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HomeMy WebLinkAbout01-5871O08482.00055110.3.011RWSIDCPI150455 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLIPPINGER and NANCY K. : CLII'PINGER, : Defendants IN THE cOURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW INMORTGAGEFORECLOSURE NOTICE TO DEFEND 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 attomey and filing in writing with the court your defense 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 fights 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 O08482.00055110.3.011RWSIDCP I1504 55 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLIPPINGER and NANCY K. : CLI?PINGER, : Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.0/- ' 71 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE COMPLAINT 1. The Plaintiff, The Bank of Landisburg, hereinafter sometimes called Mortgagee, is a banldng business association with a Principal place of business at Landisburg, Perry County, Pennsylvania. 2. The Defendants, Ronald B. Clippinger and Nancy K. Clippinger, his wife, hereinafter sometimes referred to as "Mortgagors", are adult individuals residing at 351 West North Street, Carlisle Borough, Cumberland County, Pennsylvania. 3. At all times material to the Plaintiffs cause of action, the Mortgagors, Ronald B. Clippinger and Nancy K. Clippinger, have been the owners of a tract of land and the buildings thereon hereinafter called the "land" located in Carlisle Borough, Cumberland County, Pennsylvania, being known and numbered as 163 West Chestnut Street, Carlisle, Pennsylvania. 4. The land is described in Exhibit "A", attached hereto and made a part hereof by reference. 5. On May 7, 1999, in consideration of the loan of Thh-ty-Two Thousand and 00/100 ($32,000.00) Dollars made by the Mortgagee to the Mortgagors, the said Mortgagors executed and delivered to the Mortgagee, a note secured by a mortgage on the land obligating the Mortgagors to pay the Mortgagee the principal sum on demand with interest thereon at the rate of 7.25% percent per annum, on the unpaid balance and to make bi-weekly payments on account of principal and interest, in the absence of the demand in the amount of Three Hundred Seventy-Five and 68/100 ($375.68) Dollars together with other terms and conditions set forth in the said mortgage. The mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Mortgage Book 1540, Page 796 and re-recorded in Mortgage Book 1634, Page 33. A copy of said mortgage is set forth in Exhibit "B" attached hereto and made a part hereof by reference. 008482-00055/'~ 0.3.011RWSlDCPI150455 6. The Defendant Mortgagors are in default on the mortgage in that they have failed to pay the entire balance due on demand and have failed to make the bi-weekly payments from and after January 7, 2000. 7. The Defendants, Ronald B. Clippinger and Nancy K. Clippinger, are the present real owners of the land. 8. The amount due the Plaintiff under the mortgage is computed as follows: Principal balance $ 31,198.28 Interest through 10/1/01 at 7.25% 3,605.54 Late fees 450.72 10% Attorney's collection fee 3,525.45 TOTAL $38,779.99 9. The Defendants are not a members of the Armed Forces of thc United States and are not entitled to any benefits of the Soldiers and Sailors Relief Act as amended. WHEREFORE, Plaintiff demands judgment against the Defendants in the amount of Thirty-Eight Thousand Seven Hundred Seventy-Nme and 99/100 ($38,779.99) Dollars, together with interest thereon at the rate of 7.25% per annum from October 1, 2001. JOHNSON, DUFFLE, STEWART & WEIDNER Richard W. Stewart Johnson, Duffle, Stewart & Weidner Third and Market Streets Post Office Box 109 Lemoyne, Pennsylvania 17043 717-761-4540 Attorneys for Plaintiff 008482-00055/10.3.01/RWS/DCP/150455 ALL THAT CERTAIN lot of ground with improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North line of Chestnut Street at the West line of property formerly owned by James McElwee; thence westerly along the said Chestnut Street, a distance of 60 feet to a point at line of property formerly of John Bishop; thence extending northerly at even width of a distance of 120 feet to the line of property formerly of the heirs-at-law of J.D. Zimmerman, deceased and having thereon erected a two story frame stable or shed known as 163 Chestnut Street, Carlisle. BEING THE SAME PREMISES which Ronald B. Clippinger, by his deed dated May 7, 1999, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 199, page 225, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants herein. RON~D B. CLIPPINGER and NANCY K. CLIPPINGER, his wife, of Car~sl~ C~erland County, Pennsylvania of Ca~li~ler Cure.land Coun~yt venns~vaniar bounded and de~cnibed {con~inued on back) 1540~ ,796 E~{IBIT "B" BEGII~riNG at a point on the north line of C~estnut Street at the Wes~ line of property formerly owned by Ja~es McEl%~e; thence ~sterly '~o~g the said (/%estnut Street, a distance of 60 feet to a point at the lin~ of property fo~,~rly of John Bishop; thence extending northerly at even width of a distance of 120 feet to the line of property fo£~,~rly of the h~irs at law of J. D. Z~.t%~rman, deceased and having erected a two story fr~L~ semhle or shed known as 163 Chestnut Street, Carlisle. t ~W. TNG the same property which Ronald B. Clippinger granted and conveyed to ~Lld B. Clippinger and Nancy K. clippinger, his wife, by deed dated May 7, 1999 and recorded in the Office of the Recorder of Deeds for Cumberland G~unty in Deed Book 199, Page 225. The undersigned, RONALD B. CLIPPINGER AND NANCY K. CLIPPINGER. his wife, hereby acknowledges a mortgage to BANK OF LANDISBURG, dated May 7, 1999, in the amount of $32,000.00. Said mortgage is being rerecorded to include the legal description which was inadvertantly omitted when said mortgage was originally recorded on May 10, 1999 in Cumberland County Mortgage Book 1540 Page 796. RONALD B. CLIPP1NGER NANCY K. CLI~PINGER (SEAL) COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBF~]~qD On this, the [ tT'r~ay of August, 2000 , be:fore me, the undersigned, a Notary. Public in and for said State and County, personally appeared RONALD B. CLIPPINGER AND NANCY K. CLIPPINGER, his wife, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument and acknowledged to me that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My~c~mmission expires: ' · /'-'M LJtq N~tarial Seal Betzi A. Morrison, Notary Pul:[[c Carlisle Boro Cumberl~,~l County My Commission Expires Dec. 15.2000 Member, Penns~tanla Association ol PROVIDED, HOW~:VL~R, that in case o~fauh at any time, in payment of said principal o...~'or sum, or.of interest ot charges or ,pte?...i,.ual o~ i~nce, or of any ~n thereof, when due and ~yabie res~tlvely, by the terms and conditions of ~id obligation ~or ~e s~ o~ ~en~ (20) da2s as a[ote~id, ot in the ~dotmance o[ an~ o~ the covenants as to [i~ insurance, lanes ot water and ~we¢ ~nts ot ~tg~ o¢ c~ ~ afo~id, the whole o~ ~id gtinci~i debt o~ sum and imetest then unpaid, shall theteu~n ~come due aaa ~able ~d an ~i~ oE mo~ge ~o~losute ma~ be commenced fonbwi~ on ~hls Mortgage and ptose~ced to judgment, ex~utlon and ~le · e ~ll~;on of the whole ~ount of the ~id pdnc[~l debt and/o~ inte~st thereon remaining unpaid, together with all p~miums of i~n~, t~ and water and ~wet ~nts ~id, fees, costs and ex~nses o[ such precedings, together with an a~orney's commission o{ t~ ~r c~mm (10~). All errors in ~id pre.dings, together with sta~ of, or exemption, or extension of time o{ ~ymem, whi~ ~y ~ given by ~y A~ or Ads of ~mbly, now tn {o~e, or whl~ may ~ enacted her~fter, are ~eteby forever waived and tel~. In ie ev~t o[ ~e ~in8 of ~ ot any ~ion o{ ~e ptemlses in any pr~eedlngs under the ~wet o[ eminent domain, ~e enti~ award ~de~ ~ ~ Pz~ss s~U ~ ~id to Mon~gee, to ~ applied toward reimbursement nE all costs and ei~n~s 9[ ~ m~ion wi~ ~id p~di~, and toward the ~ymeut o{ all amounts ~yable by Mo~gagot to Mo~gag~ he.under, and · e ~y~nt of ~e i~eb~ness ~ted hereby, ot any ~ion thereof, whether or not then due ot payable, or Mo~gag~ at its option, ~y a~ly ~id award, or snf ~ ~e~of, to ~e re.ir ot mbui~dlng of ~id premises. ~O pROVID~ further that it is thereby and hereby expressly agr~d that in the event of any brach br Mortgagor of any covenant, c~dition, or ~teement of ~id ~it~ obligation, ot nE this Mo~gage, it shall ~ lawful [or the Mo~gagee to enter upon all and slngulat the lands, ~Hdings and premi~ he.in ~ni~latly descried ~na by this Indenture mortgaged, together with the he~dltaments and sppu~enances, ~d ~h ~d eve~ ~ thereof, ~d to take ~s~ssion of ~e ~me and o{ the {ixtures, nppllnnces and equipment theteln comain~, and to have, hotS, ~,n-~e. I~ in the Moment nc any other per~n ot ~t~ns, u~ and o~rate the same in such ~rcels and on ~ch terms and ~or tach ~ti~ of time as MoP.gee may d~m proper in the ~le discretion of Mortgagee, the Mo~gagot agreeing that Mo~gngot shall and ~iB, ~henevet t~uested by Mop.gee so to do, ~sign, transfer and deliver unto Mo~gagee, any lease or sublease; and to collect and r~elve ~ ~nu, i~es ~d pm{au o[ ~e ~id mortgaged premiss and eve~ part theto~ for which ~is Indenture shall ~ a sufficient war.at wh~er or not such 1~ or subl~ h~ ~n assigned to Mo~agee, and to make from time to tlme, nH alte~tlons, ~novatlons, and ~l~ts thegn as ~y ~em judicious m Mo~gngee, and steer deducting the cost o{ any or all such directions, tenovatlons, ~d ~ts and ~ incident to ~kln8 ~d t~lnlng ~ssesslon of the mo~gaged pm~ and the management end · e~f, ~d k~ping ~e ~me pto~ insured, to apply the residue of such rents, issues and profits, if any, arising ~ afore~id, to ~e ~ym~t of all ~xes, c~rges, c~i~, as~ssmen~, water and ~et rents and any other liens ~at may ~ print in Ilea or ~yment m the pt~cJ~ debt ~ by ~ll Inden~re and p~mlums for said insurance, with interest thet~n, ot to the interest and princ]~l due and ~ ~ ~b Ingrate of Mo~gage, with ali costs and nttom~'s f~s, In such order ot pdorJ~, ss Mortgagee, in the ~ie di~ion of Mon~, ~Y d~ermine, any suture, law, ~stom ot u~ to ~e cont~, no~ithstandlng; it ~ing exptessJ~ ng~, however, that the ~ag o{ ~ion ~ Mo~gag~ under this ~tovlslon shall not telleve any default which may have been ma~e by Mo~r, or prevent the enfo~ement of any o{ the remedies by thb Indenture, or by ~ld r~it~ obligation, provided in case o~ such default; ~d it is fu~er ~pressly undet~ ~d sgr~ ~at the ~medles by this Indenture and ~id recited obligation provided for the enfo~ement o~ the ~vment of ~e prlnci~l ~m hereby ~ted, with any additions thet~o as above pmvlded, together with interest ~her~n, ~ he~in~fo~ and for the ~rfor~nce of ~e ~ve~nts, conditions and agreements, matters and things herein contained, or by this Indenture ~fet~ to, a~ ~mulative and ~nmrrent and ~ ~ pur~ sln81~ ot succ~sively or together at the sole discretion of the Mo~, and ~y ~etc~ ~ often ~ ~Jon ~et~ot ~H ~D for ~e pu~ of ~rlng ~id ~s~ion of ~id moagaged premiss to Mortgagee, in the e~ent o{ an~ b~ch ~ Mo~gor d~ he~ suthori~ and em~wer any a~orney o[ any Court o~ Common Pl~s in any County of the Commonw~lth of Penn- srlvanb, or of any ~het c~ ~ere or eJ~whete, ~ attorne~ for Mortgagor, as well ns ~or all persons claiming under, by, ot through Mon~gor, to si~ an agr~ment for entering in any comment court an amiable action in element [or ~ssesslon of the p~mi~s mo~gaged by ~is Indenture, to~het wi~ the het~i~ents and appu~enances as well ns all fixtures, appliances and equipment o[ any nature what~- ~er, now or he~[~/ ~s~led u~n or in ~id mon~ged pto~ (without any stay of ex~ution or ap~l), against ~Jd Mo~gor, well as nil ~r~ns claiming under, by, ot through Mortgagor and therein confess judgment for the r~ove~ by the Mortgag~ o[ the of the ~id mo~g~ premiss tog~et with ~e he~dit~ents and appurtenances, ns well ss all Hxtutes, appliances and ~uipment o[ any nam~ what.et n~ or he~ftet i~lled u~n ot in ula mon~ged propers, for which this Indenture (or copy thereof verified br davit) s~ll ~ a mf[iclent war.at; wher~n ii the Mongag~ ~ desires, a ~dt of Possession may ~ issued Ionhwlth, without any print welt or p~d~ w~r, MoaP~oi hereby telling and ngt~ing to telea~ the Mop.gee from ~11 errors and de[~l what--er ~r~g m~ anion and/or jud~ent and in ~uslng such writ or writs to ~ issued, and in any preceding ther~n or concerning the and here~ agr~g ~t no writ of ermt or obj~ion shall ~ made or taken thereto, pmvlded that the Mortgagee shall have ~iled in such ~ioa an affidavit by it, ot ~me one on ~hal[ of Mortgagee, ~ing fo~h the fans necessa~ to authorize the ent~ o{ such judgment, according to the terms of this Indenture, o{ whi~ [sou such affidavit shall ~ conclusive evidence. PROVID~ AL~AYS, N~EK~E~SS, that if thc ~id Mo~gagor, Mortgagor's heirs and assigns, shall and do well and truly pay or to ~ ~id unto the ~id Mon~gee, its successors and assigns, the aforesaid debt together with imetcst as aforesaid, as set {onh in the condition of ~is obli~ion, and d~s fu~her uthfy and di~harge the same, and the premiums of insurance aforesaid, and huther will, deleing and ~e~ y~r of the continuance o[ this Mon~ge, comply with all conditions and tequlremenu for ot in tes~ct to ali razes, water and ~er ~ts, charges or claims ~ afo~uld, all o{ which the ~id Mortgagor, for Mottgagor's heirs and assigns, hereby expressly covenants, agr~ to do and ~dorm, then and from thenceforth, as well this present Indenture, and the estate hereby granted, as the ~id t~ited obliga- tion, ~ ~ome void o[ no offS, an~iag heteln~fo~ confined to the contn~ no~Jthstandlng. ~ PROVID~ ~, and it b he.by and ~e~ expressly covenanted and agr~d that in the event there is more than one ~ ~med heteln ~ a Mon~gor, the sln~[ar word "M0~got", wherever occuring herein, shall ~ d~med and taken to m~n the glu~l. A~ p~OVIDED ~R~ ~t ~I g~n~, ~venants, waivers, options, stipulations, promises, undennklngs, agr~ments, and rights and ~neflU given to, and obli~tions ot llabilitles'lm~d u~n, ~ch and all of said panles hereto shall inure to and bind them joindy and ~e~ly ~d its, his, her and ~elr, and ~ch of their resp~tlve, belts executors, adminlstratots, successors sad assigns. IN wITI'n'F.3S WHI:ILEOF, the said Mortgagor has hereunto set hand and seal the day and year first abo~e wrlrten. Commission ~xpires: I hereby ce~if¥ that the pteche a~dtess o! the Mortgag~ herein is ?. 0. Bo× 60 Shermans Dale, PA 17090 Artomey for Mort~z~ COMt, ION~EALTH OF PENNSYLVANIA ..? · ~,: ~ ,,~.' C~rlisi~, PA this ~ day of~~ ~ v ~~ R~rder~~ RECORDED in the Office for Recording of ,Dee(h~ Mortgages,. etc., in and tot the ~n~ of WI~ESS ~W HA~.'~d ~1 of Off ce this .......... - ........ ~V of -% ' ~ - t540 .799 , BOO~ ~AGE ).3.011RWSIDCPI150455 · i VERIFICATION I, RItONDA M. ItAAS, Assistant Branch Manager of The Bank of Landisburg, the Plaintiff named in the foregoing Complaint, as such I am authorized to make this Affidavit on Plaintiffs behalf and have knowledge of the facts ~ forth in the foregoing and that said facts are true and correct to the best of my knowledge, information and belief. I understand .that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification authorities. RHONDA M.~IAAS SHERIFF'S RETURN - REGULAR CASE NO: 2001-05871 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LANDISBURG BANK OF THE VS CLIPPINGER RONALD B ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER RONALD B the DEFENDANT at 1800:00 HOURS, at 351 WEST NORTH STREET CARLISLE, PA 17013 NANCY CLIPPINGER a true and attested copy of on the 12th day of October , 2001 by handing to COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this /~-> day of ;P~othonotary So Answers: R. Thomas Kline lO/lS/2OOl JOHNSON DUFFIE STEWART WEIDNER v -DepUty gheriff ~/ ~. SHERIFF'S RETURN - CASE NO: 2001-05871 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LANDISBURG BANK OF THE VS CLIPPINGER RONALD B ET AL REGULAR DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER NANCY K the law, DEFENDANT , at 1800:00 HOURS, at 351 WEST NORTH STREET CARLISLE, PA 17013 NANCY CLIPPINGER on the 12th day of October , 2001 by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 6 00 00 00 10 00 00 16 00 Sworn and Subscribed to before me this /~- day of 0 a~-~ ~l A.D. onotary So Answers: R. Thomas Kllne 10/15/2001 JOHNSON DUFFIE STEWART WEIDNER ,, eputy Sheriff O08482-O0055/12.28.01/RWS/DCP/153207 THE BANK OF LANDISBURG, RONALD B. CLIPPINGER, Plaintiff CLIPPINGER and Dc fendants NANCY K. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION- LAW IN MORTGAGE FORECLOSURE PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment by default in favor of the Plaintiff, and against the Defendants, Ronald B. Clippinger and Nancy K. Clippinger in theamount of $38,779.99 with interest at the rate of 7.25 percent per annum from October 1, 2001, and costs, by reason ~fthe failure of the Defendants to enter an appearance or to file an Answer within 20 days of the date of service of the Complaint endorsed with a notice to defend. It is hereby certified Clippmger and Nancy K. C1 default occurred and at least aforesaid notice, together wil Dated: that written notice of intention to file this Praecipe was mailed to the Defendants, Ronald B. [ppinger, at their last known address on December 7, 2001; said notice being mailed after the ten (10) days prior to the date of the filing of this Praecipe. A tree and correct copy of the h receipts for mailing, are attached hereto and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Richard W. Stewart Attorney I.D. No. 18039 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 7614540 Attorneys for Plaintiff 008482-00055/12.6.01/RWS/DCP/152568 THE BANK OF LANDISBURG, RONALD B. CLIPPINGER, Plaintiff CLIPPIN~ TO: RONALD B. CLI1 NANCY K. CLIP DATE OF NOTICE: Dece YOU ARE IN D PERSONALLY OR BY OBJECTIONS TO THE £ FROM THE DATE OF HEARING AND YOU M/ THIS NOTICE TO A LA~ GO TO OR TELEPHONE Certified Mail Return Rece~ 7000 0600 0025 5.~ 7000 0600 0025 5 3ER and NANCY K. ffendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE 'PINGER, 351 West North Street, Carlisle, PA 17013 'INGER, 351 West North Street, Carlisle, PA 17013 nber 7, 2001 IMPORTANT NOTICE EFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR '.LAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS tHIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A ~Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTSi YOU SHOULD TAKE VYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, FHE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Central Pennsylvania Legal Services 213-A North Front Street Itarrisburg, PA 17101 (800) 932-0356 pt Requested 36 0243 36 0250 JOHNSON, DUFFLE, STEWART & WEIDNER By Richard W. Stewart Third and Market Streets P. O. Box 109 Lemoyne, PA 17043-0109 (717-761-4540 Attorneys for Plaintiff ~ DOD 7000 0600 0025 5536 0243 7000 0600 0025 5536 0250 IN THE COURT OF COMMON PLEAS OF' cu~:RT THE BANK OF LANDISBURG, Plaintiffs) vs RONALD B. CLIPPINGER AND NANCY K. CLIPPINGER De~ndant(s) File No. 01-5871 NOTICE OF FILING JUDGMENT ( X ) Notice is hereby given that a 'judgment in the above-captioned matter has be~n entered against you in the ernount of $38,779.99 on ~-~ ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary Civil Div. Notice sent to: TELEPHONE NO: 717/761-a54o (This Notice is given in accordance with Pa.R.C.P. 2363 NAME ADDRESS Mr. and Mrs. Ronald B. 351 West North Street Carlisle, PA 17013 Richard W. Stewart. 301 Market Street ,,L~moyne, PA .'17043 . "'' '~" C lipm in_~er If you have any questions regarding this Notice, please contact the filing party: NAIVIE: ADDRESS: PKAECIPE FOR WRIT OF EXECUTION--(MONEY JUDGMENTS) · P.R.C.P. 3101 to 3149 Etc. THE BANK OF LANDISBURG RONALD B. CLIPPINGER and ..... 1 IN THE COURT OF COMMON PLEAS OF CL~BERLAND 'COUNTY. PENNSYLVANIA %¥~t No ...... .. ..................... Term, 19 ...... No 01-5871 ~35._.2_~.01 Amou,~ dun ............$ 38,779.99 Au'f, CO,~ 6/25/02 Cos,, ................ ~ ........................ To the Prothonotar7 et,eld Court: ISSUE WIUT OF ~EC~ION IN ~E ABOVE MA'A ........................................................................... D~rc.a.p~ (3) and against ._; ....... -. ........................................................ Garnishee (4) andlndax ~d,w~ . (,) ag~..:...R~__~..B...._.C_L_I.P._P.._I~...R....ap..'d..._N.._A~._y K. CLIPPINGER' ... ............................................................. D~l'aadant (s) and ~} ag-~n~t .... T ..................... ? ..................................................... · - .......... ' ................................................... - ..... Garni~hao ~ · Ih l~nda~s agalmt the real property of the defendant (s) In the name or.lhe Oar.hhec (s) as [nllow~: (.$p~clficall). dc~cr~%e pt~p~rq,) Levy upon and sell all that certain tract of real estate situate in Carlisle Borough, Cumber]and County, Pennsylvania, owned by the Defendants, Ronald B. Clippinger and Nancy K. Clippinoer, as more fully describedin Exhibit !~A" attached hereto and made a part hereof by reference. (§) ]gxe,n,[:),~on ha~ (not) b-':cn walvad. ....... .. ...... ................... ~nder garag~gh (Il wh~n ~e wrR Is directed to ~a sher~ oI Ino~er co~ty as lug~orlzed by Rule ~e ~ouniI ~ould be ~nder Rule ~103(e) a wrlt ~ed on a Iransterr~ Ju dlement may ~ dlreeled only lo the sherl~ ol the which ~a~g~gh (3} above should be comgl~d only It a ~amed garnlshc~ Is to ba ~alu'd~d In ~e ~arlSraph (4) . (Il should ~ completed only If Index lng oI ~e exocutlon In the counly of ls3uznce~is desired a~horlzed by ~ula ~10i(s). Wa~n the writ lssu~ lo another county lndex]n Is re O08482-O0055/3,4.02/~WS/DCP/155309 EXHlffiIT "A" ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by land now or formerly of Ira W. Miller; on the East by South Hanover Street; on the South by land now or formerly of William P. Stull; and on the West by a public alley. CONTAINING 40.5 feet in front on South Hanover Street and extending at an even width a depth of 240 feet to said alley. BEING improved with an apartment house and outbuilding known as 242 South Hanover Street, Carlisle, Pennsylvania. BEING THE. SAME PREMISES Chester W. Schlusser, Sr., by deed dated July 15, 1998, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 181, Page 511, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants heroin. TAX PARCEL NO. 04-21-0320-448 SEZIED, taken in execution and to be sold as the property of Ronald B. Clippinger and Nancy K.'li~lippinger, judgment debtors and real owners. 008482-00055/3.5.02/RWS/DCP~155309 THE BANK OF LANDISBURG, RONALD B. CLIPPINGER, Plaintiff CLIPPINGER and Defendants NANCY K. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SAI,F, OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129,? TO: RONALD B. CLIPPINGER and NANCY K. CLIPPINGER Your real estate situate in the Borough of Carlisle, Cumberland County, Pennsylvania, known as 242 S. Hanover Street, Carlisle, Pennsylvania is scheduled to be sold at Sheriff's Sale on June 5, 2002, at I0:00 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania to enforce the Court Judgment of $38,779.99 obtained by The Bank of Landisburg against you. THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and other major improvements erected on the land, attached hereto as Exhibit "A" and made a part hereof by reference. THE LOCATION of your property to be sold is: 242 S. Hanover Street, Carlisle, Pennsylvania 17013 THE PROPERTY IS IMPROVED WITH an apartment house and outbuilding THE JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 01-5871 Civil Term 2001 in the Court of Common Pleas of Cumberland County, Pennsylvania The name and address of the owner or reputed owner of this property is: Ronald B. Clippinger and Nancy K. Clippinger, 351 West North Street, Carlisle, PA 17013 008482-00055/3.4.02/RWS/DC~/155309 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff within thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse, Carlisle, Pennsylvania, Telephone (717) 240-6390. 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: 1. The sale will be canceled if you pay to the Sheriff of Cumberland County, the amount of the judgment plus costs. To find out how much you must pay, you may call the Sheriff of Cumberland County at (717) 240-6390. 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. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTI:IER 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 the Sheriff of Cumberland County at (717) 240-6390. 2. You may be able to petition the Court to set aside the sale if the 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 the Sheriff of Cumberland County at (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. O08482-O0055/3.4.02/RWSIDCP'I155309 5. You may be entitled to a share of the money which was paid for your property. A schedule of distribution of the money bid for your property will be filed by the Sheriff within thirty (30) days of the sale date. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions are filed with the Sheriffwithin ten (10) days after the date of the filing of the schedule of distribution. 6. You may also have other rights and defenses, or ways of getting your property 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Date: March '7 ,2002 JOHNSON, DUFFLE, STEWART & WEIDNER BY: Richard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-761-4540 Attorney ID No. 18039 Attorneys for Plaintiff O08482-O005513.4.021RWSIDCF~I155309 EXHIBIT "A" ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by land now or formerly of Ira W. Miller; on the East by South Hanover Street; on the South by land now or formerly of William P. Stull; and on the West by a public alley. CONTAINING 40.5 feet in front on South Hanover Street and extending at an even width a depth of 240 feet to said alley. BEING improved with an apartment house and outbuilding known as 242 South Hanover Street, Carlisle, Pennsylvania. BEING TI-IE SAME PREMISES Chester W. Schlusser, Sr., by deed dated July 15, 1998, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 181, Page 511, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippmger, Defendants herein. TAX PARCEL NO. 04-21-0320-448 SEZIED, taken in execution and to be sold as the property of Ronald B. Clippinger and Nancy K. Clippinger, judgment debtors and real owners. O08482-O0055/3. 4.02/RWSIDCP/155309 EXHIBIT "A" ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by land now or formerly of Ira W. Miller; on the East by South Hanover Street; on the South by land now or formerly of William P. Stull; and on the West by a public alley. CONTAINING 40.5 feet in front on South Hanover Street and extending at an even width a depth of 240 feet to said alley. BEING improved with an apartment house and outbuilding known as 242 South Hanover Street, Carlisle, Pennsylvania. BEING TI:[I~, SAME PREMISES Chester W. Schlusser, Sr., by deed dated July 15, 1998, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 181, Page 511, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants herein. TAX PARCEL NO. 04-21-0320-448 SEZIED, taken in execution and to be sold as the property of Ronald B. Clippinger and Nancy K. Clippinger, judgment debtors and real owners. O08482-O005513. 4.02/RWSIDCFf1155309 THE BANK OF LANDISBURG, Plaintiff V. : RONALD B. CLIPPINGER and NANCY K. : CLlPPINGER~ : : Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of Landisburg, by its attorneys, Johnson, Duffle, Stewart & Weidner, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located 242 S. Hanover Street, Carlisle, Pennsylvania. Name and ad&ess of Owner(s) or Reputed Owner(s): Name: Ad&ess: Ronald B. Clippinger 351 West North Street Carlisle, PA 17013 Nancy K. Clippinger 351 West North Street Carlisle, PA 17013 Name and ad&ess of Defendant(s) in the judgment: Name: Ad&ess: Ronald B. Clippinger 351 West North Street Carlisle, PA 17013 Nancy K. Clippinger 351 West North Street Carlisle, PA 17013 propm'ty to be sold: Name: The Bank of Landisburg Name and last known ad&ess of every judgment creditor whose judgment is a record lien on the real Ad&ess: P.O. Box 179 Landisburg, PA 17040 008482-00055/3.4.02/RWS/DCP'/155309 5o Pennsylvania State Bank Lee M. Diehl Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. Thomas Day, Jr. Susan K. Day Vincent H. Gettel Shirley Ann Gettel First Union National Bank c/o Bruce D. Foreman, Esquire 4409 N. Front Street Harrisburg, PA 17110 408 Franklin Street Carlisle, PA 17013 c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 c/o Mark A. Denlinger, Esquire 10 E. High Street Carlisle, PA 17013 P.O. Box 85 Spring Run, PA 17262 123 S. Broad Street Philadelphia, PA 19109 Name: The Bank of Landisburg Name and address of the last recorded holder of every mortgage of record: Address: P.O. Box 179 Landisburg, PA 17040 Chester W. Schlusser, Sr. c/o Robert G. Frey, Es~luire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 Name and address of every other person who has any record lien on the property: Name: Address: Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 6. Name and address of every other person of whom the Plaintiff has knowledge who has any record interest in the property and whose interest may be affected by the sale: Name: Address: O08482-O0055/3.4.02/~WS/DCP'/155309 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: Address: I verify that the statements made in this Affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: JOHNSON, DUFFIE, STEWART & WEIDNER ~ch~rd W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-761-4540 Attorney ID No. 18039 Attorneys for Plaintiff O08482-O0055/3.4.021RWSIDCP/155309 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLI~P1NGER and NANCY K. : CLIPPINGER, : Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE COUNTY OF PENNSYLVANIA : COUNTY OF CUMBERLAND : RICHARD W. STEWART, being duly sworn according to law, deposes' and says that he served the attached Notice of Sheriffs Sale and Divestiture of Liens upon all judgment creditors, mortgagees, and other persons who have any interest of record in or lien of record upon the property scheduled to be sold at Sheriffs Sale in the above matter on ~ C~¢C¥~, I B , 2002, by mailing a copy of the attached Notice by United States Mail, First Class, Postage Prepaid, addressed as follows: Pennsylvania State Bank c/o Bruce D. Foreman, Esquire 4409 N. Front Slreet Hamsburg, PA 17110 Lee M. Diehl 408 Franklin Street Carlisle, PA 17013 Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 Thomas Day, Jr. Susan K. Day c/o Mark A. Denlinger, Esquire 10 E. High Street Carlisle, PA 17013 O08482-O0055/3.4.021RWSIDCP/155309 Vincent H. Gettel Shirley Ann Gettel P.O. Box 85 Spring Run, PA 17262 First Union National Bank 123 S. Broad Street Philadelphia, PA 19109 Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Attached hereto are original receipts for mailing addressed to the individuals and entities set forth above. SWORN TO ~D~SLrBSCRIBED beforej~ae t.h,e. ~ day of }'~,0~,, ~ ,,,2002. Notary Public ~' 15dC~A~D~. STEWART 008482-00055/3.4.02/RWS/DCP/155309 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLIPPINGER and NANCY K. CLIPP1NGER, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 C1VIL ACTION - LAW IN MORTGAGE FORECLOSURE TO: NOTICE OF SHERIFF'S SALE AND DIVESTITURE OF LIENS Pennsylvania State Bank c/o Bruce D. Foreman, Esquire 4409 N. Front Sheet Hamsburg, PA 17110 No. 2000-1288 Lee M. Diehl 408 Franklin Street Carlisle, PA 17013 No. 1998-05278 Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 Mortgage Book 1468, Page 330 No. 1999-7107 Thomas Day, Jr. Susan K. Day c/o Mark A. Danlmger, Esquire 10 E. High Street Carlisle, PA 17013 No. 20004868 Vincent H. Gettel Shirley Ann Gettel P.O. Box 85 Spring Run, PA 17262 No. 2000-08283 First Union National Bank 123 S. Broad Street Philadelphia, PA 19109 No. 2001-02455 O08482-O0055/3.4.02/RWSlDCPI155309 Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 You are hereby notified that the lien of judgment or lien of mortgage that you may have against real estate owned by the above-named Defendant against the land owned by the Defendant at 242 S. Hanover Street, Carlisle Borough, Cumberland County, Pennsylvania, and more fully described in the exhibit attached hereto, will be divested by a Sheriffs Sale scheduled to be held on June 5, 2002, at 10:00 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Unless you take action to stop the Sheriff's Sale, or unless you appear at the Sheriffs Sale and bid to protect your interest, your lien against the land scheduled to be sold at Sheriffs Sale will be divested by the Sheriffs Sale. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or govemmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be tiled by the Sheriff within thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse, Carlisle, Pennsylvania, Telephone (717) 240-6390. Date: March 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 2002 JOHNSON, DUFFIE, STEWART & WEIDNER Richard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-761-4540 Attorney ID No. 18039 Attorneys for Plaintiff 008482-00055/3.4.02/RWS/DCP/155309 EXHIBIT "A" ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by land now or formerly of Ira W. Miller; on the East by South Hanover Street; on the South by land now or formerly of William P. Stull; and on the West by a public alley. CONTAINING 40.5 feet in front on South Hanover Street and extending at an even width a depth of 240 feet to said alley. BEING improved with an apartment house and outbuilding known as 242 South Hanover Street, Carlisle, Pennsylvania. BEING THE SAME PREMISES Chester W. Schlusser, Sr., by deed dated July 15, 1998, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 181, Page 511, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants herein. TAX PARCEL NO. 04-21-0320-448 SEZIED, taken in execution and to be sold as the propc~-ty of Ronald B. Clippinger and Nancy K. Clippinger, judgment debtors and real owners. The Bank of Landisburg VS Ronald B. Clippinger and Nancy K. Clippinger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5871 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Richard Stewart. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 25.20 Mileage 6.90 Levy 15.00 Advertising 15.00 Certified Mail .86 Poundage 11.69 Law Journal 251.45 Patriot News 193.75 $596.35 paid by attomey 5/29/02 Sworn and subscribed to before me This q r~ dayof~ 2002, A.D. ~. ~ ~' / ! Prothonotary R. Thomas Kline, Sheriff Real Esfate Deputy 008482-00055/3.4.02/RWS/DCP/155309 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which ;nay be affected by the sale: Name: Address: I verify that the statements made in this Affidavit are tree and correct to the best of my personal knowledge or ioformation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: JOHNSON, DUFFIE, STEWART & WEIDNER Richard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-7614540 Attorney ID No. 18039 Attorneys for Plaintiff THE BANK OF LANDISBuRG, RONALD B. CLI!'?INGEp,, Pla/ntiff : CL/~P/NGER- and NANCy K. : Defendants : NO. 01-5871 CIVIL ACTION _ LAW MORTGAGE FORECLOSUR~ TO: RONALD B. CL/~PINGER and NANCy K. CLIPPINGER Your real estate situate in the n ..... Street, Carlisle, Pennsylvania is -~,,~ uugn of Carlisle, Cumberland County, Pennsylvania, known as 242 S. Hanover scheduled to be sold at Sheriffs Sale on June 5, 2002, at I0:00 a.m. in the Cumberland County Courthouse, Car/is/e, Pennsylvania Landisburg against you. to enforce the Court Judgment of $38,779.99 obtained by The Bank of THE PROPERTY TO BE SOLD is delineated in detail in a legal de !he measured boundaries of the property, together ~.,_ . seripfion mainly c,,ns-'--' ~ erected on the land, wma a ~r/ef me ~.... -~ ...... v ~rmg Oza statement of attached hereto as Exhibit n ..... u~ [ne um~dmgs and other ,.,~;... :_ "A" and made a part hereof by reference. '""J'" ~mprovements THE LOCATION of your property to be sold is: THE PROPERTYiS/MPROVED W/TH.~ anarh-~. - ~ THE JUDGMENT under or pursuant to whmh your property is being sold is docketed to' The name and address ofthe OWner or renute ,., .... ~.,_. · · . · -~- d .... ~ uxt[ns property is: out the apared to find out if ,roperty as if WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-5871 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due THE BANK OF LANDISBURGPLANTIFF(S) From RONALD B. and NANCY K. CLIPPINGER, 351 W. NORTH ST., CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 242 S. HANOVER ST., CARLISLE PA 17013 (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 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 he/she has been added as a garnishee and is enjoined as above stated. Amount Due $38.779.99 Interest 10/1/01 - 6/5/02 $1,912.08 Atty's Corem % Atty Paid $119.25 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MARCH 8, 2002 REQUESTING PARTY: Name RICHARD W. STEWART, ESQ. Address: 301 MARKET ST. LEMOYNE PA 17043 Attorney for: PlaINTIFF Telephone: (717) 7614540 Supreme Court ID No. 18039 CURTIS R. LONG Prothonotary, Civil Division Hutchinson, Tina From: · Sent: To: Subject: Jane B. Hoover i'j.b.hoover@pa.net] Friday, March 15, 2002 10:10 AM Hutchinson, Tina Re: Questions for Saturday Hi Tina, The upcoming specials are; April is triple hostess credit with the customer special, purchase the open weave entertainment basket and get the plastic divided liner/protected free ..... they save $25.99 on the liner. May's customer special, is buy the 12 inch oval baker and get the 12 inch oval baker basket in fruit wood free .... they save $39.99 on the basket. I don't know what June's special is yet. Also, by holding a show, April, May or June they will beable to come to my hostess appreciation Bingo. I have several pieces of the "01d Gloryware" in my kit that I will bring tomorrow. Regarding the cheese basket, which one is she interested in? The one with the swing handles or without. Looking forward to seeing you tomorrow, thanks for writing and please don't hesitate to write with anymore questions. Jane ..... Original Message ..... From: Hutchinson, Tina <thutchinson@CCPA.net> To: <j.b.hoover@pa.net> Sent: Friday, March 15, 2002 9:07 AM Subject: Questions for Saturday · Hi Jane, > Just a few questions for you regarding Saturday: · - I have' someone interested in booking a show but she would like to know · what specials are in what months before she commits herself to booking. > Could you please email me a list of the upcoming months with the specials? · And which months (if any) are double or triple hostess credits. I remember · the triple credits are coming up but I told her that wasn't a very good > customer special month. She seems more interested in having a good customer > special. · - I have someone interested in the red, ~i~~ pottery that was the · postcards that were sent out, but she is hopping ~ s a sample of something · on Saturday. Do you have any of t~%~ieces th~.'~/ could bring? Real Estate Sale #65 On March 15, 2002 the sherifflevied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, PA known and numbered as 242 South Hanover Street, Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 15, 2002 THE PATRIOT NEWS THE SUNDAY PATRIOTNEWS Proof of Publication ' UnderAct 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 and The · - 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 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 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 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 in Miscellaneous Book "M", Volume 14, Page 317. COPY ~~j SwOr~e to er~rlibed~etor' r~t~his ~ d~Ma_Y ~ A.D. H am~u~, ~u~n ~/ - s A L I I i NOTARY PUBLIC M~r, P~n~ ~t~ U ~s My ~mmissJon 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 $ 192.00 $ 1.75 $ 193.75 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general c~rcu on, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of thc said Cumberland Law Joumal on the following dates, viz: APRIL 26, MAY 3, 10, 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 tree. REAL E~TATE ~a~LE NO. 65 Writ No. 2001-5871 Civil The Bank of Landtsburg Rona/d B. Clippinger and Nancy IL Clippinger Atty.: Richard Stewart EXHIBIT ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania. bounded and described as follows: ON the North by land now or for- merly of Ira W. Miller; on the East by South Hanover Street; on the South by land now or formerly of Wtlliara p. Stuli; and on the West by a public alley. ._ C~ONTAININCr 40.5 feet in front Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 Rf~ALD B. CLIPPINGER and NANCY K. CLIPPINGER PRAECIPE FOR WKIT OF EXECUTION ~ (MONEY ;~UDGMENTS) · P.R.C.P. 3101 to 3149 Etc. THE BANK OF La~ISBURG IN THE COURTOF COMMON PLF. A~ OF ~"-' ...................................... C~E~ 'COUNTY, PENN-~Y~VANIA ' 97Z752 Att':,'~ C~m... ' ' Corn ............... $ ...................... To Ih~ Pmthonot~ryo~.zld C~urt: I$$UEWILITOF EX~,C%rFION IN THE ABOVE MA'I (]) D;rccted 1o the Sh=~[/o[ ~'q]~ '~ (;) ,:.~, _.___.R~LD. B. CLIPPING~R and NANd~ K. CLIPPINGER (4) ~ud h~ ~ wdt ' RONALD (~) ,4~t ..: ..... B. CLIPPINGER ar~ NANCY K. CLIPPINGER' _. -----~ ..................................................... l~t,.nd,nt (,) ~.d ~) ~.,, ............................................................................... · - ..........r ................................................... ; .... O~mishee (,), m · Ils i~.nd~n~ M&$n. th~ r~al property o1' t]]~: defendant [ s) In th~ ~zm~ of.the Oamhb~ (s) as tnllow~: (-$p~cii'ically d=cn'b= properly) Levy upon and sell all that certain tract of real estate situate in Carlisle BorouDh, Cumberland County, Pennsylvania, owned by the Defendants, Ronald B. C]~ppin~er and. Nancy K. C]~?pinDer, as more fully describedin Exhibit ~"4%" attached hereto and made a part hereof Dated ..... ; .................. " ...... ........ 1= which Isled. ~nara[r~Ph (~,) ' (~) should b~ comple[~d only Il Index nI ol ~ execution la he rounly of fzsuznce~ ts de,red Is 008482-00055/5.29.02/RWS/DCP/155309 THE BANK OF LANDISBURG, RONALD B. CLIPPINGER, Plaintiff CLIPPINGER and NANCY Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of Landisburg, by its attorneys, Johnson, Duffle, Stewart & Weidner, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located 163 Chestnut Street, Carlisle, Pennsylvania. Ronald B. Clippinger Nancy K. Clippinger Name and address of Owner(s) or Reputed Owner(s): Name: Address: 351 West North Street Carlisle, PA 17013 351 West North Street Carlisle, PA 17013 Ronald B. Clippinger Nancy K. Clippinger Name and address of Defendant(s) in the judgment: Address: 351 West North Street Carlisle, PA 17013 351 West North Street Carlisle, PA 17013 property to be sold: Name: The Bank of Landisburg Name and last known address of every judgment creditor whose judgment is a record lien on the real Address: P.O. Box 179 Landisburg, PA 17040 008482-00055/5.29.02/RWS/DCP/155309 Pennsylvania State Bank c/o Brace D. Foreman, Esquire 4409 N. Front Street Harrisburg, PA 17110 Lee M. Diehl 408 Franklin Street Carlisle, PA 17013 Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 Thomas Day, Jr. Susan K. Day c/o Mark A. Denlinger, Esquire 10 E. High Street Carlisle, PA 17013 Vincent H. Gettel Shirley Ann Gettel P.O. Box 85 Spring Run, PA 17262 First Union National Bank 123 S. Broad Street Philadelphia, PA 19109 Name and address of the last recorded holder of every mortgage of record: Name: Address: The Bank of Landisburg P.O. Box 179 Landisburg, PA 17040 Raymond E. Diehl Genevieve A. Diehl c/o Michael J. Hanfi, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 Name and address of every other person who has any record lien on the property: Name: Address: Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 6. Name and address of eve~ other person of whom the Plaintiff has knowledge who has any record interest in the property and whose interest may be affected by the sale: Name: Address: 008482-00055/5.29;02/, RWS!DCP/155309 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: Address: I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. Date: JOHNSON, DUFFIE, STEWART & WEIDNER Richard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-761-4540 Attorney ID No. 18039 Attorneys for Plaintiff O08482-O005515.29.02/RWSIDCPI155309 THE BANK OF LANDISBURG, RONALD B. CLIPPINGER, Plaintiff CLIPPINGER and NANCY Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE OF SHER~'F'S SAI,E OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.7, TO: RONALD B. CLIPPINGER and NANCY K. CLIPPINGER Your real estate situate in the Borough of Carlisle, Cumberland County, Pennsylvania, known as 163 Chsetnut Street, Carlisle, Pennsylvania is scheduled to be sold at Sheriffs Sale on September 4, 2002, at 10:00 a.m. in the C~mberland County Courthouse, Carlisle, Pennsylvania to enforce the Court Judgment of $38,779.99 obtained by The Bank of Landisburg against you. THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and other major improvements erected on the land, attached hereto as Exhibit "A" and made a part hereof by reference. THE LOCATION of your property to be sold is: 163 Chestnut Street, Carlisle, Pennsylvania 17013 THE PROPERTY IS IMPROVED WITH a two story frame stable or shed THE JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 01-5871 Civil Term 2001 in the Court of Commnn Pleas of Cumberland County, Pennsylvania The [tame and address of the owner or reputed owner of this property is: Ronald B. Cli~yoin~er and Nancy K. Clippinger, 351 West North Street, Carlisle, PA 17013 008482-00055/5.29.02/RWS/DCP/155309 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be flied by the Sheriff within thirty (30) days aRer the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse, Carlisle, Pennsylvania, Telephone (717) 240-6390. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SItF, RIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to the Sheriff of Cumberland County, the amount of the judgment To fred out how much you must pay, you may call the Sheriff of Cumberland County at (717) 240-6390. 2. You may be able to stop the sale by filing a petition asking the Court to slrike 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 m~ay need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the the Sheriff of Cumberland County at (717) 240-6390. 2. You may be able to petition the Court to set aside the sale if the 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 the Sheriff of Cumberland County at (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. O08482-O005515.29.02/RWS/DCPI155309 5. You may be entitled to a share of the money wh/ch was paid for your property. A schedule of distribution of the money bid for your property will be filed by the Sheriff within thirty (30) days of the sale date. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions are filed with the Sheriffwithin ten (10) days after the date of the filing of the schedule of distribution. 6. You may also have other rights and defenses, or ways of getting your property 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 O~'FICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717)249-3166 Date:May .... 2002 JOHNSON, DUFFIE, STEWART & WEIDNER BY: Richard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-7614540 Attorney ID No. 18039 Attorneys for Plaintiff O08482-O0055/5.29.02/RWS/DCP/155309 EXIHBIT "A" ALL THAT CERTAIN lot of ground with improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North line of Chestnut Street at the West line of property formerly owned by James McElwee; thence westerly along the said Chestnut Street, a distance of 60 feet to a point at line of property formerly of John Bishop; thence extending northerly at even width of a d/stance of 120 feet to the line of property formerly of the heirs-at-law of J.D. Zimmerman, deceased and having thereon erected a two story frame stable or shed known as 163 Chestnut Street, Carlisle. BEING THE SAME PREMISES which Ronald B. Clippinger, by his deed dated May 7, 1999, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 199, page 225, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants herein. TAX PARCEL NO. 04-21-0320-359 SEZIED, taken in execuhon and to be sold as the property of Ronald B. Clippinger and Nancy K. Clippinger, judgment debtors and real owners. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-5871 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF LANDISBURG, Plaintiff(s) From RONALD B. CLIPPINGER AND NANCY K. CLIPP1NGER, 351 WEST NORTH STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE 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 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 attachmant 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 $38,779.99 Interest FROM 10/1/01 TO 9/4/02 - $2,613.69 Atty's Corem % Atty Paid $743.10 Plaintiff Paid Date: JUNE 4, 2002 REQUESTING PARTY: Name RICHARD W. STEWART, ESQUIRE Address: 301 MARKET STREET LEMOYNE, PA 17043 Attorney for: PLAINTIFF Telephone: 71%761-4540 Supreme Court ID No. 18039 Due Prothy $I.00 Other Costs CURTIS IL LONG Prothonotary, Civil Division 008482-00055/5.29.02/RWS/DCP/155309 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLIPPINGER and NANCY K. CLIPPINGER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE NOTICE OF S~RIFF'S SALE AND DIVESTITURE OF LIENS TO: Pennsylvania State Bank e/o Bruce D. Forem~an, Esquire 4409 N. Front Street Harrisburg, PA 17110 No. 2000-1288 Lee M. Diehl 408 Franklin Street Carlisle, PA 17013 No. 1998-05278 Thomas Day, .Ir. Susan K. Day c/o Mark A. Denlinger, Esquire 10 E. High Street Carlisle, PA 17013 No. 20004868 Vincent H. Gettel Shirley Ann Gettel P.O. Box 85 SpringRun, PA 17262 No. 2000-08283 First Union National Bank 123 S. Broad Street Philadelphia, PA 19109 No. 2001-02455 Raymond E. Diehl Genevieve A. Diehl c/o Michael J. Hanf~, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 Mortgage Book 1605, Page 70 Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. 008482-00055/6.10.02/RWS/DCP/155309 c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 No. 1999-7107 Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 You are hereby notified that the lien of judgment or lien of mortgage that you may have against real estate owned by the above-named Defendant against the land owned by the Defendant at 163 Chestnut Street, Carlisle Borough, Cumberland County, Pennsylvania, and more fully described in the exhibit attached hereto, will be divested by a Sheriffs Sale scheduled to be held on September 4, 2002, at 10:00 a.m. in the Cumberland County Courthouse, Carlisle, Pennsylvania. Unless you take action to stop the Sheriffs Sale, or unless you appear at the Sheriffs Sale and bid to protect your interest, your lien against the land scheduled to be sold at Sheriffs Sale will be divested by the Sheriffs Sale. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff within thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (I0) days of the date it is filed. Information about the schedule of distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse, Carlisle, Pennsylvania, Telephone (717) 240-6390. 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 1'HE O~'FICE LISTED BELOW TO FlND OUT WHERE YOU CAN GET LEGAL i~.LP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Date.' ~_~ k3h~_ I 0,2002 JOHNSON, DUFFIE, STEWART & WEIDNER '"lidchard W. Stewart Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, Pennsylvania 17043 717-761 4540 Attorney ID No. 18039 Attorneys for Plaintiff O08482-O005515.29.02/RWSIDCP/155309 EXHIBIT "A" ALL THAT CERTAIN lot of ground with improvements thereon erected situate in the Third Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and descr/bed as follows, to wit: BEGINNING at a point on the North line of Chestnut Street at the West line of property formerly owned by James McElwee; thence westerly along the said Chestnut Street, a distance of 60 feet to a point at line of property formerly of John Bishop; thence extending northerly at even width of a distance of 120 feet to the line of property formerly of the heirs-at-law of J.D. Zimmerman, deceased and having thereon erected a two story frame stable or shed known as 163 Chestnut Street, Carlisle. BEING THE SAME PREMISES which Ronald B. Clippinger, by his deed dated May 7, 1999, and recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 199, page 225, granted and conveyed unto Ronald B. Clippinger and Nancy K. Clippinger, Defendants herein. TAX PARCEL NO. 04-21-0320-359 SEZIED, taken in execution and to be sold as the property of Ronald B. Clippinger and Nancy K. Clippinger, judgment debtors and real owners. 008482-00055/5.29.02/RWS/DCP/155309 THE BANK OF LANDISBURG, Plaintiff RONALD B. CLIPPINGER and NANCY K. : CLIPPINGER, : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5871 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AFFIDAVIT OF MAILING COUNTY OF PENNSYLVANIA : · ' SS: COUNTY OF CUMBERLAND : RICHARD W. STEWART, being duly sworn according to law, deposes and says that he served the attached Notice of Sheriffs Sale and Divestiture of Liens upon all judgment creditors, mortgagees, and other persons who have any interest of record in or lien of record upon the property scheduled to be sold at Sheriffs Sale in the above matter on ,2002, by mailing a copy of the attached Notice by United States Mail, First Class, Postage Prepaid, addressed as follows: Pennsylvania State Bank c/o Bruce D. Foreman, Esquire 4409 N. Front Street Harrisburg, PA 17110 Lee M. Diehl 408 Franklin Street Carlisle, PA 17013 Chester W. Schlusser, Jr. Barbara L. Reisinger Chester W. Schlusser, Sr. c/o Robert G. Frey, Esquire Frey & Tiley 5 S. Hanover Street Carlisle, PA 17013 Thomas Day, Jr. Susan K. Day c/o Mark A. Denlinger, Esquire 10 E. High Street Carlisle, PA 17013 O08482-O0055/5.29.02/RWSIDCPI155309 Vincent H. Gettel Shirley Ann Gettel P.O. Box 85 Spring Run, PA 17262 First Union National Bank 123 S. Broad Street Philadelphia, PA 19109 Raymond E. Diehl Genevieve A. Diehl c/o Michael J. Hanft, Esquire 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 Tax Claim Bureau One Courthouse Square Carlisle, PA 17013 Attached hereto are original receipts for mailing addressed to the individuals and entities set forth above. SWORN TO AND SUBSCRIBED before me the _~clay of~ ~-]-Dt3~. r~, 2002. Notary Public RICHARD W. STEWART No~4al Seal Dada C. Parmer, Notary Public Lemoyne Bom, Cun~erland County My ~3mmisaton Expires Dec. 29, 2005 CERTIFICATE CERTIFICAT1~ . RIC~IARD W. STE% 301 MARKET STRE CERTIFICATE OF RICHARD W. 301 MARKET STPe~ L~YNE PA 17043 VINCENT H. t~"r,'r:L & SHIRLEY ANN PO Box 85 SPRING ~i]N PA 177&? U.S. PO~TAL SER CERTIFICATE OF RICHARD W. STEWA~ 301 MARKET STREET r L~OYNE PA 17043 9~4C~4A.q DAY. ,'~. ,~ gHSAN K. DAY C/O MARK A. DENLINGER, ESQUIRE 10 E. HIGH STREET, CARLISLE PA 17013 PS FORM The Bank of Landisburg VS Ronald B. Clippinger and Nancy K. Clippinger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5871 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on June 19, 2002 at 11:35 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: Ronald B. Clippinger, by making known unto Ronald B. Clippinger personally, at 351 West North Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on June 19, 2002 at 11:36 o'clock AM, 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: Nancy K. Clippinger, by making known unto Ronald B. Clippinger, husband of defendant, at 351 West North Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2002 at 2:45 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald B. Clippinger and Nancy K. Clippinger located at 163 Chestnut 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 following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Ronald B. Clippinger, by regular mail to his last known address of 351 West North Street, Carlisle, PA 17013. This letter was mailed under the date of July 08, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Nancy K. Clippinger, by regular mail to her last known address of 351 West North Street, Carlisle, PA 17013. This letter was mailed under the date of July 08, 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, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Ricihard Stewart for The Bank of Landisburg. It being the highest bid and best price received for the same, the Bank of Landisburg of P.O. Box 179, Landisburg, PA 17040, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $706.77, it being costs. Sheriff's Costs: Docketing $ 30.00 Poundage 13.85 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 6.90 Certified Mail 1.17 Levy 15.00 Surcharge 30.00 Law Journal 265.40 Patriot News 193.75 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriff's Deed 29.50 $ 706.77 paid by attorney 10/14/02 This lq ~ day of ~ R. Thomas Kline, Sheriff 2002, A.D. B 0 Prothonotary ' Real Estate Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-$871 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF LANDISBURG, Plaintiff(s) From RONALD B. CLIPPINGER AND NANCY K. CLIPPINGER, 351 WEST NORTH STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE 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 garmshee(s) is 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) Ifpr°perty °f 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 $38,779.99 Interest FROM 10/1/01 TO 9/4/02 - $2,613.69 Atty's Corem % Arty Paid $743.10 Plaintiff Paid Date: JUNE 4, 2002 REQUESTING PARTY: Name RICHARD W. STEWART, ESQUIRE Address: 301 MARKET STREET LEMOYNE, PA 17043 Attorney for: PLAINTIFF Telephone: 71%761-4540 Supreme Court ID No. 18039 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division Real Estate Sale # 66 On June 18, 2002 the sherifflevied upon the defendant's interest in the real property situated in The Borough of Carlisle, Cumberland County, PA known and numbered as 351 West North St., Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 18, 2002 Real Estat~ Deputy pROOF OF pUBLICATION OF NOTICE IN cUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF pENNSYLVANIA : coUNTY OF CUMBERLAND : rland Law Journal, of the County _ ' e, Editor of the cu, m~e -~ o ,,s that the Cumberland o,,oer M. Morgenthal, Esqmr!k~,,rdina to law, aeposes an~ oay County and State _ ~'v~esald, being duly sworn, awv - ~ a legal periodical published in the Borough of Carlisle in the and stare a~m ~ designated by the local courts as the official legal LaW Journal, 1952, and of all legal notices, and has, since January 2, 1952, been regularly aforesaid, was established lanuary 2, ' r ublication attached hereto is -. · for the publicat~n . _ the tinted notlc~ o p id Cumberland Law prosodical .. . *~ oald county, and that. pr~.,:~.,~ and ~ssues of the sa issued wee}cry m m~ o _ --%ted in the regular ealuu~o exactly the same as was p,~ ~ statement by the Cumberland AffianTfurt~at he is authorized to verifY this periodical of general circulation, and that he is not interested in the subject Law Journal, a legal advertisement, and that all allegations in the foregoing matter of the aforesaid notice or statements as to time, place and character of publication are tree. W~t No. 2001-5871 Ci~I ~e B~ of ~dtsburg ~n~d B. Chpp~ger ~d N~cy ~ CBPp~ger E~BIT ~ ~T CERT~N lot of ~ound situate in the ~ird w~d of the Borough of c~lisle. Cumberl~d ~c~ly hounded ~d described ~ foBoWs, to ~t: BEGINNING at a point on the No~ ~e of Chestnut s~eet at the West line of property formerly o~ed by d~eS MeElwee; thence westerly ~ong the s~d Chestnut Street. a dist~ce of 60 feet to a po~t at Bne of prope~ fo~er~ of SWORN TO AND SUBSCRIBED before me this ______~_9 day of AUGUST 2002 ~tr-'~e'-t',-~a dist~an~e of 60 feet to a point at line of property formerly of John Bishop: thence extending northerly at even width of a distance of 120 feet to the line of property formerly of the heirs-at-Jaw of J.D. Zimmerman, deceased mud having thereon erected a two stow frame stable or shed known as 163 Chest- nut Street, Carlisle. BEING THE SAME PREMISES which Ronald B. Clippinger, by his deed dated May 7, 1999. and re- corded in the Office of the Recorder of Deeds of Cumberland County in Deed Book 199, page 225, granted and conveyed unto Ronald B. Clip- pinger mad Nancy K. Clippinger. De- fendants herein. TAX PARCEL NO. 04-21-0320- 359. SEZIED, taken in execution and to be sold as the property of Ronald B. Clippinger and Nancy K. Clippin- ger, judgment debtors and real own- ers, THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to ~aw, 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 ~ and ~ 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 pubJication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ 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 subiect 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 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 in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S A L E /t66 NP. AL E=,~TAT Ri ~Ll! NO. 66 W~ No. C~11~1 ~ Bank M ~nd~ Ro~M B. Cl~ln~ and ~nw K. Cl~pln~ N~: RMha~ D~0~ ~ ~T ~ ~ of ~ w~ i~ ~ ~ s~ m~ B~ ~smu~ S~ f~y ~ wc~y ~o~ to ~ linc of law of LD. ~mm~, ~ ~ a k~ ~ 163 C~mut S~ ~isle, B. ~i~, ~ ~ ~ ~ May 7, 1~,~ ~i~ ~d T~ P~ NO. ~21- 03~359. p~ of Ron~d B, ~i~u Clippings, judger ~M~ ~ ~ ~. Advertising Sworn to and subscribR~ Notarial Seal I ~'-') Y ~u, t ~.D. Te~ L. R~II, N~ Publ~ C~ ~ Harrisburg, Dau~n C~ ~m~r. Penns~a ~s~n ~ ~y commission expires June 6, 2006 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 $ 192.00 $ 1.75 $ 193.75 Cost publisher of The Patriot-News and ~L~Zq~j~:~,~, newspapers of generaJ receipt of the aforesaid notice and publication costs and certifies that the same have COMMONWEALTH OF COUNTY PENNSYLVANIA OF CUMBERLAND }SS: I, Robert p. Zie ler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of Landisbur is the grantee the same having been sold to said grantee on the 4t__hh day of Se~ A.D., 2002, under and by virtue ora writ Execution issued on the 4t~h day of June, A.D., 20~02, out of the Court of Common Pleas of said County as of Ci~vi/Term, 20~01 Number 5871, at the suit of Bank of Landisbur against Ronald B Cli in er & Nanc K is duly recorded in Sheriff's Deed Book No. 254, Page 440. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~day of __ ~d_.~ _, A.D. 2002