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Home My WebLink About00-05454 ~,. w' "",,",., -'"'""~- r,-, SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-05454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRINCIPAL WHOLESALE MORTGAGE VS COLLINS KEVI L ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: COLLINS KEVIN L but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On September 25th , 2000 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff's Costs: Docketing 18.00 Out of County 9.00 SurQharge 10.00 Dep. Northumberlan 81.60 .00 118.60 09/25/2000 FEDERMAN & PHELAN ~--? :- Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 'l~ day of 0e..a...., ;;two A.D. ~~~r~ W=. "'~""-~ -'" "~~~ -- - ,~- ~ ':' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-05454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRINCIPAL WHOLESALE MORTGAGE VS COLLINS KEVI L ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: COLLINS LORI A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On September 25th , 2000 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 09/25/2000 FEDERMAN & PHELAN ~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this '1~ day of~e:t;:L.., ~.<nrO A.D. ~Q~,&f'{ Prothonotary . . - , PLAINTIFF: PRINCIPAL WHOLESALE MORTGAGE P: CORPORATION VS: DEFENDANT: COLLINS, KEVIN L. & D: COLLINS, LORI A. D: 139 E. DEWART ST. D: SHAMOKIN PA 17872-4803 D: CASE #: 00 NO 5454 CTY FILED: CUMBERLAND FILE DATE: 00/08/07 DATE RECEIVED: 00/08/25 ASSIGNED TO: 2 DEF LAW FIRM: CUMBERLAND EXPIRES: 00/09/06 SHERIFF'S RETURN I HEREBY CERTIFY AND RETURN I SERVED: KEVIN L. COLLINS BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: CIVIL ACTION -LAW MORTGAGE FORECLOSURE PERSON SERVED: KEVIN L. COLLINS sw. orn to and SUbsor~br ~o:ei ~" Lh:t~ ~ of A. D. 20bCll Q,. 41..,-. rr::n, i ,....T"i;ROTH~N~ ~ My Carom. Exp. 1st Man: Jan. 2002 DATE SERVED: 00/09/06 CAPACITY: PERSONALLY TIME: 6: 35 PM PLACE SERVED: 139 E. DEWART ST., SHAMOKIN, PA COUNTY OF NORTHUMBERLAND AND CONTENTS THEREOF. STATE OF PENNA" MAKING KNOWN UNTO : HIM SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF BY DEPUTY: DRUST, THOMAS BY: THE ~s.~~ I HEREBY CERTIFY AND RETURN THAT I SERVED: LORI A. COLLINS BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: CIVIL ACTION-LAW MORTGAGE FORECLOSURE PERSON SERVED: KEVIN L. COLLINS ~" , DATE SERVED: 00/09/06 CAPACITY HUSBAND & ADULT IN CHARGE TIME: 6:35 PM , 1.::j.1l.\ PLACE SERVED: 139 E. DEWART ST., SHAMOKIN, PA COUNTY OF NORTHUMBERLAND AND STATE OF PENNA., MAKING KNOWN UNTO : HIM CONTENTS THEREOF. THE SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF sworn.to and Sllb~ ~ nre this ~ day of~ . A. :D. .2001" . ' ~.~.::~Q~ PROTHONOTARY My GQl~,Exp, IstMon.Jan. 2000 BY DEPUTY: DRUST, THOMAS BY: ~s.~ SHERIFF'S COSTS: REC #: 17171 NO. OF ATTEMPTS: $ 81.60 3 DOCKET PAGE #: 00 CV 0486 -, [" . 't In The Court of Common Pleas of Cumberland County, Pennsylvania ^' Principal Wholesale Mortgage VS. Kevin L. Collins. et. al. Serve: Kevin L. Collins Corp.. et. al. N 20-5454 Civil o. Now, 8/22/00 ,200 tJ , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Northumberland County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. . .. ~~~i! ), 1'~ Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy ofthe origi.lJal and made lmown to the contents thereof. So answers, Sheriff of Coun1y, PA Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE 1vlILEAGE AFFIDAVIT $ $ "" ~~ .L .' "'j~.' In The Court of Common Pleas of Cumberland County, Pennsylvania " Principal Whole~~e Mortgage Corporation, et. al. Kevin L. Collins, et. al. Serve: Lori A. Collins No. 20-5454 Civil Now, 8/22/00 , 20 C () , I, SHERIFF OF CUJ\.1BERLAND COUNTY, P A, do hereby deputize the Sheriff of County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ..' . /'~~~ ,)~ ~~ Sheriff of Cumberland County, PA Affidavit of Service 'j , I :\ " Now , ,20 , at o'clock M, served the II II il :1 II " II :j :1 ! 1 ; i i I I 1 I I I I j 1 I I I \ within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE . J:vITLEAGE AFFIDA VrT $ $ - - ~-" ""'. ':Ii; FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PRINCIPAL WHo.LESALE Mo.RTGAGE Co.RPo.RATlON, F/K/A RELIASTAR Mo.RTGAGE Co.RPo.RATION 711 IDGH STREET DES Mo.INES, IA 50392-0780 Plaintiff : CUMBERLAND Co.UNTY : Co.URT OF Co.MMON PLEAS : CIVIL DIVISION : NO. 00-5454 VS. KEVIN L. COLLINS Lo.RI A. COLLINS 139 EAST DEWART STREET SHAMo.KIN, PA 17872 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT o.F DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against KEVIN L. Co.LLINS and Lo.RI A. Co.LLINS, 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 8/1/00 to 10/1 0/00 $114,936.20 $1.664.95 TOTAL $116,601.15 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. ~FED~UIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: l'rd- 11 2000 Ii'/ (l/;J;,) J:2 _ . I PRO. PRo.T **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, ** " ~ ~,~,,',_r,,^~~ ,,%i -~ l,~__~_.' - ~ .. .;:-~:' , FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINICIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant(s) TO: KEVIN L. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 DATE OF NOTICE: SEPTEMBER 27. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO ~!T A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR T '~~~~IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BAN 'Pteti IS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO IB AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 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 ATTORNEY FOR PLAINTIFF PRINICIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant TO: LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 DATE OF NOTICE: SEPTEMBER 27. 2000 ;1:1.ff" 14,;.. il"i/'l", THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLEC'I' ,J'r'~BT. 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.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ,"~- ~,~"""'~""'"-'......."" 0 ~ _~~ ~.~ ".." ~'. . FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINICIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant(s) TO: KEVIN L. COLLINS 3010 MORNINGS IDE DRIVE CAMP HILL, PA 17011 FILE CCPY DATE OF NOTICE: SEPTEMBER 27. 2000 . . THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LlBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff "." ~~ Eti'-, :; ;:i , :'J il :1 " H Ij !l ,~i 'I i! " " ;] , il I :1 :1 lj Ii II II '1 " Ii ii Ii ,I Ii ii I i; ii ,! :1 I I I I I i i I I "",- "" "''t,~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF I I I , PRINICIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant TO: LORI 3010 CAMP A. COLLINS , MORNINGS IDE DRIVE HILL, PA 17011 1"'11 r' ''il:;', I''''''' f'" f'>i ~:,\,1 , "B '"" ....,4 i ~ DATE OF NOTICE: SEPTEMBER 27. 2000 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. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS , NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment' may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: . CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ."" 'I FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff PRINCIPAL WHOLESALE MORTGAGE Co.RPORATION, FfKlA RELIASTAR Mo.RTGAGE CORPORATIo.N Plaintiff : CUMBERLAND COUNTY :j I I I II II I'J !I rij I! ,! : Court of Common Pleas : CIVIL DIVISION vs. : NO. 00-5454 KEVIN L. Co.LLINS Lo.RI A. COLLINS Defendant(s) VERIFICATION o.F No.N-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant KEVIN L. Co.LLINS is over 18 years of age and resides at 139 EAST DEWART STREET, SHAMOKIN, PA 17872. (c) that defendant Lo.RI A. Co.LLINS is over 18 years of age, and resides at 139 EAST DEWART STREET, SHAMo.KIN, P A 17872. This statement is made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. (Rule of Civil Procedure No. 236 - Revised) PRINCIPAL WHo.LESALE Mo.RTGAGE CORPo.RATION, F/K/A RELIASTAR MORTGAGE CORPo.RATION : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION Plain tiff : NO. 00-5454 vs. KEVIN L. COLLINS LORI A. COLLINS Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on OCTo.BER {:{ . 2000. ~y. 4CJAo 0,2. 7t(O?R.I'1JDEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attomey for Filing Party SillTE 900 TWO PENN CENTER PLAZA PHILADELPHIA PA 19102 (215) 563-7000 **TillS 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 AND TillS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** / ,"" '~--'-' 4!'il'.,j;-"-'-~~-1 ~ ~.,"~,..m ""'-~!II,,~lii0'ij""'I~~~ '"""""""""",,-,...." M~'~~~~ "~ '-' ,'~ ". . '~'-. '.,,,,," ,="-'- ~-'-r 1i. .. .'C~ ~. ~.. ~~~ '- ~ u ~~ 0' ;:R~:'j; Z':::;'~ ~f ~:(-:- ~-;2 ~:;,:.-' ~ -<' ........ 0. N w ~ i ----< o ~~ .. o C' C> C) --l o -n ;9 ,.,,-n "..---. , 1--' - - ; ,,~-=:) w :;:p.> . ~ . I :_;':~ ,!l '-.. ::;:.:~ ~ ":;:J --l . --~----- .. . .....~, ~ ... PRAECIPE Fo.R WRIT o.F EXECUTIo.N - (Mo.RTGAGE Fo.RECLo.SURE) p.R.e.p. 3180-3183 PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/KIA RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, No. 2000-5454 v. KEVIN L. COLLINS LORI A. COLLINS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $116.601.15 Interest from 10/10/00-03/07/01 $2.835.68 and Costs (per diem - $19.16) iI19,436.83TOTAL J~~ TWO PENN CENT PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff ) Note: Please attach description of property. No. ",,,, "-,, , ~ , , -, ..... " ' - '"' ", 0,-""" ~ ~ 'rJ "0 "0 g2 ~. ~ ~~ fD a=.., " P.- OZ (l " a=~Q == '" I:"ll:"l 'tl ~ ~ .fl ... OO~ !S~ a \I.l....~ i~ t"'~ ~~ ~o s ~~~ => 'rJ ~~~ t:l~ ::1.0 o~ >-3 ~ ~:;.:I ~z ~.., " 0' o~z ~~o g~ ~ ~~ > " ~..,r' . r' < ~~ t'" '" 0~1:"l z~ N " zt:l~ ~~'" 0 :! Sl .., o . ~~\I.l "'0 0 ~ 1:"l0 0 " ~~~ ~ 0 t"'o O>~ -:<a= p.. t"'t'" > ~~2 ='rJ ...t'" ~~; "Oa= ~ ~ I:"l Z'" I:"lo QO \I.l .. ~ \I.lZ ..,t"'o Zz -.l\l.l ~ \I.l ...;i:~ Z"O N.., ~ O\l.l.., \I.lt'" ~ ~ z"'l;') ~I:"l .., ~a; <> I:"l ... .., 0 ~~ Z I:"l ~~S I:"l~ O~~ ~..,~ zt:lO ~ I:"l t'" "O~t'" >~... .... Z ~..,\I.l -.l\l.l N.., ~ I:"l .., ~} ~, .' ~ . r~, :-:.: ,.' -- " _ 0, ''"'''', ,_ ,>", ~" , !!'I!'I~,~,~" ,',~ ,. ~ '11 J, .0 ._ __J:l\~~,o ~ n_~1f1W~~~"...,.,_"",.~,..~"I~)WH~""",~..,.,.""""",..."",~ =~, \. - ! ... . DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in Lower Allen Township, Cumberland County, State of Pennsylvania, bounded and described as follow, to wit: BEGINNING at an iron pin, said iron pin being seven hundred thirty-five (735) feet east of the northeast corner of Thirty-second Street and Morningside Drive; thence eastwardly along the northern side of Morningside Drive, sixty (60) feet to' an iron pin; thence northwardly along the line of property now or formerly of Harry R, Lukens and Daisy N, Lukens, his wife, one h,undreq fifty (150) feet to an iron pin; thence westwardly along the line of property of the Pennsylvairia Railroad, sixty (60) feet to an iron pin; thence southwardly along the line of property now or formerly of Luther W. Andrews and Agnes E. Andrews, his wife, one hundred fifty (150) feet to an iron pin, the place of BEGINNING. BEING Tax Parcel Number 13-23'-0551-148 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kevin 1. Collins and Lori A, Collins, his wife, by Deed from Luther W. Andrews, widower, by his Attorney-in-Face Sharon A, Hargrave, dated 9/23/96, and recorded 9/24/96, in Deed Book 146 Page 443. "'~l1!51i".d"""",".~r -------- ....-- , ", '~" -'~- - rv , ~~ C .e- ...... .~ ~ ~ ..0 ."1 '" ('..) "Q. r- /.J "'. (') C> )~ . . 0 ~ a -" ;<9 ......... i" '" D If) o 8 0 ,-, , () " 0 0 C '""O:ttJ n I,EI~~ a 0 mrn ..... Z:c w -"',,--r, 0 I I ~ 6i~ :-:~](7 ...... ~ )()~) 0- ~ -<L. (~~ 7J w ~ ~o " ~ 1"- ~ r ~o :z: z~;;; ... I , , , :s8 I)i' ,~, ,.... - - - S! ... t ...... t - ~ w "0 ... . , - ~ u:> =< - - , - ,. '-Lf --.( ,A t Jl I' 'f,\ 1 cI \ \ '\ 'J; -,,- , ~~ 1,;,,1 , t'~ ~ PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FfKlA RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KEVIN L. COLLINS LORI A. COLLINS NO. 2000-5454 Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Mfidavit No.1) PRINCIPAL WHOLESALE Mo.RTGAGE Co.RPo.RATIo.N. F/KIARELIASTAR Mo.RTGAGE Co.RPo.RATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 Mo.RNINGSIDE DRIVE. CAMP HILL. PA 17011. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KEVIN L. Co.LLINS 139 EAST DEWART STREET SHAMo.KIN, PA 17872 Lo.RI A. COLLINS 139 EAST DEWART STREET SHAMo.KIN, PA 17872 2. Name and address ofDefendant(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 " - ~ - ~~';t", t' . 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.) TMS Mortgage Inc. d/b/a 1770 Tribute Road., Ste 100, The Money Store Sacramento, CA 95815 Citifinancial, Inc. 6520 Carlisle Pk., Mechanicsburg, P A 17055 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 3010 Mo.RNINGSIDE DRIVE CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 27. 2000 DATE :2;~~~~ Attorney for Plaintiff ~~~~!lI'.-.r'.iI. ~ iWlQ_o:r.-'~"'iilJi'_~g~:I~:~: ~=~~'.~, u ,,~. ." - ~~ 'iI=I-"" >.. ">- '0> ,," -. ...." 0 0 0 C 0 <'" ","1 -oro Cl ,,~ ~rT C, ~' -l -X ZS; w ;;8 (/) .:~: - --("" , ~o " ~~i ~;-~ ~8 -~r 6~~ )> ~.) c ~ 'j.) ;g \0 IJ -~ - " . ,," FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/KJA RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant(s). CERTIFICATION 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 (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~~~ ~~ F FEDE , ESQUIRE - Attorney for Plaintiff ~~ -lol~~ ~ ~ .~. ~ ~ ~~~[j!~\i'~';""''"'''~' '-~-...........'.~ ;:,' ~'. < . ~, 'C', "~' ' ~\,~ -~"""_.': ~ 0 C} 0 " "CD 0 mrr' " Z" -4 " 2:0 w ~;8 en ;;:.: -<2 U"> 1;20 L> ,-'C. ::I> - r- -"~ 20 ::t: (j:JJ )'>0 -..".c) c: ~) om ~ w 35 \0 -< --n -- " ~ -, - - , . ,> ')#llh, , , I , ! ".. f PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FfKlA RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY No. 2000-5454 Plaintiff, v. KEVIN L. COLLINS LORI A. COLLINS Defendant(s). October 27, 2000 TO: KEVIN 1. COLLINS LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, P A 17872 --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 AND THIS DEBT WAS NOT REAFFIRMED, 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 3010 Mo.RNlNGSIDE DRIVE. CAMP HILL. PA 17011. is scheduled to be sold at the Sheriff's Sale on March 7,2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PRINCIPAL WHOLESALE Mo.RTGAGE Co.RPo.RATIo.N. FIKIA RELIASTAR Mo.RTGAGE Co.RPo.RATION (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the _June 6, 2001_ Sheriff's Sale. No.TICE o.F OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS 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. .,L' , ~~ ..""-~ - "~~~~~ -~. W"'~~ ,,- - ~'-1" 'W~, 4> ~ 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 yo.UR PRo.PERTY AND YO.U HAVE o.THER RIGHTS EVEN IF THE SHERIFF'S SALE Do.ES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. 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 the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHo.ULD TAKE THIS PAPER TO. yo.UR LAWYER AT o.NCE. IF YO.U DO. No.T HAVE A LAWYER o.R CANNOT AFFo.RD o.NE, Go. TO. o.R TELEPHONE THE o.FFICE LISTED BELOW TO FIND o.UT WHERE yo.u CAN GET LEGAL HELP. CUMBERLAND Co.UNTY ATTo.RNEY REFERRAL CUMBERLAND Co.UNTY BAR ASSo.CIATION 2 LIBERTY AVENUE CUMBERLAND Co.UNTY Co.URTHo.USE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 "~ ',- ~,~ ,. . . DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in Lower Allen Township, Cumberland County, State of Pennsylvania, bounded and described as follow, to wit: BEGINNING at an iron pino said iron pin being seven hundred thirty-five (735) feet east of the northeast corner of Thirty-second Street and Morningside Drive; thence eastwardly along the northern side of Morningside Drive, sixty (60) feet to an iron pin; thence northwardly along the line of property now or formerly of Harry R. Lukens and Daisy N, Lukens, his wife, one hundred fifty (150) feet to an iron pin; thence westwardly along the line of property of the Pennsylvania Railroad, sixty (60) feet to an iron pin; thence southwardly along the line of property now or formerly of Luther W. Andrews and Agnes E. Andrews, his wife, one hundred fifty (150) feet to an iron pin, the place of BEGINNING. BEING Tax Parcel Number 13-23-0551-148 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kevin 1. Collins and Lori A. Collins, his wife, by Deed from Luther W. Andrews, widower, by his Attorney-in-Face Sharon A, Hargrave, dated 9/23/96, and recorded 9/24/96, in Deed Book 146 Page 443. ~~_~iit4~~t~!!'.~~iimli!ltli!M~""j;f!!l~,j,/dii"'-lilii""-""'''''t''%''-'';'''i:.,''~"#k4:i!l~A'Mat' J ~llh.dAliJ:'iliillltTI1JlM; jj 1 111 . " " ,^' '," n _, "~ , " -I ILJ .', ~8!:' , (") C> ? c CJ s:: 0 ", -om C") 2m -; ,.. ,r :n "ii';;:;;'" zr- w :~,,~~ (J) )> lJ'..} -< ',"' . -, J L, ~::-4C> kG -0 -r"'<T-i ~o 2 ~':'~Il C?o :>g ~ Om Z W ~ =< '0 -< "" ~, , '.,-~: AFFIDAVIT OF SERVICE PLA"INTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY No.2000-5454 DEFENDANT(S) KEVIN L. COLLINS LORI A. COLLINS Type of Action - Notice of Sheriff's Sale Sale Date: March 7, 2001 SERVE AT 139 EAST DEW ART STREET SHAMOKIN, PA 17872 SERVED Served and made known to Kevin Collins , Defendant, on the 2 2 n d day of Nov,) ,20GL at 5:15 ,0'clock_P.m.,at 139 East Dewart Street Sham6kin, PI'I. 17872 . Connnonwealth of Pennsylvania, in the manner described below: Defendant personally served. xxx AdultfarnilymemberwithwhomDefendant(s)reside(s). Relationship is Wife-Lori 1\. Collins Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant( s)' s office or usual place of husiness. an officer of said Defendant(s)'s company. Other: Description: Age~ Height~6" Weight/3D Race~SexE-- Other Brown hair I, BriandJ. Duffv , a competent adult, being duIy sworn according to law, depose and state that I personally handed a true and correct copy of the No . 'ff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. p.' NOrA : . _ ..naa.. L. AI. lit,,,. """-! ""-'" IoION"I/ii;. . . Sworn to and subscribed My c-_~!"> loci. 0, N""I.')' Pul>llc. before me this ~ daO ="_ ~""". County ~1i;~..~/~ - '2~OO-;t~ By: Apr//'.2002 1 (f;vvv - M .~> NOT SERVED -ffl On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unkoown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102 (215) 563-7000 .at h~'""",""<>"~ '~L ~,~"" -~~~~~Js'Jf;!.%;~'.w.!-~"'''''- ~-'~""'!III' . ~ -~~.IIlIJ;;a ~ " - r: '-, .-" .~. 0 0 0 C 0 -n :;;: f.:::::J .--.j UC;::' r<1 -I-~ Q1[T' C") :~j\~ ,-on zf~ :::QH (f)J.;: 1'V ;:=;;r -<.d,~ ._-1 ~--' roo "", w!.:~ <:: )>0- :3 qo 26 CP. ori1 )>c ~ Z &:' =< '< ,~ AFFIDAVIT OF SERVICE PLAINTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY No.2000-5454 DEFENDANT(S) KEVIN L.COLLINS LORI A. COLLINS Type of Action - Notice of Sheriff's Sale Sale Date: March 7, 2001 SERVE AT 139 EAST DEWART STREET SHAMOKIN, PA 17872 SERVED Served and made known to Lori 1'1. Collins , Defendant, on the 22nd day of Nov. .200..Q at5: 15 , o'clock~.m., at 139 East Dewart Street Shamokin, PI'I. 17ak2nnnonwealth of Pennsylvania, in the manner described below: xxx Defendant personally served. AduIt family member with whom Defendant( s) reside( s). Relationship is AduIt in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant( s)' s company. Other: Description: Age ~5 Height~" Weight!1!L Race~Sex~ Other Brown hair I, Brian J. Duffy ,a competent aduIt, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the s set forth herein, issued in the captioned case on the date and at the address indicated above. NOTARlAI. SEAl. PA'I1IlCIA L M. MONGIl:ll.O, Not!"!' Public """- 1IDto, .........."'n... Ccunty My Commlolion bpi... t.priI " 2002 Sworn to and subscribed before me this ~ day of Nov _ ,200..0 Alary: - -~ /' {r;t~ //11 On the day of By: Bri .. NOT SERVED ,200_, at o'clock _.m., Defendant NOT FOUND becanse: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, P A 19102 (215) 563-7000 ~.l ,l ~JlIijjL "'''"''''''""-~'~''1~_llllIMib!l!.I!l>jllil.iiilli.!0k\.filllf~~' ~-~ ;.," ~.' ", ~ ,"~,. < "1 . I<': (") 0 0 C C) s: ~n -0,..,,, r:::> -:i 9]63 0"1 _.AI n , 1'-:".: Ze' :-:.~;i23 CI)~:: N -<~c ~~ ';7~ i::;c :f;:, :t>> zC ::E: ~~J ;I? 50 '?? csrn c Z ~ ~ --l -< -< ., .- ",- ~ ~ .- ,. ;'~ . PRAECIPE FOR WRIT OF EXECUTION. (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTARMORTGAGE CORPORATION CUMBERLAND COUNTY No. 2000-5454 Plaintiff, v. KEVIN L. COLLINS LORI A. COLLINS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $116,601.15 Interest from 10/10/00 to 9/5/01 (per diem - $19.17) $6,326.10and Costs TOTAL $122,927.25 W1?~~ RANK FE ERMAN, SQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. ,. ~~~iillh~~"'~~l'<;lil~ilili\;.;;'~Jf~*,~"i~~_I",,"--IlIL_i.!lilil~-l!!li'" ;.' - ~~ .~ .-. -~. --~''''''''':I ~" " . "" f;l;l ~ ""... 00.- oo~~ Z .... ...<< ""'~~ "'" f;l;l . O~Z U g ."" <000 ;l~~ 0Q\:= "",::loo r.,< oz f;l;l Z "" 00< ~~ 0 f;l;l ... <> "" ~ f;l;l"'" ~""Z ;;;J ""'.... ""000 00 U ""'" .,j ~oo ~<... oo~ ~'F 00.- 0) ZZ 0"''''' it:: 00",,00 i': OZ ~""'~ Z"'" f;l;l = Z~.- 0) '.g ... .... ci ~~ ..."'" '" "",<< en f;l;l~0 ""'0 r., 0 .~ 0) < 0;:; oj ""'~~ ,!O ~ . ""'<~ ""'U - oi: o . .., ~ o f;l;l . >, 0 "" .. oj 0 ~go .; U< ;l~ ... U~Z S 0 uz ~~u ;;. J;l <8 . ""t;;;! N r.,;;;J ~~ >, ""'000 ~ 5" 00 OZf;l;l zo a Z<~ 0) U :=O~ ..."'" ~~ >f;l;l ~ ~~ > 01:: 0 0.. E-< ~...< ~ [:2Q\:= ;;;JZ ""~ [:2 r., 0 << ~ ~~~ f;l;l~ ::loo 0) 0< ~--- ~ Usa ~oo ... Oi f;l;lf;l;l tl~~ U en ~ 0) :== zo "0 .t; ""~ 0) "0 ;lu - .~ << Z;;;J ~ r.. ...u ~ "-~~ =-~~ - . , ~ -" DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in Lower Allen Township, Cumberland County, State of Pennsylvania, bounded and described as follow, to wit: BEGINNING at an iron pin.. said iron pin being seven hundred thirty-five (735) feet east of the northeast corner of Thirty-second Street and MorningSide Drive;. thence eastwardly along the northern side of Morningside Drive, sixty (60) feet to an iron pin; thence northwardly along the line . . of property now or formerly of Harry R. Lukens and Daisy N. Lukens, his wife, one hundred fifty (150) feet to an iron pin; thence westwardly along the line of property of the Penpsylvania Railroad, sixty (60) feet to an iron pin; thence southwardly along the line of property now or formerly of Luther W. Andrews and Agnes E. Andrews, his wife, one hundred fifty (150) feet to an iron pin, the place of BEGINNING. BEING Tax Parcel Number 13-23-0551-148 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kevin L. Collins and Lori A. Collins, his wife, by Deed from Luther W. Andrews, widower, by his Attorney-in-Face Sharon A. Hargrave, dated 9/23/96, and recorded 9/24/96, in Deed Book 146 Page 443. " "-"*t I, I ! ~ I ~ II " i~ Ii , I Ii ,I j ! I'i I II I ! I I !I I ,! j I I I , I " I , I I i I I , I i i ! I I I i i I , ,~..-"~..~~l*lM"",,,~~'iIIlOtll&<.->l<~iili!I1i'M~;j;i.ci'>ilAA,",I,""h<i&~..,~~!il;jo,II;~ii*.I1.P-~..'filS!i1i~~"" .-e. -0 -v Q- ...... ~ ~ ....... () c" ....0 ..... 1.t ~ -- C1) "-' .- ...... ""6Q. ~ . , ~ ....... 0 ~ -:t () 8 ~ . .~ 0 "- 0 c- o 8 --c () () ~ s: -'" ...0 8 "'tlw L ...... c; ~ m... c: -r5 ...... tv z'" -~.,.. "1 'f~,.2] ..... ~ 2;:= .,- ~ (f) :r: , -gi:9 ~ ~ J I-U ;:$- eo "'C; ., , ~ [:J ~~ ~ "~O ~ ?Eo - )j:n -"" , .. .. 5>0 - :"0..(") , ~ , , ... ~ - ern , " ~ ~::> 5;! \0 :b " , ... b;V -< ~ ... "" ... , ... ... )f "'" ,. , .. ,1);l..<l>...l!Il:ol.~ ~.. ~W~"', ~=I 'lI1lIl!iU '_~Io'.1 u IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DIg~~ICT OF PENNSYLVANIA prt I f\I( IP/3 L l./o> 6 9Cj ~ 8 rcx(;'\ Bk. No. 00-04744 ~ IN RE: Kevin L. Collins Lori A. Collins Debtor (s) Chapter No. 7 -" ," ,I'll." ~v' ...i "" Principal Residential Mortgage, Inc. ,. ..,.1. r1 .Ii.,::''i . .~ I 11 U.S.C. 5362 Movant v. Kevin L. Collins Lori A. Collins .- and Lawrence G. Frank, Esquire (Trustee) Respondent(s) ORDER MODIFYING 5362 AUTOMATIC STAY AND NOW, this r-jfh day of vanllClq , /5(JJ/ upon Motion of Principal Residential Mortgage, Inc., (Movant), it is: ORDERED that the Automatic Stay of all proceedings, as provided under 5362 of the Bankruptcy Code 11 U. S. C. 5362 is modified with respect to premises 3010 Morningside Drive, Camp Hill, PA 17011, as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriff's Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. ORDERED that Rule 4001 (a) (3) is not applicable and Principal Residential Mortgage, Inc. may immediately enforce and implement this Order Granting Relief from the Automatic Stay. is; h:.::....JitJ. ~;;-".~ .,' Robert J. Woodside, Bankruptcy Judge cc: Judith T. Romano, Esquire One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Lawrence G. Frank, Esquire 2023 North Second Street Harrisburg, PA 17102 (Trustee) Austin F. Grogan, Esquire 24 North 32nd Street Camp Hill, PA 17011 , , ~ ,.., '..'- . . :-i ::;'i ,::;tJrg. PA , ,c.,': A.M.-P.M. ""..- f Kevin L. Collins Lori A. Collins 139 East Dewart Street Shamokin, PA 17872 'l\.. L J~ s:,:~:\,oort o uty Clerk \.i.~r::..:.__ ~1:!lii~*i!IHiill~~",~~~lli,i~'dj",j>il1l'.M.tii;;);!hJ>'~'~'i!c"",,,.Li;~J';il'.fr;c1),;i,;-,--...j~~",~~~,.,.,j;';";'~~-'1II' '--Ji.ii.~~~!Wl;>tl;.",,~W~.l!Il . C) ~ -uet Qln, ",,-:r. e;;.c: ;:$~. ~.c../ ~O )>0 C ~ ~-' "") <...." I i I I Q o - ,.~ l:.- e:: :z I co ---~ ,--,~-;;: 'Tl --,,-riTI .":c.' t~:) :'-., f >:..~'-:.\ ~~9, ~ -< :c. ::J::: o \0 ." ""-.= ~ - , '" , -., . "., - . Iiil!o&i . .. PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KEVIN L. COLLINS LORI A. COLLINS NO. 2000-5454 Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL WHOLESALE MORTGAGE CORPORATION. F/K/A RELIASTAR MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 MORNINGSIDE DRlVECAMP HILL. PA 17011 I" Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KEVIN L. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 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 ~ ",,",~ ~.~- ~ ,~~.."~ . ~., ,. , . '11 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) TMS MORTGAGE INC. D/B/A THE MONEY STORE 1770 TRIBUTE ROAD, SIDTE 100 SACRAMENTO, CA 95815 CITIFINANCIAL, INC. 6520 CARLISLE PIKE MECHANICSBURG, P A 17055 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 I ,', 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: i.1 NAME LAST KNOWN ADDRESS (If address cmmot be reasonably ascertained, please so indicate.) [,:!: " I 11 Ii None ~':: ,"I 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.) [: (':j I-j Ii !'J Tenant/Occupant 3010 MORNINGSIDE DRIVE CAMP HILL, P A 17011 ;,i Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. e.s. Sec. 4904 relating to unsworn falsification to authorities. ~ q,bL ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff June 5. 2001 DATE :~~~__~";'iI:&l~m"&:lli&~~h_..ciim~"iIiiOl"~~IAtc-",",."t':""'-0Il'''',;I.l'4nll'.i~,i:;;'~1'~j.";,,"iidN:1&lO~~~Ul!!lM'i::-!iE;l.illi!-~"==~~~~ T -- _ ~~~ ,_ "~'O_ ._." > , " ',,' .~~~, v.. ~~.~_ --Bi r ... 0 0 0 C -on s: '-- -~., -om S mrti -- 2:r I -.n"l 2r.;:; ,-, co J'....... ~~. ItL r:o "'"' j ::'i~ ~ g~ ~c :y.:: )>0 C ~ ~ ~::> \0 -< --- ~ ..~ ..~ .~ I I '""O<I#"il>i.,,:'l."! FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELlASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 2000-5454 KEVIN L. COLLINS LORI A. COLLINS Defendant(s). CERTIFICATION 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 (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. ~1~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~~W#%"QM~gJiffi,9..lli~",,&[~~1~lgW~Ill$i:~~"~"'''''''Wfl ,~ - '--~~--~~~-"'-'--"~< ,"",-~._~~" ~ r. ~ ,-- H ~_', " ,~, ~ .- !WII"" (") c :s: UOJ ITlrr Z""T'~ z-' (jjr;:: -<2:: r:o ;< ~() :;;;;0 C ~ ,~ ~~ -~~-''f,ij o ~~ '- c: -- - I CO ;~;~ {';::D ,~() CSi'"n s;! :n -< ;::r-~ ::;;: '0 to , -,..~~~ -. "......-~" - " ~ , 1..1. -='~"_:l.,1Zf:-" , AFFIDAVIT OF SERVICE , PLAINTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY N 0.2000-5454 DEFENDANT{S) KEVIN L. COLLINS LORI A. COLLINS Type of Action - Notice of Sheriff's Sale - ~ale Date: SEPTEMBER 5, 2001 SERVE LQRI A. c:9,LLINS AT . 139EASTDl'l~ART~TREET SHAMOKIN;PAI7872 SERVED ,="'... =~ ""'= ~mt; a ~ _ , D,C,_ """'" ~-::' {J://HL ,'"oG at9/~5 , o'cloc~.m., at A3c; . (////ztd!~ ~ ~ ~u, Connnonwealth ~ of Pennsylvania, in the manner described below: Defendant personally served. AduIt family member with whom Defendant(s) reside(s). Relationship is AduIt in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant( s) reside( s). Agent or person in charge ofDefendant(s)'s office or usual place ofbnsiness. an officer of said Defendant( s)' s company. Other: /' D~ Ag~ Heigh~ Weight~ Race~SexL Other I, ~t ~~, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subsc~ befor~ this !bL.: daj' of ~, 200_( Notary: ROBERT J..eOLTON, DISTF\1CT JUSTICE Northumbelland County. Pennsy!vanta MltQisWaI District 08.03-02 My ClImmlSSion expil8ll January 2, l!OOlI On the day of NOT SERVED . 200~ at o'clock _.m., Defendant NOT FOUND because: Moved Unkoown No Answer Vacant Other: Attornev for PI 'ntiff Frank Federman, Esqui~e - I.D. No, 12248 One Penn Center at Suburban Station 1617 John F. Kennedy BouIevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Sworn to and s bsc~ before me this day of 200 l Notary: "J.""""'''''~'_' ~ , ~i1~!IIj;i~~~Jlliii~j\\,w,lti,;*",;jj"""'i!-~lr"Aeg~iJJmi;,"k]12:.iliorl~j;o,;"f.'I'jt:i1l!}JI~,'Oh~"lffillilJi5I'-$il,~"^,,;,(;li,,I~~.Jl>>i! ,o~ """-_'~'" ,"_~"",,. "~,~ ,. ._ .~'"'"'~","'" -","-"",' """"'".,","", '"", o c: 7 v(iC rrl\". ~i' ~\.:' ~~'" __no :.; ~ " "pi ~~" '" c:,. \,C "..~. ,nj ::(~ '-~] ': ~- :' '\ 1 ;~ , , 'r-t:" ~i't :'~':-'~~:::H 1\ ,.",',f.," ",."""",,,~. '"" -., ~~~ -~. '''~ ~~ -, .- ~" ~, AFFIDAVIT OF SERVICE PLAINTIFF PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY N 0.2000-5454 DEFENDANT(S) KEVIN L. COLLINS LORI A. COLLINS Type of Action _ ;Notice of Sheriff's Sale Sale Date: SEPTEMBER 5, 2001 SERVE KEVIN L. COLLINS AT 139 EAST DEWART STREET SHAMOKIN, PA 17872 SERVED '''"':' 0"""'" Imo~. ~a~~ . _rum, ~ ,'" ~"'({,aL- . ",,1, a~l/..5 , o'clock/.f..m., at tJ' '/~?~f ~ .Connnonwealth of Pennsylvania, in the manner described below: Defendant personally served. /7 .~ ) ~ Adult family member with whom Defendant(s) reside(s). Relationship is ';?t//. Adult in charge of Defendant( s)' s residence who refused to give name or relati hip. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: A~ 4f'O / / Heigh~ Weighrf?flf Race~SexE- Other I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and suJl,qf~d befor\:jB/e this ~1.y of ~ VI>'-' ,200. Notary: By' ROBERT HIOLtON, OISTflICT JUS1'i~ NotII'lumberland CounlY. Penl1~y!Van1a NOT SERVED . Moll/islaml District O.O~ My Oimlml$lllon Ei$ltllll Jlll1uary 2. 201lil On the . day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unkoown No Answer Vacant Other: Attorne for aintiff-...__ Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 - . .~'~!li~iilii1i!!:l!";~Ji:jWw~"'!kiiiI~,,"-"'iL""I""l"1i:;i',,"b."~~J,,"",,:,;;~~~!iI~iUI~_!OOlm~"""l'=--l1 bJl __.a .~ ...,...., ;:..:~- ,>-' ~,- P)!--, (~. .-<..., ~ ~ ~~ .,~, ' " ,1',) '),..'A .".<I!..f '.:";:'_ < r ,.; .' ',; ,- ", .~~ ,,:", ",.~} " "'"\l'.j.l ,": ~ :: ,. . . o ~ c::- t"<>.~ ,~l I..C I",. ')'t J'.~';,\ I, '"!i --::','." ,'i Ii .c.'.W " , .",,1 ~.w~~ . ~'_. > ... Principal Wholesale Mortgage Corporation F /KJ A Reliastar Mortgage Corporation -vs- Kevin 1. Collins and Lori A. Collins In The Court of Common Pleas of Cumberland County, Pennsylvania No.2000-5454 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Law Library County Levy Postpone Sale Surcharge Certified mail Mileage Law Journal Patriot News Out of County Northumberland County Share of Bills 30.00 14.56 15.00 15.00 .50 1.00 15.00 20.00 30.00 2.30 8.68 265.40 197.58 9.00 93.14 25.53 $ 742.69 Pd by arty 02/27/01 Sworn and subscribed to before me ~~ This .( f~ay of j~ 2000, A.D. qJh' C. "hw;, / ~ r onotary / R. Thomas Kline, Sheriff BY~ Real Estate Deputy I.~-n ck 31Sd (2w. If) f) 3 1 ~,_.__M_" ." ~~ ........ ~ I ,___ ~....'.,' ~ .. ~ .. PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KEVIN L. COLLINS LORI A. COLLINS NO. 2000-5454 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FIK/A RELIASTAR MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 MORNINGSIDE DRIVE , CAMP HILL, PA 17011. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KEVIN L. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 2. Name and address ofDefendant(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"~ ~~ ~, , -- ~,,: .. 4 , .. 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.) TMS Mortgage Inc. d/b/a 1770 Tribute Road., Ste 100, The Money Store Sacramento, CA 95815 Citifinancial,Ine. 6520 Carlisle Pk., Mechanicsburg, P A 17055 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.) I; , I'; I:~ J'; j"; 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 3010 MORNINGSIDE DRIVE CAMP HILL, P A 17011 ~~ i"' I I l Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 2~ Attorney for Plaintiff October 27.2000 DATE ~ .~" "~ .-' " -:_~ '''io_, .. .... . . ... PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FfKJA RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY No. 2000-5454 Plaintiff, v. KEVIN L. COLLINS LORI A. COLLINS Defendant(s). October 27,2000 TO: KEVIN L. COLLINS LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, P A 17872 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VB PREVrOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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 3010 MORNINGSIDE DRIVE, CAMP HILL, PA 17011. is scheduled to be sold at the Sheriff's Sale oIl March 7, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PRINCIPAL WHOLESALE MORTGAGE CORPORATION. F/KJA RELlASTAR MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the _June 6, 2001_ Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take 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 Qut 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. "" ;~'<"'",~-~,-,,""'~"'"_.'~ "'~,-~ ." -:.:! I ! , , ~. ., You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE C~ISI.:J!;, PA p013 (717) 249-3166 (800) 990-9108 ~ o fu ~ I I I I I I I , I , I , I I I I 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 within 30 days of the sale. 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 the distribution is filed. 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. . ~. ,~ ~~ . ": . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-5454 CIVIL ~ TERM CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland COUNTY: Principal Wholesale Mortgage Corporation F/K/A To satisfy the debt, interest and costs due Reliastar Mortgage Corporation PLAINTIFF(S) Collins, 139 East Dewart Street, Shamokin, PA 17872 from Kevin L. Collins and Lori A. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also d\rected to attacht!1~ property of the defendant(s) not levied upon in the possession of ~, '"":t'_'J"~, ,.-t> . ..". GARNISHEE(S) as follows: . .. and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of ttie defendant(s) and fror[l delivering any property of the defendant(s) or otherwise disposing thereof; . ~ ! (3) If property olthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other thana named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. l.l. Due Prothy Other Costs $.50 $1.00 Amount Due $116,601.15 from 10/10/00-03/07/01 - $2,835.68 Interest and Costo Atty's Comm % Atty Paid $?06 60 Plaintiff Paid Date: October 31. 2000 Curtis R. Lonq Prothonotary, Civil Division ~ kZtJ.-, ~ 2. ~.-.___/ Deputy REQUESTING PARTY: Name Frank Federrran, Esq. Address: Two Penn Center Plaza,- Suite 900 Philadelphia, PA 19102 Attorney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 ,"- -~~--,'" , .1 'e;. ~ -, '-~1H"J:"~~-., --, ~ 1iilI~ '--".""-"!~'''~-'WjtJl.~"~~ ~",.. """...... ~- "~'-="'-~=I"~lIIiI . REAL EST A:fE SALE No.3 1.111 ~ J, :;l.r>'O the sheriff levied upon the defendanl;, interest in the real property situated in J,u..... - 41ft. 1,n...jL-" Cumberland County, Pa., known and numbered as: 3()I"mlr'tl:..,JJ-~ ~ and more 1ulI; (lescribed on Exhibit "An filed with this writ and by this reference incorporated herem. "'lte:,A::J 1M. "'~'L. ~ :J.nO By:Dfii:l~ ~ ~ ~ '. nt;l- "'~, 'v..,_...... E" ii -, -~ -~ .=0,="". ,# , . PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY No. 2000-5454 Plaintiff, v. KEVIN L. COLLINS LORI A. COLLINS -'" Defendant(s). June 5, 2001 TO: KEVIN L. COLLINS LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, P A 17872 .- **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, 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 3010 MORNINGSIDE DRIVECAMP HILL, PA l70llis scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PRINCIPAL WHOLESALE MORTGAGE CORPORATION. FfKlA RELlASTAR MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5,2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. <--~ ~--=,,-"' -"","-" . -, ""'~ , , - "=-'= - -~, "',~-~; ". You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. -, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. .- 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state 'Yho will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~ ~ ~...","",'~-..., . -.. DESCRIPTION .~ ALL THAT CERTAIN lot or piece of land situate in Lower Allen Township, Cumberland County, State of Pennsylvania, bounded and described as follow, to wit: BEGINNING at an iron pin., said iron pin being seven hundred thirty-five (735) feet east of the northeast corner of Thirty-second Street and.Morningside Drive; thence eastwardly along the northern side of Morningside Drive, sixty (60) feet to an iron pin; thence northwardly along the line of property now or formerly of Harry R. Lukens and Daisy N. Lukens, his wife, one hundred fifty (150) feet to an iron pin; thence westwardly along the line of property of the Pennsylvania Railroad, sixty (60) feet to an iron pin; thence southwardly along the line of property now or formerly of Luther W. Andrews and Agnes E. Andrews, his wife, one hundred fifty (150) feet to an iron pin, the place of BEGINNING. BEING Tax Parcel Number 13-23-0551-148 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kevin L. Collins and Lori A. Collins, his wife, by Deed from Luther W. Andrews, widower, by his Attorney-in-Face Sharon A. Hargrave, dated 9/23/96, and recorded 9/24/96, in Deed Book 146 Page 443. ~~lMj--".'Mi!l$M'J_.1."<!il"iM~,~"''''''_-i-'''w!i",..MJl&''''ct\@ji"",*j~~~~--~1M11I1Jrl!i!:fJ~!!l~~1 _~_,,_":~: E~::~] .11 r "-~ -,," ~" ,,~-~ - ~ -".~, - - -~~- - - .~,' o 5S "TJ63 tf1f'n ~:1'! c.6); ~"- ~~ ~- "",0 ~O C ?j ,:::> \0 ''[ 'n.~lfl[ ~ I!ilhl o '- c::: =e , O:l o "n i;~~;;g -C,rTi ~~~i t!; ~~j~ (JfTI ;g =0 -< ~ 3: - - ~ . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FORPLAmTIFF COURT OF COMMON PLEAS CIVIL DIVISION PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION 711 illGHSTREET DES MOINES, IA 50392-0780 TERM Ct:lT~ Plaintiff NO. CC - 54SI..( v. CUMBERLAND COUNTY KEVIN L. COLLmS LORI A. COLLmS 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE "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 AND TIDS DEBT WAS NOT REAFFIRMED, TIDS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: 40369928 !IU.. -ill """", 1. Plaintiff is PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/KJA RELIASTAR MORTGAGE CORPORATION 71 I HIGH STREET DES MOINES, IA 50392-0780 2. The name(s) and last known addressees) of the Defendant(s) are: KEVJN L. COLLINS LORI A. COLLINS 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 2/21/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1367, Page 292. By Assignment of Mortgage recorded 6/9/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 549, Page 587. 4. The premises subj ect to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified hy written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 7..' =' -':b,- 6. The following amounts are due on the mortgage: Principal Balance Interest 3/1/00 through 8/1/00 (Per Diem $23.45) Attorney's Fees Cumulative Late Charges 2/21/97 to 8/1/00 Cost of Suit and Title Search Subtotal $107,008.23 3,611.30 4,000.00 484.28 550.00 115,653.81 Escrow Credit Deficit Subtotal 717.61 0.00 717.61 TOTAL $114,936.20 7. I The attorney's fees set forth above are in conformitX 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 tolthe Sale, reasonable attorney's fees will be charged. ' 8. , This action does not come under Act 6 of 1974 bec*use the original mortgage amoilllt exceeds $50,000. I I The Combined Notice has been sent to the Defendart(s) by regular and certified mail as required by 35 P.S. g1680A03c on the date(s) set fqrth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." : I The Temporary Stay as provided by the Homeown~r's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the *aintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attache4 hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance haslbeen rejected by the Pennsylvania Housing Finance Agency. I WHEREFORE, PLAINTIFF demands an in rem Judgment ~gainst the Defendant(s) in the sum of $114,936.20, together with interest from 8/1/00 at the rate ~f$23A5 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and I sale of the mortgaged property. : ?-~r~ /s/ Frankl Federman FRANK IfEDERMAN, ESQUIRE Attorney for Plaintiff 9. 10. " ~, ~ - "-. '.0 - 136231:001:MELISSA SELLERS: Imago 1 of24 Residential Mortgage, Inc. A Comp8"rOt me Prindp.ll Fmanci8J GJO/JP Principal Residential Martgage, Inc. Plan Ahead. Get Ahead.- Loan Number 4036992-8 June 2, 2000 Kevin L. Collins 3010 Momingside Drive Camp Hill, PA 17011 RE: Kevin L. & Lori A.Collins 3010 Momingside Drive CampHill,PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSlURE This is an official notice that the mortgage on vour home is in default and the lender intends to foreclose. Soecific information about the nature of the default is provided in the attached Dal!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM tHEMAP) may be able to help to save vour home. This notice exolains how the program works. To see ifHEMAP can l1eh. YOU must MEET Willi A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF TIlE DATE OF THIS NOTICE. Take this Notice with YOU wheE yOU meet with the Counselilll! Agency. The name. address and ph)ne number of Conswner Credit Counseling Agencies serving YOUr County are listed at the end of this notice. If YOU have any auestions. you may call the Pennsylvania Housing Finance Al!encY toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869. : \e}U"\\S\T \\f\\\ Des Moines, Iowa 50392-D78) II " , -.- it--"",i, o 136231:001 :MELISSA SELLERS: lma e 9 of 24 I' Ii r; ! I i' Residential Mortgage, Inc. A Compsnyal tM PnncipaJ F1fI8nCia/GrDup Principal Residential MOTigage, Inc. Plan Ahead. Get Ahead." , i' I'. I: ! June 2, 2000 Lori A. Collins 3010 Morningside Drive Camp Hill, PA 17011 RE: Kevin L. & Lori A.CoIlins 3010 Momingside Drive Camp Hm, PA 17011 Loan Number 4036992-8 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on YOUr home is in default. and the lender intends to foreclose, Specific information about the nature of the default is orovided in the attached oa!!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to save your home. This notice explains how the program works. To see ifHEMAP can hel]). vou must MEET WITII A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DA YS OF TIlE DATE OF THIS NOTICE. Take this Notice with yOU when you meet with the Counselin!! A!!encv. The name. address and ohone number of Consumer Credit Counselin!! Agencies servin!! your County are listed at the end of this notice. If vou have anv Questions. YOU mav call the Pennsvlvania Honsin!! Finance A!!encv toll free at 1-800-342-2397. (Persons with imoaired hearing can call (717) 780-1869. ~~\~<< \\t:.. Des Moines, Iowa 50392-078l . ~ -.O""'l<i.., , 13623l:00l:MELISSA SELLERS: ~~ 2 0[24 i.' \,: This notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to explain it. You may also want to cOlltact an attorney in your area. The local bar association may be able to help you find a la';vyer. LA NOTIFlCACION EN ADJUNTO ES DE SUMA IMPORT ANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO EST A AGENCIA (PENNSYLVANIA HOUSING FINACE AGENCY) SIN CARGOS AL NUMERO MENCIONDO ARRlV A. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ORIGINALLENDER:unknown CURRENT LENDER'SERVICER: Princioal Residential Mortgage. Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE fClR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS If you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (The "Act"), you may be eligible for emergency mortgage assistance: . If your default has be,:n caused by circumstances beyond your control, . If you have a reasonable prospect of being able to pay your mortgage payments and, . If you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of forecJ,)sure on your mortgage for thirty (30) days from the date of this Notice. During that time :rou must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEF AUL T'. EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DA TE. CONSUMER CREDIT COUNSELING AGENCIES- If you meet with one of the consumer credit counseling agencies listed at the end ofthis notice, the lender may NOT take action against you f01 (30) days after the date of this meeting. The names. addresses and telephone numbers of desienated consumer credit counse1illl!. agencies for the county EXHIBIT "A" ~. , ~', . 136231:001:MELISSA SELL~~~Jmaga2.~L24 .. in which the oropertv is :,ocated are set forth at the end of this Notice. It is only necessary to schedule om: face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infonnation about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit cO\lllseling agencies have applications for the program and they will assist you in submitti ng a complete application to the Pennsylvania Housing Finance Agency. Y our applicatio:~ MUST be filed or postmarkcd within thiny (30) days of your face-to-face meeting. ~ I' F' c, ~: YOU MUST FILE YOVR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FOIlECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding will be pursued against Y(IU if you have met the time requirements set forth above. You will be notified directly hi the Pennsylvania Housing Finance Agency of its decision on you application. Note: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION ))URPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECf THE DEBT. (If you have filed blmkruplq you can Slill apply for Emergency Mortgage Assistan<:e.) HOW TO CURE YOUR MORTGAGE DEFAULT /BRING IT UP TO DATE). EXHIBIT DAD - .~ ',' ....c,- , 136231:001:MELISSA SELLERS: Imag~ 4 of24 ~-, - r~ P I ! NATURE OF DEFAULT-The MORTGAGE debt held by the above lender on your property listed above: IS SERIOUSLY IN DEF AUL T because: I; !-; c j;' YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: April through June in the amount of $3180.83 c~ ~? t;- " f~ " B.YOU HAVE FAILED TO TAKE THE FOLLOWING ACTlON:(not applicable): [C' HOW TO CURE Tm~ DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $3180.83, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WInCH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cashier's check. certified check. or money order made payable and sent to: i; ~ f Principal Residential Mortgages, Inc 711 High Street Des Moines, Iowa 50392-077 IF YOU DO NOT CURE THE DEF AULT-lfyou do not cure the default within TIllRTY (30) DAYS oftile date of this Notice, the lender intends to exercise its rie:hts to accelerate the morte:a!!:e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (3(') DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose lI~Don your mort!!:and orooertv. IF THE MORTGAGE IS FORECLOSED UPON. The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure thl: delinquency before the lender begins legal proceedings against you, you will still be requ:.red to pay the reasonable attorney's fees that were actually incurred, up to $50.00. HClwever, iflegal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY neriod. vou will Dot he reauired to Day attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. EXHIS/TUAU , " .J:.1cl:ii!lll!oiilliO'i<- ,136231:001:MELISSA SELLERS: Image~5 of24 RIGHT TO CURE TilE DEFAULT PRIOR TO SHERIFF'S SALE:-- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ril!ht to cure the default and prevent the sale at any time UD to one hour before the Sheriffs Sale, You may do so by Davin!! the total amount then Dust due. olus anv late or other charl!es then due. reasonable attornev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as snecified in writinl! by the lender and by Derfonninl! any other reQuirements under the mortl!al!e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. , r; I ~", ' EARLIEST POSSmLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be aooroximatelv SIX (6) months from the date orthis Notice, A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the req~~ired payment or action will be contacting the lender. HOW TO CONTACT THE LENDER: Principal Residential Mortgages, Inc. 71 I High Street Des Moines, Iowa 50392-077 Phone 1-&00-962-4450, extension 77 Fax (515) 247-6554 Contact Person: Tanuny Clark EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings coul d be started by the lender at any time. ASSUMVION OF MORTGAGE- You Dmay or ~may not (CHECK ONE) sell or transfer your home to f' buyer or transferee who will assume the mortgage debt., provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and tat the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY 10 OBTAIN MONEY TO PAYOFF 1HE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. TO HAVE nus DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO 1HE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE 1HE RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) EXHIBIT "N -, .,-, ~,,-{; , 136231:001:MELISSA SELLERS: 1ma e 6 of24 !' f " ;':' ti, " TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, ~]' TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ~i- i:;- I e "i' CONSUMER CREDIT COtNSELING AGENCIES SERVING YOUR COUNTY ARE LISTED ON THE ATTACHED ENCLOSURE. ,: i: I k i I I I I I Ii i:x. It/Slir "Jl" ..... ~~..." :: , 136231:00 I :MELISSA SELLERS: 1m. e 7 of 24 i!l- II 'lir-' ,,-:~ I', ~ i~ I j, " !'-, "" Notification To: [: r I !: !:onsumer Credit Counselinl!: Al!:encv Date: Name of Mortgagee: I ! t: Address: I; I'; I,., I I; ;~ :c' I,; In accordance with the Pennsylvania Homeowner's Emergency Mortgage Assistance Program (Act 91 of 1983), we have been approached for mortgage counseling assistance by: ----------------------...----------------------------------------------------------.----- Name of Applicant -~-------------------------------------------------------------------------------------- Address ----------------------------------------------------------------------------------------- Telephone Number Mortgage Loan Number Address of property on which mortgage is in default, If different from above. The counseling agency met with the above named applicant on Date Who have indicated that they are more than sixty (60) days delinquent on their mortgage payments and have received notification ofintention to foreclose from Principal Residential Mortgage, Inc. 71] High Street Des Moines, Iowa 50392-077 In accordance with the Homeowner's Emergency Mortgage Assistance Program, this is to inform you that: ExHIBrr '~" ~, . ~, _~_ - 1< - 136231:001:MELISSA SELLERS: Image.8 of24 1. If the delinquency cannot be resolved within the 30 day forbearance period as provided by law, the applicant listed above may apply to the Pennsylvania Housing Finance Agency for Eomeowner's Emergency Mortgage Assistance. 2. By copy of this Notic,~, we are notifYing all other mortgagees, if any, which the applicant had indicated as also having a mortgage on the property identified above. 3. It is our understanding that the 30 day forbearance period in which we are now in ends on July 2, 2000. 4. No legal action to enfJrce the mortgage may occur during this forbearance period, unless procedural timo~ limits were not met by the homeowner. Statemenh; of Policy Name of Counseling Agency: Signer and Title: Telephone Number:_ Address: EXHIB"'~' ,- ,,~ .., ,'- - .. - ~,' ~, -~,-,,~ Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lt"'",u:g-~linton COUllti.. 21;8'TI;;:~ t:e~o=W1ity Action (STEP) P. O. Box 1328 W'tlli:unsoo_ p. 1~-03 (5-0 3 . ,~ .." " , ) 26-Q587 F_~"'l: (570) 322-2197 cees oOfor..heaster:t P;\ 201 Basin Street . (Wi5!P0=)' 3 PO"" PA 17703 , 2.3.0627 F.~"'l: (570) 32.3'0626 CLIN'rON COUNTY cces oiNortheastern P;\ 16~1 S Atherton St . Swte 100 Sl::lte COllege, FA. 16801 (814) 2.38-3668 FA."'l:(814) 238-3669 COLUMBIA comtn CCCS of Nor..heastern Pennsvlvania 1400 Allington Executive Park Suite 1 Clarlts Summitt PA 18411 (570) 587-9163 or (800) 922,9537 FA."'l: (570) 587-913419135 31 W. Market Street POB 1127 W'ill<es-Barre. PA 18702 (570) 821-0837 or (800) 922-9537 F.~"{ (570) 821-1785 Cor:nmissiQn on Economics Opportunity of Luzerne Count'J 163 Amber Lane W'tIkes-Barre, PA 18702 (570) 826-0510 or (800) 822-r059 F.~"{ (570) 829.1665-CALL BEFORE FAXING (570) 455-4994 HAZELTON F_~,,{ (570) 455-5631-CALL BEFORE FA."'aNG (5iO) 8.'364090 TUNKHANNOCK Booker T. Washington Center 1720 Hoiland Street Erie, PA 16503 (814) 453-574-1 FA."{ (814) 453-5749 John F. K.!nnedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAJe(814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Han".sburg. PA 17102 (717) 541.1757 Urban League oDletropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 F.~'{ (717) 234-9459 CO=Ullity Adon Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 F.~,,{(71i) 234-2227 CRAWFORD COUNTY Greater Erie CommW1it'/ Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAJe (814) 45&-0161 Shenango Valley U roan League, Inc 601 Indiana Avenue Fanell. PA 16121 (412) 981-5310 CtJMBERI.A..~ COu""N'1'Y Financial Counseling Serrices of Fr=kIin 31 West 3td Street Waynesboro. PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FA."{ (711) 731-9589 Adams COUllty Housing _'wthorit'/ 139-143 Carlisle St Gettysburg, PA 11325 (717) 334-1518 F.~,,{(717)334-8326 'EXHIBIT IJAII PENNSYLVANIA BU1..LETIN. V01... 29. NO. 2:].. JUNE S. 1999 .---~ ~~ ~~'!lIr."'_ 1\11 THAT CERTAIN lot or piece of land situate in Lower Allen Township, Cumber- land Ccuney, Sca~e of Pennsy~van~4, bo~ndQd and described as follow~, co w~c: BEGINNING at an iron pin, said iron pin being seven. hundred thirty-five (735) feee east of the northeast corner of Thirty-second S~reet and Morningsidm Drive; thence eascwardly along the northern side of Morn~ngs1de Drive, six~y (60) feet ~o an iron pin; ~hence northward~y a~on8 the ~ine of property now- or formerly of Harry R. Lukens and Daisy N. Lukens, his wife, one hundred fifty (150) feet to sn iron pin: chence westward~y .~Qns the l~ne of propercy of the Pennsylvania RailroGd, sixty (60) feet to an iron pin; chence southwardly along the line of property now or fo~- merly of Luther W. Andrews and Agnes E. Andrews, his ~ife, one hundred fifty (150) feet to an iron pin, the Place of BEGINNING. BEING THE SAME PREMISES which Harry L. Anderson snd Arlene H. Ande~son. his w~fe, by ~heir Peed dated July 26. 1957 and recorded in the Office of the RecQrder of Deeds in and for Cumber~and County ~n Deed Book Y. Volume 17, Page 494, 8ran~ed and conveyed unto Luther W. Andrews and Agnes E. Andrews. h~s wife. The sa1d Agnes E. Andrews ~~ed February 4. 1990 thereby vesting sole t~tle unCo Lucher W.-Andrews. w~do~er, Grantor herein. 'Th~ said Lu~he~ W. ~drewsJ by a General Power of Ateorney dated Apri1 9, 1990, d~d appo~nt Sharon A. Hargrave as his A~eorney-in-Fact. Sa~d Power of Attorney ~s in~ended Co be rQcorde4 eontem- poraneous2y herew~th. - PREMISES: 3010 MORNINGSIDE DRIVE .~ -" ~ d,' k VERIFICATION VICKIE JAKSICH hereby states that she is FORECLOSURE MANAGER of PRINCIPAL j f n : RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that he/she is t ;):, ,i i~. '. authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his /her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn I , , i i l. i falsification to authorities. -j~ ): b i DATE:~ ~} bO JOOII!IL liIIIiiliIIlifom..~'.L., -~. ~"'~""""'''' . Htl;&iil!IIWil'lrun,""J~ilfi:tli.~~"-1--- >"'- -" ~>< -, --, tl1a ~~.",--., , -~. "" ~ --p (J ~ ~ n 0 0 ~ 0 -n It- ~ "'" :;:1. 8 !'l lr} C5 "'tlro c:: !:2C' '" j-;n'IJJ . -,:1 B C tic.: I ;~? .0 V) ~z -.I "<) '-0 () () :,:;:0 ~(~) "'" :r:+1 CI) ~ J . ~o ::r: O~ 20 Iv ~ p:! ~ ~2 '? Om ~ ~ ~ 0 'j;! :0 'D -< ~ '-( .. ~u _ .. ~ .". "- - ',I .. SALE DATE: SEPTEMBER 5,2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FfKJA RELIASTAR MORTGAGE CORPORATION No.: 2000-5454 vs. (:) S~ ~~y ~~.. ):0:<": 7 ~ ::> f=' o :" ;'1 " I KEVIN L. COLLINS LORI A. COLLINS .;:-- c':; AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 3010 MORNINGSIDE DRIVE. CAMP HILL. PA 170ll. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required byPa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. F FEDE At omey for Plainti August 14, 2001 , 'I PRINCIPAL WHOLESALE MORTGAGE CORPORATION, F/K/A RELIASTAR MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KEVIN L. COLLINS LORI A. COLLINS N0:'2000-5454 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) PRINCIPAL WHOLESALE MORTGAGE CORPORATION, FIK/A RELIASTAR MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 MORNINGSIDE DRIVE CAMP HILL. PA 17011 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KEVIN L. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 2. Name and address ofDefendant(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.) .. TMS MORTGAGE INC. D/B/A THE MONEY STORE 1770 TRIBUTE ROAD, SUITE 100 SACRAMENTO, CA 95815 - "" CITIF1NANCIAL, INC. 6520 CARLISLE PIKE MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.)- None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~L ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff June 5. 2001 DATE -'- - ., - - ." "' DATE: June 5, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) KEVIN L. COLLINS LORI A. COLLINS PROPERTY: 3010 MORNINGS IDE DRIVE CAMP HILL, P A 17011 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street, Carlisle, P A. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. 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"' r:1' " ., C(O "l:I ;0. <"l III ~ "' F "l:I ;0. - c:l - w - ..., - Q '" r S' '" .~ !2~~ en003 CD a (D ::. <n III Oo<n::. to 00 ... ~IB' .~ o 3l lil :J> 0. 0. 0; "' "' ~O"" "1Jcn;:::lm 2:......(00 Eir--...J."m c.c...m;:;o C1l 0 :J :s: -o:T:J)> :::;:J -'.,., () z OJ. C1l > ~^s-z }>~..,o ->'~~"1J ~a.C/)I 0,< c m WlJJo-r ~oC:)> Q:)~a-z ~C1lOJ ""<:J ~(J1 Q. ..., . OJ CJ)e leg (D~ o C1l ;;:~ . a a ." o "' or <0 '" -n '" '" ',M~""""""'" Principal Wholesale Mortgage Corporation F /kIa Reliastar Mortgage Corporation ,~_."d._' __,_,,__~__,~__~~~_._~~"..~-.->___~___._ In The Court of Common Pleas of Cumber!~~_County--,- Pennsyl~~ia .~ --Mf;';,li 'I! 'I il Ii I 1 " ! :-, . " I ,I , , II ii' i :1 STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler ' I, ______________________________________________________________________________Ilecorderof Deeds in and for said Counly and State do 'hereby certify that the Sheriff's Deed in which ________________ J)~\!~.!'AL!8!'_tj.q!!!'.l_!.!qE_t_~~g=_-'~!:~.?_c:.~~~_i_':.~___ ____________________________________ is the grantee the same having been sold to said grantee on the _______________________.?_~~____________________ day of September .2001. . . ________________________________________ A. D., , _____, under and by v.rtue of a wnt______________ Execution . _________________________________ ________ _ _ _____lSSued on the _ ______ltt4 __ ___ ______ ____ ___________ June 2001 cbly of __________________________ A. D., _____, out of the Court of Cornman Pleas of said County'as of Civil _____________________ ----- --__..._ --_ _______ ___ __ __ ____ ___ _________________ _______ Term, Z OO.Q____ Number ___2~.?_4:~_____, at the suit of -l?uuc.ipaLRh.o.le.s.a..le_M.Q.ttg,;1..&.~_~_'1.1:E_J'L~L~__~~!i_':~~~!___ Mortgage _________________ ----_____________ __ against_ .K.~yj.1!. _I: _~__~ Q!J __4_92}.!!!l_s_____ __ ____________ __ _ is duly recorded in Sherifr. Deed Book No. _-*.~tl_______, Page __~3_l!.!_____. IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office this ____?:_~__ day of __________~_________ A. D., ,;I-,Cf_9__l --~--~._-~I---~- Ilecorder of Deeds IlIltIlnleI oIlleeds. Cumbell8mI CGunty, Cadis\e, PA My CommiSSioft E!pires the filsl Mandl, a1J1a._ .Hm ""-~'"",...""'-"'j~~O -~ . ~~-t<-\"_ the same, Federal National Mortgage Association of 1900 Market Street, Suite.800, Philadelphia, PA 19103, being the buyer in this execution, paid SheriffR. Thomas Kline the surn of $1,630.93. Sheriffs Costs: Docketing $ Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 30.00 700.00 15.00 15.00 30.00 10.00 1.00 9.75 1.37 15.00 30.00 270.05 225.60 25.66 25.00 2L.i!l $1,430.93 paid by attorney 10-05-01 Sworn and subscribed to before me So Answers: This 3/~dayof(!)~ ~~.,.,...<~ - ~ R. Thomas Kline, Sheriff 2001, A.D. n~ O. ""]p"pP,. ~AK q ~ \' -Ii rothonotary BY . () "JtYLLJY\ Real state Deputy ~.~ jO'oV ~ "lJ1! en... .j'-l'l/~ (2v-,11'i30r .M"'c~ <." '"",_l .~< SCHEDULE OF DISTRIBUTION SALE NO. 55 Writ No. 2000-5454 Civil Term Principal Wholesale Mortgage Corporation Flkla Reliastar Mortgage Corporation VS Kevin 1. Collins and Lori A. Collins Filed October 5, 2001 Date of Sale: Buyer: Bid Price: September 05, 2001 Federal National Mortgage Association $35,000.00 Real Debt Interest Attorney writ costs $116,601.15 6,326.1 0 961.79 Total $123,889.04 Distribution Amount Collected Legal Search Sheriff's Costs $1,630.93 200.00 1,430.93 So Answ,;;;, / ~ .r~mlv'<'1 ~ " R. Thomas Kline, Sheriff c.1 "V'!I1IlIJl;~lliPlI~". '. ='"' -~.,- <~~ n".,~" j: '.'< ".. L!$!Wi;\l~~.,". \- ',h ,_.~" .<~....... . , ., TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WIDCH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 55 Held Wednesday, September 5, 2001 Date: September 5, 2001 TAXES: Receipts for all taxes for the year 1998 to 2000 inclusive. Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriffto dated ,2001, and recorded ,2001, in Cumberland County Deed Book ,Page RECITAL: BEING the same premises which Luther W. Andrews, widower, by and through his attorney-in-fact Sharon A. Hargrave dated September 23, 1996 recorded September 23, 1996 in the Office of the Recorder of Deeds in and for Cumberland County in Carlisle, Pennsylvania in Deed Book 146, Page 443 granted and conveyed to Kevin L. Collins and Lori A. Collins, his wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of 32nd Street and the roadbed of Morningside Drive. 6. Building and use conditions and restrictions as set forth in Deed of Paul L. Cressman and Lenora O. Cressman recorded in Deed Book "T," Volume 13, Page 33 and other deeds of record of Paul L. Cressman and Lenora O. Cressman, which restrictions may be imposed by implications on the subject premises. 7. Mortgage in the amount of $110,000.00 given by Kevin L. Collins and Lori A. Collins - - '-"" . J.....~, ~ i."~ '~>k"'- ~o AccuBanc Mortgage Corporation dated February 21,197 recorded February 27,1997 In Mortgage Book 1367, Page 292. Complaint in Mortgage Foreclosure filed by Principal Wholesale Mortgage Corporation as Plaintiff against Kevin L. Collins and Lori A. Collins as Defendants in the Office of the Prothonotary of Cumberland County to file number 2000-5454. Default judgment entered October 13,2000 in the amount of $116,601.15. 9. Mortgage in the amount of $16,910.54 given by Kevin L. Collins and Lori A. Collins to TMS Mortgage, Inc. dated June 20,1997 recorded June 29, 1997 in Mortgage Book 1396, Page 7. 10. Mortgage in the amount of $10,970.22 given by Kevin L. Collins and Lori A. Collins to Citifinancial dated December 1, 1999 recorded December 6, 1999 in Mortgage Book 1585, Page 1025. 11. Rights granted to the Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 82, Page 224. 12. Rights granted to Pennsylvania Power and Light Company by instrument recorded in Miscellaneous Record Book 82, Page 122. 13. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 14. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to the improvements on the subject property. 15. Satisfactory evidence to be produced that Plaintiff in the above referenced foreclosure action was the proper party to bring the action. It is to be noted that the holder of the mortgage of record is AccuBanc Mortgage Corporation. 16. Real estate taxes accruing on and after January 1, 2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be vali or bi until countersigned by an authorized signa ... REAL ESTATE SALE NO. 51 Wlit No. 2001,1728 Civil Manufacturers & Traders Trust Company, Successor By Merger With Keystone Financial Bank. N.A.. Successor In Interest To Farmers Trust Company vs. Douglas S. Graham and Margot B. Graham Atty.: Bonnie Dahl ALL that certain tract ofIand with the improvements thereon erected, situate in the Fifth Ward of the Bor- ough of Carlisle. Cumberland Coun- ty. Pennsylvania. more particularly bOWlded and descrtbed pursuant as follows: BEGINNING at a point on the Northern Line of Gobin Street, which point is westwardly 315.79 feet from the Eastern boundary line of land Hamilton Development thence along the Northern line of Gobin Street by a CUl"Ve to the left, having a ra- dius of 403.62 feet in the center line of said street. Westwardly 80 feet to a point on line of land now or formerly of Reisinger Brothers. Inc.; thence by the latter land. North 20 degrees 47 minutes West, 122.65 (erroneously referred in Deed as 122.56) feet to a point on line of land of Carlisle Fair Association: thence by the latter land. North 70 degrees 41 minutes East. 87.43 feet to line of land now or formerly of Robert E. Wall and wife: thence by said Wall land. South 17 degrees 16 minutes 14 seconds East. 127.43 feet to the Place of BEGIN- NING. BEING THE SAME PREMISES which John A. Karagiannls and Ana, Ua S. Karagiannis, husband and wife by Deed dated December 7, 1987 and recorded December 7. 1987 in the Recorder's Office in and for Cumberland County, Pennsylvania In Deed Book Volume B33. Page 1006, granted and conveyed unto Douglas S. Graham and Margot B. Graham. husband and wife, the mortgagors herein. 5 ~~ ""'~~'-Jv i. '"^.._"'" " ~. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF'CUMBERLAND) . ... NO. 00-5454 CIVIL 1JX TE~ CIVIL ACTION, LAW - TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Principal Wholesale Mortgage Corporation, F/K/A Reliastar Mortgaoe Corporation PLAINTIFF(S) from Kevin L. Collins and Lori A. Collins, 139 East Dewart Street, Shamokin, PA 17872 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islare enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than,a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $116,601.15 L.L. from 10/10/00 to Y/~/Ul Interest (p",rrH"", $1<l 17) $fi1?fi.1O and costs Due Prothy Atty's Comm % Other Costs $1.00 Atty Paid Plaintiff Paid $961. 79 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division REQUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Suburban Philadelphia, PA 19103 Plaintiff 215-563-7000 12248 Station, Suite 1400 Attorney for: Telephone: Supreme Court 10 No. i'~"" it;;"~ ~II~"'_"""'H"- .>6'ilWwo;;~~'Il!!LIl/I"""~'Thiilo,~iiiib;il!~';"ll!!;,."il!l(~"","~~j~rr!B':- ,- ~~"'~~~OltllmtiMl!l\'!i~-~-'"'_ - liilA'--....~-~iiII! -,~ "'"' .. .. -' "' .. REAL ESTATE SALE No. 55 UlIOU~ /9, dXJ ( the 5heriffleviedupontheC1el~r:'''-'' interest in the real property situated in MlJ...J&J Ai) () 0 j1 ~ cumberlan~ County, Pa., known and numbered a~O fYlO"lfljit~ lJ~ . (luv<,(J iJ;J.Jl.and more fully described on exhibit "A" fHed with this writ and by this reference incorporated herein. By:%J~ ~ O-Puh; J 0ateJ.U r1L 19, ;; (JtJ / (--J c:v;] CVi1 c::::;::I G:e> WiI . \ -~\ ' , \_~ ",l __J U . ,- -' " '-'-'. ',' ,'''.;>,' " "\ \1\\1\ rc [, ,-(~wj .,.,'..1-,0 ,\\,\\..., '. ' ~~\\,1'-"'~"~ ' ~,> ~- -~, ~ ~ .-~~ ~~ ~ -~j-- r j' PRINCIPAL WHOLESALE MORTGA,GE CORj'ORATION, F/K/A RELIASTAR MORTGAGE CORl'ORATlON CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CML DMSION KEVIN L. COLLINS LORI A. COLLINS N0:'2000-5454 Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PRINCIPAL WHOLESALE MORTGAGE CORPORATION. F/K1A RELIASTAR MORTGAGE CORPORATION. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 3010 MORNINGSIDE DRIVECAMP HILL. PA 17011 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KEVIN L. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 LORI A. COLLINS 139 EAST DEWART STREET SHAMOKIN, PA 17872 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 hdlder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ~ TMS MORTGAGE INC. D/B/A THE MONEY STORE 1770 TRIBUTE ROAD, SUITE 100 SACRAMENTO, CA 95815 -, CITIFlNANCIAL, INC. 6520 CARLISLE PIKE MECHANICSBURG, P A 17055 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.)- None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~< ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff June 5. 2001 DATE ,,~ - ~'~ ~ <. --, '""~ 'i>I<l~- ~1d. <. j" ." PRINCIPAL WHOLESALE MORTGAGE' . CORPORATION, FIK/A RELlASTAR MORTGAGE CORPORATION ' CUMBERLAND COUNTY No. 2000-5454 Plaintiff, v. KEVIN L. COLLINS LORI A. COLLINS - .." Defendant(s). June 5, 2001 TO: KEVIN L. COLLINS LORI A. COLLINS 139 EAST DEWART STREET SHAMOKlN, P A 17872 **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 AND TillS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A ITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 3010 MORNINGSIDE DRIVE CAMP HILL, PA 17011is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by PRINCIPAL WHOLESALE MORTGAGE CORPORATION. F/K1A RELIASTAR MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. 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. 'llih;.'; I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. , "'" ',", ri it ~; ',i ~ ~1 ~~. '" I I I I ! ! ! ~ re I I I ! I I [ , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See' notice 'on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. 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 the distribution is filed. 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 REAL'ESTATESALENo.55 'Writ No. 2000-5454 ... C.fvnTerm , Principal Wholesale Mortgage Corporation ffkJaI Realiastar MOrt{,age ~iporation vs Kevin L,Colllns and Lori -J;.'~ CoUlins 'Atly: Frank Fedennan , DESCRIPTION , " , .AL~_THAr CERTAIN lot or pkcc of land ,>ilU'a{~ in . LoWt'f' Allen, Township, Cunibeiiarid 'COtiiuy. State of Pcnn~ylvariia, bounded aM dcscribt'd as follows; to wit: I BtQl~n\jG at <In iron pin, said iron pi'n : being' St'VL'n hundred thirty-fIve -035) feet , cii:;"t ,'''-of Ihl.' northe3~ cOmer of Thirty- i 's(Xxuld Street and Momlngside Driw; I tbenceea.slviardly..u()l1g the northern side of I M<:irriUig;,jJ~__Driw, '~lxty (60) k.c:(to~an iion - pin; northwardly along the line of. -pfoPt.'11Y now or form~r1y, of' H'arry R. I Lukens and Daisy N. Lukens, his ....ife, onc I hllndrctl fifty ,(50) foct 'to. an tron pin: thence \\'cstwal'dly :drmg the Hnc of : propertY of the Pennsylvania Railroad. :c;ixty , (60) feet to an irOll pin; thence.southw:mily aking ih<;: line of. property no'", or formerly of, Lutl1cr W. Andrews and Agne!'. E. Andrews,. his w,lft.:. one hundroo fifty (J501 feet, [0 an. iron pin, the place of BEGINr-:lNG. BEING .T:1\ P..lrccl Number 13-23-055[- I'll\. nTLE 1"0, SAID prcmi~es, J:., vestoo in Kevin L, Collins and Lo.ri A. Collin<;, his \'lite, by DCcJ fiuni Luther W Andrew,," wid~{.'by his /mof11t.'y-in-P:tct:.Sharon A. Har:gr.av.e~,da(cq 9f2.1/9f), and rcctmied 912AI : ~96. in,~ ~~~~~..~llge~~__~_ t""'""~ -^ , - "*' 0;<.",: <, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss James L. Clark being duly sworn according to law, deposes and says: 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot,News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 24th and 31st day(s) of July and the 7th day(s) of August 2001. That neither he nor said Company is interested in the 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; aM That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf 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 inli ellaneous Book "M", v;~:~~;~:; ;;;;;~~;;,;;;;;;;;;;~,;;;.~;~;;;~;;;;;m , M S ALE #55 NolarialS..l Tony L. Russell, Notary P HarriobUl1l, Oouphln County My Commission Ellp1res June 6, 2012 Member, PennsylVania Assoc:~tion 01 Nota", commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE 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 $ 224.10 1.50 225.60 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot,News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... "~ ,-,- '~" -. ESllWl1!!: ~ NCIl. 55 Writ No. 2000,5454 Civil Principal Wholesale Mortgage Corporation f/k/a Reliastar Mortgage Corporation VB. Kevin L. Collins and Lori A Collins At1y.: Frank Federman DESCRIPTION ALL 1HAT CERTAIN lot or piece of land situate in Lower Allen Town- ship. Cumberland Coun1y. State of Pennsylvania. hounded and de- scribed as follow. to wit: BEGINNING at an iron pin. said iron pin being a seven hundred thir1y-five (735) feet east of the northeast corner of Thirty-second Street and Morningside Drive; thence eastwardly along the north- ern side of Morningside Drive. sixty (BO) feet to an iron pin; thence northwardly along the line of prop' erty now or formerly of Harry R. Lukens and Daisy N. Lukens. his wife. one hundred flf1y (150) feet to an iron pin; thence westwardly along the line of property of the Pennsylvania Railroad, sixly (60) feet to an iron pin; thence southwardly along the line of property now or formerly of Luther W. Andrews and Agnes E. Andrews. his wife. one hundred flf1y (150) feet to an iron pin. the place of BEGINNING, BEING Tax Parcel Number 13, 23,0551,148. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kevin L. Collins and Lori A Collins. his wife. by Deed from Luther W. Andrews. widower. by~ Attorney,in-Fact Sharon A Hargrave: ~ dated 9/23/96. and recorded 9/ \. 24/96. in Deed Book 146 Page 443. \ ~ ~ .~ -~'-", . r PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.l784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe 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: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verity this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Ro~or SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 . NOTAR LOIS E. SNYDE~ PublIc CdiIe.Boro, Cull County My CoIIlII.lulon Exp/nla Man:h 5,2005