HomeMy WebLinkAbout98-03374
AAMES CAPITAL CORPORATION
plaintif f
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
q~ - 3-=?) ,If
(\I.I~J~' \<<'J\iY)
vs.
PAUL R. HARRIS A/KIA PAUL
R. HARRIS, JR. AND CYNTHIA
L. HARRIS AND THE UNITED
STATES OF AMERICA
Defendants
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
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 the
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.
Court Admin., Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
Legal Services, Inc.
a Irvine Row, Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI US TED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEt~DANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE US TED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Court Admin., Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
Legal Services, Inc.
a Irvine Row, Carlisle, PA 17013
717-243-9400
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AAMES CAPITAL CORPORATION
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVAl,IA
vs.
NO. 9 f- 33 N Cev.:i .77...-
PAUL R. HARRIS A/K/A PAUL
R. HARRIS, JR. AND CYNTHIA
L. HARRIS AND THE UNITED
STATES OF AMERICA
Defendants
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
COM P L A I N T
1. Plaintiff, AAMES CAPITAL CORPORATION, is a California
corproation, with an address of 350 SOUTH GRAND AVENUE, LOS
ANGELES, CALIFORNIA, 90071.
2. Defendant, PAUL R. HARRIS, A/K/A PAUL R. HARRIS, JR., is
an adult individual whose last known address is 1106 EASY ROAD,
CARLISLE, PENNSYLVANIA 17013. Defendant, CYNTHIA L. HARRIS, is
an adult individual whose last known address is 1106 EASY ROAD,
CARLISLE, PENNSYLVANIA 17013.
3. The United States of America is a nation located on the
continent of North America.
4. The United States of America is hereby joined as a
party in accordance with the provisions of the Act of Congress on
the United States of June 25, 1948, c. 646, 52 Stat. 972, as
amended, 28 USCA Section 2410, and for the reason that the United
States of America may allege to have an interest in the premises
subject to the Mortgage herein on account of said tax lien. The
United States of America is being joined herein for the purposes
of having any liens discharged which it may have pursuant to PUB.
L. 89-719, Title I. Section 109, November 2d. 1966, 80 Stat.
1141, as amended, 26 USCA Section 7425.
5. On or about December 15, 1997, the. United States of
America filed a tax lien against the Defendants, Paul R. Harris,
AppliClUon ,
Loan Number PA020391
ADJUSTABLE RATE NOTE
(6 Month LWOR lad", - RII. Clpo)
_ _ THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE
AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE
CAN CHANGE AT ANY ONE TIME AND THE MINIMUM AND MAXIMUM RATE I MUST PAY.
JUNE 11. 1997
COSTA MESr. . CALIFORNIA
ICIly! \1I,lfl
1106 EASY ROAD, CARLISLE, PENNSYLVANIA 17013
1....,..,y..4oMul
I. BORROWER'S PROMISE TO PAY
In relurn for. loan thll I h.ve "ceiv.d. I promlIC 10 PlY U.S. S 252,000.00 (this lD\Ountu
called 'prineipal'). plu, int"..I. to the onler of the Lender. Th. Lender Is ONE STOP MORTGAGE,
INC., A WYOMING CORPORATION
I uDd.Uland th.1 the Lender lIIAY Iran.fer this Nole, Th. Lender 0' anyone wbo lale.. this NoC' by lrUl.fer and who
I. ",Ulled 10 rocelve p.y_" under Ihil NOIe Is called the "Nole Holder". '
Z, INTltREST
IDlcroll will b. charged Dn unpaid principal unll1the lull &mounl of principal h.. bcCII pald. Inlerell will be
caleulal.d on Ihe bui. of I IZ.ll1llnth year and . 30.d.y month. I will p,y Int.."1 b.glnning II . y,"ly lite of
10.360 %. Tho Interell ralc 1 will pay will change in accordance with Se,'ion 4 or thl. Note. The iOlerest
IIIe "'lulred by thl. Scotian Z and Seellon 4 of Ihl. Not. I. Ihe rale I will p.y both before and .ner any der.ull
d..crlbed In Seellon 7(0) of Ihl. N01., If I fall 10 p,y any 1Ill0unl. due. in addition 10 any other righll pOIIC...d by
the Note Holder. any accNed but unpaid Inlercst may be added to the unpaid principal and accrue inlcrell at the
inleru1 rate in ert'ecl from lime to lime under thi! NOlO.
3. PAYMENIS
W Time and PlICO or Payments
I will PlY principal and 101."11 by making paymenl. every monlh. I will mal:e my monthly paymenll on the Ont
d.y of.ach month beglMlng on AUGUST 1 . 1997. I will make lhm paymenll every month until I h.ve
p.ld 111 of the principal and Inlere.1 Ind any other chargc. d.sc,lb.d below th.ll m.y owe under thl. Naill. If. on
JULY 1 . 2027 . I 11111 owe lD\Ounll under thl. NOle. I will p.y those """unlO In full on thar date.
which I. called the 'lIIAlU,iry dOle'. 1 will make my monthly p.ymenlO If AAMES HOME LOAN, P.O.
BOX 76930. LOS ANGELES, CALIFORNIA 90076
or al a dirrerenl place if requited by the Nott. Holder.
(11) Amouot of My Ini~al Moolhly Payment.!
Each of my initial monthly payments will be in the amount ot U.S. $ 2 f 278.81 . This amount may
change.
(C) Monthly Payment Chang"
Clwlg.. In .... monthly paymenl will reOeel chillg" in the unpaid prioclpal of .... loan and In the 101er,,1 rale
thll I mull p.y. The Note Holder will delennlne my MW InlCrClt rat. and th. changed amount of my moothly
p.ymenlln ....rdance with Secllon 4 of thl. Naill.
(0) Application of Paymenl.
PaymenlO received by the Nole Holder will be applied In the following order: (I) any prep.yment charger duo
under this Note: (11) amounll payable under p,"grapb Z of the Seeurity In,,,,"",nt (defll\Cd below): (Iii) inter"l due
under this Note; (lv) prlncipll due under this Note; and (v) btc-chargu due under thll Not~.
4, INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change OBt"
Thelnt.'''11I1e I will pay lnay change on the Orst d.y of JULY 1 " 2002 ,and on tlW day
every 6th moolb therCIner. Eleh date on which my interest nte could change Is called a .Change Date".
(8) Th. Index
Beg.lnning with the finl Change Dale, my interest rate will be based on an Indc.x. The "lndC\" II the average or
inlCtbank. orfered tAtel for si~ manUI United Sllte& dollar depolil! In the LendoR rnark~ based on quotations of major
bwka rUBOR.), a.s published In the Western Edilion ot the The WAll Suet' Jounl41. The mOlt retent Index. figure
available ~ of the date 4S days before each Change Date il called the .Current Inde~.. Ie the Index is no lODger
available, the Note Holder will choose a new lndeA which is baaed upon comparable inforr11lltion. The Note Holder
will give me nolice of this chOIce.
(C) Calculation or Changu
atrore each Change Dilte. the Note Hold::r will calc;ulalc my new inleten rate by addina FOUR AND
950/1000
perecnlage poinl(') (4.950 %) (the 'Margin') to the Curccollodex. The Note 1I0ldor will then
round the relult ot this addition to the neueU one.eiablh of onepercc.ntage point (0.125%). SubjeGllO the limiu
stated In Seclion 4(D) below, Ule rounded an".Ount will be my neW interest rale un1i1 the next Change Dilte. The Note
Holder wil1lheD detenninc the amount of the monthly payment that would be sufficient to ~ay Ule unpaid principal
Ulat I un cApect.ed 10 owe at the Change Date in full on the maturity date al my new interelt rale in substantially equal
pa.yments. TIle rcsull of lhis calculation will be the new amount of my montll}Y payment.
PENNOVLVAN'A FIXED/ARM PROGRAM ~) jI /)t
un 'O,M11'" 1/11 P'g' 1 013 Borrowe,', Initio.1':(g- C44 - -
ah)~~tT\re /1
..,<'11 ..,..~
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(0) L10l11l on Int"..t R.ot. Ch.n&"
Th, IrnerelC rllC thai t un required 10 PlY It the Om Chanle Oatc will nut be grelter than 13 .360 "
or leu Ulln 10.360", Thereafter. my Internl rate will never be In.creued or deereued on In)' Iln&lo
CI1.... 0.1. by more thon bnc ond o",.hllr pOtt,oll&' poln" (I.SOO") Crom Ih. rll. of iOI.re" I bm b.en p.ylng
ror tho pleeedln& 11.(6) moolb(l). My IlIlOlesl "" ",ill n.v" be a""" Ihan 17 . 360 " or ,... than
10.360 lI.
(E) Erroetl.. Dlt. of Chln&"
My new lnttreat tale will become errectlve on each Chantc Dale:. I will pa)' \he amount of m)1 new 0lUII11Il1
payment bellMllI, on the nut monthly (Ilymenl date after Un: Chlf18C Olte unlllthlllmount or my mOlltWy I,aymcnt
<h1ll&OI'1l1n.
(I') NoU" 01 Ch.nl"
The Nol.l: Holdar wlll deUver or lUlU 10 UU: .. oath:c: of an)' than~ot In my Interest rate and the amount of my
IllOnlhly p.y....t berore th. err"lIve d.te or ..y chon Be. Th. 0011.. ",lIIloelude lorumullon required by I.w 10 b.
aiven me ond a110 th. till. lIId IOlephon. numbor of I penon who will an.wer ony qUOlllun I may h.v. "audlng the
nollec.
5. BORROWER'S RIGHT TO !'REPAY; PREfA YMEl'IT CHARGE
I h.v. th. right 10 Ollk. p.ymenl. or prlnolpll II ony tlm. b.fore they m due. 10B.ther with "cNed iOIClOIl.
lVl1.n 1 m.ke I prep'YUltnl. I ",11\ teUth. NOle Ilolder In ",rlllns thai I 111I dol~ 10. III Ollke . pllllol prep'YOlent.
th.re ",III be no ehan~esln Ih. due d.te or In the amoUDt or my monthly paymeol unl,.. U" 1'010 lIolder agrees in
writln& 10 those ebonges. Ir th. original principII amounl of thl. Noto I. leu thon or equal 10 $'0.000 '."d the
Property IccurinB repayment ot this N01C contains nol morc than two (2) rcsldolula1 unln, then 1 nay muc I rull
prepayment or partial prapaymenll without paylnllny prepayment char~c. In llt Olher CUCI, if within five (S) years
from th. data of exoculion or the Security InllNmenl (u denn.d b.low) I male. a 1\111 preplYlI'<ll' or panlal
pr.payl1lCJl'(.). I will ., the ..me lime pay 10 the Noto lIolder a prepaymeul ol,arB', The prepaYUltnl charge will be
equal 10 .1x. monlhs Jdvmcc Interen on the amount or the prepayment Ulilt. when added to all other amounU prepaid
durina the twelve (12) month period Immedialely prcccdin8 the date of the prcpoymenl, exceed. twenty perctnt
(20~) of the original principII amount or lhi. 1'010.
6. LOAN CHARGES
Ir I law. whleh applies 10 thh loan and which sell maximum loon chuse,l. is fmally Inlerpreled 10 !hat th.lnter..'
or other loan <harges collected or to b. collecl.d In coMeclioD with thl.loan ...eed the pennllled limits, lhen: (I)
any ..ch loan eharge .hall be reduced by Ihe amount noe",all' 10 reduce Ibe <huBe to the pennlllod 1Im11: ond (ii)
any IUms already collceled from me which exceeded permitted. limit! will be refunded to me. The Note Holder may
choose to make this refund by reducing the principal I owe under this Note or by makiog a direct payment to mo. If
a refund reduces principal. the reducllon wlll be llcated at a panial prepayment.
7. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Cbargea lor Orerdu. Payments
Ilthe Note Holder h.. not r...lv.d the rull unouol or any monthly paymenl by the end or TEN
( 10 ) cal.ndar days a~er lh. date It i. due. I ",ill pay a late charg. to the Note Holder. The amou"t of the charge
will b. TEN AND 000/1000
percenl ( 10.000 ,,) of my overdue payment of principal arnllnl,re,t. I will pay thll lalO <hllg. prompUy
bUI only once on each late paym.nt.
(B) Default
III do not pay the lullllnOWlt or "th monthly payment on the date It il du., I will be In d.l,ult. If I am in
default. the Note Holder may require me (0 pay immediately the full amount OfPllnclpal which hIlS not been paid and
all interest !hIt 1 owe on that amount, logelhcr wllh any olber charges that 1 owe under thb Note or lhc Security
10llNment (d.nned below).
(C) No Walvu By Nole Holdu
Even if, al a time when I am In default, the Nole Holder does nol require me to pay lnunedialcly in full as
delcrlbed abovel the Note Holder willllill have the dghlla do 10 if IIUT1 in defauh at a later time,
(D) 'Paymml at Note Ho1dula Cosu and E;'Il;penu.,
If the Nole Holder hu requlled me to pay Immediately in tun u delcribed above, the Note Holder will have the
right to be paid back by me 10r all of IUCQstl Md expensea in enforciDB this Note to the extent not prohibited by
applicable law, whether or 110t a lawsuit II filed. Those expenses inelude. for eumple. reasonable attorney" feea.
B. GlVING OF NOTICES
Unless applicable law lcqulres I different method. MY notice thai mlJlt be given 10 me undellhi, NOle will be
Biven by delivering it or by malllng it by fiut elan mail to me at the Ploper1y Address abovo or at II different addreu
If I give the NOle Holder a notice of TDY different address. Any notice that must be given (0 the Note Holder Wlder
this Note will be given by malllng II by fint clan mall (0 the Note Holder at the address alated in SccUon 3(A) above
or at a differmt iiJddress if I am Biven a notice of that-different address,
9. OBLIGA nONS OF PERSONS UNDER TinS NOTE
If more than one person sit!,ns this Note. each penon is fully and penonally obliBated to keep all of the promises
made in this Note. lneluding the promise to pay the rull amount owed. Any penon who is a guarantor, surety or
endorser of this Note il allO obligulcd 10 do Illese Ihings. MY person who lakel over thelc obligations, including the
obligations of a gulU'iiU1tor, lurely or endorser of this Note. is also obligaled 10 keep all oC the pft)mises made in this
Notc. TIle Note Holder may enfolcc its rights under thil Note "gainst ellch penon individuAlly 01 a.gainst all of us
logelher. TItiB means that anyone or UB may be required to pay all of the amounts owed. under this Note.
10. W AIYERS.
I and any other penon who hM obligation. under this NOle waive Ille righu of presentment and DOti~ of
dishonor. -PlClentment- mew the righl to require the Note Holder to demand payment of arnoun!1 due. -Notice of
dilhoDor- meaus lhe right to lcquire the Note Holder to give notice to other personllhal amounls due have not been
paid.
PENNSYLVANIA FIXEOfARM PROGMM
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AAMES CAPITAL CORPORATION,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 1998 3374 CIVIL
PAUL R. HARRIS A/KIA PAUL R.
HARRIS, JR. AND CYNTHIA L.
HARRIS AND THE UNITED STATES
OF AMERICA,
Defendants
IN MORTGAGE FORECLOSURE
MOTION FOR SERVICE OF NOTICE OF SALE
IN REAL PROPERTY ACTION
IN ACCORDANCE WITH RULES 3129(b) (2)
OF PENNSYLVANIA RULES OF CIVIL PROCEDURE
Plaintiff, Aames Capital Corporation, through its counsel, Leon
P. Haller, Esquire hereby respectfully submits:
1. Plaintiff has brought a mortgage foreclosure action
whereupon it seeks to foreclose against certain property owned by
Defendants located at 1106 Easy Road, Carlisle, PA 17013.
2. Defendants Paul R. Harris alkla Paul R. Harris, Jr. and
Cynthia L. Harris were served with the Complaint, June 19, 1998 by
Regina Kilner, adult in charge accepting service for the Defendants
at the property. United States of America was served with the
Complaint, June 23, 1998. Defendant Cynthia L. Harris was served
with the Notice of Sale, November 29, 2000 at 916 Scottish Drive,
Mechanicsburg, PA 17055. However, the Sheriff's office has been
unable to serve Defendant Paul R. Harris alkla Paul R. Harris, Jr.
with the Notice of Sale at the property, or at the forwarding address
found for the Defendant. The Plaintiff believes that the Defendant
has no interest in the property and has no desire to oppose the
Sheriff's Sale.
3. Plaintiff has conducted an investigation in order to
determine the whereabouts of the Defendant, through its attorney, by
attempting to obtain a forwarding address from the post office, the
Department of Transportation, Credit Bureau, and also by attempting
to obtain a phone number for the Defendant, but no new information
455 Linden Street. Allenlown, PA 18102
. RR 3, Box 2025, Effort, PA 18330.1901 1 ~
... Allenlown Office: 610-395.8741 :%i
~ Pocono Office: 570-992-2425 ,~ ~
e-mail: mkrolz@earthllnk.net
''',' , . ~. ,;' ':,' > '. I"," . ,..' ~. .
.... CONFIDENTIAL INVESTIGATIONS.. '..
",' ',\'" -.' ':(~~".' , '~;.', ",',,'
Loss Prevontion f' Asset Searches' Business Intelligenco
Insurance Fraud to Skip. Tracing . Missing Persons
Beckground Investigations . Witness IntelViewlng
Undercover Investigetlons . Personal Protection
Pre-employment Investigetlons . Suoye/"ance
Process Service' Litigation Support
INVESTIGATIONS & lEGAl SUPPORT SERVICES
Caption AAMES CAPITAL VS HARRIS
To: BARB VILLARIAL
Date: 12/01/00
Court Term No.
Your File No.
CI Doc. No.
1998-3374-CIVIL~
00-330
00-330
Known Information (Supplied by Client):
Name: PAUL R. HARRIS
- -
Address: 2237 SHADOW RIDGE CT
City/State/Zip: OKLAHOMA CITY
SSN: 215-80-4633
CYNTHIA L. HARRIS
----_._~.__._-- ---_.
916 SCOTTISH CT
MECHANICSBURG, PA 17055
NOT GIVEN
~
INVESTIGATION REPORT
Subject Identifiers (Obtained from Public Records) Investigation Sources Listed on Page 2
Name: PAUL R. HARRIS JR CYNTHIA L. HARRIS
Social Security Number: 215"80-4633 196-48-3884
State of Issue: MARYLAND PENNSYLVANIA
Yearof/ssue: 1974 - 1975 1972 - 1973
Year of Birth: 1960 07/1957
Driver's License No: NO RECORD FOUND NO RECORD FOUND
State of Issue.' NOT APPLICABLE NOT APPLICABLE
File Creation Date: 07/8B 04/83
Last Record Found On3: 08/00 10/00
MOST CURRENT ADDRESS(ES)
Mast recent address obtained from public records: NEW ADDRESS FOUND
Address4:
Defendant #1: 1106 EASY RD, CARLISLE, PA 17013
Defendant #2: SAME ADDRESS FOUND FOR BOTH
Telephone Directory Search5:
Defendant #1: 717-241-6999 CO. OF PAUL HARRIS
Defendant #2: SANE
~
1 Obtained from Consumer Credit Report Header File. DMV records are not accessible for purposes of SkipTracing. See
notice on page 2 under Department of Motor Vehicle Operator Information.
2 Original date subject's record is listed in Consumer Credit Report Header Files.
3 Date most recent address was reported in Consumer Credit Report Header Files.
4 Most recent address found after reviewing all address sources.
5 As listed with A T& T directory assistance or from InfoUSA telephone database(listing most recent record).
-'
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Aames Capital Corporation
-vs.
Paul R. Harris alkfa Paul R. Harris JR
And Cynthia L. Harris and The United
States of America
In the Court of Common Pleas of
Cumberland County, pennsylvania
No. 1998.3374 Civil
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law. says on October 9,2000 at
I :10 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the
property of Paul R. Harris alkfa Paul Harris JR and Cynthia Harris located at 1106 Easy Road, Carlisle,
Cumberland County, Pennsylvania, according to law.
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 manner: The Sheriff mailed a notice of the pendency of
the action to one ofthe within named defendants to wit; Paul R. Harris, JR by Certified Mail Return
Receipt Requested, Restricted Delivery, Deliver To Addressee Only to his last known address 1106 Easy
Road, Carlisle, Penusylvania. This letter was mailed under the date of October 12,2000 and returned to the
Sheriffs Office on October 17,2000 with reason checked Moved Len No Forwarding Address.
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 manner: The Sheriffmailed a notice of the pendency of
the action to one of the within named defendants to wit: Cynthia L. Harris by Certified Mail Return Receipt
Requested, Restricted Delivery, Deliver To Addressee Only to her last known address P.O. Box 1098,
Carlisle, Pennsylvania. This leller was mailed under the date of October 12, 2000 and returned to the
Sheriffs Office on October 31, 200 with reason checked Unclaimed.
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 manner: The Sheriff mailed a notice of the pendency of
the action by regular mail to one of the within named defendants to wit: Paul R. Harris, Jr. to his last known
address 1106 Easy Road, Carlisle, Pennsylvania. This letter was mailed under the date of October 18, 2000
and never returned to the 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 manner: The Sheriff mailed a notice of the pendency of
the action by regular mail to one of the within named defendants to wit: Cynthia L. Harris to her last known
address P.O. Box 1098, Carlisle, Pennsylvania. This letter was mailed under the date ofOetober 31, 2000
and never returned to the Sheriffs Office,
Timothy R. Reitz, Deputy Sheirffwho being duly sworn according to law, says on November 29,2000
at 8:40 O'clock P.M. EST, he served a true copy of Real Estate Writ Notice Poster and Description in the
above entitled action upon one of the within named defendants to wit: Cynthia L. Harris, by making known
unto Cynthia L. Harris at 916 Scottish Drive, Mechanicsburg, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and attested copies ofthe same.
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S ,,-- ."'_.f...r;t",";I...,......~.-f._ .d' ,!...~....',..J,.'..
o.answer . .,.. , . '? .'. .
. ,
R. Thomas Kline, Sheriff
Byk.;Jt;a-
Real Estate Deputy
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AAMES CAPITAL CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
PAUL R. HARRIS A/K/A PAUL R.
HARRIS, JR. AND CYNTHIA L. HARRIS
AND THE UNITED STATES OF AMERICA: NO. 1998 3374 CIVIL
DEFENDANTS IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I a e dep sited in the U.S. Mails at
Harrisburg, Pennsylvania on 0 0 , a true and correct
copy of the Notice of Sale 0 Real Esta e pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders of record by
regular first class mail (Certificate of Mailing form in compliance
with U.S. Postal Form 3817 is attached hereto as evidence), and
also to the Defendants by Certified Mail. Service addresses are as
follows:
Paul R. Harris a/k/a
Paul R. Harris, Jr.
1106 Easy Road
Carlisle, PA 17013
Thanas J. wiJ.lians, Esquire
10 E. High Street
Carlisle, PA 17013
Cynthia L. Harris
1106 Easy Road
Carlisle, PA 17013
Dennis A. Knaub
c/o Hanover Auto Works
519 South Hanover Street
Carlisle, PA 17013
CamDnwealth of Pennsylvania
Department of Revenue
Bureau of Carpliance
Dept. 280946
Harrisburg, PA 17128-0946
U.S. Attorney's Office
Tenth & Constitution Avenue N.W.
Main Justice Building-Room 5111
Washington, D.C. 20530
U.S. Attorney's Office
Federal Building
228 Walnut Street
Harrisburg, PA 17108
CuIlIUl.wcalth of Pennsylvania
Dept. of Revenue
Box 8940
Harrisburg, PA 17105
Internal Revenue Service
Federated Investors Tower
13th Floor - Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
U. S. Treasury Department
P. O. Box 12051
Philadelphia, PA 19105
Coastal Federal Mortgage Co.
300 Craig Road
Manalapan, NJ
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U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
U.S. Attorney's Office
Federal Building
228 Walnut Street
Harrisburg, PA 17108
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
One piece of ordinary mail addressed to:
Internal Revenue Service
Federated Investors Tower
13th Floor - Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
Postmark:
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Postage:
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One piece of ordinary mail addressed to:
U. S. Treasury Department
F. O. Box 12051
Philadelphia, PA 19105
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Aames Capital Corporal ion
-vs-
Paul R. Hurris nlk/a Paul R. Harris JR
And Cynthia L. Harris and The United
Stales of America
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1998-3374 Civil
Richard E. Smith, Deputy Sheriff. who being doly sworn according 10 law. says on October 9, 2000 at
1:10 o'clock P,M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the
property of Paul R, Harris nIkIa Paul Harris JR and Cynlhia Harris located at 1106 Easy Road, Carlisle,
Cumberland County, Penasylvania, according to law.
R. Thomas Kline, Sheriff. who being duly sworn according to law says he served the above Real Estate
Writ Notice Posler and Description in the following manner: The SherilTmailed a nolice of the pendency of
the action to one of the within named defendants to wit: Paul R. Harris, JR by Certified Mail Return
Receipt Requested, Restricled Delivery, Deliver To Addressee Only to his last known address 1106 Easy
Road, Carlisle, Pennsylvania. This lelterwas mailed under the date of October 12,2000 and returned to the
Sherifrs Office on October 17,2000 with reason checked Moved Left No Forwarding Address,
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 manner: The Sheriff mailed a notice oflhe pcndency of
the action to one of the within namcd defendants to wit: Cynthia L. Harris by Certified Mail Return Receipt
Requested, Restricted Delivery, Deliver To Addressee Only to her last known address 1',0. Box 1098,
Carlisle, Pennsylvania, This letter was mailed under the dale of October 12, 2000 and relurned 10 the
Sherifrs Office on October 31,200 with reason checked Unclaimed,
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 manner: The SherilTmailed a notice of the pendency of
lhe action by regular mail to one of the within named defendants to wit: Paul R. Harris, Jr, to his last known
address 1106 Easy Road, Carlisle, Pennsylvania. This letter was mailed under the date of October 18,2000
and never returned to the SheriIT's Office
R, Thomas Kline, SherilTwho being duly sworn according to law, says he served the above Real Estate
Writ Notice Poster and Description in the following manner: The SherilTmailed a notice orthe pendency of
the action by regular mail tn one of the within named defendants to wit: Cynthia L. Harris to her last known
address P.O. Box 1098, Carlisle, Pennsylvania. This letter was mailed under the date ofOclober 31,2000
and never returned to the Sherifrs Office,
Timothy R, Reitz, Deputy Sheirffwho being duly sworn according to law, says on November 29, 2000
a18:40 O'clock P.M. EST, he served a true copy of Real Estate Writ Notice Poster and Description in the
above enlitled action upon one of the within named defendants to wit: Cynthia L. Harris, by making known
nnto Cynthia L. Harris at 916 Scottish Drive, Mechanicsburg, Cumberland County, Pennsylvania, its
contents and at the same time handing to her pcrsonally the said true and attested copies of the same.
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 above described premises al public venue or outcry on January
10,2001 at 10: 00 o'clock A.M. EST at Court House, Carlisle, Cumberland County, Pennsylvania and sold
the same for the sum of$ 1,00 to Jill Winkea for Aames Capital Corporation, It being the higheslbid and
best price quoted for the same Aames Capita; Corporation of 350 S Grand A venue, Los Angeles CA being
the buyer in this execution paid to SherilT R, Thomas Kline the sum of$ 734,02 it being costs.
SheriIT's Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
County
Certified Mail
Mileage
Surcharge
30.00
13,80
15,00
15,00
30.00
10.00
1.00
13.89
14.88
30,00
."_._.._-"..:-~.-....-
,
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PAUL R. HARRIS A/K/A PAUL R. HARRIS, JR. AND
CYNTHIA L. HARRIS
A SCHEDULE OF DISTRIBUTION, being a list of the persons andlor
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (lO) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you. .
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 567. Appreved May 16, 1929
Commonwealth of Pennsylvania, County 01 Dauphin) ss
James L. Clark bolng duly sworn according to law, deposes and says:
,.,'<~'e!,~~,.Da'L'ESTAn: SAIJ!No.39'i'J';,1:{i,','
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i!/f,'[m' ;!rcl.ll"'U " ~~'~'AI~.;"..iW'",il.
t:.'f;~'-~'': J;:1", n ,il~UAU'I l'IVI.'-i'~'H,f'ij-
1';6;M::_~.J~i'P\'1'AttY;' u.enP:HaUor'.I;;'{';'_:});';,' .
.'.""'."!}.'~;~.~i~"O' E'.se.. A~. ~.ON'..l'.!"."'.'.""''',''''''
;;~\.i~'iiiAT'ciRTA1Wir' 'ofli~d.)liti;'it1ij,;
'~~);\Fl.j'!dofd,';\rii; . ~lp;~;C\lmbtrl.lnd
'COunlY::Pennsyl~anla,. .und'~'and~. cscrl!><d
!"~fdlnl( lo'lli. .f!t1a~ SubdIVIsion,' Plan, for
'.Cliirles';E;I.GlllauS!i.'datiMAujilst'lWo19&5 .'
., i'piip'i\'td,'lif/,!:liry>'ItN.ldlingtr,1oR,S""arid'
',:. ided1rfth":Ofl\','!iif'lli..ReiOider.:of,'
i.~JI$9'~~~.',~.,,~~fi~I.~o'~~~"~' '.:,'~,'
';~~~G;ftliiii"n.i\l1~~.X~{i'lri~i~j.;i.
" '48Hisy;'Riiid,';'whlch/'~lril}Ii're mi1<<d
" "28O'00'(et't'from'ih;'ii:,;tCtllriilnt'riKlionof "
the sold Easy Road .with L.R..21033; then .Iong
I.arid;~ow.,o.r. fo.""erIYi.oL.lhe. Ch"I"E,lrlo'.. Publisher's Receipt for Advertising Cost
Glllaush;et,u~',An~;:E'8enel;RoI7.: .I,ux.; .
'5<!ulhJ8 ~efnm'.I0.mlnu!" E,l1~~.18 feet>., publisher of The Patriot.News and The Sundav Palrlot-News, newspapers of general
1~;;.~~n,.V%~~':l;n~~~"sI',~eS::f~~e receipt of the aforesaid notice and pubiication costs and certifies that the same have
. mln.I" Wes~131IX!f..tlo'anlron pin; then
a.lonS.land. .now.or. f9rni'.,ly..f J.... tons.
Noft~'J8 d~! )0, .o' l1utes,W~q52.18 feet,
10. a nail on the cenl. line of the, sold Easy
'Rnadthenalong,!ild, , ledlnei,North 62
degrees 10 minu~ '13100 feet 10, ~ ~al~ .
thepolnlandplace'018 GINNING..... .'
BEING Lot';.M.'.rthi'I"",,".reler,nced . Plan
. .nd ,.contalnlriIiY"'l'M';iq.u.. a.'..... '.:r.iet.. . ".Be. lng,
known ,,1106 E,'ll'Jd:'" <:,.';":"":,'
TO BE SOLD ..t~.~iiip;rtyoll'aUI Illlam;
"o'lkl. l'aulo'R.llarrls; Jr,i,and Cynthia L lIarris
.' ~i4C~I:i~!!~~iE!lI\~~iJudSl1\e~I, No, .1998
. '!PARCEl.:j~9C,'!'..:",'
. ,'.,.,';" ,<," ",',~"~.' ,.'I,~l~";'...._ ".:, .>:.
That he Is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania. with Its principal office and place of business at 612 to 616
Markel Street, In the City of Harrisburg. County of Dauphin. State of Pennsylvania, owner and publisher of 1M
p'atrlot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 612 10 618
Market Street, In the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1654. and September 16th, 1949, respectively, and all have been continuously published
ever since;
That lhe printed notice or publication which Is securely attached hereto is exactly as printed and published In
their regular dally and/or Sunday/ Metro editions which appeared on the 31 st day of October and the 7th and 14th
day(s) of November 2000. That neither he nor said Company Is Interested In ths subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal Ilnowledge of the facts aforesaid and Is duiy authorized and empowered to verify this
statement on bshalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds In and for said County of Dauphin riscSllaneous Book "M",
';'~: ~~;~~~. ,:;,,;;;;.;;;;;;;;;g;;;L;,;;;,;;;;;;;;;;....;;~.....;;;;.;.o.
s A'L E #39 Notarial Sool 7J .I ~
Tony L. Russell, Notary PIJbtlc <'
Harrisburg, Dauphin County
My Commission ExpIres June 6, 2002
Mnmber. Pennsylvania Assoclotion 01 Notaries My commission expires June 6, 2002
CUMBERLAND COUN1Y SHERIFFS OFFICE
CUMBERLAND COUN1Y COURTl10USE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$
$
$
179.25
1.50
160.75
By....................................................................
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATEOFPENNSYLVANIA :
SS.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 27, NOVEMBER 3, 10,2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO. 39
~--
Roger M. Morgenthal, Editor
Wrtt No. 199a-3374 Civil
Aames Capital Corporation
VS.
Paul R. Harris A/K/ A Paul R.
Harris. JR. and CynthIa L. Harris
and The United States of Amertca
SWORN TO AND SUBSCRIBED before me this
10 day of NOVEMBER. 2000
i
I
1 Atty.: Leon P. Haller
. LEGAL DESCRIPTION
I ALL THAT CERTAIN tract ofland.
\ suuate in Lower Frankford Town.
I ship. Cumberland County. pennsyl-
: vanta, bounded and described ac-
. cording to the Final subdivision Plan
, for Charles E. GllIaugh dated Au-
. gust 20. 19a5 prepared by Larry
V. Neldllnger. R.S. and recorded In
the Office of U,e Recorder of Deeds
....,,..........."....1...,..'" r,...~nt" h., P'~n Rnnk
_---Notary;-
NOilStl/\L :tEAl
LOIS E. SNYOER. ~lololY Public
Cartir.IQ Bora, Cumberland County, PA
My Commiuion Expiros March 5. 2001.
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U. S. Treasury Department
P. O. Box 12051
Philadelphia, PA 19105
4. Name and address of last recorded holder of every mortgage
of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) :
Coastal Federal Mortgage Co.
300 Craig Road
Manalapan, NJ
5. Name and address of every other person who has any record
lien on the property: UNKNOWN
6.
interest
sale:
Name and address of
in the property and
UNKNOWN
every other person who has any record
whose interest may be affected by the
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale: TENANTS IF ANY ...
Regine Kilmel a/k/a
Regina Kilmek
1106 Easy Road
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
Dorothy L. Mott, Esquire
114 South Street
Harrisburg, PA 17101
Markian R. Slobodian, Esquire
901 North Second Street
P. O. Box 11967
Harrisburg, PA 17108-1967
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavi "re true and
correct to the best of my personal knowledge, informat' n and belief.
I understand that false statemen~s herein are m subject to the
penalties of 18 PA C.S. Section 49 relatin n orn falsification
to authorities. ~
Leon P. aller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102 (717) 234-4178
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PAUL R. HARRIS A/K/A PAUL R. HARRIS, JR. AND
CYNTHIA L. HARRIS
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of. Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
!
L I
,;
Court of Common pleas of the within COUllty to IHlt 01'11 <I.. th.. nale
for a grossly inadequate price or for other prop..r' C,HI/I'" Thin
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IO DELIVERED.
3. A petition or petitions raising tll(! 1..C/,,1 i II II 1I ()I 1 or l'l~,htll
mentioned in the preceding paragrapho Illllnt be pn::lclltcd to the
Court of Common Pleas of the within Coullty. The p,,1; ltlOll IIIUllt be
served on the attorney for the creditor 01' 011 the cnJdltor before
presentation to the court and a propooed order or: rule lIIuut be
attached to the petition.
If a specific return date is deuired, IIlIch datu lIIunt be
obtained from the Court Administrator'oOffleo - civil Dlvioion, of
the within County Courthouse, before a prcULJlltiltloll of the petition
to the Court.
A copy of the Writ of Execution io L1ttilClwd hel:eto.
PURCELl., KHUG & IlM,Llm
Attorneyu for Plaintiff
1719 North Front Street
Harrisburg, l'A 17l.02
(71'1) 234 -4178
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In The Court of Common Pleas of Cumberland County, Pennsylvania
.;
Aames Capital Corporation
VS,
Paul Harris et al
Serve: United States of America
No. 98
3374 civil
19_
Now, June 17
Dauphin
19 9,~ SHERIFF OF CUMBERLAND COUNTY, PA do herebv deputize the Sheriffof
- .
County to execute this Writ, this deputation being mode at the request and risk of the Plaintiff.
~~~
SherifforCumberlnnd COUn!)', Po.
Affidavit of Service
Now,
within
19
0' clock
M, served the
, at
upon
at
by handing to
attested copy of the original
the contents thereof.
o true and
and mode known to
So answers,
Sheriff of
Coun!)', Po.
COSTS
Sworn and subscribed before
me this
19_
SERVICE
MILEAGE
AFFIDA VIT
s
day of
s
AAMES CAPITAL CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS, CIVIL ACTION - LAW
PAUL R. HARRIS A/K/A PAUL R.
HARRIS, JR. AND CYNTHIA L. HARRIS
AND THE UNITED STATES OF AMERICA: NO. 1998 3374 CIVIL
DEFENDANTS IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public in and for said
Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly
sworn according to law deposes and states that the Defendant (s)
above named are not in the Military or Naval Service nor are they
engaged in any way which would bring them within the Soldiers and
Sailors Relief Act of 1940, as amended.
Sworn to and subs~ribed :
befor~/me .this 0 d~y:
of ~~;I(.;';Cil.9 Y'd' :
LEON P. HALLER, ESQUIRE
NOTARIAL SEAL
MARYLAND K. FERRETTI, Notary Public
LOWER PAXTONTWP., DAUPHIN County
My Commission ExplrasAUGUST 8, 2002
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AAMES CAPITAL CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
PAUL R. HARRIS A/K/A PAUL R.
HARRIS, JR. AND CYNTHIA L. HARRIS
AND THE UNITED STATES OF AMERICA:
DEFENDANTS
NO. 1998 3374 CIVIL
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on AUGUST 6, 1998 I served the Ten Day
Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
~
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Leon P. Haller PA I.D.
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
#15700
AAMES CAPITAL CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
PAUL R. HARRIS A/K/A PAUL R.
HARRIS, JR. AND CYNTHIA L. HARRIS
AND THE UNITED STATES OF AMERICA: NO. 1998 3374 CIVIL
DEFENDANTS IN MORTGAGE FORECLOSURE
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
P.R.C.p. 3180-3183
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter on the real estate
located at 1106 EASY ROAD, CARLISLE, PA as follows:
Amount due pursuant to Judgment
$ 292,644.05 ./
Interest
(Per diem of $71. 50 from
7/1/98 to 12/9/98)
$ 11,511.50
Late Charges at $251.26
(7/98 to 12/98)
$
$
1,256.30
Escrow deficit
1.500.00
TOTAL WRIT
$ 306,911.85**
** Together with any additional interest, charges and costs to the
date of Sheriff's Sale.
By
Dated: September 8, 1998
LEON P. HALLER I.D. #15700
ATTORNEY FOR PLAINTIFF
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attached is a description of the real estate.
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4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
coastal Federal Mortgage Co.
300 Craig Road
Manalapan, NJ
5. Name and address of every other person who has any record
lien on the property: UNKNOWN
6 .
interest
sale:
Name and address of
in the property and
UNKNOWN
every other person who has any record
whose interest may be affected by the
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS IF ANY
Regine Kilmel a/k/a
Regina Kilmek
1106 Easy Road
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated,)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of 18 PA C.S. Section 4904 relatin 0 unsworn
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: September 8, 1998
"
"
PAUL R. HARRIS A/K/A PAUL R. HARRIS, JR. AND
CYNTHIA L. HARRIS
A SCHEDULE OF DISTRIBUTION, being a list of the persons andlor
governmental or corporate entities Qr agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
,
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PAUL R. HARRIS A/K/A PAUL R. HARRIS, JR. AND
CYNTHIA L. HARRIS
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities Qr agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. I f you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
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4. Name and address of last recorded holder of every moz:l:!;lll\ge
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
coastal Federal Mortgage Co.
300 Craig Road
Manalapan, NJ
5. Name and address of every other person who has any record
lien on the property: UNKNOWN
6.
interest
sale:
Name and address of
in the property and
UNKNOWN
every other person who has any record
whose interest may be affected by the
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS IF ANY
Regine Kilmel a/k/a
Regina Kilmek
1106 Easy Road
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
Cu~BERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information "y,d
belief. I understand that false statements herein are made subject:
to the penalties of 18 PA C.S. Section 4904 relatin 0 unBworn
falsification to authorities.
~
Leon P. Haller PA I.D.Wl5'700
purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: September 8, 1998
REAL ESTATE SALE i~o. 35 .
Gn ~~.k )1. f91Y, the sheriff levied upon the defeoo211t.1
tntefGst in the feal property sHuated in t, ..;..e.(.. ;:;.~~ ~7'
Cumberland Countl', Pa., known and numbered as:j!t1(. Ea/(yfJ,..L
(),Al..1.J!,-- and mWJ fully dBSCrlb:lti on Exhibit ....A.. filed wi~1
this writ and by this mference incorporated herein.
~a'A.I2;aj;>>L/I. 197A BY:~~. ~JJ2LZ{. ~
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JOliN W. I'URCEI.L
1I0WAR!) Il. KRUG
l.EON J'. IIAl.LER
JOliN W. PURCELL JI(.
ORlAN J. TYLER
JIl.1. M. WINEKA
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
IIARRISDURG. PENNSYLVANIA 17102-2392
TELEPHONE(717) 234-4178
PORECLOSURE DEPT. PAX (717) 234-1206
JOSEPH NISSLEY (1910.1962)
ANTHONY DiSANTO
OF CO' JNSEL
HERSHEY
1099 GOVERNOR ROAD
(7171533-3636
NOTICE TO:
Paul R. Harris a/k/a
Paul R. Harris, Jr.
1106 Easy Road
Carlisle, PA 17013
Cynthia L. Harris
ll06 Easy Road
Carlisle, PA 17013
U.S. Attorney's Office
Tenth << Constitution Avenue N.W.
Main Justice Building-Room 5111
Washington, D.C. 20530
U.S. Attorney's Office
Federal Building
228 Walnut Street
Harrisburg, PA 17108
Chief-Special Procedures
Internal Revenue Service
P.O. Box 12051
Philadelphia, PA 19105
Coastal Federal Mortgage Co.
300 Craig Road
Manalapan, NJ
Regine Kilmel a/k/a
Regina Kilmek
1106 Easy Road
Carlisle, PA 17013
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached
hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
~ES CAPITAL CORPORATION,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
PAUL R. HARRIS A/KIA PAUL R.
HARRIS, JR. AND CYNTHIA L. HARRIS
AND THE UNITED STATES OF AMERICA:
DEPENDANTS
NO. 1998 3374 CIVIL
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF .CIVIL PROCEDURE 3129
T~.KE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: Wednesday, December 9, 1998
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner'S Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
1106 Easy Road
Carlisle
Cumberland County, Pennsylvania
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
No. 98 3374 Civil
is:
THE NAME (S) OF THE OWNER (8) OR REPUTED OWNERS of this property
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, situate in Lower Frankford Township, Cumberland
County. Pennsylvania, bounded and described according to the Final Subdivision Plan for
Charles E. GilIaugh dated August 20, 1985 prepared by Larry V. Neidlinger, R.S. and
recorded in the Office of the Recorder of Deeds of Cumberland County in Plan Book 48,
Page 99, as follows:
BEGINNING at a nail in the center line of T -487 - Easy Road, which point is referenced
280.00 feet from the center line intersection of the said Easy Road with L.R. 21033; then
along land now or fonnerly of the Charles Earl Gillaugh, et ux. and Eugene I. Rotz, et. lIX.,
South 38 degrees 10 minutes East, 252.28 feet to an iron pin; then along other lands now or
formerly of the same, South 52 degrees 10 minutes West, 132.00 feet to an iron pin; then
along land now or fonnerly of Jesse Long, North 38 degrees 10 minutes West, 252.28 feet
10 a nail on the center line of the said Easy Road; then along said center line, North 62
degrees 10 minutes East, 132.00 feet to a nail, the point and place of BEGINNING.
BEING Lot 114 of the above-referenced Plan and containing 30,000 square feet. Being
known as 1106 Easy Road.
TO BE SOLD AS THE PROPERTY OF PAUL R. HARRIS A/K/A PAUL R
HARRIS, JR. AND CYNTHIA L. HARRIS ON CUMBERLAND COUNTY JUDGMENT NO:
1998 3374 CIVIL.
PARCEL: 14-05-0423-039C
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LEOS P. IIALLER
JOIIS W. PURCEI.I. JII.
\'ALEIIIE A. GllSS
JII.L ~I, WISt:KA
LAW OFFICES
PURCEU, KRUG AND lW.LER
1719 NORTH FRONT STREET
HARRISIIURG. PENNSYLVANIA 17102-2392
TELEPHONE 17171 23~-117H
FORECLOSURE DEIYr. FAX (717) 23~.1206
JOSEPH NISSLEV ltI10.BIIJ2,
ANTHONY OISANTO
OF COUNSEL
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HERSHEY
1099 GOVERNOR ROAD
(717) 533-3831
District Director
Internal Revenue Service
P.O. Box 12051
Philadelphia, Pennsylvania 19105
Attention: Chief - Special Procedures Section
Re: AAMES Capital Corporation vs.
Paul R. Harris alkla Paul R. Harris, Jr.
Cynthia L. Harris and U.S.A.
In the Court of Common Pleas
Cumberland County, Pennsylvania
No. 1998 3374 Civil
NOTICE TO THE UNITED STATES OF AMERICA
OF NON-JUDICIAL SALE OF PROPERTY
SUBJECT TO TAX LIEN
1. Attached is a copy of the Notice of Federal Tax Lien (Form
668) marked Exhibit "A".
Exhibit "A"
(a) District - Philadelphia, PA
(b) Serial No. - 239736123
(c) Name of Taxpayer - Paul R. Harris, Jr. and
Cynthia L. Harris
(d) Address -202 Silver Spring, Mechanicsburg, PA 17055
(e) Date and Place filed -Prothonotary of Cumberland
County, Pennsylvania, to No. 97-6890 FTL on 11/27/97.
2. Sale Information
PAUL R. HARRIS A/K/A PAUL R. HARRIS, JR. AND
CYNTHIA L. HARRIS
A SCHEDULE OF DISTRIBUTION, being a list of the persons andlor
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights, If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania l70l3
Phone (717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
l. You may file a petition-with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
. \
GEP 08 19.0.P
Re:
Z 383 560 608
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AAMES vs. Paul and Cynthia Harris
Cumberland County Sale 12/9/98
IRS 25 Day Notice
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