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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO, 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(? 1 <;) <;61-7000
COUNTRYWIDE HOME LOANJ, INC,
7105 CORPORATE DRIVE
PLANO, TX 75024
COURT OF COMMON PLEAS
CIVIL DIVISION
ATTORNEY FOR PLAINTIFF
Plaintiff
TERM
NO, (}-() -0004-
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v,
CUMBERLAND COUNTY
NORMAN R, NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
Defendant( s)
CTVlT, ACTTON - T,AW
MORTGAGE FORF,CT 'oSTJRF,
NOTWF
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HA VE 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, **
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 properly or other rights important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #: 4820224
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1. Plaintiff is
COUNTRYWIDE HOME LOANS, INC,
7105 CORPORATE DRIVE
PLANO, TX 75024
2, The name(s) and last known address (es) of the Defendant(s) are:
NORMAN R, NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described,
3, On 10/18/96 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No, 1347, Page 448, By Assignment of Mortgage recorded 12/5/96 the mortgage was
assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book
No, 536, Page 209,
4, The premises subject to said mortgage is described as attached,
5, The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 3/1/00 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith,
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6, The following amounts are due on the mortgage:
Principal Balance
Interest
2/1/00 through 7 !II00
(Per Diem $15,04)
Attorney's Fees
Cumulative Late Charges
10/18/96 to 7/1100
Cost of Suit and Title Search
Subtotal
$65,551.15
2,286,08
3,277.00
252.36
5.5ll.illl
71,916.59
Escrow
Cred it
Deficit
Subtotal
60,90
D..JlQ
6.O..2ll
TOTAL
$71,855,69
7, The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged,
8, This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000,00,
WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of
$71,855,69, together with interest from 7/1100 at the rate of$15,04 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property,
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FRANKFEDE
Attorney for Plaintif'
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ALL those cer-tain tracts of land and pr,mises sit.uate, lying and being in the Borough of Carliale
in the County or Cumberland. and Commonwealth of Pennsylvania, mOre part.icularly described as follows:
T.R.A.cr 1: On the West by NQrth Pitt Street; on. the North by land now or formerly of Albert.
Kelly; on the Eaet by Fairground Lane; and on the South by land now or Cormerty of John W. Spangler.
SRid premises having. frontage of twenty feet on Pitt Street, and tnC.tendlng back to Fairground Lane ..
distance of 140 teet, more or less.
TRACT 2: On the W_ by Pitt Street; on the No~th by land now or formerlY of AUc:e-M. Fry; on
the East by Creek Lane; and on the South by other lands now or fonner\y at John W. Sp""gle~.
Containing 6 reet In (ront on PItt Street and extending at an even width 170 reet, mo~e or IdS, to Creek
Lane aforesaid. '
l3EING the same premise.. whic:h Edward Stoner, by his Deed dated Apri129, 1991, om<! recorded
in. the office of the RecoJ"ael" or Deeds in and f"or Cumberland County, PexulSY1vaniA. in Deed Book ora",
Volwne as, Page 898. grNlted and. conveyed unto Thomas P. Tucker, Jr., Grantor herein..
KimbeTly R. Williams, of Cw:o.berland County, pennsylvania, joins in this Deed foZ" the expres$
purpose of oonveying any and all interests in said property purst.18At to an unrec:or<1ecl inst.allment sale
agreement between Thomas P. Tucker, Jr. ....d XlInberly R. Williama dated June 1. 1994.
AND the said Grantor will warrant specially t.lle p1"operty hereby conveyed.
PREMISES: 619 NORTH PITT STREET
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VERIFICA nON
BRANDON SCIUMBA TO hereby states that he is VICE PRESIDENT of COUNTRYWIDE
HOME LOANS, INC, mortgage servicing agent for Plaintiff in this matter, that he is 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 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 falsification to
authorities,
DATE:
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05554 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOE LOANS INC
VS
NEIDIGH NORMAN R
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
NEIDIGH NORMAN R
the
DEFENDANT
at 0019:50 HOURS, on the 18th day of August
, 2000
at 619 NORTH PITT STREET
CARLISLE, PA 17013
by handing to
NORMAN R. NEIDIGH
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
S?~~_t:~t
R. Thomas Kline
08/21/2000
FEDERMAN & PHELAN
Sworn and Subscribed to before
me this t; ~ day of
~ J_mr-O A.D.
C)1;~ten?:t~A' ,AfId!
By:
De~tJ
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UNITED STATES BANKRUPTCY COURT FOR
1? :2.. 0 J:;2 t.f
(OUf1~r'1 j,.)' de
THE MIDDLE DlSTRI~J PJ~SYL VANIA U
~~~\,~-:. //'~:,:tH' _~r~~; )~~ ;~ frr'-~ ,r?~~Sl
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: Chapter No.3"
KMg~51
INRE:
Norman Ray Neidigh aJkIa Norman R. Neidigh
Debtor
Countrywide Home Loans
,
Movant
v.
Norman Ray Neidigh aJkIa Norman R. Neidigh
and
BLED Harrisburg PA
11 U.S.c. 9362 TIME AM'
~. .-PM.
Charles J. Dehart, ill, Esquire (Trustee)
Respondent
APR 1 0 2002
I/ilit ~, -p
AND NOW, this IV day of ~F'
consideration of the Motion for Relief and Motion for Default of Movant, Countrywide Home Loans, it
pe;ierk, u(;~ Court
Clerk
, 2002, upon
is hereby
ORDERED that the Order for Reliefbe entered by default with respect to premises at 619 North
Pitt Street, Carlisle, P A 17013, to aIIow the Movant to foreclose on its mortgage, which mortgage was
recorded in Cumberland County, in Mortgage Book 1347, Page 448, and aIIow the purchase 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.
By the Court:
I8J IloIlertJ. Woodslde
Robert J. Woodside, Bankruptcy Judge
cc:
Judith T. Romano, Esquire
One Penn Center at Suburban Station
1617 John F. Kennedy Blvd., Suite 1400
Philadelphia, PA 19103-1814
Norman Ray Neidigh
618 N. Pitt Street
Carlisle, P A 17013
".
Timothy J. Colgan, Esquire
One South Baltimore Street
DiIlsburg, PA 17019
Charles J. Dehart, III, 'Wsquire (Trustee)
P.O. Box 410
Hummelstown, P A 17036
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. Docket for Case:-" + GetCaseNoO +" (" + DktTypeExpand(m.gsDktType) + ")
Page I of3
4,
Bankruptcy Docket Report
1 01-03234 (Harrisburg)
NEIDIGH, NORMAN RAY
Docket items entered between 01/01/1931 and 04/2212002
Filing No. Docket Entry View
Date document
06/05/0 I I VOLUNTARY PETITION under chapter 7 [EOD 06/06/01] [CG] Doc #1 PDF (4
ORIGINAL DOCUMENT_ [EOD 06/06/0 I] [CG] ~
06/06/0 I 2 NOTICE of intent to dismiss case unless missing documents are filed: due by None
06121/01 Re: Item # L [Rescheduled] [EOD 06/06/01][CG]
06/14/0 I 3 Matrix in correct format (FAXED) Re: Item # 2_ [EOD 06/15/01] [KZ] Doc #3 PDF (3
~
06/18/0 I 4 ORIGINAL DOCUMENT Re: Item # 3_ [EOD 06/18/01] [KZ] Doc #4 PDF (2
~
06/28/01 5 MOTION for extension oftime to file Schedules (FAXED COPY) Re: Item # 2_ None
[EOD 06/28/01] [CR]
06/28/01 6 ORDER extending time for filing Schedules: due by 07/13/01 Re: Item # 5_ None
[Rescheduled] [BOD 06/28/01] [CR]
This entry cancels the previous due date. Re: Item # 2. [EOD 06/28/01] [CR]
06/29/0 I 7 MOTION for extension of time to file Schedules (ORIGINAL TO FAXED COPY None
IN ITEM #5) Re: Item # 6. [EOD 06/29/01] [CG]
06/29/0 I 8 ORDER extending time for filing Schedules: due by 07/17/01 Re: Item # 7_ None
[Complied] [EOD 06/29/01] [CG]
This entry cancels the previous due date_ Re: Item # 6_ [EOD 06/29/01] [CG]
07/02/01 9 CERTIFICATE OF MAILING of notice of341 meeting_ [EOD 07/02/01] [DS] None
341 MEETING WAS NOT HELD UNDER CHAPTER 7, CASE CONVERTED.
[EOD 08/16/01] [DS]
07/05/0 I 10 MOTION for relief from stay re: COUNTRYWIDE HOME LOANS, INC (FEE None
PAID, REC #571674, $75.00) [Disposed] [EOD 07/05/01] [JR]
CERTIFICATE OF NON-CONCURRENCE Re: Item # 10. [EOD 07/05/01] [JR]
07/05/01 11 ORDER that answers aredue on 07/25/01 Re: Item # 10_ [EOD 07/05/01] [JR] None
07/12/01 12 CERTIFICATE of service Re: Item # IL [BOD 07/12/01] [CG] None
07117/01 13 MOTION to convert from chapter 7 to chapter 13 [Disposed] [EOD 07118/01] None
[JR]
07117/01 13A Schedules, Statements and all missing documents Re: Item # 8. [EOD 07/18/01] pac #13A PDF
[CA] (21 nages)
, Doc #13B PDF
07/17/01 13B Ch. 13 Plan [EOD 07118/01] [CA]
(3 pages)
_ _ .lnPacer?ExecThis=docket&puid=O I 0 194883 99&case _ no=200 1-03234&office= I &DktType=4/22/2002
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Page 2 of3
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07/18/01 14 ORDER converting chapter 7 to chapter 13 Re: Item # 13. [EOD 07/18/01] [JR] None
ALL FURTHER ENTRIES ARE UNDER CHAPTER 13 Re: Item # 14_ [EOD
07/18/01] [JR]
07/30/0 I IS CERTIFICATE of Mailing of Notice of341 Meeting_ Objections to the plan are None
due IS days after meeting held. [EOD 07/30/01] [CA]
08/17/01 16 PRAECIPE/WITHDRAWAL FILED BY COUNTRYWIDE HOME LOANS, None
INC Re: Item # 10_ [EOD 08/17/01] [JR]
08/27/0 I 17 341 meeting not held-to be rescheduled. [EOD 08/27/01] [CA] None
09/17/01 18 CERTIFICATE of service of notice of rescheduled 341 Meeting [EOD 09/17/01] None
[CA]
10/09/0 I 19 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING None
on 11/08/01 at 02:00 P.M. at FED BLDG., BKRPTCY CTRM.(3RD FLK),
THIRD & WALNUT STS_, HARRlSBURG,PA. 17108 Re: Item # L [Disposed]
[EOD 10/09/01] [DR]
10/12/01 20 341 meeting he\~. [EOD 10/12/01] [CA] None
10/16/01 21 OBJECTION to Phin by Trustee. [Disposed] [EOD 10/16/01] [CG] None
11/05/01 22 STIPULATION by DEBTOR and TRUSTEE in satisfaction of the Trustee's None
Motion to Disniiss Re:Item # 19. [EOD 11/05/01] [DR]
APPROVED by the court. Re: Item # 19_ [EOD 11/05/01] [DR]
11/09/0 I 23 Amended Ch_ 13 Plan (Requested Proof of Service) Re: Item # 13B. [EOD None
11/09/01] [NP]
This entry disP9ses of motion. Re: Item # 2L [EOD 0l/18/02] [DR]
I l/09/0 I 24 MOTION FOR ORDER TO PAY TRUSTEE WITH CONSENT OF DEBTOR None
[Disposed] [EbD 11/09/01] [NP]
11/09/01 25 ORDER to paYitrustee.Re: Item # 24. [EOD I l/09/01] [NP] None
11/16/01 26 CERTIFICATE of service Re: Item # 23. [EOD 11/16/01] [DR] None
(No notice attashed, requested notice to be filed) [EOD 11/16/01] [DR]
CERTIFICATE OF MAILING RE: NOTICE ON CHAPTER 13 PLAN
AMENDMENTdue on 12/04/01 Re: Item # 23. [EOD 11/19/01] [DR]
12/06/01 27 OBJECTION to plan by COUNTRYWIDE HOME LOANS Re: Item # 23. None
[Disposed] [EOD 12/06/01] [DR]
12/07/01 28 CORRESPONDENCE SETTING HEARING on o l/3 1/02 at 09:30 A.M. at None
FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS.,
HARRISBURG,PA. 17108 Re: Item # 27. [Rescheduled] [EOD 12/07/01] [DR]
0l/17/02 29 Amended Ch. 13 Plan (SECOND AMENDED) Re: Item # 23_ [EOD 01/18/02] Doc #29 PDF
[DR] (4 pages)
This entry disposes of motion. Re: Item # 27. [EOD 01/18/02] [DR]
This entry cancels the previous due date. Re: Item # 28. [EOD 01/18/02] [DR]
(Requested Notice to Creditors to be sent) [EOD 01/18/02] [DR]
01/28/02 30 CERTIFICATE OF MAILING RE: NOTICE ON CHAPTER 13 PLAN None
AMENDMENTdue on 02/14/02 Re: Item # 29_ [EOD 0l/28/02] [CR]
01/29/02 31 PRAECIPEIWITHDRA W AL Re: Item # 27 _ [EOD 0 l/29/02] [CR] .. None
o l/29/02 32 ORDER ConfIrming Plan [EOD 01/29/02] [CR] None
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Page 3 00
03/07/02 33 MOTION for relief from stay RE: COUNTRYWIDE HOME LOANS. FEE None
PAID. RECEIPT #579821, $75.00. [Disposed] [EOD 03/07/02] [CR]
CERTIFICATE OF NON-CONCURRENCE [EOD 03/07/02] [CR]
03/07/02 34 ORDER that answers aredue on 03/27/02 Re: Item # 33. [EOD 03/07/02] [CR] None
03/15/02 35 CERTIFICATE of service Re: Item # 34. [EOD 03/18/02] (DS] None
04/10/02 36 MOTION for default judgment Re: Item # 33_ [Disposed] [EOD 04/10/02] [CR] None
04/1 0/02 37 ORDER granting default judgment Re: Item # 36. [EOD 04/10/02] [CR] None
ORDER granting relief from stay Re: Item # 33. [EOD 04/10102] [CR]
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
v.
No. 00-5554 CIVIL
NORMAN R. NEIDIGH
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$74,668.17
Interest from 1/4/02 to 9/4/02
(per diem -$12.27)
$2,993.88 and Costs
TOTAL
$77,662.05
~riA~g~AMQ~
FRANK FERMAN, ESQ
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
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LEGAL DESCRIPTION
ALL THOSE CERTAIN tracts of land and premises situate, lying and being in the
Borough of Carlisle in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as follows:
TRACT 1: On the West by North Pitt Street; on the North by land now or formerly of
Albert Kelly; on the East by Fairground Lane; and on the South by land now or formerly
John W. Spangler. Said premises having a frontage of twenty feet on Pitt Street, and
extending back to Fairground Lane a distance of 140 feet, more or less.
TRACT 2: On the West by Pitt Street; on the North by land now or formerly of Alice M.
Fry; on the East by Creek Lane; and on the South by other lands now or formerly of John
W. Spangler. Containing 6 feet in front on Pitt Street and extending at an even width 170
feet, more or less, to Creek Lane aforesaid.
TAX ill # 06-20-1798-046
PREMISES BEING KNOWN AS 619 NORTH PITT STREET, CARLISLE; PA 17013
VESTED BY: DEED dated 10/18/96, given by Thomas P. Tucker, Jr., single man to
Norman R. Neidigh, a single man recorded 10/22/96 in Book 147 Page 868.
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOOO-5554 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cnmberland COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC
PLANTIFF(S)
Prom NORMAN R NEIDIGH 619 NORTH PITT STREET, CARLISLE, P A
(1) You are directed to levy upon the property of the defendant(s) and to sell SEE ATTACHED LEGAL
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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined
from paying any debt tom for the account of the defendant (s) and from delivering any property of the
defendant (s)or otherwi~e disposing thereof;
(3) Ifproperty of the dOfendant(s) not levied npon an subject to attachment is found in the possessiou
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated_
Amount Due$74,668.17 LL
Interest $2,993.88 INTEREST FROM 114/02 TO 9/4/02 (PER DIEM-$12.27)Due Prothy $1.00
Atty's Conun
Atty Paid $717.98
Plaintiff Paid
%
Other Costs
Date: APRIL 24, 2002
CURTIS R. LONG
Prothonotary, Civil Division
By:
97'- () ~
REQUESTING PARTY:
Name: FRANK FEDERMAN ESQ
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BOULEVARD STE 1400
PHILADELPHIA PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 2155637000'
Supreme Court ID No_ 12248
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COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-5554 CIVIL
NORMAN R. NEIDIGH
Defendant(s).
April 22, 2002
TO: NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, P A 17013
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY iNFORMA TION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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 ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at. 619 NORTH PITT STREET. CARLISLE. PA 17013. is
scheduled to be sold at the Sheriff's Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $74.668.17 obtained by
COUNTRYWIDE HOME LOANS. INC. (the mortgagee) against you. In the event the sale is
continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
caIl: (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 wiIl have of stopping the sale. (See notice on page two on how to obt!tn an attorney.)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by caning (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 fun amount due in the sale. To
find out ifthis has happened, you may can (717) 240-6390.
4. Ifthe 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 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.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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LEGAL DESCRIPTION
ALL THOSE CERTAIN tracts ofIand and premises situate, lying and being in the
Borough of Carlisle in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as foIlows:
TRACT 1: On the West by North Pitt Street; on the North by land now or formerly of
Albert KeIly; on the East by Fairground Lane; and on the South by land now or formerly
John W, Spangler. Said premises having a frontage of twenty feet on Pitt Street, and
extending back to Fairground Lane a distance of 140 feet, more or less.
TRACT 2: On the West by Pitt Street; on the North by land now or formerly of Alice M.
Fry; on the East by Creek Lane; and on the South by other lands now or formerly of John
W. Spangler. Containing 6 feet in front on Pitt Street and extending at an even width 170
feet, more or less, to Creek Lane aforesaid.
TAX ill # 06-20-1798-046
PREMISES BEING KNOWN AS 619 NORTH PITT STREET, CARLISLE; PA 17013
VESTED BY: DEED dated 10/18/96, given by Thomas P. Tucker, JL, single man to
Norman R Neidigh, a single man recorded 10/22/96 in Book 147 Page 868.
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COUNTRYWIDE HOME LOANS, INC.
CUMBERLAND COUNTY
,
Plaintiff,
v.
COURT OF COMMON PLEAS
NORMAN R. NEIDIGH
CIVIL DIVISION
Defendant(s).
NO. 00-5554 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
COUNTRYWIDE HOME LOANS. INC., 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
fonowing information concerning the real property located at .619 NORTH PITT STREET.
CARLISLE. P A 17013 .
1. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, P A 17013
2. Name and address ofDefendant(s) in the judgment:
Same as above
3. Name and last known 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 indicate)
ORRSTOWN BANK
P.O. BOX 250
SHIPPINSBURG, P A 17257
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
None
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5. Name and address of every other person who has any record lien on the property:
1
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
SUSAN M. MITCHELL
158 W. SOUTH STREET
CARLISLE, PA 17013
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 calUlot be reasonably
ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
PO BOX 2675
HARRISBURG, PA 17105
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
13 NORTH HANOVER STREET
CARLISLE, P A 17013
TENANT/OCCUPANT
619 NORTH PITT 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 of18 Pa. e.s. Sec. 4904 relating to unsworn falsification to authorities.
April 22. 2002
DATE
~QA lII\/'OJ\^--.
RANK FE RMAN, ESQUIRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
NORMAN R. NEIDIGH
NO. 00-5554 CIVIL
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:
(X) an FHA mortgage
() non-owner occupied
() vacant
o Act 91 procedures have been fulfined
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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RANK F ERMAN, ESQUiRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
PLANO, TX 75024
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-5554-CIVIL
NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, P A 17013
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against NORMAN R.
NEIDIGH, 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 7/1100 TO 9/13/00
$71,855.69
$1.128.00
TOTAL
$72,983.69
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.
1M~ 1Jh~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGFS ARE HEREBY ASSESSED AS INDICATED. (l ~
DATE: 9p...-/. /1.4 ~O Jy ~ k~
~ I PROPROTHY
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR TIlAT 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. **
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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
COUNTRYWIDE HOME LOANS, INC.
COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
NORMAN R. NEIDIGH
NO. 00-5554
Defendant(s)
TO: NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
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DATE OF NOTICE: SEPTEMBER'S. 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 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249.3166
Frank Federman, Esquire
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRAJiKFEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS, INC.
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
NORMAN R. NEIDIGH
: NO. 00-5554-CIVIL
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRAJiK 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 of the
following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act
of Congress of 1940, as amended
(b) that defendant NORMAN R. NEIDIGH is over 18 years of age and resides at
619 NORTH PITT STREET, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
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FRANK FEDERMAN
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236 - Revised)
COUNTRYWIDE HOME LOANS, INC.
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DMSION
NORMAN R. NEIDIGH
: NO. 00-5554-CML
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
SEPTEMBER II.( .2000. .
'--Byd~ ,[} ~A'7JfDEPUTY
If you have any questions concerning_ this matter, please contact:
FRANK FEDERMAN. ESQUIRE
Attorney for Filing Party
SillTE 900
TWQ PENN CENTER PLAZA
PIDLADELPIDA PA 19102
(215) 563-7000
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IFYOUHAVEPREVIOUSLY
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. "
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FEDERMAN AND PHELAN
By: FRAJ{KFEDE~
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHll,ADELPHIA, PA 19102
(215) 563-7000 ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
: Cumberland County
Plaintiff
: Court of Common Pleas
vs.
: CIVIL DIVISION
NORMAN R. NEIDIGH
: NO. 00-5554
Defendant(s)
PRAECIPE TO VACATE JUDGMENT
WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly vacate the Judgment which was entered on September 14, 2000
against NORMAN R. NEIDIGH, Defendants, in the amount of$72,983.69 relative to the
instant matter, without prejudice, upon payment of your costs only.
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F FEDERMAN, ESQUIRE
Attorney for Plaintiff
Dated; JANUARY 3, 2001
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By: FRANK FEDERMAN
Identification No. 12248
OIle Pelll1 Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
PLANO, TX 75024
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-5554
NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
Defendant(s)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment, in rem, in favor of the Plaintiff and against NORMAN R.
NEIDIGH, 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 fonows:
As set forth in Complaint
lnterest 7/1/00 to 1/3/01
$71,855.69
$2,812.48
TOTAL
$74,668.17
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.
/1~ ~J1ut
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: 9"u~'r f, ,;)(}o/
(l1~h1JA R f~~\
PRO THY
"TIllS FIRM IS A DEBT COLLEcrOR ATTEMPTING TO COLLECT A DEBTAND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKR,UPTCY AND TillS DEBT WAS
NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHQULD NOT BE CONSTRUED TO BE AN AlTEMPT TO COLLEcr
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. "
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FEDERMAN AND PHELAN, L.L.P.
~Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
vs.
CUMBERLAND COUNTY
NORMAN R. NEIDIGH
TO: NORMAN R.
619 NORTH
CARLISLE,
: .NO.
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PA 170 13 ~,,<;.t;,);,~.\L[J4' ~.cxv
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DECEMBER~2~~OO
00-5554
Defendant(s)
,
DATE OF NOTICE:
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 ENFOR~MENT OF LIEN
AGAINST PROPERTY. riLE COpy
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
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
One Penn Center at Snburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS, INC.
: CUMBERLAND COUNTY
Plaintiff
: Court of Common Pleas
VS.
: CIVIL DIVISION
NORMAN R. NEIDIGH
: NO. 00-5554
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiffin the above-captioned matter, and that on information and belief, he has knowledge of the
fonowing facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service ofthe 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 NORMAN R. NEIDIGH is over 18 years of age and resides at
619 NORTH PITT STREET, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
q-- Atlu.L 8-:~YhP
FRANK FEDERMAN
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236 - Revised)
COUNTRYWIDE HOME LOANS, INC.
Plaintiff
: CUMBERLAND COUNTY
: Court of Common Pleas
vs.
: CIVIL DIVISION
NORMAN R NEIDIGH
Defendant(s)
: NO. 00-5554
Notice is given that a Judgment in the above captioned matter has been entered against you on
JANUARY tt: .2001.
By 01'" O. 'truPO.~ /
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUIRE
Attorney for Filing Party
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(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 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. ""
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-5554
NORMAN R. NEIDIGH
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$74,668.17 ..;
Interest from 1/3/01 - 6/6/01
$1,889.58 and Costs
(per diem - $12.27)
$76.557.75 TOTAL
~~~~ ------
FRANK FEDERMAN, ESQUIRE
ONE PENN CENTER at SUBURBAN STATION
SUITE 1400
PHILADELPHIA, PA 19103
Attorney for Plaintiff
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ALL those eertain tracts ot land and pr~es sitWl~e, lying and being in the Borough of" CarUsle
in the County ol'Cumberland and Commonwealth oCPennsylvania. mo.... part.icularly deseribed.... CoUows:
TRAC'1' 1: On the West by North I'itt Street; on the North by land now or formerty of Albert
K..Uy; on the ltast by Fairsround Lane: and on the South by land now Or formerly of John W. Spangler.
Said premises having a Crontase of twenty Ceet on Pitt Stree~, and extending back to Fairsround Lane a
distance of 140 feet, mOre or I.......
TRACT 2: On the West by Pitt Street; on the North by la4d now or Cormerly of" AIice-M. Fry; on
the East by Creek Lane; and on the South by other lands now Or Connerly or John W. Spangler.
Containing 6 feet in front on Pitt Street and extending at an even width 170 Ceet, mare or less, to Creek
Lane aforesaid. -
IlEING the same premises which EdW81'd Stoner, by his Deed dated April 29, 1991, and recorded
in the office of the Recore.... of" Deeds in .....d for Cumberland Co_~. PltnnSY1'll'8Di!>. in Deecl Book "B",
Volume 35, Page 898, gr_ted and eonve,yed unto ThOl'l1BB P. Tueker, Jr., Grantor herein..
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COUNTRYWIDE HOME LOANS, INC.
CUMBERLAND COUNTY
Plaiutiff,
v.
COURT OF COMMON PLEAS
NORMAN R. NEIDIGH
CIVIL DIVISION
Defendant(s).
NO. 00-5554
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
COUNTRYWIDE HOME LOANS. INC., 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
fonowing information concerning the real property located at 619 NORTH PITT STREET.
CARLISLE. P A 17013.
'----
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
NORMAN R. NEIDIGH 619 NORTH PITT STREET
CARLISLE, P A 17013
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.)
Orrstown Bank
P.O. Box 250
Shippensburg, PA 17257
Susan M. Mitchell
158 W. South Street
Carlisle, P A 17013
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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.)
None
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 plaintiffhas 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
619 NORTH PITT STREET
CARLISLE, PA 17013
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, P A 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 of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
February 26,2001
DATE
~~~-----
FRJV{KFEDE~AN,ESQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
NORMAN R. NEIDIGH
NO. 00-5554
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 subj ect to the provisions of Act 91
because it is:
(X) an FHA mortgage
() non-owner occupied
() vacant
() Act 91 procedures have been fu1fiIIed
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
~~4Ffl~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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COUNTRyWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-5554
NORMAN R. NEIDIGH
Defendant(s).
February 26,2001
TO: NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
**THIS FIRM [S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE- IF YOU HA VE 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 619 NORTH PITT STREET, CARLISLE, PA 17013, is scheduled
to be sold at the Sheriffs Sale on JUNE 6,2001 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by
COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. If the Sheriff's sale is
postponed, the property will be relisted for the September 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:
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.
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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.
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.
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. Ifthe amount due from the Buyer is not paid to the Sheriff, you win 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 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
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ALL tho.e eertam traets or land and prpnises situate, lying and being in the Sorough of Carliste
in the County of Cumberland and Co=onwea1th o{PelU1sylvania. mOre particularly described "" follows:
TRACT 1: On the West by NQrth Pitt Street, on the North by land now or {ormerly of Albert
K<!:lJy; on the East by Fairsraund Lane: and on the South by land now or formerly of John W. Spangter.
Said premises having a frontage of twenty feet on Pitt Street, and extending back to Fairground Lane a
distance of 140 feet, more or 1-.
TRACT 2: On the Wat by Pitt Street; on the North by land now or {ormerlY' or Allce-M. Fry; an
the East by Creek Lane; and on the South by other lands now Or formerl:y of John W. Spangler.
Containing 6 feet In front on Pitt Street and extending at an even width 170 feet, more or less, to Creek
Lane aCoresaid. -
SEING the same premises whic:h Edward Stoner, by his Det!ld dated April 29, 1991, and r""orded
in the amee af the Recorder oC Deeds In IInd for Cumberland County, Pennsyl......m,e. In Deed Baak -:a",
Vollune 35. Page 89S, granted and oanveyed unto Thon>aa P. Tucker, Jr., Grantar herein.
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71 72532705
KISKADDON
PAGE 04
AFFIDAVIT OF SERVICE
PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
NORMA.."I R. NEIDIGH
CUMBERLAND COUNTY
No.OO-5554
PEFENDANT(S)
SERVE AT
619 NORTH PITT STREET
CARLISLE, PA 17013
Type of Action
- Notice of Sheriff's Sale
Sale Date: JUNE 6, 200 I
SERVED
Served and made known to '1-1,.."",,,,\,\ ().. N~;~"" ~'h ,Defendant, on the \ ll~ day of ~...,.<..\"., 200-1.
al 10'.'<; .o'c!ock~.m_,al 10\1\ "1\01"4-'" p;~ So-\-. <::'O"~\;~\.A.. 'P1"\ nOl3 ,Commonwealth
of pennsylvania, in the manner described below:
.,. Defendant personally served_
Adult falJlily member with whom Defendant(s) reside(s). Relationship is
Adult in. charge ofDefendant(s)'s residence who refused to give name or relationship_
_ Manager/Clerk ofpiace oflodgin.g in which Defendan.t(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defe!:ldant(s)'s company-
Other:
Description: Age .3.0' $ Height ~~ Weight \ So () Race ~ Sex ~ OtheT
I, ~UL \:;. W~~ , a competent adult, being duly sworn according to law, depose a!:ld state that I personally handed
a true and correct copy of lhe Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
Ibe address indicated above.
Swam to and subscribed
before me this _ day
of , 200~_
Notary:
By:
NOT SERVED
On the
day of
.200_, at
o'clock _,m., Defendant NOT FOUND because:
Moved _ Unknown _ No Answer
Vacant
Other:
Swam to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Allorney for Plaintiff
Frank Federman, Esquire. I.D. No. 12248
One Penn Center Suburban Station, Suite 1400
Philadelphia, PA 19103
(n 5) 563-7000
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SALE DATE:
JUNE 6, 2001
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION - LAW
COUNTRYWIDE HOME LOANS, INC.
No.: 00-5554
vs.
NORMAN R. NEIDIGH
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:
619 NORTH PITT STREET. CARLISLE. PA 17013.
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner
required by Pa. 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 a copy of the notice is attached as an
Exhibit. A copy ofthe Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt
stamped by the U.S. Postal Service is attached for each notice.
~~~
FRANKFEDERMAN,ESQUrnE
Attorney for Plaintiff
May 1,2001
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COUNTRYWIDE HOME LOANS, INC.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
NORMAl" R. NEIDIGH
CIVIL DIVISION
Defendant(s).
NO. 00-5554
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
COUNTRYWIDE HOME LOANS, INC., Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets fonh as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 619 NORTH PITT STREET,
CARLISLE. PA 17013.
I _ Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
NORMAN R. NEIDIGH 619 NORTH PITT STREET
CARLISLE, PA 17013
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 ~
reasonably ascertained, please so indicate_)
Orrstowii Bank
P.O. Box 250
Shippensburg, PA 17257
Susan M. Mitchell
158 W. South Street
Carlisle, P A 17013
~, ,
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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.)
None
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 evel)""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
619 NORTH PITT STREET
CARLISLE, P A 17013
Domestic Relations of Cumberland
County
13 North Hanover Street
Carlisle, PA 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 tounswom falsification to authorities.
February 26.2001
DATE
~~ ~--------
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
,.
-[
"
.
;
DATE: 02/26/01
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S) NORMAN R. NEIDIGH
PROPERTY: 619 NORTH PITT STREET
CARLISLE, PA 17013
Improvements: Residential Property
CUMBERLAND COUNTY
The above-captioned property is scheduled to be sold at the Sheriff's Sale on JUNE 6,
2001, at 10:00 a.m. in Cumberland Countv Courthouse, South Hanover Street, Carlisle, PA. 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. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
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Countrywide Home Loans, Inc.
VS
Norman R. Neidigh
-.-. "~j, "1
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-5554 Civil
R. Thomas Kline, Sheriff, who being dilly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Posting BiIIs
Advertising
Law Library
County
Levy
Postpone Sale
Surcharge
Certified mail
Mileage
Law Journal
Patriot News
Share ofBiIIs
30.00
11.76
15.00
15.00
.50
1.00
15.00
20.00
30.00
2.38
6.20
228.20
188.25
25.09
$ 588.38
Sworn and subscribed to before me
This :2'1 tl:-dayof 9,," -
2001, A.D. ~ {2 tyy""i;. < Ili)o7
r onoUuy .
paid by attorney
06-11-01
~~~~
R. Thomas Kline, Sheriff
BY~d~ S.J~
De ty Shenff
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COUNTRYWIDE HOME LOANS, INC.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
NORMAN R. NEIDIGH
CIVIL DIVISION
Defendant(s).
NO. 00-5554
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
COUNTRYWIDE HOME LOANS, INC., 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 infonnation concerning the real property located at 619 NORTH PITT STREET,
CARLISLE, PA 17013.
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
NORMAN R. NEIDIGH 619 NORTH PITT STREET
CARLISLE, PA 17013
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.)
Orrstown Bank
P.O. Box 250
Shippensburg, P A 17257
Susan M. Mitchell
158 W. South Street
Carlisle, PA 17013
.
-~ ""'"'"
.
-,
,
. ,
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.)
None
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 carmot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
619 NORTH PITT STREET
CARLISLE, PA 17013
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 of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
February 26.2001
DATE
~~ ~--------
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
'=~""'IlI;="~
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COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-5554
NORMAN R. NEIDIGH
Defendant(s).
February 26, 200 I
TO: NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
**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 619 NORTH PITT STREET, CARLISLE. PA 17013, is scheduled
to be sold at the Sheriff's Sale on JUNE 6. 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
COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. If the Sheriffs sale is
postponed, the property will be relisted for the September 5, 2001 Sheriffs 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 out how much you must pay, you may
can: (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
-
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 Sheriff's Sale is not stopped, your property will be sold to the highest biddeL 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.
s. 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 buyeL 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 ofthe money bid for your house will be filed by the Sheriff within 30 days ofthe 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, PA 17013
(717) 249-3166
(800) 990-9108
~ ~
~-
I ALL tho.e certain tracts of land and prj'mi.ses situate, lying and being in the Borough oC CarUste
in the County ot'Cumberland and Commonwealth olPennsylvania, more partic:ularly de""'"ibed.... foUowa:
II
T~cr 1: On the West by Nortb Pitt Street; on the North by land now or formerly of Albert
K..Uy; on the East by Fairground Lane; and on the South by land now Or formerly of John. W. Spangler.
Said premises having a frontage of twenty feet on Pitt Street, and extending back to Fairground Lane ..
distance of 140 feet, more or 1_.
TRACt' 2: On tbe West by Pitt Street; on the North by land now or formerlY or AIics-M. Fry; on
the East by Creek lAne; and on the South by other lands now or formerly of John W. Spangler.
Containing 6 feet in front on Pitt Street and extending at an even width 170 leet, more or le$S, to Creek
Lane aforesaid. .
BEING the same premise.. whlc:h Edward Stoner, by his Deed dated April 29. 1991. and r,""orded
in the office ol the Recorder oC Deed.. in Ilnd for Cumb....land County, Penns,yt-.ranijo. in Deed Book "B",
Volwne 36. Page 898, granted Ilnd conveyed unto Thomas P. TWlker, Jr., Grantor herein.. '
.
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WRIT OF EXECUTION and/or ATTACHMENT
.,-- . ;, 1 i;
COMMONWEALTH OF PENNSYLVANIA)
COUNlY OF CUMBERLAND)
NO. 00-5554 CIVIL 19:: TERM
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
,,'~"'''''''
;_::'f~ satisfy the debt, interest and costs due Countrywide Home Loans, Inc.
",VI _' ,~
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PLAINTIFF(S)
from NnT1l'lr.ln R. NjO.;(Hgn_ l11q N Pi........~.... r;::!rlicl(;:.. p~ "I7()"I ':t
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Leqal Description
i"
(2) You are also -directed to allach the property of the defendant(s) not levied upon in the possession of
~Il;; ~:1' ,'_.'
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:liVi !~_ ';j, <<fl.:!MI'"
GARNISHEE(S) as follows:
",'-)jf
and to notny the garnishee(s) that: (~a.c~.'llent has been issue\l;,_IW t)JMa~tsb~~4s)J6L\!r~ e~oined from paying any
debt to or for the account of the defM'lll'linT(s) arid from delivering any 'prbPilfft or'111e''defd~~nfffl\''Or otherwise disposing
thereof;
(3) If propertYllf thedefendaf1l(S)fflHevi~d upon an subject te-altachm9"'\.l&twnd-inthe~$SeSSiOn of anyone other
than a named garnishee, you are directed,to notny him/herthat he/she has been added as agarnishee and is enjoined as above
stated. '
Amount Due 574.668.17
from 1/3/01 - 6/6/01- $1,889.58 and
Interest Coots (per Eliem $12.27)
Ally's Comm %
L.L.
Due Prothy
Other Costs
s.~o
$1.00
Ally Paid
Plaintiff Paid
$117 10
Date:
March 6. 2001
rllt+i ~ R T .nnlJ
Prothonotary, Civil Division
fi(Yn p 2. 7p0/~~ )
,-bv:
Deputy
REQUESTING PARlY:
Name Frank Federman, Esq.
Address: One Penn Center at Suburban Station
Sm.te 14UU
Phil~lfhia, P~ 191Q3
Allorney for,: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No_ 12248
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REAL ESTATE SALE No. j'f
------/".
un fY/ aM1 If, J. 00 I the sheriff levied upon the detenoa, .
Interest In the real property situated in {' ~ &>o(j h..
6umbertand Collnty, Pa., known and number8das: (,Iq N. pj;;t -ti.
tc.....{~-4-.
and more fully described on ExhIbIt "A" II8d with
this writ and by this reference incorporated hen1IR.
By: tI~ ~
f)t.p,-,- --J~
Date: fI/~ 9,.1 00 I
V'IN\f!\l) SNN3d
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: COUNTRYWIDE HOME LOANS, INC. )
)
CIVIL ACTION
vs.
NORMAN R. NEIDIGH )
)
CIVIL DIVISION
NO. 00-5554 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
)
)
SS:
I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME
LOANS, INC. hereby verify that on 4/23/02 true and correct copies of the Notice
of Sheriffs sale were served by certificate of mailing to the recorded lienholders,
and any known interested party see Exhibit "A" attached hereto. Notice of Sale
was sent to the Defendant(s) on 4/23/02 by certified mail return receipt requested
see Exhibit "B" attached hereto.
DATE: Auqust 1 . 2002
~lr,Jf.A.A~
F NK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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NORMANR.NEIDiGlI
619 NORTH PITT STREET
CARLISLE, PA 17013
SENDER:
KMD
REFERENCE: SALES 4820224
P$ Form 3800 June 2000
RETURN Postage ~
RECEIPT Certified Fee
SERVICE
US Poslal Service
Return Receipt Fee
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AFFlDA VIT OF SERVICE
P71V\
PLAINTIFF
COUNTRYWIDE HOME LOANS, INC.
NORMAN R. NEIDIGH
CUMBERLAND COUNTY
KMD
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No. 00-5554 CIVIL
DEFENDANT(S)
ACCT. #4820224
SERVE NORMAN R. NEIDIGH AT
619 NORTH PITT STREET
CARLISLE, PA 17013
Type of Action
- Notice of Sheriff's Sale
Sale Date: 9/4/02
SERVED
Served and made known to t.fD(~ Q.. \\\,e'lCkish.. , Defendant, on the g~
at q:$~O'c!ock/tm,atb1S-Ne1~ ~d\- ,<:;t.. (Cut.s\e
day of ~u_, 20c0.
~ ,Q::nwealth
of Pennsylvania, in the manner described below:
X-Defendant personally served_
Adult family member with whom Defendant(s) reside(s)_ Relationship is
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 business_
an officer of said Defendant( s)' s company_
Other:
Description:
Height~O '~eightVat Race 11L sex-M.. Other
a competent adult, being duly sworn according to law, depose and state that I personally handed
otice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
I, U.
a true an correct copy of the
the address indicated above_
By:
PLEASE II.TTEMPT SERVICE AT. LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
Notarial Seal
Lisa M. Greason, Notary Public
Carlisle Bora, Cumberland County
y Commission ir - Sept. 9, 2002
NOT SERVED
,200_, at
o'C!ock__m_, Defendant NOT FOUND because:
Moved
Unknown
No Answer
Vacant
1" Attempt:
/
/
Time:
2nd Attempt:
/
/
Time:
3rd Attempt:
/
/
Time:
Sworn to and subscribed
before me this _ day
of , 200 _-
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which CountrYwide Homes Loans Inc is the grantee the same having been sold to
said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the
24th day of April, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2000
Number 5554, at the suit of CountrYwide Home Loans Inc against Norman R Neidigh is duly recorded
in Sheriff's Deed Book No. 253, Page 3701.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
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day of
kp-
, A.D. 2002
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---rr Rec rder of Deeds
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Countrywide Home Loans, Inc.
VS
Norman R. Neidigh
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2000-5554 Civil Term
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on May 9, 2002 at 3:49 o'clock PM, he served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendant, to
wit: Norman R. Neidigh, by making known unto Jacqueline Poper, girlfriend of
defendant, at 619 North Pitt Street, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that
on July 9,2002 at 2;20 o'clock P.M., he posted a true copy ofthewithin Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Norman R. Neidigh located at 619 North Pitt Street, Carlisle, Pennsylvania, according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law says he served
the above Real Estate Writ, Notice, Poster and Description in the fonowing manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Norman R. Neidigh, by regular mail to his last known address of619
North Pitt Street, Carlisle, PA 17013. This letter was mailed under the date of July 10,
2002 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County
Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum
of$I.00 to Attorney Frank Federman for Countrywide Home Loans, Inc. It being the
highest bid and the best price received for the same Countrywide Home Loans, Inc. of
7105 Corporate Drive, Piano, TX 75024, being the buyer in this execution paid SheriffR.
Thomas kline, the sum of $734.42, it being costs.
Sheriff s Costs:
Docketing
Poundage
Posting HandbiIIs
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
$30.00
14.40
30.00
30.00
30.00
20.00
1.00
6.90
1.17
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Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of
Proceeds
Sheriff s Deed
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30.00
30.00
237.50
193.75
25.20
25.00
29.50
$ 734.42 paid by attorney
9/17/02
Sworn and subscribed to before me
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This S"~ day of 0 ~ . Thomas Kline, Sheriff
2002, A.D. ~~ ~'~::a~J~~i4
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COUNTRYWIDE HOME LOANS, INC.
,
.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
NORMAN R. NEIDIGH
CIVIL DIVISION
Defendant(s).
NO. 00-5554 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
COUNTRYWIDE HOME LOANS, INC., 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
foIlowing information concerning the real property located at .619 NORTH PITT STREET.
CARLISLE. PA 17013.
1. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address carmot be
reasonably ascertained, please indicate)
NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, PA 17013
2. Name and address ofDefendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address carmot be reasonably
ascertained, please indicate)
ORRSTOWN BANK
P.O. BOX 250
SHIPPINSBURG, P A 17257
4, Name and address oflast recorded holder of every mortgage of record:
Last Known Address (if add~s carmot be reasonably
ascertained, please indicate)
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Name
None
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5. Name and address of every other pers~n who'has any record lien on the property:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
SUSAN M. MITCHELL
158 W. SOUTH STREET
CARLISLE, PA 17013
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 indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be reasonably
ascertained, please indicate)
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
PO BOX 2675
HARRISBURG, P A 171 05
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
13 NORTH HANOVER STREET
CARLISLE, PA 17013
TENANT/OCCUPANT
619 NORTH PITT STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
April 22. 2002
DATE
~AA.W 0 A Af\/'O.Af\....
RANK FE RMAN, ESQUIRE
Attorney for Plaintiff
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COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-5554 CIVIL
NORMAN R. NEIDIGH
Defendant(s).
April 22, 2002
TO: NORMAN R. NEIDIGH
619 NORTH PITT STREET
CARLISLE, P A 17013
"THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFOR/vIA TlON
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, 619 NORTH PITT STREET, CARLISLE, PA 17013. is
scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $74,668.17 obtained by
COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. In the event the sale is .
continued, an announcement wiII be made at said sale in compliance with Pa.R.C.P., Rule 3129.3.
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 wiII be cancened 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
cal1: (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 wiII have of stopping the sale. (See notice on page two on how to obtlltn an attorney.)
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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 Sheriffthe 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 wiII 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, PA 17013
(717) 249-3166
(800) 990-9108
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LEGAL DESCRIPTION
ALL THOSE CERTAIN tracts ofland and premises situate, lying and being in the
Borough of Carlisle in the County of Cumberland and Commonwealth of Pennsylvania,
more particularly described as folIows:
TRACT 1: On the West by North Pitt Street; on the North by land now or formerly of
Albert Kelly; on the East by Fairground Lane; and on the South by land now or formerly
John W. Spangler. Said premises having a frontage of twenty feet on Pitt Street, and
extending back to Fairground Lane a distance of 140 feet, more or less.
TRACT 2: On the West by Pitt Street; on the North by land now or formerly of Alice M.
Fry; on the East by Creek Lane; and on the South by other lands now or formerly of John
W. Spangler. Containing 6 feet in front on Pitt Street and extending at an even width 170
feet, more or less, to Creek Lane aforesaid.
TAX ill # 06-20-1798-046
PREMISES BEING KNOWN AS 619 NORTH PITT STREET, CARLISLE; PA 17013
VESTED BY: DEED dated 10/18/96, given by Thomas P. Tucker, Jr., single man to
Norman R. Neidigh, a single man recorded 10/22/96 in Book 147 Page 868.
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WRIT OF EXECUTION and/or ATTACHMENT
,
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOOO-5554 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS INC
PLANTIFF(S)
From NORMAN R NEIDIGH 619 NORTH PITT STREET, CARLISLE, P A
(I) You are directed to levy upon the property of the defendant(s) and to sell SEE ATTACHED LEGAL
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 notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined
from paying any debt to or for the accoimt of the defendant (s) and from delivering any property of the
defendant (s) or otherwise disposing thereof;
(3) Ifproperty 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 he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$74,668.17 L.L.
.;; "".
Interest $2,993.88 INTEREST FROM 114102 TO 914102 (PER DIEM-$12.27)Due Prothy $1.00
Atty's Corum %
Arty Paid $717.98
Plaintiff Paid
Other Costs
~
Date: APRIL 24, 2002
CURTIS R. LONG
Prothonotary, Civil Division
By:
97"
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REQUESTING PARTY:
Name: FRANK FEDERMAN ESQ
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BOULEVARD STE 1400
PHILADELPillA PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 2155637000'
Supreme Court ill No_ 12248
.
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Real Estate Sale #05
On May 9,2002 the sherifflevied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, P A known
and numbered as 619 North Pitt Street, Carlisle,
and more fully described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
Date: May 9, 2002
By:
0o~S~
Real Estate Deputy
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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
Frank J. Epler being duly sworn according to law, deposes and says:
That he is the Controller 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 andJIN
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 andlor Sundayl Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th
day(s) of August 2002_ 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; and
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 stockhoiders 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 in Miscellaneous Book "M",
Volume 14, Page 317_
~~..~.....................................................,-
- this 14th day 0 ug t 2002 AD_
Notarial Seal
Terry L_ Russell. Nota'Y Public '/> /' /$
City Of Harrisburg, Dauphin County ';d~
My Commission ExpiresJune6,2006 NO :l\RY PUBLIC
Member, Pennsylvania Association Of NotartesMy commission expires June 6, 2006
PUBLICATION
COPY
SALE#5
~-REA[ ESTATE SALENo~5'-
_ WrR No. 200D-SS54
... Civil Term
. . .Countrywlde HQme
Loans, Inc.
..... vs
,Nonnan R. Neidigh
, ,AUy: Frank Federman
I DESCRlPTION
AP., TAOSE CERTAIN lmcls of land and
premJ~~s sit,uate, lying and being in tbe Borough
. of Carl~le m the County of Cumber- land and _
COI?moIl..yealth of Pennsylvania, more
particularly described as folfows: '
TRACf I:" On the West by North Pitt Street; on
the North by land now or, formerly of Albert
&l1y; on the East by Fairground Lane; and on
the South by land now or fonnerly of John W.
," Spangler. Said ~remiscs having a frontage of
tW~~llty feet, on Pitt Street, and extending back to
FalQl:round Lane a distance of 140 feel, more or
,lc'ls.
;: J:.RACT 2: On the West by Pitt Street; on t~e
NortltbylandnoworfonnedvorAlk,M_Fry' Publisher's Receipt for Advertising Cost
'on'the ~t by Creek Lane; mid on the South by.. .
:':;;:i"ttf.!'WQ.t,~.ow,or f?rmerly,o,f John W. Spangler,_ ., publisher of The Patnot-News and The Sundav Patnot-News, newspapers of general
,:,::'.",.",::,:,~~,::~Jeet tn,ponl Oil; filLI Street. and Je receipt of the aforesaid notice and publication costs and certifies that the same have
:~nd,l~,~ff.ln.,eve:n WIdth 170 leet, more or less',
: to C.re,ek~1Ie afcm;s~i~ I
,JiAXID iil6,10- 1798-O4~ ,,',,- ;
:.i:.':.PREMlSES:BEfNG,'KNOWN as 619 North:Jiltt i
-street, CadlsJe, PA 17013. ":
VESTED BY: Deed dated 1011R196, given fiy :
Thomas p, Tucker, Jr., single man, to Norman R.' i
Neidigh, a single man, n:corr1ed 10/22/96 ia Book 1',':-
_.. 147 Pall"e 868. ':'
CUMBERLAND COUNTY SHERIFFS OFRCE
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
$
$
$
192.00
1.75
193.75
By...........m.........................m'_._.._..m..............
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. 1.1784
STATE OF PENNSYL VANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Joumal, 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 26, AUGUST 2,9,2002
Affiant further deposes that he is authorized to verifY this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SALE NO.5
/
Roger M. Morgenthal, Editor
Writ No_ 2000-5554 Civil
Countrywide Home Loans, Inc.
vs_
Norman R Neidigh
Arty_: Frank Federman
LEGAL DESCRIPTION
ALL TIl0SE CERTAIN tracts of
land and premises situate, lying and
being in the Borough of Carlisle in
the County of Cumberland and Com-
monwealth of Pennsylvania. more
particularly described as follows:
lRACT I: On the West by North
Pitt Street: on the North by land now
or formerly of Albert Kelly: on the
East by Fairground Lane: and on
the South by land now or formerly
John W. Spangler. Said premises
having a frontage of twenty feet on
VH.t, c..+",...",,=-_ ,';,-,,;:,.d..__'5'I~--!;p'_~'\,:~,,~.q$.<,t.>';\
SWORN TO AND SUBSCRIBED before me this
9 day of AUGUST. 2002
NOTARIAl. SEAL
LOIS E. SNYOER.::J PuIlIIc
cartisle Boro, ClI, County
My CoIlIIIIi8sIon ExpIres ~ 5, 2005