING 28,444 square feet. more or less. l. \ , I j , TAX PARCEL NUMBER: 11-10-0610-098 PREMISES: 1 DEADEN>> LANE, SHIPPENSBURG, PA 17257 .JUN-11-97 09 :4!5 AM FEDERMAt-lli.F>HELHtl ~1~!563='!" P.02 VJ:llxnCA'1'XON E:l1zabeth Blue 1111'11)1 .t&t.. tllat Il.e/Ilhe 1Q AIIG!st4nt Vice-President of CountrywidA HomQ Loa~8, Inc. mortqaie Sft1'Vicinq aqent tor Plai~tit~ in t1l111 &att.r, tbat she is authorizld to take this V.ritication, and tbat the stat.mlnts made in tile toragoinq Ci?il Action in Hortqaq. ror.clo.~. ar. true Ind Correct to thl I)lst ot h.r knOWlldge, intormatioD Ind ~eli.:. Tile ~Dd.rsignld UDder.tand. that thl. .tatameDt is .ade Subject to the penalti.1I ot 18 Pa. C.S. .ee. "'04 Z'e1at:in'i to ~lI"'orn rll:s1ricllt:l.on to ~ autl1oriti... lie t:. : 2.?.-qi 9 C:. {} Lwr.l-, A ~". ) ~ ~ ~ ~ ~ \ ~' ~ ~ ~ ~ ~. ~~ 'i~ I\:' \:" ~ J..J 9-J ~ tS" ~ ~ ~ , "1. .. - (") _0 0 c:: ~d :,."- un -C; t :r: ;;J C!.J ~^,~' :c]t ...-.,/ -.: ';'i;:g ~:.;; : TlfTl '''' :"J 'J -, . '\ I t;:; r~.; -(1 _',0 ,: :,-;, 1'._("-: -.... j-;:D '."C' .~,' C) ~~~" r:? (5111 ..": :n ;S --J --.. -.: , ,"" ~ FEDERMAN AND PHELAN FRANK FEDERMAN, ESQUIRE Identification No. 12248 ATTORNEY FOR PLAINTIFF Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (2151 563-7000 COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORPORATION) Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. WILLIAM H. WALKER CUMBERLAND COUNTY No. 98-782-CIVIL Defendant(s) TO: WILLIAM H. WALKER 339 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 DATE OF NOTICE: MAY 1. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARL mE , '^ "'0 j \ I>- n (717) 249-3166 ~ ~ Q~ Fra k Federman, Esquire Attorney for Plaintiff 0 <!:l 0 G :;u .\1 -n;:-;~ :~~ :::J nll';~ ;.... ,_I.." -, In.=:;: :'::~/I , "fTi ;::-..C V!'_'.~ (:l) ':)0 ---- '~llS r.:;,-":' ~ .;.1.~ 1 ;:-;F.:~ ::;: is;!:] . --c") .,J"~ ~~~ ~j (Srn --I :':) ,:.n ~,. :.0 --. -< r \' ,. .. .~ '. " n ,.., n ':" ~o.J ~~ I \': .t. ~J { ~ ~ \ :~ "I ::1 -< '0. r- '. , .:'n ~: -: (:.::.> ,9 f:':( :-~{:J -, , , I ." ''" ,"j:O , :( j .,.(") .~ S,.: '*::' ljf n " - . :.rl :;5 ::! -< -.....,_...-,,; ~ > ....., ~ % ~ ~ ~ ~ ~ lI' ....... l' " & :-J t'\ ~ 'l-i' ~ ~ f" c ~ (J ...0 !J F; ;:OJ 0 '" r f -niJ- -,. :'\ - . -.':J D:I;, :;':"1- ..-:.-lJ -: . 'ii:fJ ~ >:.t ~~,' : ....n , GO .jC) :. ~ ~::\ . h}llJ ; . , :.."\~ .r~:"l ( ~_I..l -' ,..0 ~. .. ~, l~5rn ~71 :'...1 :.n :Ii ...: ,~ ~~ ~~ FEDERMAN and PHELAN Dy: FRANK FEDERMAN Identification No. 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. IF/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION VS. WILLIAM H. WALKER NO. 98-782 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK PEDEHMAN. ESQUIRE. hereby veri f ies 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 WILLIAM H. WALKER is over 18 years of age and resides at 339 FARMINGTON DRIVE, SHIPPENSBURG, PA 17257. This statement is made SUbject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ )~ I~r'~~ PI NK P'EDEH AN, ESQUIRE Attorney for Plaintiff ....'......,... -,' ...... ." 0 ,,j (") ~:~ ::'::..1 " , ..,-, i".e' '. -, ;~ :-. ~. ~I' -< ,-j p , ,." ,.. r-n ; " V - !J? ;. , '-.. \...1 '~J C) .~ -'j (-'.' .-~: ." -, ; . ~-,~J <., (; .' ~-~ .:-? ci m -,1 =< :n ~ 10 I! I; [' '" " I" I 'I.... , I COUNTRYWIDE HOME LOANS, INC. IF/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION VB. WILLIAM H. WALKER NO. 98-782 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. It COUNTRYWIDE HOME LOANS. INC. (F/K/A COUNTRYWIDE FUNDING CORP.I, 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 1 DEADEND LANE. SHIPPENSBURG. PA 17257. 1. Name and address of owner(s) or reputed owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) WILLIAM H. WALKER 339 FARMINGTON DRIVE SHIPPENSBURG. PA 17257 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 ADOVE J. 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) NONE 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) PNC BANK. N.A. WESTERN LOAN CENTER. 2730 LIBERTY AVENUE PITTSBURGtl, PA 17222 I, , , r. . .. ~ ' ,'\' \ " ,J. N~me ond ~ddreaa of every other person who has any record lien on the property: \ '~ ' t:!AM~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) ( , ''''J , ~9~.E Ii (it N~me ~nd address of every other person who has any record interest in the property and whose interest may be affected by the sale: t:!AM.E LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) .- CUMDERLAND COUNTY DOMESTIC ~ELnTIONS DEPARTMENT CUMBERLnND COUNTY COURTHOUSE SOUTH HANOVER STREET CARLISLE. 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: J NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) ') I , I TENANT/OCCUPANT 1 DEAD END LANE SHIPPENSDURG. PA 17257 j , !'I_iU'_15,-1.998 DA1'E I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~~~-- FRAN FEDERMAN, ESQUIRE Attorney for Plaintiff ~ .. ...... (') "~';) ,,-J c;; c., -I' "'.'r'": -.". ::rJ ::..... rji,. : ._~ .Il:',] ;~: .-t,' , -.: ~ f.' >,11'1 (: !' ,~ '_J~ ') r7'.; ,~<.. or) .,.....-) ."~ "j:?:i , " :'...C) ~:~ I~~~' ~'? (511'Z ,,~, - :n 5;; :'1 ~, I" -~ '... You may need an atto~ney to asse~t your rights. The sooner you contact one, the mo~e chance you will have of stopping the Bille. (See notice on pilge two on how to obtain an attorney.) YOU MAY STILL DE ADLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the She~iff's Sale to the highest bidder. (2151 563-7000. You may be able to petition the Court to set aside the the bid p~ice was g~ossly inadequate compared to the value prope~ty. is not stopped, your property will You may find out the price bid by 2. sale if of your 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 oWne~ 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 She~iff and the Sheriff gives a deed to the buyer. At that time, the buye~ may b~ing 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 dist~ibution of the money bid for your house will be filed by the Sheriff on This schedule will state who will be ~eceiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the p~oposed distribution is wrong) are filed with the Sheriff within ten (lO) days afte~ 7. You may also have othe~ ~ights 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 ". ... ALL THAT CERTAIN tract of land situate in the Township of Hopewell, County of Cumberland, and Commonwealth of Pennsylvania, more fully bounded and described as follows. to wit: BEGINNING at a point on the Western right-of-way line of Township Route 696. at corner of lands now or fonnerly of Ernest E. Maley; thence by said right-of-way, on a curve to the left having a radius of 400 feet an arc distance of 68.11 feet to a point; thence continuing by same South 15 degrees 34 minutes 20 seconds East, a distance of 96.34 feet to a point; thence by same on a curve to the right having a radius of 1570 feet, an arc distance of 62.26 feet [Q a point at the Northwest corner of the intersection of Township Route 696 and Township Route 315; thence by Township Route 315, on a curve to the left having a radius of 325 feet and a distance of 94.84 feet to a point; thence by the Northern right-of-way line of Township Route 315, South 85 degrees 28 minutes 00 seconds West, 68.28 feet to a point, a corner common to Lots Nos. 1 and 2 on Subdivision Plan of Gary D. Reihart, Trustee, dated August 3, 1973, and recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 24, Page 117; thence by Lot No.2, North 04 degrees 32 minutes 00 seconds West 187.25 feet to a point, on line of lands now or formerly of Ernest E. Maley; thence by said lands now or fonnerly of Maley, North 75 degrees 17 minutes 51 seconds East 147.57 feet to a point, on the Western right-of-way line of Township Route 696, the place of BEGINNING. HA VING thereon erected a single-family dwelling house known and numbered as One Dead End Lane, Shippensburg, Pennsylvania. 17257. BEING all of lot No. 1 as shown on the preliminary Subdivision Plan for Gary D. Reihart, Trustee. recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle. Pennsylvania, in Plan Book 24, Page 117. CONTAINING 28,444 square feet, more or less. TAX PARCEL NUMBER: 11-10-0610-098 TITLE TO SAID PREMISES IS VESTED IN William H. Walker, married man by Deed from Dennis W. Barrick and Nancy J. Barrick, his wife dated 7/29/92 recorded 7/29/92 in Deed Book 35-U Page 578. .'~ ~. " ~: (J '''' c Co.., 0 "- 0" tJ f~,"; ::t: f),IITJ :::lot ;'~"1 E;~:',!.I -< ;','i:.D ,'- CD 'nl"Tl -' "1.10 r-::t.; :.JC:' "";:.\.'l :71 ' j-q ",~. ~. :~:{-? ...1.. _:)0 I)) "'orn ..,;. '.) :'1 :n ;,"f , r" :0 -.-.; ,"' , I:" I " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , " RE: COUNTRYWIDE HOME LOANS, INC. VB. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ,I ~ .~ , (, 1 WILLIAM H. WALKER NO. 98-782 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: ,. ) , I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME LOANS. INC. hereby verify that on AUGUST 28. 1998 true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to ') .1 , I the Defendant(s) on MAY 15. 1998 AND AUGUST 28. 1998 by first class mail and certified mail, return receipt requested, see Exhibit "B" j ( attached hereto. DEFENDANT(s)' certified mail was returned but not signed, see Exhibit "C" attached h"C~J ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DATE: December 7. 1998 ,~ ! " '"'- ~-- -- -.--.----- _. ---- ~ ---.- _.~.- --------_. ru Ll1 ..:J Ll1 C , 00 r- ..a IT' Q. R[TUn" m:CCIIlT ,SEt'VlCe . Nor,o. U...nollAl II . "'J'ITAllr. PDaIlf /Ill 0fI DATE , , ;.--;.;. -- '-"', ,.' nr'ilJ1lCnOC(uvrnl' ,:r"'III(Hrr 'J1r.Tllmll'r<f;r" TO'AI.t'Q'il"'.r...."dl'(['1 \,', I ;;~,.~S~. \-.p\ -\0' SENT TO: WIJ.UAII II, ~ 3JV FAXKl~roN uklVV. SlUPl'EliIIl8UllG. PA 1I:tS7 . . ",---,"", -'~::.r PS FORM 3800 US Postal Service Receipt for Certified Mail W1H)JoJJ2J h. ,. -_.-...-.~ .'. rrl l.I1 00 .JI r- -l.I1 .~ l.I1 .JI c- Q. RCTUmj RECEiPT SEIWiCE !QfAl ~CSTAGE M,O 'EE5 j 1 Ii I Not 'OR IPj~RN..~,ONAl ,"All ,G!J I'O!;IA(.E ~~f.~J~ f~~~f~~; M'OI ~~~,~~~~EC ':EI1TF ,EO "~E - ::1; ~1Jr.~1 ..€ C ED t / SENT TO: ''';:.L..I.:\:i !i.. ,;,",~,~:i~ j;.) ~'a..t:.a.;..:!G\:~':.; :,.....L...~ 3ilJ.:":'~~:':,=:8:.;a,-:, ~)A 17 ~57 PS FORM 3800 US Postal Service Receipt for Certified Mail C "15- 'lV4l.I<€'R c 12 ~ ~ ~, ~, ." ...' 0' .., ~& tiE 0:. w, l51. jjj~ w~ ~.. ..- ..;:: , " ; I (; ~ &:! :r :I ,. , 12 w 0. o .. . !i~ zw wo: ..0 0:1 "z 120: ~~ 0:0: W.. "'0 u... jjji3 w- uo: S!!! ..;:: ~ . I 1 , ., z ~ 0: o .. i!i I I I' '0 SENDER: . Chll<:II 00. nlI.jllII 'r"' '''''ll"m f1ltslllclfhl o.~IY . Punt yal' NIAll! MId .1lJdlU'" nn 100 '~'It 01 lhill lorm so !hlll ....., can 'flluln Itll' cmd 10"," . Alli"h thit 101m to the Ironl 011"-' fMlbttco. 01 on 1M hock II 3P.W:U Iloos 111)1 pall?lll . fhlt R"Iuln Rocool WIn snow 10 ....horn 1M '''11C1o \/rill 1....M!f1!'(1 antllM dIlllt delMlfltd I 0150 wish 10 rocclvo tho following sorvieos (for an oxtra fue o Restricted Dcllvory 3. ruclo Consult postmastor 'or 100. 4n. Articlo Number P 967 805 852 fOlI50d 10: WlU.lM Ii. JL\UlI::k JJ'I i"ILU1'ot.'t1l;/ v'<I'I" :JitU'k'I:...-;SIlUlU;. 1'0\ lh:jl 4b. Service Typo )( CERTIFIED . . 5, Received By: (Print Name) o <.:l Domestic Return Receipt SENDER: . Complete Ilems I andlor 2104' oddlhooal s.crvoCCS . Pnnt 'fOUr rlalM llnd address on tho IltIICfse 01 this term so thai We cnn return this o:.atd 10 you. . Attach thiS 101m 10 1M Iron! 01 thlt mailpece. Of on the back I(space does rot pmmll. . Tho Return RecUtpl mil shoW 10 whOm tho arldo was dehvcrod and lhe Wlo dolivefed 3. ArtiClo Addressed 10: I also wish 10 receIve the following services (for an exlra fee): 1. 0 Addressee's Address 2, 0 Restricted Delivery Consult postmaster for fee. 4a. Article Number fi1..~....:..'~~ 'j. I.\:~.~.r.; P 965 576 853 Jj:l ("'_o\:-~:'~~t','~'':''d 1')..' .'.~: 4b. Service Type )!~l~I(:.::,'j":..:...(,. ..#.\ ~;..;:- )( CERTIFIED 7.. Dale of Delivery 5, Received By: (Plinl Name) 8. Addressee's Address (ONLY il teques/ed 81ld fee paid,) .- PSFO Domestic Return Receipt CMS~WM.\~J<.. .,. ...." I, ~J, , (J , ,.0 t~ '. , C';J -, \ ..,; :-, --I r ;11 " , ~.J <TI ~ I .r;., <::.:> ". ;6 :9 'J ; . "- '.... '" :;:f; ,,- ,. .(') ':'i' :'.'rn . , ~"_l .:-1 > .." :.1 - . 1:J -, Countrywidc Home Loans, Inc. (F/K/A Countrywide Funding Corp,) -vs- William H. Walker In the Court 01' Co mill on Pleas of Cumberlund County. Pcnnsylvania No 98-782 Civil Terlll Steve M. Whistlcr, Dcputy Sheriff. who being duly sworn according to law, says on June 29, 1998 at 3:45 P.M. E.D.S.T., he postcd a copy of Real Estatc Writ Notice Poster and Dcscription on the propcrty of William H. Walker loeated at I Deadcnd Lane, Shippensburg, Cumbcrland County, Pennsylvania, according to law. Kcnncth E. Gossert, Dcputy Sheriff, who bcing duly sworn according to law, says on Junc 4, 1998 at 5:10 o'clock P.M. E. D. S. T., he served a true copy ofRcal Estate Writ Noticc and Description, in thc above entitled aetionupon thc within nalllcd dcfcndant to wit: William H. Walker, by handing to Tammy Walkcr, wife at 339 Farmington Drive, Shippcnsburg, Cumberland County, Pcnnsylvania, its contcnts and at the same time handing to her personally the said true and attested copics of the samc. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, says on July 6, 1998 at 7:20 o'clock P.M. E.D. S. T., hc served a true copy of Rcal Estate Poster in the abovc cntitled action upon the within namcd dcfcndant to wit: William H. Walkcr, by handing to Tammy Walker, wife at 339 Farmington Drive, Shippensburg, Cumbcrland County, Pcnnsylvania,. Its contcnts and at the same time handing to hcr pcrsonally the said true and attested copies of the same. R. Thomas, Kline, Sheriff, who being duly sworn according to law, says he served the within Real Estate Writ Notice Poster and Deseription in the following manner: The Sheriff mailed a notice of the pendency of the action by regular mail to the within named defendant to wit: William H. Walker at his last known address 339 Farmington Drive, Shippcnsburg, Pennsylvania. This letter was mailed under the date of July 7, 1998 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or out cry at Courthousc, Carli sIc, Cumbcrland County, Pennsylvania, on Dccembcr 9, 1998 at 10:00 o'clock A.M. E. S.T., and sold the same for thc sum of$ 911.76 to Attorney James Kayer for secretary of Housing and Urban Developmcnt of Washington D.C.. His/Hcr Successors and Assigns. It being thc highcst bid and best pricc rcccivcd for the samc Sccretary of Housing and Urban Developmcnt of Washington D.C. His/Her Successors and Assigns, Liberty Square Building, 105 S. 7th Street, Philadelphia, Pcnnsylvania, being the buycr in this Execution paid to R Thomas Klinc, Sheriff, the sum of$ 911.76, it being Sheriffs Costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowlcdging Dced Auctioneer Law Library 30.00 17.88 15.00 15.00 30.00 10.00 .50 ". ALL T.HAT CERTA[N tract of land situate in the Township of Hopewell. County of Cumberland. and Commonwealth of Pennsylvania. more fully bounlled anll describell as follows. to wit: BEG[NN[NG at a point on the Western right-of-way line of Township Route 696. at corner of lands now or formerly of Ernest E. Maley; thence by said right,of-way. on a curve tll the left having a radius of 400 feet an arc llistance of 68.11 feet to a point: thence cominuing by same South 15 degrees 34 minutes 20 seconlls East. a distance of 96.34 feet to a point: thence by same on a curve to the right having a radius of 1570 feet. an arc distance of 62.26 feetlO a poim at the Northwest corner of the intersection of Township Route 696 and Township Route 315: thence by Township Route 315. on a curve to the left having a radius of 325 feet and a distance of 94.84 feet to a point: thence by the Northern right-of-way line of Township Route 315. South 85 degrees 28 minutes 00 seconds West, 68.28 feet to a point. a corner common to Lots Nos. I and 2 on Subdivision Plan of Gary D. Reihart, Trustee. dated August 3, 1973. and recorded in the Oflice of the Recorder of Deeds of Cumberland County in Plan Book 24, Page 117; thence by Lot No.2. North 04 degrees 32 minutes 00 seconds West 187.25 feet to a point, on line of lands now or formerly of Ernest E. Maley; thence by said lands now or formerly of Maley. North 75 degrees 17 minutes 51 seconds East 147.57 feet to a point. on the Western right-of,way line of Township Route 696. the place of BEGlNN[NG. HA VING thereon erected a single-family dwelling house known and numberc:d as One Dead End Lane, Shippensburg, Pennsylvania. 17257. BEING all of Lot No. 1 as shown on the preliminary Subdi\'ision Plan for Gary D. Reihart, Trustee, recorded in the Office of the Recorder of Deeds in anll for Cumberland County at Carlisle, Pennsylvania, in Plan Book 24, Page 117. CONTAINING 28,444 square feet, more or less. TAX PARCEL NUMBER: 11-10-0610-098 T[TLE TO SAID PREMISES [S VESTED [N William H. Walker, married man by Deed from Dennis W. Barrick and Nancy J. Barrick, his wife dated 7/29/92 recorded 7/29/92 in Deed Book 35-U Page 578. ....,., 4 I . \ i COUNTRYWIDE HOME LOANS, INC. (F/K/A COUNTRYWIDE FUNDING CORP.) CUMBERLAND COUNTY COURT OF COMMON PLEAS :.\. If; If,: I' , ~t I, / VB. CIVIL DIVISION WILLIAM H. WALKER . . NO. 98-782 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY May 15, 1998 TO: WILLIAM H. WALKER 339 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 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 1 DEADEND LANE. SHIPPENSBURG. PA 17257, 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 $73.876.69 obtained by COUNTRYWIDE HOME LOANS. INC. IFIKIA COUNTRYWIDE FUNDING CORP. I (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: 12151 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. 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 1. be sold calling 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 riqhts 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 . ~ . . ALL T,HA T CERTAIN tract of land situate in the Township of Hopewell, County of Cumberland, and Commonwealth of Pennsylvania, more fully bounded and described as follows, to wit: BEGINNING at a point on the Western right,of.way line of Township Route 696, at corner of lands now or formerly of Ernest E. Maley; thence by said right-of-way, on a curve to the left having a radius of 400 feet an arc distance of 68.11 feet to a point: thence continuing by same South 15 degrees 34 minutes 20 seconds East, a distance of 96.34 feet to a point: thence by same on a curve to the right having a radius of 1570 feet, an arc distance of 62.26 feet to a point at the Northwest corner of the intersection of Township Route 696 and Township Route 315; thence by Township Route 315, on a curve to the left having a radius of 325 feet and a distance of 94.84 feet to a point: thence by the Northern right-of-way line of Township Route 315, South 85 degrees 28 minutes 00 seconds West, 68.28 feet to a point, a corner common to Lots Nos. I and 2 on Subdivision Plan of Gary D. Reihart, Trustee, dated August 3, 1973, and recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 24, Page 117: thence by Lot No.2, North 04 degrees 32 minutes 00 seconds West 187.25 feet to a point, on line of lands now or formerly of Ernest E. Maley; thence by said lands now or formerly of Maley, North 75 degrees 17 minutes 51 seconds East 147.57 feet to a point, on the Western right.of-way line of Township Route 696, the place of BEGINNING. HA VING thereon erected a single-family dwelling house known and numbered as One Dead End Lane, Shippensburg, Pennsylvania, 17257. BEING all of Lot No. 1 as shown on the preliminary Subdivision Plan for Gary D. Reihart. Trustee, recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Plan Book 24, Page 117. CONTAINING 28,444 square feet, more or less. TAX PARCEL NUMBER: 11-10-0610-098 TITLE TO SAID PREMISES IS VESTED IN William H. Walker, married man by Deed from Dennis W. Barrick and Nancy J. Barrick, his wife dated 7/29/92 recorded 7/29/92 in Deed Book 35-U Page 578. ;: ~. ., \,. ~ " . 5. Name and address of every other person who has any record lien on the property: t:!A!:IE 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: ~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) CUMBERLAND COUNTY DOMESTIC RELATIONS DEPARTMENT CUMBERLAND COUNTY COURTHOUSE SOUTH HANOVER STREET CARLISLE. 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 1 DEAD END LANE SHIPPENSBURG. PA 17257 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 :v "::~o::.:. h i fie. tion to .,thOt i ~..: .1. ro- ~'^" , DATE ~kMAN, ESQUIRE Attorney for Plaintiff ."' . . " ., (: t fj: I REAL ESTATE St.LE No. /3 On 1')")1 ~ ':t/, I '1 ? ~ the sheriff levied upon the defendants interest In the real property situated In ~~ 7c.ujJ Cumberland County, Pa., knO'Nn and numbered as: / ~ ~ ~;'-I(JA(f and moce fully described on Exhibit "A" filed W/ltl this writ and by this referllnce 11Icorporated herein, " ., il:, . " j :~ ( ''il& !\ l I' '} I j 11 D1.;;''<1: /1Yj ~ ~~" ? q r ~!tf s l ---. ! , L U ! i ; V PI If,l, l! :, ;lI1::1 d ! , i I I I I I i\ I h 1 -. ~~ ,. ! ' : . 1 Ob. I1J DE E 02 AVW . ,. . ...,IJ ~jilli!lb ',r,,;, i~ iJ,.lj.,O