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Home My WebLink About98-06021 /' ~- " ~ "~ . . .' .. <; r- "\" " . ., ...... , ...~ " \)o.~,... , -.. ~" +:.:. .. c ~~.... ..... ~.J "'- -~ -- \0 f ... \J ...... ....... .- .. '.' 1'( -'"" ~ \ L....J a- ~. GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VEL JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. lL GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA), 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 4823 BRIAN ROAD, MECHANICSBURG, PA 17055. 1. Name and address oE Owner(s) or reputed Owner(s): NAr~E LAST KNO;IN ADDRESS (i f add~-ess cannot be reasonably ascel.t~ill0d, please so indicate) JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 2. Name and address oE Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE .. ,1. Name and dddn~:H_; ol till' ,'I;;l- l'I"'ot'd"d !~, lrl..!- (,~ ,"/el'Y mOI'lcJ.:lej'> uf r('('unl: tJAME L^~;T r:NO~'n! ld)Dl~ ESS (i f (Ide! r(~SE; Cdllnul !II' !(',l:;Ull,IIJly ,1:;c('rtd.inC:!d, p 1 '_',:1:.;'_' :;" ::. l: ' I ~ ' ;tST_l1ARYLAND~~J5~O~!,_... ATTN: 501-341 199 MITCH.E.L..k..-ROA!1 MILLSBORQ, DE 19966 S. N:tmp ,lnrl ,1rlrlrp~Hi of (lV"l",! nrh.'~' p('r;~r);l ~,'/110 has any r0cord 1 ien : : ~. - . ~ : j' .: ~ NAME LAST KN0"1!0 [d)!)EESS (i [ address cunnal De reasonubly ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KN0'IN ADDEESS (i [ address cannot be reasonably ascertained, please so indicate) NONE 7. Name aCld address of every other person whom the plaintiff has knowledge who has any interest in the property ",hich may be affected by the sale: NAME LAST KNO\'IN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 4823 BRIAN ROAD MECHANICSBURG. PA 17055 DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE. PA 17013 HAMPDEN TOWNSHIP 230 S. SPORTING HILL ROAD MECHANICSBURG. PA I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 8. 1999 DATE fRANK FEDE MAN, ESQUIEE Attorney or Plaintiff . ~ . .~ cc !O . . . . ~ , ~ . .. - & 2 ' t li : _;; t . E 0 ~ is ~ .. " - ...,..,/ ..... 0::" 0 '-'" .. ~ '.- I it" ,1.- 1_ :. . ,'. I , " ,::-1 . ,'./) ,..... .' .-J'-~:~ii- -."7~~~2.. /" --~.~-. /- ....;.: -~~,.. ,s. . .~~ OQ J0<l ~ ~ .;. -J ... ',.;, ex g ~..:t '.'.f~' :E d ~.":\ r?.'::' ~\.. '" u..~~()~..J ('" o .~v ~lV' "<-{> ('~) .:-;., ~{,I W Z .\~ I ') ~ g ...,.... .~';.. ~.~ <(~ <{;:... .~... ~~rr ,'.; LL w... ' - .. .... z~ a: ;;~ w z. () ~~ -" . , ffl~ w'z ~ g~ ffi :s~ ~ .z ~ o. :! ~~ ~ ~~ " ~- 0~~ j ~g: "j" :!-. : ~ .~. 'I :1 " ::..... . (:)0 2Z -~ -,w _0 <0 :E:d < 11.' O~ < WZ ....2 <~ c.JZ -.. u.. 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", ~~. !!;'I~~ ,1:3\ ~~ ~ .......tt> I~ '(-,o 0 a:lo; ~ .'J0-4"" w......... _ :::f-l- c.J~:g .., I ~:'i ~: 9" i~ :!~ E ~Ig~ li~o ~~ ~ a:::J fH ~I~! ~ ~\ to ~~ <1:'"'0 XI'" 8 :;;~::;~QcG ~ ~ ~9 ~ I · VI ~t; ~ 6 :J ~g: '.) '" '" '" :;; :; ,..: '" M E <; ~ Vl "- .. <>: 0.. " w ,..., <n H ~ ! '~ . I ,: .. ',\' Ii I .' .. '" '" '" ;;; ;; ,..: '" M E <; ~ Vl "- , -' ~ h n . ... ~~,j' " - tJ 9 a c is;:;~;';'7 oq; ~ :1 I~ "",; - iE..: 1,. .., 1('..11"",.'("" ~.._,..'f' ":r: :l.;:'l..:_~_.,:~-J~.. ~~ ,,';; r--:-.~':_"_-:=,,,;:::- :--.-._)....~ )3ao,Q.~ ~.--" ~:;-'~~ ./'" ~,'I>' ~\. "', ,,~\ ,'.11 "''''. ~",'!> . 'J'c~~ <)~.. ~ .:' / ~'?~~~ i:-~" ~ "- / .\':l ..~~ . " '~1>,) <<"'''' \.t>...,"" " i:< '" '" '" w .., '" '" '" ;;; ;; ,..: '" M E <; ~ Vl "- . (:)0 ZZ -~ ....w ct~ :;;= . u... o~ . WZ ....2 <~ ~~a: u.. Ww - ~~ .... z~ -. a: e. W z. c.J .~ uO -" ., ~~ w Z5z ~ 0;2 >~~ ffi ov> VI 10.:: ~ o~ . Wo :n ~... ~ ~Q lI!:te; :J::!g: " 9 o ~ !l!! E<=l ~ ~ ~ . .. ~ e ~~ . ..'" 5 '" ;; ~ ~ '" 0.: '" . '" '" E ~ '" ;;; N c co ;; ~ , ... ,..: .. . '" . M . . E . <; , 0 ~ Vl "- , \ ~ . :,1 r: < ~ L'. . -. . CJ a- '" rtJ rtJ rtJ TT1 "" a- 0. } POSTMARK uR DIlE / .;/ I~ ~ w > Z "' ... o .. o ~ :; a: "' ~ u ;: '" "' u " ~ .. ).. ,c \\'\ .:.,." "' z :: e: o .. ~ ---------------.~4t-------- SE>.jT TC} ',.) " . ~"''- . fl.",' 'i,'" ,,'. "'. ' , ..~".:.~;.:,.~T,~,',::A, YAll - -- - - - - - - - - - - - - -- -- ."-- - -- .., a- '" rtJ rtJ rtJ TT1 "" a- 0. Jt.FF9,.."T ~. A1l.:lOLD. ~R. 7 COL~~LA AVnSU~ ~~~ HIL~. PA 1701l F)S F,.~;:-:;:<1 ~'::':': U:-i P::S:::I S\:r'lICe IJ'lY'K Receipt for Certified Mail ..} I . ........ lt~ '," ,"-'u""'l ,. '~u.[.'Al>" ~.,.~ ',.Go:; - .,'";~, '<':~~~;;;',A:;;:'~L- '~'_ 'Osr.~ARK OR DATE ': SE~I: F~ I , /J.YCE A. AllNll'.fJ, ^/</A ALYCE A. A.~,O~. ,~., A/,;/A .u.1CI, .~. M.m:.D, .!.\.it..i.\ .u.ll..t: r\. id.~oiJ\l!.'\.o~ 31), CIl:::STiilJ'T S'ltl.h'l C~t.""..? ,lli.~, PA 1/01.:. \ \~- -~. r:K) f' -:'Fi,': US :::;~:::," S-::i'Jlce , .K Receipt for Certified Mail o ~ w ~ o ~ "'~ >~ zw we: ...e oe " "'- .':J;=: ~= ~~ tu: ~c !d~ Vi2 ~2 <~ ~= ... "' z :: e: o .. ~ -- - - ._- -- -- - - - - - - - - -- I , r l ( , 6. The following amounts arc due on the mortgage: Principal Balance Interest 3/1/98 through 8/1/98 (Per Diem $17.63) Attorney's Fcc::; Cumulative Late Charges 9/21/92 to 8/1/98 Cost of Suit and Title Search $85,822.42 2,715.02 4,291.00 13 0.68 550.00 Subtotal 93,509.12 Escrow Credit Deficit 0.00 516.08 Subtotal 516.08 TOTAL $94,025.20 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. Defendants' Application for Assistance under Act 91 of 1983 has been rejected by the pennsylvaia Housing Finance Agency, a copy of which rejection is attached hereto as Exhibit "B". 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. 5 1692 et seg. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in ;,ritinq \;ithin thirty (3D) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) ;,ith ;,ritten 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 an in rem Judgment against the Defendant(s) in the sum of $94,025.20, together with interest from 8/1/98 at the rate of $17.63 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. '}~J :r~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff NOTICr: or INTENTION TO rORECLOSr: AND ACCELERATr: LOAN BALANCE DATE: June 22 I t 998 CERTlrIED MAIL NO. P RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220437842 4823 BRIAN ROAD MECHANICSBURG, PA 17055-3014 TO: JEFFREY E. ARNOLD SR 4823 BRIAN ROAD MECHANICSBURG, PA 17055-3014 This company is the holder of the FIRST MORTGAGE (AND NOTE) premises, or is the mortgage service agent for such holder. referred to as we, us or ours). on the above ( Hereinafter As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the April I, 1998 and subsequent monthly payments as listed, and/or for other reasons as indicated below:* 3 payments @ $793.56 $2,380.68 Accrued late charges................ .............. .$65.34 NSF Check Fees.................... . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date.. .. . . . .. .. . . .. ... .. .. $0.00 ~ Less available suspense credits.................. .$344.42 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,101.60 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780 Waterloo, IA 50704-0780.. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is net made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay t:XHIBJT A DMS5-BRCHPA (Page 1 of 2) -. Junl~ ~~. 11)lJK PilKI~ 2 220/d nv./ off tht~ d(~ht. I f W(~ P!fl!r YOllf C.I~(~ to our ilttornt!Ys. but you cUrt! the default t}ldon! tlwy tW,lopn 11~Kill procl!(!dinK5 iIX,'Iln~a you. you will stiLl havl! to pity lhf! r(!i1snn,lhl(~ ;Illorrwy'~; rl"'s, ilGtll<llly incurp!d. up to $50.00. However, if ingal procnedin~s arc started agai.nst you, you will lU.lvl! tu pay the reasonable attorney 5 fees even if they are over $50.00. Any attorney's fees will bl! added to whatever you owe us, which may also include our reasonable costs. [f you cure the defauLt within the thirty day period, you will not be required to pay attorney's fees. Remember you arc also responsible for keeping all real C5tate taxes current. We may also sue you personally for the unpaid balance and all other sums due under the mortgage. I~ you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then dUCt as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held ~ould be approximately one-hundred and fifty (150) days from the date of this letter. A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will then increase the longer you wait. You may find out at any time exactly ~hat the required payment ~ill be by calling us at the follo~ing number: 1-800-850-4622. The payment must be in cash I cashier's check, certified check or money order and made payable to us at the address previously stated. You should realize that a Sheriff's sale ~ill end your o~nership of the mortgagcd property and your right to remain in it. If you continue to live in the property after the Sheriff's salct a lawsuit could be started to evict you. NOTICE - This is an attempt to collect a debt and any information obtained ~ill be used for that purpose. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS. CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE. (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However I you arc not entitled to this right to cure your default more than three times in any calendar year. EXHJBlT A DMS5-8RCHPA (Page 2 of 2) OUl'ld.'9'" WEU 10::11 FAX .11\1 ~.1t1 .10.1'" ,. .IWJ:.\LT rJJ 0111 .---~-_. aJD4 37 XLI ~ PENNSYLVANIA HOUSING FINANCE AGENCY Homeowners' Emergency Mortgage Assistance Loan Program bxmenu Gener.1 Infurmatlon (7t '7) '7HU-l940 !:..2I!..!:nwtlUl.~e 2101 North Front Street Glloerw.llufnrmattun t_aOO_342._2J9'7 2101 Nonh [1totll Sttc.ct P.O. Box 15206 TDD* l'ar lharlnM Impdrlld (7\7) 780-1869 P.O. Uox 155jO Harri,butU.. PA. 17105-5206 Fax* (71'7) 71:1\-399:5- H.Hrlllburn. PA 17\05.5530 ~ ."tv ,'- Of ,9 G .' 9/0" /t'J9Q GMAC MCR'I'G1\GE CORP COLL&CT~ONS O&PARTMKNT 3~S~ HAMMOND OR PO 50X 780 ~^TGRLOO,~. 50702 SUBJIi:Cr: J\LYCio: A ARlIOL.D "023 BRI;..N an NKCH1\NXCSUUi.lC;, "1\. 1.7U'SS Your app~icll.eion t:or a JiOMBOWNIi:R'S BMSRGSUCY 1!l.ORTC'rAG1i: .,p.,SSJ:STJ\NCF. LOAN han bean OGN"IED pur~uant to Ace 91 of ~~D3, 35 P.S. saction ~68.40~~C DC Qoq, an~/or Agency Guide1~nos 16 PA.Code s~ction 40.101 ~t ~eq. ~or t~" ~o11owin9 rou~onu: ~. No reaHonab~a prosPQct at moregagor rd~umin~ tu~1 mortgugo payments w!chin ~hir~Y'Di~ (36) monthQ and payi.ng mortgagr'll (w1 by muturity ba.&:O~d on: Mort.gagor' 9 inoomb ic. inLlutf i, ci.ce to ma~ntain mortgugQ. 2. No rcaoonab1o pro~poct o~ mortgMgor rOD~ing ~u1~ mortgage puymento w1~hin thirtY-9i~ (361 montho and paying mortga9~(D) by matur~ty badod on: Xn~u~tici~nt income whi10 employed. 3. No roaeonab~e proopect o~ mortgagor reoumin'l fu~1 mortgago payments within ehir~y~cix (36) ~ontns and paying mortgage(ft) by mAturity baQod on: The circumdt~ce&:O do noc quality D~ an Emergency ~or~ga9o Aooi9tKncC situation b~e r~ther an ongoing Qi~uation which 6evurcly limitB th~ probability of resumpeion of pAymcnt~ and p~ym~nt of mo~tgag~ by maturity. You may be ontit~ad to an 4ppeal hearing it you diQ~grce with our d~ci~ion. We mUS~ rec~ive 0. writtlilln X'oquest :eor a hearing within 15 dayo of tho poat;m.3.rk dnt:.o of thia letter. (Appeal requy>>to muot be in wric~ng; a verba~ requeot is noe accCPtab~&). Th~ hearing may b~ con. ductc4 by a telephopO con~orence ca1l: thQre~or~. you mUGt inc1ude your tele~hone numb~r. ~RQqull!!lii:S: u:l:or'-neari.iigs mu-s-C-gt:."li"ee-t11.'iireti""C'Jon no tha.""t.- a. hea.r::ti'ig ""1:D~qu-eritezr ariCf muct coaant:-. first C~A.8, regiotored or certified muil to: C~hief counse1 ~ Hearing Roqucae, PHFA/HEMAr , 2~ol North vront s~reet, P. o. Box ~56~8. Ha~~isburg, Penney~vania 17105-5628. The Agency will aeeempt eo schedule tho hear~n9 with~n thirty (30) dayD after tho requ~Be ia recaivod. Whwn sending your appeal, plea~Q ce oure to prine your name logib1y an~ inc1uce your nocial sliIIcurity nurncer. You have a right to be repreoentoQ by an nteorn~y in connoction with your appoal. If you cannot ~ford ~ attorney you ~y b~ e1i9io1e for Legal serviccG roproGentation. YOU can contact a Lega~ ServiceD repruscnta~ive through the following to11 ~reo numoer 1_800_732-3545, please be aware that 8chuduling an appeal hearing ~o~s not neces~arily sc~y ~or.cloDure procBsdings. D~SCLOSURE OP USE OF ~NFORMAT~ON OBTAINEO FROM OUTS~PE SOURCE: ~. Di~closu~e inapplicub~e. The Federa1 Equal Credit Opportunity Act prohibito arodieoro from di~crim~natin9 agu1nnt credit app1icants on tho b~Gis of race, color, r011gion, nationa1 or~gin, ~ex, marital statue, age (provided ehae tho applicane hOon tho capaci.ty to cpter into II. bin-ding contruct) because a11 or part of the app1icant'B income deriveo ~rcm any public aaQi~tanco program. or because th~ app1icant haa in good faieh oxerci~Qd any right under tho Consumer Credit Protmc- eion Ace. Tho Federal Aganey that adminiotero complianco with ~hio l~w concerning thi~ creditor is the Pedora1 Trade comminnion, Equul credit Opportunity, Wa~hington, D.C. Tho PennGyl...,ania uout;llng Finllnce Agency EXHIBIT "8" <,r DESCHIPTIO'i ALL THAT CERTAIN tra.:t of land with the improvements thercon ere.:ted, situated on the Northwest side of Brian Roac!, Hampden Township, Cumberland County, Pennsylvania, being Lot No.8. Blu.:k E. Plan Nu. 4 uf Del Brook Manor, Plan Buuk II. Page 33. bounded and described in accordance with a Plan of Survey by Gerrit J. Betz Associates. Inc.. dated April 11. 1980 bearing Drawing No. 80-080, as follows, to wit: BEGINNING at a hub on the Northwest sidc of Brian Road (50 feet wide right of way) at a corner of Lot No.7 of the abuve mentiuned Plan of Lots; now or latc of Eugene R. Viccaro, said point being 473.10 fect to interse.:tion of Charles Road and Brian Road; thcnce extending from said beginning point and alung Lut NO.7 North 5 degrees 28 minutcs West 125 feet to a hub at property now or late of Harry M. Weitze; thencc extcnding along samc Nurth 84 dcgrecs 32 minutes East 65 feet to a hub at Lot No.9 uf the above mentioned Plan of Lots now or late of Henry F. Eisenhower; thence extending along same South 5 degrees 28 minutes East 125 feet to a hub on the Northwest side of Brian Ruad. aforementioned; thence extending along same South 84 degrees 32 minutes West 65 feet to the first mentioned hub and place of beginning. 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Sr.. i\lyee 1\. Arnold A/kia Alyce A. Arnold Sr.. aikia Alice A. Arnold. aikia Alice i\. Minahan In the {'OUrl or ('olllultln Pleas or {'umhedand ('ouuty. Peunsyl vania No. 'J8.hIl21 Civillerlll Dawn I ..Kell. Deputy Sherif!'. who hein~ duly sworn aeeordin~ to law. says lln Septemher 28. I I)!)!) at 7:25 0 'cloek P.M. EDS'!'. She posted a copy of Real Estate Writ Notice Poster and Description in the ahove entitled action upon the property of JcITrey E. Arnold and Alyce A. Arnold located at 4823 Brian Road. Mechanieshur~. Cumherland County, Pennsylvania, according to law. Timothy Reitz, Deputy Sherin: who hein~ duly sworn accordin~ to law. says on August 12,1999 at 111:45 o'clock A.M. EDST. he served a copy of Real Estate Writ Notice and Description in the ahove entitled action upon one of the within named defendants to wit: Jeffrey E. Arnold. by making known unto Nancy Beinhower. Mother at 7 Columbia Drive, Camp llill. Cumherland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies o( the same. Timothy Reitz. Deputy Sheriff. who being duly sworn according to law. says on August 20,1999 at 6:28 o'clock P.M. EDST. he served a true copy of Real Estate Writ Notice and Description in the above entitled action upon onc of the within named defendants to wit: Alyce Arnold et al hy making known unto Alyce Arnold at 426 Pawnee Drive, Meehanieshurg, Cumberland County, Pennsylvania. its contcnts and at the same time handing to her personally the said true and attested copies of the same. Michael E. Barrick, Deputy Sherin: who being duly sworn according to law, says on September 3D, 1999 at 6:24 0 'cloek P.M. EDST, he served a copy of Real estate Poster, in the above entitled action upon one of the within named defendants to wit: Jeffrey Arnold, by making known unto Nancy Beinhower, Mother at 7 Columbia Drive, Camp Hill, Cumberland County, Pennsylvania. its contents and at the same time handing to her personally the said true and attested copies of copy of the same. Michael E. Barrick, Deputy Sherin: who being duly sworn according to law, says on September 28, 1999 at 7: 16 0' clock P.M. EDST, he served a copy of Real Estate Poster in the above entitled action upon one of the within named defendants to wit: Alyce A. Arnold et al by making known unto Alyce Arnold at 426 Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania. its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn aecording 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 first class mail to one of the within named defendants to wit: Jeffrey Arnold to his last known address 7 Columbus Drive, Camp Hill, Pennsylvania. This letter was mailed under the date of October I, 1999 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 to one of the withinnamed defendants to wit: Alyee Arnold to her last known address 426 Pawnee Drive, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587. Aooroucd May 16. 1929 Commonwealth of Pennsylvania. County of Dauphin) .0 Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controllor 01 THE PATRIOT.NEWS CO.. a corporation organized and existing under the laws of the Commonweallh of Pennsylvania. with ilS principal office and place 01 business at 812 10818 Market Street. in the Clly of Harrisburg. County of Dauphin. Stale 01 Pennsylvania. owner and publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS newspapers of general circulation. printed and published at 812 to 818 Market Slreet, in the Clly, County and Slale aloresaid; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS were established March 4th. 1854. and September 18th. 1949, respeclively. and all have been conlinuously published ever since; That the prinled notice or publica lion which is securely allached herelo is exaclly as prinled and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 261h day 01 October and Ihe 2nd and 9th day(s) 01 November 1999. That neilher he nor said Company is interested in the subjecl mailer of said printed no lice or advertising. and that all of the allegalions of this statement as to the time. place and character 01 publication are true; and That he has personal knowledge of Ihe lacls aforesaid and is duly authorized and empowered to verify this slalement on behalf 01 The Palriot.News Co. aloresaid by virtue and pursuanl 10 a resolution unanimously passed and adopled severally by the stockholders and board 01 directors 01 the said Company and subsequenlly duly recorded in the olfice for the Recording of Deeds in and for said Counly 01 Dauphin in Miscellaneous Book "M". vO;::~I.::g;I~~ : f~" kZD/l~ COpy S ALE #10 Swo 'l)lth day o,!}'ovember,) 1 999 A.D. Nul;lII(l1 SPill ~-., // ./ ~ J "ny I Ilu<;<;dl, Nnlary Pl.;tJi; //",-,~,y l, (~--;/ .i./-~ _'-;-'--~,~ ft!lIr;!J\Hq. l),wptllfl COil " . - '- I."t C()'l1~t;t ;'i'OIl f:>'P'H':; .I\lnt: ij', ;,r'i1;' NOTARY PUBLIC ~>111:"", ,'.,:,:,' '"..~lI'.,I" :. ,:' ", My'-c'oi"Dmission expires June 6. 2002 , CUMBERLAND COUN1Y SHERIFFS OFFICE COURTl-OUSE CARLISLE. PA. 17013 Statement of Advertisino Costs To THE PATRIOT.NEWS CO., Dr. For publishing the nolice or publication attached hereto on the above stated dales $ Probating same Notary Fee(s) $ Tolal $ 365.06 1.50 366.56 publisher's Receipt for Advertising Cost THE PATRIOT.NEWS CO., publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS. newspapers 01 general circulation. hereby acknowledge receipt of the aloresaid nolice and publication costs and certilies that the same have been duly paid. THE PA TRIOT.NEWS CO. By...................................... ............................. GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY June 30, 1999 TO: JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, 3797 CHESTNUR STREET CAMP HILL, PA 17011 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 4823 BRIAN ROAD. MECHANICSBURG. PA 17055, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland county Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $99.807.84 obtained by GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) (the mortgagee) against you. If the sale is postponed, the property will be relisted for the MARCH 1. 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS 1. . YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. i , , ' 3. You may also be able to stop the sale through other legal proceedings. I. ~. r ,; You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (S'ee 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 DOE~_~~~~~LA~E~ 1. be sold calling If the Sheriff's Sale to the highest bidder. (215) 56)-7000. is not stopped, your property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the ~id price was grossly inadequate compared to the value prof. 'rty. ). The sale will go through only Sheriff the full amount due in the sale. happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. if the buyer pays the To find out if this has 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 Jiitll'/iIV),JCot . 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 .TII/k/li'll 1,).(1(, . 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 GMAC MORTGAGE CORPORATION IF/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA), 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 4823 BRIAN ROAD. MECHANICSBURG. PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) JEFFREY E. ARNOLD. SR. 7 COLUMBIA AVENUE CAMP HILL. PA 17011 ALYCE A. ARNOLD. A/KIA ALYCE A. ARNOLD. SR.. AIKIA ALICE A. ARNOLD. A/KIA ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 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) DAUPHIN DEPOSIT BANK AND TRUST COMPANY 213 MARKET ST~E~~ P.O. BOX 2961 HARRISBURG, PA 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) CUMBERLAND COUNTY DOMESTIC RELATIONS DEPARTMENT CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SOUARE Cl'.RLISI,E, Pl'. 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 4823 BRIAN ROAD MECHl'.NICSBURG. PI'. 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ kkf\J\ ~~~\'^'~ FRANK FEDERM N, ESQUIRE Attorney for Plaintiff Januarv 7. 1999 DATE GKAC MORTGAGE CORPORATION (F/K/A GKAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY January 7, 1999 TO: ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 4823 BRIAN ROAD. MECHANICSBURG. PA 17055, is scheduled to be sold at the Sheriff's Sale on JUNE 9. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96,846.00 obtained by GKAC MORTGAGE CORPORATION (F/K/A GKAC MORTGAGE CORPORATION OF PENNSYLVANIA) (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: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , , !! YOU MAY STILL BE ABLE TO SAVE YOUR ~ROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DO~S TA~_~~~A~~ 1- be sold calling If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stopped, your property will You may find out the price bid by I' I , , I' , ' 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (215) 563-7000. if the buyer pays the To find out if this has 4. If the amount due from the Buyer is not pa id to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after ! ~. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland county Courthouse CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEAI.TH OF PENNSYl.VANIA) COUNTY OF CUMI3ERLAND) NO "fI-I,II.' I CIVIL 1!J: '1"'1111 CiVIl. ACTION. LAW TO THE SHERIFF OF. . <:lllllberlillld COUNTY To satlsty the deb!. interest and costs due (1-1J\C ~k)rl'ld'lC' Cnl]l. (F/K/A (;Hr.,' ~~l/ t qd'l".C:'!!!'-._,,' I'Al . PLAINTIFF(S) DEFENDANT(S) I ( I' ~ ' from. . ,'ellrey !.;. Arnold, Sr. ill"! Alyce A. Arnold .'Ie. (1) You are directed to levy upon the prope~y of the defendant(s) and 10 sell. . __.__.seeJegal_de~_"ription ofproperty ......___. -------~-----~------_._---_._~--_.._-----_..__._------.__.- (2) You are also directed to attach the prope~y ot the defendant(s) nollevied uron in tile possession 01 ___ _.___~___.~"_ ______________.___________________...____n_____________._______.____~___ _...._~_._.__..__.._._.___._._ GARNISHEE(S) as follows: -------~-------~._---~_._---------"- and to notify tile garnisllee(s) tllat: (a) an attacllmentllas been issued: (b) tile garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of tile defendant(s) not levied upon an subject to attachmenl is found in U,e possession of anyone other than a named garnisllee, you are direcled to notify Ilim/Ilertllat he/she Ilas been added as a garnisllee and is enjoined as above stated. Amount Due. Interest from Ally's Comm Ally Paid Plaintifl Paid ~qfi..BAfi.110 1/8/99 to sale C2,+l.8. 32 L.t. _.__.$.50 @ $15.91 per diem. P I" . .._ uue ro I ,y -SLllO Otller Costs % S12ti. fiO Date: ,January 13.......lm Curtis R. Lonq Prothonotary, Civil Division by _ '~/'J/(i. K ,.x;-le, Yfi!j Deputy REQUESTING PARTY: Federman and Phelan ['ronl, rcdcnroFT,--Esq. Two Penn Center Plaza - Name Suite 900 Address: Philadelphia, PA 19102 Allorney for: Plaintiff Telephone: -----12151 563-7000 Supreme Cou~ 10 No. 12248 i ~ti\L t~ IAi t St\LL l'ill. 5' fJ~:l L : u( M;J /~' /I f 9 the sheriff levied upon the defendants lll~st In the real property situated in /.h--r1j'r.t-vc k~J Cumberland Ce'L:n:y, Pa" f:nO'Nn end lH~rnbGfed a5:/~Al"<~ -M,. /J AU l)~r"~ " r,':' r",,\! "'~,,':,.;h..r.' "n Ex' (I' I'b:! "A" 11"'''0' \"1''''" //I~.4-~(J \.'U.I,,'I,oI,lu,,'_'~'''''''''';,U...'' I 0) 1111 this writ and by this rorc:ellc9 Inccr~oral6d herein. ""'fJ'r<<'?/ ~/991 ~"u~~ /. c?:c:/tJ.,. '/~<:?T" ""') -' ~:4.r'\~ ,-' ..-..,.0:..., C..::'; r:-" ~Ti:J !Nil .J FED EHMAN ANn i'IIELArI By: FHANK FEIJEHMArI IDENTIFICATION NO. J~~4H TWO PENN CENTEH PI~ZA, SUI'I'E 900 PHILADELPHIA, PA J9JO~ LV21__2 G] -]0 () () ATTOIWEY FOH PLA I N'I' IFF COUH'!' OF COMMON Pl.EAS CIVIL IlIVIf;IOtl Gl.IAC HOHTGAGI'; COHPORA'I'lOIl (F/K/A GMAC HORTGAGE CORPOHA'I'ION OF PENNSYLVANIA) CUHIJI-:HLArm COllIlT" v. NO. 9B-6021-CIVIL JEFFHEY E. ARNOLD, SH. ALYCE A. ARNOLD, A/K/A ALYCE A. AHNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the Judgment which was entered on JANUARY 13, 1999, against JEFFREY E. ARNOLD, SR. AND ALYCE A. ARNOLD, A/KIA ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN, Defendants, in the amount of $96,846.00, upon payment of your costs only. -- ^-'Y-.k.. / ~ "&V>..n---I-Ov'\ F~NK FEDERMAN, ESQUIRE Attorney for Plaintiff Dated: June 30, 1999 .tr co 0 rI' 0 :;:, r~ (', ;>- 1t .Q y;; ..;J ,-- .' 7:' 0 ;:, 0 r0 ()O 1I1 ~.~ co ~ :<".~ '- ;.' '.1: ... -- ,):' 0 1> :Fr 4.;:"; (.;' -: :~~ .J C~ , L() j 17:" "" !n UI; I ::~~ 8 --' '11 ~!' ~. ::;:; 'Q.. I' e-I (> 0" :..5 FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - suite 900 Philadelphia, PA 19102 (UJ!.L2~~-:LO.Q 0 Attorney for Plaintiff GMhC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704-0780 VS. JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 NO. 98-6021 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JEFFREY E. ARNOLD. SR. AND ALYCE A. ARNOLD. AIKIA ALYCE A. ARNOL~ SR.. A/KIA ALICE A. ARNOLD. A/KIA ALICE A. MINAHAN, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 6/24/99 TO 12/8/99 TOTAL $94,025.20 $ 5.782.64 $99,807.84 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ...-~--- f\____ ,/' ,...---'Ai. ;( -AI?lAr ._--0 1l..J):~ "'-. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: jvl'-., q..\\ iCfiq , INDICATED. IS, C_\.i'\.L.,) liQ.., \ j)Ilj PRO PROTHY FEDERMAN AND PHELAN FranK Federmdn, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 98-6021 CIVIL JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD Defendant TO: ALYCE A. ARNOLD A/KIA ALYCE A. ARNOLD, SR., AIKIA ALICE A. ARNOLD, AI KIA ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER 8. 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 to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 r \ ' Q rljl\Lc""h ~)). \; C ~\\..,,-(~r Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 98-6021 CIVIL JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD Defendant (s) TO: JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER 8. 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 to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 , (717) 249-3166 ri\ Ii N... (\ ~U\1"Vv~ ~\~ Frank Federman, Esquire Attorney for Plaintiff c- c- - c- --- ~ - ,) .J (.1 ~ 1 (fJ - x'. ::J +5 lJ C) C ("oj 'It .:;j (6 -z ~ >- (0 co ,-- u: " ;. r) 1T ~\ .-r (". 9 if 'J , 1.1-1" .J C:',J ,. ..J c.C ~ i -~. '=' -- '1 " ) 3 '0. c; oj (':'1;_ (~, : " G' ft I 'r \J -- . . ~__ I{ !I,) L1....i ~ '.- I' :,,: " en U U' U I'KAl';CII'g FOK WKIT OF 1.;XI,:ClJ'1'I0:-; - (:\WltT(;,\l;E FOIU':CI.OSIIKE) 1'.lt.C.I'. .\1"0-.\1".\ GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) COURT ur CUMMON PLEAU CUHUEHLAND COUNTY, PA NO. 9U-6021 CIVIL plaintiff vs. I'KMl'II'I': I'll" ww.1"I' Ot' ,,:xE('ln'lo~ l\IOl(I(;,\(a: UH{H'UISl;Kt:1 JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN Defendant(s) TO THE DIRECTOR OF THE OFFICE OF TilE PRO'l'1I0110Thl\Y: Issue writ of execution in the above mutter: Amount Due ~99 . BQ2___84 Interest from 6/24/99 TO 12/8/99 (PER DIEM - $16.41) L2.75Q.c.23. unci Costs ilQ? 564.72 TOTAL r-~ / . Qc;?y.. /) ,-~ n-v\ ESQUIRE PLAZA ,/ f...n-/." FRANK FEDERMAN, TlVO PENN CENTER SUITE 900 PHILADELPHIA, Ph 19102 Attorney for plaintiff Note: Please attach description of property. :l> 0. 0. '1 ro Ul Ul .. W" ~;;:O ~~ "l .....t< ..... 1)."0 , :>olo< :>ol "lOt< \ .....0 ..... "l ~to:! ~ lD:.;C: .... Ulto:!:': :tof ,... "0 ~~ Gl UlCll~ ro '" t< . ~ (")- :o:>'J~ 0. H Z rt :> SZ :T~~ rt ,'" t"'l ~B~ 0 0 ~>'J< 0 n :.:Gl -"" CllCllfi '1 - ~15'" o~ O:l- :J ~"O t"'l'" ro ) .,.~ . t< to:! ~o ",t"'l '" 'Cl ~ c: '< - ~,tl~ t""(") OJ III to:! ~ "'r1 Gl:.: I 'tf tlj" 1~ 0 ~O ~O '" Cll t>:l 2:~to:! 0 "l>'JO :.; '" 0..... 0< Gl:o O~ IV en' ~ '0 --- ~~to:! to:!>'J .... ,., .... OGl (")"" aO'd 00:-::;:: , ~. O~ 00 n ~ ~:.; :: ~ <: :oGl H :.-~~ en 'dto:! 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C' <2 "-) GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. It GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA), 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 4823 BRIAN ROAD. MECHANICSBURG. PA 17055. NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 1. Name and address of Owner(s) or reputed Owner(s): JEFFREY E. ARNOLD. SR. 7 COLUMBIA AVENUE CAMP HILL. PA 17011 ALYCE A. ARNOLD. A/K/A ALYCE A. ARNOLD. SR.. A/K/A ALICE A. ARNOLD. A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holdcr of every mortgage of record: NAM.!'; I~ST KNOWN ADDRESS (if address cannot be reasonably aficcrtaincd, plcasc ~o indicate) DAUPHIN DEPOSI~-PANK AN~ TRUST COMPANY C/O 1ST MARYLAND BANK CORP. ATTN: 501-34:1, 499 MITCHELL ROAD MILLSBORO. DE 19966 5. Name and address of every other person who has any record licn on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) TENANT/OCCUPANT 4823 BRIAN ROAD MECHANICSBURG. PA 17055 DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE. PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. June 30. 1999 DATE ..... ") '- a: lr. [-,: 1--; r, ; " lJ .1:-. , cJ , .) : - I , ,). :.-, i " ; ),'" -. ~. ; " ::..:') ;l a . C , c" () You may need an attorney to a~sert your right", The sooner you contact one, the more chance you will have of ~topping the sale. (S'ee notice on page t'o'iO on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YQlJ ._H.AVE OTHER RIGHTS EVEN U:...'!'JIE SHERIFF'S SALE DOES TlII\.Lp.Id\G.E... 1. be sold calling If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stoppudt ynllr property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (717) 240-6390. it 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 .'linen! If -; ,,(.if,. 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 ,Tllil,Wv 7,,;,'77.. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (BOO) 990-910B ) GHAC MORTGAGE CORPORATION (F/K/A GHAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY January 7, 1999 TO: ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. Your house (real estate) at 4823 BRIAN ROAD. MECHANICSBURG. PA 17055, is scheduled to be sold at the Sheriff's Sale on JUNE 9. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $96.846.00 obtained by GMAC MORTGAGE CORPORATION CF/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY 8E ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff I 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: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you wi 11 have of stopping thn sale. (See notice on page two on how to obtain an attorney.) YOU KAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGH'!'lI._EYEN_..I,FJJ:tE_SHERIFF'S SlILE DOE.S_TAKE..PLACE, 1- be sold calling If the Sheriff's Sale to the highest bidder. (2151 563-7000. is not stopped, your property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (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 I i, ~. I I ! I ~. I> i; r',. I r . , 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT KAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland County Courthouse CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 '. ~ ~ , DESCRIPTIO" ALL THAT CERTAIN tract of land with the improvements thereon erected, situated on the Northwest side of Brian Road. Hampden Township. Cumberland County. Pennsylvania. being Lot No.8, Block E. Plan No. ~ of Del Brook Manor. Plan Book II, Page 33, bounded and described in accordance with a Plan of Survey by Gerrit J. Betz Associates, Inc.. dated April II. 1980 bearing Drawing No. 80-080. as follows. to wit: BEGINNING at a hub on the Northwest side of Brian Road (50 feet wide right of way) at a corner - , of Lot No.7 of che above mentioned Plan of Locs; now or late of Eugene R. Viccaro, said point being ~73.1O feet to intersection of Charles Road ami Brian Road; thence extending from said beginning point and along Lot NO.7 North 5 degrees 28 minutes West 125 feel to a hub at property now or late of Harry M. Weitze; thence extending along same North 8-1 degrees 32 minutes East 65 feet to a hub at Lot No.9 of the above mentioned Plan of Lots now or late uf Henry F. Eisenhower; thence extending along same South 5 degrees 28 minutes East 125 feet to a hub on the Northwest side of Brian Road, aforementioned; thence extending along same South 8-1 degrees 32 minutes West 65 feet to the first mentioned hub and place of beginning. BEING known as -1823 Brian Road. Tax Parcel # 1O-21-2i9-215 TITLE TO SAID PREMISES IS VESTED IN Alice A. Arnold and Jeffrey E. Arnold. Sr., Her Husband by Deed from Alice A. Minahan n/k/a Alice A. Arnold dated 9/28/89, recorded 1O/~/89. in Deed Book E 3~. page 11~3. .- ~ ... GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN : NO. 98-6021 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION IFIKIA GMAC MORTGAGE CORPORATION OF PENNSYLVANIA), 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 4823 BRIAN ROAD. MECHANICSBURG. PA 17055. 1. Name and address of Owner(s) or reputed owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) JEFFREY E. ARNOLD. SR. 7 COLUMBIA AVENUE CAMP HILL. PA 17011 ALYCE A. ARNOLD. A/K/A ALYCE A. ARNOLD. SR.. A/KIA ALICE A. ARNOLD. A/K/A ALICE A. IUNAHAN 3797 CHESTNUT STREET CAMP HILL. PA 17011 2. Name and address of Defendant(s) in the jUdgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every jUdgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE .i. 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWII ADDRESS (if address CitIlnot be reasonably ascertained, pleilsc so indic~tc) DAUPHIN DEPOSIT BANK AND TRUST COMPANY 2_~.::l_~RKE.Ll;1.'l'BE_ET P.O. BOX 296], !l~R!lISBUR~~~ 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) CUMBERLAND COUNTY DOMESTIC RELATIONS DEPARTMENT CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SOUARE 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 I OCCUPANT 4823 BRIAN ROAD MECHANICSBURG, PA 17055 I verify that the statements mode in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~f\i,'Cj\ I~tk,-y,^,~ FRANK FEDERM N, ESQUIRE Attorney for Plaintiff Januarv 7, 1999 DATE FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn center Plaza - suite 900 Philadelphia, PA 19102 (2151 563-7000 Attorney for Plaintiff GKAC MORTGAGE CORPORATION (F/K/A GKAC MORTGAGE CORPORATION OF PENNSYLVANIA) 3451 HAMMOND AVENUE P.O. BOX 7aO WATERLOO, IA 50704-07aO VS. JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/KIA ALYCE A. ARNOLD, SR., AIKIA ALICE A. ARNOLD, A/KIA ALICE A. MINAHAN 4823 BRIAN ROAD MECHANICSBURG, PA 17055 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 98-6021 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JEFFREY E. ARNOLD. SR. AND ALYCE A. ARNOLD. A/KIA ALYCE A. ARNOLD. SR.. A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN, Defendant(s) for failure to file an Answer to plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - a/1/98-1/7/99 TOTAL $94,025.20 2.820.80 $96,a46.00 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 1" \ [\.. II 11~(v!If\;~ \ '-', l,tl\.lv 'v-<-----. FRA K FEDERMAN, ESQUIRE Attorney for Plaintiff DATE: Y'" /=1 FN-J INDICATED. /5/ //~,,4J F ..k.9J;-:C ./ PRO PROTHY / ~ /. DAMAGES ARE HEREBY ASSESSED AS \ ~ ~ ,,\ "'~ "J.l , ~ \;. ~ ~~ ~ ~ '"" .\ ri. '~ () \" ,.ll ,V1 'If. ~f' I\: t- ~~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION OF PENNSYLVANIA) A'1"I'OIlNEY FOil PLAINTIFF COURT 01' COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 98-6021 CIVIL JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD Defendant TO: ALYCE A. ARNOLD A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN 3797 CHESTNUT STREET CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER a. 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 to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 I I, C I I" : \ .I \" ,/ _,_ (\j,\i'.V"~\ l Ip \;CV~v\.tv Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two pcnn Cnntnr fJlaza suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION (F/K/A GMAC MORTGAGE CORPORATION or PENNSYLVANIA) A'I"I'OIHH:Y FOil PLAl NTl FF COUll'!' OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 98-6021 CIVIL JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD Defendant(s) TO: JEFFREY E. ARNOLD, SR. 7 COLUMBIA AVENUE CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER 8. 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 to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the fOllowing office to find out where you can get legal help: I ~ i , I 1 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 \' (\ ~)V"\vt\ ~~'v~ Frank Federman, Esquire Attorney for Plaintiff Ii :; r.: " \ ,tAECIPE FOR WRIT OF EXECUTION-(:'tIQHTGAGE FORECLOSURE) ., P.RC.P. 3180.3183 I I I .............................................................................. l~ THE COCf:T OF CQ:\JjlO~ PLEAS OF CUMBERLAND COUl"TY. PENNSYLY ANIA (,1!AC HORTGAG~: CORI'. (F/K/A GHAC HORTGAG~: CORP. OF PA) ......................................................---................ '" \ S 98-6021 CIVIL . o.."'..........."'.....m.............m..............Term 19....... .......................................................-..................... JEFFREY E. ARNOLD, SR. AI.YCE A. ARNOLD PRAECIPE FOR WRIT OF EXECUTION (~lORTGAGE FORECLOSURE) .......................................................-..................... . - To the Director o( the OWce o( ~- Issue writ of executio:J in the "bo\'e m"t:er: " Ar:lOunt Due $.l!f1".1;I.~.f!...99...,.... Interest from ~ I~~;~ 9 iO p~~I'~I Ji...~.~.~,I,~;.~~........ and Costs. (\ \ " . I \ ~' . .........."'........,,}~~~:..~...Uj;.l,;..::IY.o:f~y-::............. ,4ttorn;y for the Plaintiff(s) Note: Please attach description of Property. ~" " . ~ .~ ~ .~ .~ ,'~ '1 '., -- ',' , '- ~ rl, \.h '_.I .\ (~ '~}'-.. '-J ,~ ) '- -z, .J' I .J \ fV) .j , \j :) , " f~ - " I 'I; ~ ,,,.I . J 1"-' , ., '1', 'v' .~ ~-.J ,---......, \ 'f\ () ",", j c Z 3: Z ? c:: :i " '- ~ r-l > ;;- ~ ~ '" ;::: '" ;; ~ n t"' ,', ~ ';? ,', n :>> r. r~~ r. '" 1!i - 0 ri .-- > ::! 6 c .. K < ~ .. ~ ~'"': - =: ,', '" en <: :( ~ . . n 0-: LC. 0 " > CCl ~ 0 ~ n :- '" z-:: ; ~~ ~ ~ 0 >-::; r. :<; b 9 n '-:0 ~? " 0 - b ~ - ". ~ "? " ~ -- Sk 0 :j -". .i -- " ~:f--- ~ Zo ~ " en n C '" zZ :: n: 0' -:: '- t::::: ," en :J:--;: ... -.: l c :'l ...- 0.:> Q:- ~ -. 5 ":r " X c-~ " '1;1: ~ - ~> ,', ;: ~:( () >:n " c Zo '" ~ ~ , .., --== b ~: ';:;i i3 > ~, Z ,,: -1 . , ,..( " '-' ''\.f \" \.1, I' ',' %. ''l Z ? ~ " .., 2 ... .r ~ l"':l._ . G'(;J- ~ . Z ? :.., " .., 3 ... 0.:> ~ r I. I' I i (Rule ot civil Procedure No. 236) - Revised IN THE COURT OF COMMON PI.Ella OF CUHOERI.IIND COUNTY, PENNSYLVANIA CIVIL IICTION - LIIW GMl'\C MORTGAGE CORPORATION (F/K/A GMl'\C MORTGAGE CORPORIITION OF PENNSYLVANIA) NO. 98-6021 CIVIL Plaintiff vs. JEFFREY E. l'\RNOLD, SR. ALYCE A. l'\RNOLD, A/K/A ALYCE A. l'\RNOLD, SR., A/K/II ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN Defendants By:/JI (;,r~ .J . /" XC')9' ,.I~,.7',t"k',;tV' Dcru'p,: Notice is given that a Judgment in the above-captioned matter has been entered against you on :J? 1/ /.-3 /<;'4tf contact: If you have any questions concerning this matter, please (hr;\l,\j\ {j1klv\w~ FRAflK FEDERMAN , ESQUIRE Attorney for Party Filing Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 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. i , i I " \ $ ~ 'Ji,. ,'-. ~ , 1"". '. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF GHAC MORTGAGE CORPORATION (F/K/A GHAC MORTGAGE CORPORATION OF PENNSYLVANIA) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION vs. JEFFREY E. ARNOLD, SR. ALYCE A. ARNOLD, A/K/A ALYCE A. ARNOLD, SR., A/K/A ALICE A. ARNOLD, A/K/A ALICE A. MINAHAN NO. 98-6021 CIVIL CERTIFICATJ:ON FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: an FHA mortgage non-owner occupied vacant (xx) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1\ I J) ! :!h\iv.J\ U vl1X:C\.<\l~/'- FRANK FEDERMAN, ESQU1RE Attorney for Plaintiff " i, I I ! ',.