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IN TIlE COURT OF COMMON PLEAS OF CUMOERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONTIMORTOAOE CORPORATION, nsslgncc
of KEYSTONE STATE MORTOAOE
CORPORATION,
Plnintln:
NO, 98-2027-Civil
vs,
RODGER E, NICKLE nnd ROBIN L. NICKLE.
husbnnd and wile.
Dcfendnnts,
fRAECIPE FOR I>EFAULT .JlID..!iMENT
AND ASSESSMENT OIi' DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Enter judgment in Defnult of an Answer in the nmount 01'$76,440.38, in fnvor of the
ContiMortgage Corporntion. et, ai, Plaintiff in the above-captioned action, against the Defendants,
Rodger E. Nic'kle and Robin L. Nickle and assess Plaintiff's damages as follows and/or as
calculated in the Complaint:
Unpaid Principal Balnnce
Interest from 10/25/97-3/13/00
(Plus $20. I 300 per dny after 3/ J 3/00)
$52,709.11
17.533,23
Late charges (Plus $32.66 per
month from 4/28/98-9/6/00 $947,14)
383,90
Attorney's fee
2,635.46
Escrow Deficit
(Plus any additional charges that mny be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriff's sale)
3. I 78,68
Total Amount Due
~
The real estate, which is the subject matter of the Complaint, is situate in Twp of
Penn, Cumberland Cty, Cmwlth ofPA. HET a dwg kla 18 Southside Dr. Newville, PA 17241. Parcel
31-33-1910-0110,
/---:2
_.~ (/l/'
~ is p, Vitti. squire
Attorney for the Plaintiff
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t>bte,s I If real property, supply six copies of description including ifltJroven1l;lnts IIl1d an
original and copy of affidavit of ownership (PaR.C.P. t>b. 3129).
If lengthy personalty listr supply four copies of list.
To index writ, file separate praecipe with writ.
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NOTICE Qt' SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Rodger E. Nickle
Robin L. Nickle
18 Southside Drive
Newville, PA 17241
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland COllIlty, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Cowthouse on September 6,2000 at 10:00 A. M.. the
following described real estate, of which Rodger E. Nickle and Robin L. Nickle are owners or reputed
owners:
Twp of Penn, Cumberland Cty, Cmwlth of PA. HET a dwg kla 18 Southside Dr, Newville, PA 17241.
Parcel 31.33.1910.01 lB.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of
Conti Mortgage Corporation, et. al vs, Rodger E, Nickle and Robin L. Nickle at No, 98.2027.Civi! in the
amount 01'$76,440.38,
Claims against property must be filed at the Office of the Sheriff before above sale date,
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date,
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff,
Attached hereto is a copy of the Writ of Execution, It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the jUdgment. You may have legal
rights to prevent your property from being taken, A lawyer can advise you more specifically of these
rights. lfyou wish to exercise your rights you must act promptly,
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR
LA WYER 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARISLE. PA 17013
(717) 249.3166
You may have legal rights to prevent the Sheriff's Sale und the loss ofyuur property, [n order to
exercise those rights. prompt action on your purt is necessary, A lawyer muy be able to help you,
You may have the right to prevent or delay the Sherifrs Sule by filing. belore the snle occurs. II
petition to open or strike the judgment or a petition to stay the execution,
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend. you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse lor failing to file the defense on time, If the
judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trinl of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage,
You may also have the right to have the jUdgment stricken if the Sheriff has not made a valid return
of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events, To exercise this right. you would have to file a petition to strike
the judgment.
You may lIlso have the right to petition the Court to stay or delay the execution and the Sheriff's
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to hllve the Sherifrs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sherifrs Sale. To exercise this right. you should fale a
petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The
Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten ([0) days from the date
when the Schedule of Distribution is filed in the Office of the Sheriff.
~~~
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh. PA 15219
(412) 281-1725
HTHE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONTIMORTGAGE CORPORATION, assignee
of KEYSTONE STATE MORTGAGE
CORPORATION,
Plaintiff,
NO, 98-2027-Civll
vs.
RODGER E, NICKLE and ROBIN L. NICKLE,
husband and wife.
Defendants,
LEGAL DESCRIPTION
ALL that certain tract of land situate in Penn Township. Cumb~'tland County, Pennsylvania, bounded and
described in accordance with Subdivision Plan for John E, Walker prepared by LlIITY V, Neidlinger. P ,E,.
R.S, dated July 28, 1988, recorded in the Office of the Recorder of Deeds in and for Cumberland County
in Plan Book 56. Page 74, bounded and described as follows, to-wit:
BEGINNING at a point in South Side Drive (T-349) at comer ofland now or tonnerly of Daniel Rhoads;
thence along Rhoads, North 04 degrees 41 minutes 25 seconds East 42.77 feet to an existing iron pin;
thence along same, North 00 degrees 24 minutes 14 seconds West 255.00 feet to a n iron pin set in corner
of Lot No, I; thence along Lot No, I, North 89 degrees 35 minutes 46 seconds East 120.98 feet to a set
iron pin; thence along right-of-way for Lot No. I, South 00 degrees 24 minutes 14 seconds East 167.48
feet to a set iron pin; thence along same, south IS degrees 32 minutes West 125,00 feet to a point in South
Side Drive; thence along South Side Drive South 86 degrees 20 minutes OS seconds West 50,01 feet to
a point; thence continuing along South Side Drive, South 79 degrees 41 minutes 26 seconds West 41 , 14
feet to a point, the point and place of BEGINNING, BEING all ofLot No.2 of the aforesaid Subdivision
Plan, Containing 33,113.32 square feet.
TOGETHER with rights in common with others to use of common water supply from well situated on Lot
No, 3 of the aforesaid Subdivision Plan.
HA VTNO ERECTED THEREON a dwelling known as 18 Southside Drive, Newville, P A 17241, Parcel
31-33-1910-01IB,
BEING the same premises which Jol>.n E. Walker and Mary J. Walker, his wife by deed dated April II,
1989 and recorded on April II, 1989 in the Office of the Recorder of Deeds in Deed Book Volume W3 3,
Page 775 granted and conveyed unto Rodger E, Nickle and Robin L. Nickle, his wife,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA
CIVIL DIVISION
CONTI MORTGAGE CORPORATION. assignce
of KEYSTONE STATE MORTGAGE
CORPORATION,
Plaintiff,
NO, 98.2027.Clvll
vs.
RODGER E, NICKLE and ROBIN L. NICKLE,
husband and wife,
Defendants,
LEGAL DESCRIPTION
ALL that certain tract of land situate in Penn Township, Cumbcrland County, Pennsylvania, bounded and
described in accordance with Subdivision Plan for John E, Walker prepared by Larry V, Neidlinger. P,E,.
R.S, dated July 28, 1988, recorded in the Office of the Recorder of Deeds in and for Cumberland County
in Plan Book 56, Page 74, bounded and described as follows, to-wit:
BEGINNING at a point in South Side Drive (T.349) at corner of land now or formerly of Daniel Rhoads;
thence along Rhoads. North 04 degrees 41 minutes 25 seconds East 42,77 teet to an existing iron pin;
thence along same, North 00 degrees 24 minutes 14 seconds West 255.00 feet to a n iron pin set in corner
of Lot No, I; thence along Lot No, I. North 89 degrees 35 minutes 46 seconds East 120,98 feet to a set
iron pin; thence along right-of-way tor Lot No, I, South 00 degrees 24 minutes 14 seconds East 167.48
fect to a set iron pin; thence along same. south 15 dcgrees 32 minutes West 125,00 feet to a point in South
Side Drive; thence along South Side Drive South 86 degrees 20 minutes 05 seconds West 50,01 feet to
a point; thencc continuing along South Side Drive, South 79 degrees 41 minutes 26 seconds West 41,14
feet to II point. the point Ilnd place ofBEGlNNING, BEING all of Lot No, 2 of the Iltoresllid Subdivision
Plan, Containing 33.113.32 square feel.
TOGETHER with rights in common with others to usc ofcomlJ1on watcr supply from well situated on Lot
No, 3 of the aforesaid Subdivision Plan,
HA VING ERECTED THEREON II dwelling known as 18 Southside Drive, Nc\willc, P A 17241, Pllrcel
31-33-1910-011B,
BEING thc same premises which John E, Walker and Mary J. Walker, his wife hy deed dated April 11,
1989 and recorded on April II, 1989 in the Office of the Recorder of Deeds in Deed Book Volume W33,
Page 775 granted and conveyed unto Rodger E, Nicklc and Robin L. Nicklc. his wife,
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CllMDlmLANIl COUNTY IJAI{ ASSOCIATION
2 LUmRTY A V 1<; N lJl<;
CAIUSLE. I' A 17013
(717) 249.3166
You may huve legal rights to prevent till: Sheriff's Sule and the loss of your property, In order to
exercise thost, rights. prompt action on your pari is necessary, i\ lawyer may he ahle to help you,
You muy have the right to prevent or delay the Sheriffs Sale hy filing. hcfore the sale occurs, u
petition to open or strike the judgment or a petition to stay the execution,
If the judgment was entered because you did not file with the COU,i any defense or o~iection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to huve the judgment opened in you prrJlllptly file a petition with the
Court ulleging a valid defense and u reasonable excuse for fuiling to file the defense on time, If the
judgment is opened. the Sherin's Sale would ordinarily he delayed pending u trial of the issue of whether
the Plaintiff has a vulid claim to foreclose the Mortgugc,
You muy ulso huve the right to huve the judgment slricken if the Sheriffhus not made u valid retUnt
of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events, To exercise this right. you would huve to file u petition to strike
the judgment.
You may ulso huve the right to petition the Court to slay or deluy the execution and the Sheriff's
Sule if you can show u defect in the Writ of Execution or service or demonstrnte uny other legal or
equitable right.
You may also have the right to huve the Sheriffs Sale sel aside if the property is sold for a grossly
inudequute price or if there are defects in the Sheriffs Sule, To exercise this right. you should file a
petition with the Court after the sule und hefore the Sheriff has delivered his Deed to the property, The
Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date
when the Schedule of Distribution is filed in the Office of the Sheriff,
'-~814-
C~ti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 152]9
(4]2) 281.1725
**THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY,
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
"
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REAL EST~JE S,~J F No, I
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Ull /YYI~'- ~/.,:Jrrl the sheriff levied upon the defendants
Interest In the real property situated In .A~ ~
Cumberland County, Pa" known and numbered as: J~ J.,.....~.1 a~.~-,,-~
/)IL<" ~.IL. and more fully described on Exhibit "A" fll8d with
this writ and by this reference Incorporated herein.
nat9y1Jj~~~/).1. ~ By' J?r:.~ J~~
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IN THE c:OURT....Q!~MJ!! PLFAS ..2!::..C()~Ulf:R[AND ~Y, PENNSYLVANIA
CIVIL DIVISION
-----~----~
PRAECIPE f'OR \'iRIT OF E:<ECU'I'ION
- .--_,_---o_~,
Ca\)tion:
Confessed Judgment
ContiMortgage Corporation, _L Ill,
other
vs.
file /'ok) ,
Arroun t Due
Interest
98-2027-CivU
$76,440.38
10,890:13
Rodger E. Nickle & Robin L. Nickle,
Atty's Ccmn
Costs
'II:) THE PROniON:rl'ARY O~' THE SAID COUR1',
The undersigned hereby certifies that the below does not arise out of a retail
insta!.llrelnt saler contract. or account based on a confessi.on of judgnent. but if it does,
it is ba.~ed on the appropriate or,i,ginal proceeding filed pursuant to Act 7 of 1966 as
~e(h and for real property pursuant to Act 6 of 1974 as arrended.
Issue writ of execution in the above IT'atter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described PL"Operty of the
defendant ( s)
See at tached legal description,
PRAECIPE FOR ATI'ACJf-lENr EXFO.1I'IOO
Issue writ of attachtrent to the Sheriff of Cumberland County. for debt r
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the follOwing property (if real estate. supply six copies of the deScription; supply four
copies of lengthy personal ty lis t ) ,
and all other property of the defendant ( s) in the PJss8ssion, custody or COntrol of the
said garnishee ( s ).
(Indicate) Index this writ against the garnishee(s) as d lis pendens against
real estate of the defendant(s) described in the attached exhibit.
Signdturq~~~(~/~
P::int Narre: LoIIlS P: Vittl
DATE:
April 2, 2001
--
,.\ddress,
91 f, Fir th AvenUE'
Pittsburgh, PA 15219
'~:toG1ey for: Plaintiff
:-r:::le;::-,c)r.e:
(412) 281-1725
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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
HARRISBURG DIVISION
IN RE: RODGER E, NICKLE, SR. and
ROBIN L, NICKLE
Debtors,
)
)
)
CASE NO: 1-00-03836 RJW
CHAPTER 13
.."......................................,.......",.......... )
FAIRBANKS CAPITAL CORP,
Movant,
vs, ,
RODGER E, NICKLE, SR. and
ROBIN L. NICKLE
Respondents,
CHARLES J, DEHART, III,
)
)
,
I
)
)
)
)
)
Trustee,
DEEAULLOEIDEELONMO.IIOMORREiJ.EE..EROM.AUIOMA TLC_S lAY.
This ')e, day of;~LU ~, 2.0,01, upon default, no response objecting to the
Motion having been timely filed by an interested party, and upon Movant's certification of
service and certification of default, it is
ORDERED that the above-captioned Motion is granted insofar as it requests
relief from the automatic stay imposed by 11 U,S,C, Section 362,
Movant shall, within 5 days hereof, serve a copy of the within Order 01' parties
In interest and file a certificate of service,
(l.Il 1l",..~1, 01. 'f"~~..
United StateD Bankruptcy judge
c: Louis p, Vitti, Attorney for Movant
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
U_.,,_ i
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"
IN TIlE COURT OF COMMON "LEAS OF CUMBERLAND COUNTY. I'ENNSYLV ANIA
CIVIL DIVISION
CONTI MORTGAGE CORPORATION. assignee of
KEYSTONE STATE MORTGAGE CORPORATION.
Plaintin:
NO, 98-2027-CIVIL
vs,
RODGER E, NICKLE and ROBIN L. NICKLE. husband
and wife.
Defendants,
AFFI/)A VIT
I. Louis p, Vitti. do hereby swear that. to the best of my knowledge, information and
belleI'. the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to
execute, That the Defendants' last known address is 18 SOllthside Drive. Newvi lie, P A 17241.
~?~
L is p, Vitli. Esquire
SWORN TO and subscribed
before me this 2nd day of ~ ___
., Nol''lIJil/ Soul 1
';:~~::;:lilfY Puhllr.
A 'I 2001 ~, .'Ilbhurgh, Alle,Jhonycollnty
pn. , _:\:Y~~nlml"""JlI EXi'i',," .Jurlfl to, ;'01}2
. /~ ~-,;;" """."0"..;
, -----
.~- . .,-
YOU SHOULI) TAKE THIS NOTICE ANI) Tim WIUT 01<' I<:XICCIJTION TO YOUR
LAWYER AT ONCI<:. II<' YOU DO NOT UA VE A LA wn:R Ol{ CANNOT AI<'I<'ORD ONE,
GO TO OR TELEPHONE TIm OI<'I<'ICE SET I<'Olfrn 1m LOW TO FlNI> OIIT WHERE
YOU CAN (;In UX;AL ADVICE.
CIJMIUmLANI> COUNTY RAI{ ASSOCIATION
2 LIIJERTY AVENUE
CARLlSLI~,I)A 17013
(717) 249.3166
You may have legal rights to prevent the Sherin's Sale and the loss ofyuur property, In order
to exercise those rights, prompt action on your part is necessary, ^ lawyer may be able to help you.
You may have the right to prevent or delay the Sherif/'s Sale by filing, before the sale occurs.
a petition to open or strike the judgment or a petition to stay the execution,
If the judgment was entered because you did not tilc with the Court any delimse or o~ieetion
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notkle to Delimd, youmuy have the right to have the judgment opened in you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time,
Ifthe judgment is opened, the Sherifrs Sale would ordinarily be dclayed p..:nding a trial of the issue
of whether the Plaintiff has a valid claim to foreclose the Mortgage,
You may also have the right to have the judgment stricken ifthc Shcriffhas not made a valid
return of service of the Complaint and Notice to Defend 01' i I' the judgment was entered before twenty
(20) days after service or in certain other events, To exercise this right. you would have to l1Ie a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriff's Sale if you ean show a defect in the Writ of Execution or service or demonstrate any other
legal or equitable right.
You may also have the right to have the Sherifrs Sale set aside if the property is sold for a
grossly inudequate price or if there arc defects in the Sheriffs Sale, To exercise this right. you should
file a petition with the Court ufter the sale and before the Sheriff has delivered his Deed to the
property, The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10)
days from the date when the Schedule of Distribution is filed in the Ofliee of the Sheriff,
cI~)i-m::
Louis p, Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh. PA 15219
(412) 281-1725
UTHE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INI<'ORMATION OBTAINED WILL HE USED I<'OR THAT PURPOSE.u
.
. -.
-",
4, Name and address of the last recorded holder of every lI10rtgage of record:
Name
Address (Please indicate if this
cannot be rensonably nscertaincd)
CCNB Bunk. N.A.
4242 CRt'isle Pike
CampHiIl.I'A 17011
Penn~ylvania HClusing Finance
2101 N, Front Street
Harrisburg.PA 17105
Name
5, Name and address of every other person who has any record lion on the property:
Address (Please indicate If this
cannot be reasonably nsccrlained)
None
6. Name and address of every other person who has any record interest in or record lien on
the property and whose interest may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and aduress of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Penn Township
2655 Walton B
Clarion,PA 17013
Commonwealth ofPA .DPW
1',0, Box 8016
Harrisburg, I' A 17105
Clerk of Courts
Criminal/Civil Division
One Courthouse Square
Carlisle. I' A 17013
Court ofComllJOfl Plens of
Cumberlnnd County
Domestic Relations Division
1'.0, Box 320
Carlisle,PA 170i3
. " ,\,.
YOU SHOULI> TAKE THIS NOTICE AND THE WRIT OIII~XECUTION TO YOUR
LAWYER AT ONCE. W YOU 00 NOT HA VE A LAWYER OR CANNOT AFFORI> ON~~,
GO TO Olt n:LEI'HONI~ TilE OFI"ICI~ SET FOlnlllJl~LOW TO !,'INIl OUT WHERE
YOU CAN m:T LJi:GAL A I)VICE.
CUMIJICltLANIl COUNTY BAit ASSOCIATION
2 LIBERTY AVENUE
CARLISLIC,I'A 17013
(717) 249.3166
You may have legal rights to prevent the Sherifrs Sale and the loss of your propel1y, In order
to exercise those rights, prompt action on your part is nccessary, A lawyer muy be uble to help you,
You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs,
a petition to open or strike the judgment or II petition to stay the execution,
If the judgment was entered because you did notlile with the Court any defense or objection
youlllight hllve within twenty (20) days after service of the Complaint for Mortgage Poreclosure and
Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to liIe the defense on time,
If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the Plaintiff has a valid claim to foreclose the Mortgage,
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right, you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other
legal or equitable right.
You may also have the right to have the Sherifrs Sale set aside if the property is sold for a
grossly inadequate price or if there are defects in the Sherifrs Sale, To exercise this right. you should
liIe a petition with the Court after the sale and before the Sheriff has delivered his Deed to the
property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10)
days from the date when the Schedule of Distribution is liIed in the Office of the Sheri ff,
cr~;;kk.
Louis p, Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
UTHE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT ANI> ANY
INFORMATION OB'fAINED WILL BE USED FOR THAT PURPOSE."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION
CONTI MORTGAGE CORPORATION, assignee of
KEYSTONE STATE MORTGAGE CORPORATION,
Plaintiff,
NO, '98-2027.CIVIL
vs,
RODGER E, NICKLE and ROBIN L. NICKLE, husband
and wife,
Delendants,
LEGAL DESCRIPTION
ALL that certain tract of/and situate in Penn Township, Cumberland County, Pennsylvania. bounded
and described in accordance with Subdivision Plan lor John E, Walker prepared by Larry V,
Neidlinger. P,E" R,S, dated July 28,1988, recorded in the Office of the Recorder of Deeds in and
for Cumberland County in Plan Book 56, Page 74, bounded and described as follows, to-wit:
BBGlNNING at a point in South Side Drive (1'-349) at corner of land now or formerly of Daniel
Rhoads; thence along Rhoads. North 04 degrees 41 minutes 25 seconds East 42,77 feet to an existing
iron pin; thence along same, North 00 degrees 24 minutes 14 seconds West 255,00 feet to an iron
pin set in comer of Lot No, I; thence along Lot No, I, North 89 degrees 35 minutes 46 seconds East
120.98 feet to a set iron pin; thence'along right-of.way for Lot No, I, South 00 degrees 24 minutes
14 seconds East 167.48 feet to a set iron pin; thence along same, South 15 degrees 32 minutes West
125,00 feet to a point in South Side Drive; thence along South Side Drive South 86 degrees 20
minutes 05 seconds West 50.0 I feet to a point; thence continuing along South Side Drive, South 79
degrees 41 minutes 26 seconds West 41,14 feet to a point, the point and place of BEGiNNING,
BEING all of Lot No, 2 of the aforesaid Subdivision Plan, Containing 33,113.32 square feel.
TOGETHER with rights in common with others to use of co 111m on water supply from well situated
on Lot No, 3 of the aforesaid Subdivision Plan,
HAVING ERECTED THEREON a dwelling known as 18 Southside Drive. Newville, PA 17241,
Parcel No, 31-33-1910-0118,
BEING the same premises John E. Walker and Mary 1. Walker, his wife by deed dated April II,
1989 and recorded on April II, 1989 in the Office of the Recorder of Deeds in Deed Book Volume
W33, Page 775 granted and conveyed unto Rodger E, Nickle and Robin L. Nickle, his wife,
-.
WRIT OF EXECUTION and/or ATTACHMENT
!
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO, 98-2027 _ CIVll11X TElRM
CIVIL ACTION. LAW
TO THE SHERIFF' OF _SUJ.11l:>~_llar!<L_____ COUNTY,
To sallsfy the debt, Interest and cosls due _~()r~!_~/<bltga't<'._~otp?tC\tion
----'--------------------------., _u__ ,PLAINTIFF(S)
from -ROOgexJ::.......Nickle ..&...RQbir.LL,....J'li.ck.l.;;,....L6..,SQll,1:.lli!id!iL...llii VQ..... Newill"" PA 17241
._---------_._------~_.------_._---_._-- '---._._--._~~-
--'-'---
----'---------'----------,---------..--------- ___,DEFENDANT(S)
(1) You are dlreCled to levy upon the prope'ly 01 the delendant(s) and to se"_~"'''' Ikgal DEoscdption
--------..-.....-------. .
._-.~-_._-_.".._-""._-.,_._.._~._-._._-,
--------.----.----.
..-~._--_._-.-...-.----~-____.T__.__
~--_.
(2) You are also directed to attach the property 01 the defendant(s) not levied upon In the possession 01
-..-----------.----.-.
._-~----._-_.
-------~-~._-------_.._.._----_._-----
_._----..._---~--~,.__....__._._-~-_._.._---_.._--.._~---~-,-----
-._-._----~-~--...
-----
-------
GARNISHEE(S) as follows:
-~---_.~------.__._.~----~~-----
and 10 notny the garnlshee(s) that: (a) an attachmenl 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 dellveling any property of the defendant(s) 01 otherwise disposing
thereof:
(3) II property of the defendant(s) not levied upon an subject to attachment Is found In the possession of anyone olher
than a named garnishee, you are dllected to notify hlrtVher Ihat he/she has been added as a garnishee and Is enjoined as above
slated,
Amount Oue__~76d40.)8
Interest $10,890.33
L.L.
-----------
Atty's Comm
Atty Paid
Plalntfff Paid
%
Due Prolhy __
Other Cosls
$1,00
$1 n n 2..JllL.....
---~---.__.
Date: -_-Ap.-il 1 n , .200L_______,
Cmt.i.s_ R. Il)lIQ
P,othonotary, Civil Di'~lslon
b~ ..an/h 0 'L7prfV}-nt'-'J
Deputy
REQUESTING PARTY:
Name Louis P. Vitti, Esq_~._
Address: 916 Fifth AVenUe
Pittsburqh, PA 15219
Attorney for: ~itiff
Telephone: 412-281-1725
Supreme Court 10 No, ... 3810 _______..._____..~
..-------