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FEDERMAN AND PHELAN, LLP
By; FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPIllA, PA 19102
(215) 563-7000
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
711 HIGH STREET
DES MOINES, IA 50392
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
v,
NO. 06-- /.09'-
Ciu.:CT~
CUMBERLAND COUNTY
RONALD C. EBERTS, SR.
JERI L. EBERTS
208 SOUTH 19TH STREET
CAMP lliLL, PA 17011
Defendant( s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
"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
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOUDONOT
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 ASSOCIA nON
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #, 06458582
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1. Plaintiff is
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
711 HIGH STREET
DES MOINES, IA 50392
2. The name(s) and last known address (es) of the Defendant(s) are:
RONALD C. EBERTS, SR.
JERI L. EBERTS
208 SOUTH 19TH STREET
CAMP HILL, PA 17011
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 1/26/94 mortgagor( s) made, executed and delivered a mortgage upon the premises
hereinafter described to PLATTE V ALLEY FUNDING, L.P. which mortgage is recorded
in the Office ofthejRecorder of CUMBERLAND County, in Mortgage Book No. 1197,
Page 622. By Assignment of Mortgage recorded 1/10/96 the mortgage was assigned to
PLAINTIFF which, Assignment is recorded in Assignment of Mortgage Book No. 511,
Page 858.
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 5/1/00 and each month thereafter are due and unpaid, and by the terms of
said mOJigage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
4/1100 through 9/1100
(Per Diem $10.62)
Attorney's Fees
Cumulative Late Charges
1/26/94 to 9/1/00
Cost of Suit and Title Search
Subtotal
$51,682.48
1,624.86
2,584.00
110.67
750.00
$56,752.01
Escrow
Credit
Defecit
Subtotat
0.00
530.31
$530.31
TOTAL
$57,282.32
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiffs written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$57,282.32, together with interest from 9/1100 at the rate of$10.62 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.
:r~r~
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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. 157422:001:BETTY DA VIS : Image 1 of 16
July 20, 2000
Ronald C Eberts Sr.
208 S. 19th Street
Camp Hill, Pa. 17011
RE: Ronald C & Jeri L Eberts Sr.
208 S. 19th Street
Camp Hill, PiL 17011
LoanN~8:8-2~
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
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This is an official notice that the mortlnl!!e on your home is in default and the lender
intends to foreclose. SDecific information about the nature of the default is orovided in
the attached Dalles.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM !HEMAP) may be
able to helD to saye Your home. This notice exolains how the orO!!fam works.
To see ifHEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take
this Notice with YOU when YOU meet with the Counselin!! Agencv.
The name. address and Dhone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this notice. If YOU have any auestions. you may call
the Pennsvlvania Housin!! Finance Agency toll free at 1-800-342.2397. (Persons with
impaired hearing can call (717) 780-1869.
EXHIBnr A
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- 157422:001:BETTY DAVIS : Imal!;e,~ of16
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July 20, 2000
Jeri L Eberts
208 S. 19th Street
Camp Hill, Pa. 170 II
RE: Ronald C & Jeri L Eberts Sr.
208 S. 19th Street
Camp Hill, Pa. 170fl
LoanN~585~
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortl!al!e on your home is in default. and the lender
intends to foreclose. Specific information about the nature of the default is orovided in
the attached oal!es.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be
able to help to save your home. This notice exolains how the orol!I1lm works.
To see ifHEMAP can help. YOU must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TInS NOTICE. Take
this Notice with YOU when YOU meet with the Counselinl! Al!eney.
The name. address and ohone number of Consumer Credit Counseling Al!encies serving
your County are listed at the end of this notice. If YOU haye any auestions. vou may call
the Pennsylvania Housimz Finance Agency toll free at 1-800-342-2397. (Persons with
imoaired hearinl! can call (717) 780-1869.
EXHIBIT A
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This notice contains important legal infonnation. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to explain it
You may also want to contact an attorney in your area. The local bar association may be
able to help you fmd a lawyer.
LA NOTIFlCACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINACE
AGENCY) SIN CARGOS AL NUMERO MENCIONDO ARRlV A. PUEDES SER ELEGIBLE
PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S
ENlERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU
CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
ORIGINAL LENDER:unknown
cURRENT LENDERlSERVICER: Principal Residential Mortgaee. Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
XQU MAYBE ELIGIBLE fOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
f!lOM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
If you comply with the provisions of the Homeowner's Emergency Mortgage Assistance
Act of 1983 (The "Act"), you may be eligible for emergency mortgage assistance:
. If your default has been caused by circumstances beyond your control,
. If you have a reasonable prospect of being able to pay your mortgage payments and,
. If you meet other eligibility requirements established by the Pennsylvania Housing
Finance Agency
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this
Notice. During that time you must arrange and attend a "face.to-face" meeting with one
of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT
APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRrNG
YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW
TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES- If you meet with one of the
consumer credit counseling agencies listed at the end of this notice, the lender may NOT
take action against you for (30) days after the date of this meeting. The names. addresses
and teleohone numbers of desilmated consumer credit counselinr! agencies for the countv
EXHIBIT A
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- 157422:001:BETTY DA YJS: Image 3 of 16
in which the property is located are set forth at the end of this Notice. It is only
necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your
intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for specific infonnation
about the nature of your default.) If you have tried and are unable to resolve this problem
with the lender, you have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with
one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit cOWlSeling agencies have applications for the program and they
will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTL Y. IF YOU FAlL TO DO
SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH
IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE
WILL BE DENIED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria established by
the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that time, no foreclosure proceeding
will be pursued against you if you have met the time requirements set forth above. You
will be notified directly by the Pennsylvania Housing Finance Agency of its decision on
you application.
Note: IF YOU ARE CURRENTLY PROTECfED BY THE FILING OF A
PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT.
(lfyou have filed bankruptcy you can still apply for Emergency Mongage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (BRING IT UP TO
DATE).
EXHIBIT A
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NATURE OF DEFAULT-The MORTGAGE debt held by the above lender on your
property listed above:
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHL Y MORTGAGE PAYMENTS for the
following months and the following amounts are now past due:
May through July in the amount ofS2,483.22
B. YOU HAVE FAILED TO TAKE TIlE FOLLOWING ACTION:(not applicable):
HOW TO CURE THE DEFAULT-You may cure the default within TInRTY (30)
DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER, WHICH IS $2,483.22, PLUS ANY MORTGAGE PAYMENTS
AND LATE CHARGES WHICH BECOME DUE DURING TIlE TIDRTY (30) DAY
PERIOD. Pavments must be made either bv cashier's check. certified check. or monev
order made Davable and sent to:
Principal Residential Mortgages, Inc
711 High Street
Des Moines, Iowa 50392-077
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within
THIRTY (30) DAYS of the date of this Notice, tbe lender intends to exercise its rillbts
to accelerate tbe mortl!:al!:e debt. This means that the entire outstanding balance of this
debt will be considered due immediately and you may lose the chance to pay the
mortgage in monthly installments. J f full payment of the total amount past due is not
made within TInRTY (30) DAYS, the lender also intends to instruct its attorneys to start
legal action to foreclose UUOD vour mortl!:al!:ed Drouertv.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgaged property will
be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its
attorneys, but you cure the delinquency before the lender begins legal proceedings against
you, you will still be required to pay the reasonable attorney's fees that were actually
incurred, up to $50.00. However, iflegal proceedings are started against you, you will
have to pay al1 reasonable attorneys' fees actually incurred by the lender even if they
exceed $50.00. Any attorney's fees will be added to the amount you owe the lender,
which may also include other reasonable costs. Ihou cure the default within tbe
THIRTY (30) DAY Deriod. vou will not be reauired to Dav attornev's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the
unpaid principal balance and all other sums due under the mortgage.
EXHIB!T A
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RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE:-- If you
have not cured the default within the THIRTY (30) DAY period and foreclosure
proceedings have begun, YOU still have the ril!ht to cure the default and Drevent the sale at
any time UD to one hour before the Sheriff's Sale. You may do so bv DaWl! the total
amount then Dast due. DIllS anv late or other charl!es then due. reasonable attornev's fees
and costs connected with the foreclosure sale and anv other costs connected with the
Sheriff's Sale as soecifiedin writinl! bv the lender and bv performinl! anvother
requirements under the mortl!!U!e. Curing your default in the manner set forth in this
notice will restore your mortgage to the same position as if you had never defaulted.
EARLIEST POSSffiLE SHERIFF'S SALE DATE-It is estimated that the earliest
date that such a Sheriff's Sale of the mortgaged property could be held would be
annroximatelv SIX (6) months from the date olthis Notice. A notice oCthe actual
date oCthe Sheriff's Sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be contacting the lender.
HOW TO CONTACT THE LENDER:
Principal Residential Mortgages, Inc.
711 High Street
Des Moines, Iowa 50392-077
Phone 1-800-9624450, extension 77
Fax (515) 247-6554
Contact Person: Tammy Clark
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff's Sale will end
your ownership of the mortgaged property and your right to occupy it. If you continue to
live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings
and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You l8lmay or Omay not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will asswne the mortgage debt,
provided that all the outstanding payments, charges and attorney's fees and costs are paid
prior to or at the sale and tat the other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBT MN MONEY TO PAYOFF TIrE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LE.NDING INSTITUTION TO PAYOFF THIS DEBT.
TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR 8EHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HA VE THE RIGHT TO
CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
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EXHIBIT A
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TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR
ANY OTHER LAWSUIT INSTITUTED UNDER 1HE MORTGAGE DOCUMENiS,
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE
LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COtJNSELING AGENCIES SERVING YOUR COUNTY ARE LISTED ON
THE ATrACHED ENCLOSURE.
EXHIBIT A
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Pen~sylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
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C"CllJlg'.-.inr.on Counties
(Jlnrn.WICQ :'0:- Cu . t_.
2138 Lnco,", "c:-eo. m.."umt"J .,..t:cn (STE?)
P. O. Box 1323 -.
W":!Ii=!spor-:, PA 17703
(5.01326-3537
F.~~(57o) 322.2197
eees oDlor_~e:lSten P"-
201 Basin S"".. .
W"iQ' -.
(S-OIanUport, PA 17703
I ) 323~62'7
F.~"t (570) 323.a626
CLINTON eOu1'l'l'Y
cces o{ Nor..heastern P"-
1631 S AthertOn St .
Suite 100
St:lte College. P.'\. 16801
(8Hl 238-3668
F.~~(814) 238-3669
eOLtJMBIA COu~TI
eccs of~or_~eastern Pennsvlvania
1400 Ahington E:."te<:"~tive Park
Suite 1
Clarlts Summit: PA 13411
(5iO) 53i.9163 or (800) 922-9537
FAX (5iO) 58i-9134i9135
31 W. Market S~et
POB 1127
"'1lltes.Bar.e. PA 13702
(570) 821'{)837 or (800) 922.9537
F_~"{ (5iO) 321.1785
Cotll.I:lission on Economics Opportunity of Luzerne Count"f
163 Amber Lane
W"1lk2s-Barre. PA 18702
(570) 826.0510 or (300) 322'{)359
F....."{ (5iO) 829.1665-CALL BEFORE FA."ClNG
(570) 4554994 K\ZELTON
F.-\X (5io) 455.5631-CALL BEFORE F.~"ClNG
(570) 336-4090 TtiNKH.>"'iNOeK
Booker T. Washington Center
1 i20 Ho Uand S t:'eet
Erie, P."" 16503
(814) 453.5i 44
FAX (814) 453-5749
John F. Kennedy Center, Inc.
2021 East 20th St......t
E..:e. P.'\. 16510
(314) 898-0400
F.-\.1: (814) 898-1243
cees of Weste'"" PeWlSvlvania. Inc.
2000 Ling!esr.own Road .
"=='.sburg, P."- 17102
(71';") S.U.1757
U roa."l Lea","" of:,lec:-apolitan F.ar:-isburg
N. 6th St:'e<!t
F.an-;sburg, PA lil01
(717) 234-59'25
F.-\.'{ (717) 234-9459
Co=unit"f Ac:ion Co= of the Capital Region
1514 Der:'"'1 Sc-:eet
furri.sbu~, P."" 17104
(71i) 232.9757
F..;."'{ (717) 234-2~27
CRAWFORD COUl'<TI
Greater Erie Co=unit"J ."":ion Co=it+..ee
18 West 9t.'>. Street
Erie. PA 16501
(814) 4594581
FAX (814) 456-0161
Shenango Valley t; roan League. Ine
601 Indiana Avenue
Farrell. PA 16121
(412) 981-5310
Cl.;"MBERIA.'lD COL-m'Y
Financial Counseling SeI"'rices o{ ?r:mklin
31 West 3rt! Street
Waynesooro. PA 17268
(717) 762-3285
YWCA of Carlisle
301 G Street
Carlisle, PA li013
(717) 243-3818
F.-\.'l: mi) i31.9589
Adams Count"J Housing .'>.ut.'lorit"J
139-143 Carli3le St
c"ttysburo. PA 17325
(71 i) 334-1518
F.>.."{(i17) 334-8325
EXHIBIT A
PENNSYLVANIA BULLETlN. VOl.. 29, NO. 2:]. JUNE 50 1999
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ALL THAT Caa~AIN pieee or pareel of land. ~ogether wicn ~he improvemeftcs cbereoa
ere~ted_ di:ua~. iQ, the Borough of Camp Hill_ Cumberland County. pennsylv.nia.
bouudad attd de.eribe4 as follows:
BEGINN~NG a~ a poine on the vea~e~ly aide of $. 19~h S~reet, said poine b.inS cb_
dividing line beeveen ene Locs Noa. S8 and 59 on Che he~.in.t~.~ =en~ioned plan
of loea; chance ia a weseerly direceion alons said dividins line One hundred tv~n:y
. (120) feee eo Lae No. 56 on said plan; ~bence in a aouehe~ly di~ection along s.id
LoC. No.. 56 sixcy-t,wo and nine-c:enehs (62.9) feet eo Loe No.. 51 on said plan; then,ce
in an easc@~ly direction along aaid Loe No.. 57. one hund~ed tventy (120) feet to
~he wesee=ly line of s. 19~h Sereec; ehQnee in a norch~~ly dir~e~~on along said
S~ 19th Street. sixcy-~vo 3na nlne-eenths (62.9) feet to the ptace of BECINNINC.
8EING LaC No. S8. Plan oE College Park, as recorded in the Cumberland County aecc~rdarY.
Office in ~lan Book No.4. Page 8; and naving ~he~eon erecced ~ single b~ick dwelting
house known .nd numbered as 208 S. 19~h se~eet. C.mp Hill.
8E~NC THE SAME PREM~SES WHICH James &. Wood. Execueor of the &acate of Frances
~. Wood. by the deed daced November 5. 1982 aod reco~ded November 8~ 1982 in the
Offi~e of che Recorder of Oe@ds in and fo~ Cumbe.land Councy in Oeed Book 29-Y.
Page- 619. granted and eoftveyed unt.o Alfred R.. He:ss, .;IT;. and. Arlene R.ainville M.esis,.
his wife,. Gran~or9 he~ein..
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VERIFICATION
VICKIE JAKSICH hereby states that she is MANAGER OF FORECLOSURE of PRlNCIP AL
RESIDENTIAL MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
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DATE:
9///00
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-06096 Pi
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PRINCIPAL RESIDENTIAL,MORTGAGE
VS
EBERTS RONALD C SR ET AL
TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
EBERTS RONALD C SR
the
DEFENDANT
, at 1437:00 HOURS, on the 22nd day of September, 2000
at 208 SOUTH 19TH ST.
CAMP HILL, PA 17011
by handing to
TAWNYA SMITH, ADULT DAUGHTER
OF DEFT.
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
10.00
.00
37.30
So Answers:
r~~"'~~
R. Thomas Kline
09/26/2000
FEDERMAN AND PHELAN
Sworn and Subscribed to before By:
me this 6't:!:::-
day of
()~ .;l&z/D A.D.
~ t2. Ih,'e;. '. ~
Prothonotary
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-06096 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PRINCIPAL RESIDENTIAL MORTGAGE
VS
EBERTS RONALD C SR ET AL
TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland county,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
EBERTS JERI L
the
DEFENDANT
, at 1437:00 HOURS, on the 22nd day of September, 2000
at 208 SOUTH 19TH ST.
CAMP HILL, PA 17011
by handing to
TAWNYA SMITH, ADULT DAUGHTER
OF DEFT.
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00
.00
16.00
~~~
R. Thomas Kline
me this <5~
day of
09/26/2000
FRD~ ~t 17-
Dep y Sheriff
Sworn and Subscribed to before
h eP;;l, ,.. il--tJVi) A. D .
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FEDERMAN AND PHELM
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
PRICIPAL RESIDENTIAL
MORTGAGE, INC.
711 HIGH STREET
DES MOINES, IA 50392
Attorney for Plaintiff
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
:'-'
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-6096
RONALD C. EBERTS, Sr.
JERI L. EBERTS
208 SOUTH 19th STREET.
CAMP HILL, P A 17011
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 RONALD C. EBERTS,
Sr. and JERI L. EBERTS, 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 9/1/00 TO 10/24/00
TOTAL
$57,282.32
$573.48
$57,855.80
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. ~ "
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: /()-,25--OO
!?,-IJik -R,~ llllr:L
o PROTHY 'V
**TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS
NOT REAFFIRMED, T1DS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT. BUT ONLY ENFORCEMENT OF A LffiN AGAINST PROPERTY. ** .
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FEDERMAN AND PHELAN
1Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
PRINCIPAL RESIDENTIAL
MORTGAGE, INC.
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff
vs.
CUMBERLAND COUNTY
RONALD C. EBERTS, SR.
JERI L. EBERTS
NO. 00-6096
Defendant(s)
TO:
RONALD C. EBERTS, SR.
208 SOUTH 19TH STREET
CAMP HILL, PA 17011
DATE
OF NOTICE: OCTOBER 13. 2000 ,..
";'71 ,..
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COfi:;CT""Aoo ,:!;IEBT.
THIS NOTJCE IS SENT TO YOU IN AN ATTEMPT TO CO~~C1;0HE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBT~INED
FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act wi thin 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 ASSOCIA nON
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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FEDERMAN AND PHELAN
"~ank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
PRINCIPAL RESIDENTIAL
MORTGAGE, INC.
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff
vs.
CUMBERLAND COUNTY
RONALD C. EBERTS, SR.
JERI L. EBERTS
NO. 00-6096
Defendant
TO : .:IERI L. EBERTS
208 SOUTH 19TH STREET
CAMP HILL, PA 170:1.1
fILE CC;'v
I
DATE OF NOTICE: OCTOBER 13. 2000
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE
INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS
NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A
DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims set forth against
you. Unless you act within ten (10) days from the date of this
notice, a Judgment may be entered against you without a hearing
and you may lose your property or other important rights. You
should take this notice to a lawyer at once. If you do not have a
lawyer or cannot affqrd 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
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
Attorney for Plaintiff
PRICIP AL RESIDENTIAL
MORTGAGE, INC.
: CUMBERLAND COUNTY
: Court of Common Pleas
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-6096
RONALD C. EBERTS, Sr.
JERI L. EBERTS
Defendant(s)
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge 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 RONALD C. EBERTS, Sr. is over 18 years of age and resides at
208 SOUTH 19th STREET, CAMP HILL, PA 17011.
(c) that defendant JERI L. EBERTS is over 18 years of age, and resides at 208
SOUTH 19th STREET, CAMP HILL, PA 17011.
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)
PRICIPAL RESIDENTIAL
MORTGAGE, INC.
: CUMBERLAND COUNTY
: Court of Common Pleas
Plaintiff
: CIVIL DIVISION
vs.
: NO. 00-6096
RONALD C. EBERTS, Sr.
JERI L. EBERTS
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
OCTOBER :J..lJ ,2000.
By -fo~
I!r;
J~ DEPUTY
J
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESQUIRE
Attorney for Filing Party
SUITE 900
TWQ PENN CENTER PLAZA
PHILADELPHIA, PA 19102
(215) 563-7000
**TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TIllS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-6096
RONALD C. EBERTS, SR.
JERI L. EBERTS
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above rnatter:
Amount Due
$57.855.80 rI
Interest frotn 10/24/00 - 3/7/01
$1.274.34 and Costs
(per diem - $9.51)
$59.130.14 TOTAL
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F FEDERM, ESQUIRE
T 0 PENN CENTER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property. No.
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DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, together with the improvements thereon erected.
situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as
follows:
BEGINNING at a point on the westerly side of S. 19th Street. said point being the dividing line
between the Lots Nos. 58 and 59 on the hereinafter mentioned plan of lots; thence in a westerly
direction along said dividing line one hundred twenty (120) feet to Lot No. 56 on said plan; thence
in a southerly direction along said Lot No. 56 sixty-two and nine-tenths (62.9) feet to Lot No. 57 on
said plan; thence in an easterly direction along said Lot No. 57. one hundred twenty (120) feet to
the westerly line of S. 19th Street; thence in a northerly direction along said S. 19th Street. sixty-
two and nine-tenths (62.9) feet to the place of beginning.
BEING Lot No. 58. Plan of College Park, as recorded in the Cumberland County Recorder's Office
in Plan Book No.4, Page 8; and having thereon erected a single brick dwelling house known and
numbered as 208 S. 19th Street, Camp Hill.
Tax Parcel #01-22-0536-222
TITLE TO SAID PREMISES IS VESTED IN Ronald C. Eberts. Sr. and Jeri 1. Eberts, his wife,
by Deed from Alfred R. Hess. Jr. and Arlene Rainville Hess, his wife, dated 6/9/1988, recorded
6/10/1988 in Deed Book J33 page 996.
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PRINCIPAL RESIDENTIAL MORTGAGE, INC.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
RONALD C. EBERTS, SR.
JERI L. EBERTS
CIVIL DIVISION
NO. 00-6096
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
PRINCIPAL RESIDENTIAL MORTGAGE. 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 208 SOUTH 19TH STRE1;:[,
CAMP HILL. PA 17011.
1. Name and address ofOwner(s) orreputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
RONALD C. EBERTS,
SR.
208 SOUTH 19TH STREET
CAMP HILL, P A 17011
JERI L. EBERTS
208 SOUTH 19TH STREET
CAMP HILL, P A 17011
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.)
Household Financial
Services
931 Corporate Center Drive
Pomona, CA 91769
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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.)
Household Realty
Corporation
25 Gateway Drive
Gateway Square, Suite 107
Mechanicsburg, P A 17055
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
208 SOUTH 19TH STREET
CAMP HILL, PA 17011
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, P A 17013
I verifY that the statements made in this affidavit are tme 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.
November 14. 2000
DATE
~~E~ ~
Attorney for Plaintiff
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FEDE~andPHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DIVISION
RONALD C. EBERTS, SR.
JERI L. EBERTS
NO. 00-6096
Defendant(s).
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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PRINCIPAL RESIDENTIAL MORTGAGE, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-6096
RONALD C. EBERTS, SR.
JERI L. EBERTS
Defendant(s).
November 14, 2000
TO: RONALD C. EBERTS, SR.
IBRI 1. EBERTS
208 SOUTH 19TH STREET
CAMP HILL, PA 17011
**TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED
TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at 208 SOUTH 19TH STREET. CAMP HILL. PA 17011, is
scheduled to be sold at the Sheriffs Sale on MARCH 7. 2001 at 10:00 a.m. in the Cumberland COlllnty
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by
PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the rnortgagee) against you. If the Sheriffs sale
is postponed, the property will be relisted for the JUNE 6, 2001 Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the rnortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how rnuch you must pay, you may
call: (15) 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 irnproperly 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 th~ 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 bidder. Y oUi 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 ralue of your property.
3. The sale will go tl:lrrough 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 Ifrom the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never ~appened.
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 scheduk 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 willjJe 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.
i
7. You may also have other rights and defenses, or ways of getting your home back, if you act
innnediately after the sale.
i
YOU SHOULD TAKE TH1S 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.
. CUM(BERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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.
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land. together with the improvements thereon erected,
situate in the Borough of Camp Hill, Cumberland County, Pennsylvania. bounded and described as
follows:
BEGINNING at a point on the westerly side of S. 19th Street. said point being the dividing line
between the Lots Nos. 58 and 59 on the hereinafter mentioned plan of lots; thence in a westerly
direction along said dividing line one hundred twenty (120) feet to Lot No. 56 on said plan; thence
in a southerly direction along said Lot No. 56 sixty-two and nine-tenths (62.9) feet to Lot No. 57 on
said plan; thence in an easterly direction along said Lot No. 57, one hundred twenty (120) feet to
the westerly line of S. 19th Street; thence in a northerly direction along said S. 19th Street, sixty-
two and nine-tenths (62.9) feet to the place of beginning.
BEING Lot No. 58, Plan of College Park. as recorded in the Cumberland County Recorder's Office
in Plan Book No.4, Page 8; and having thereon erected a single brick dwelling house known and
numbered as 208 S. 19th Street, Camp Hill.
Tax Parcel #01-22-0536-222
TITLE TO SAID PREMISES IS VESTED IN Ronald C. Eberts, Sf. and Jeri L. Eberts. his wife.
by Deed from Alfred R. Hess, Jr. and Arlene Rainville Hess. his wife, dated 6/9/1988. recorded
6/10/1988 in Deed Book 133 page 996.
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PLAINTIFF
AEFlDA VJT OF SERVICE
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
RONALD C. EBERTS, SR.
JERI L. EBERTS
CUMBERLAND COUNTY
N 0.00-6096
DEFENDANT(S)
Type of Action
- Notiee of Sheriff's Sale
SERVE AT
Z08 SOUTH 19TH STREET
CAMP HILL, PA 17011
Sale Date: MARCH 7, 2001
SERVED
Served and made known to Kon <'\ J d C r Ji'U'k ~ R , Defendant, on the ,;? no! day of &JJo€r . 200Q,
at 8 oc) 'O'ClOCkfLm, at,;/O ~ ~. /9 fi..c0 /, tit rj/l r i)dJ; Pc, I rlJ/ / ,Commonwealth
of Pennsylvania. in the mantler described below:
:x Defendant personally served.
Adult family member with whom IDefendant(s) reside(s). Relationship is
Adult ill charge dfPefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place oflodging in which Defendant(s) reside(s).
Agent ~r person in charge ofDefe~dant(s)'s office or usual place of business.
, an offi~er of said Defendant( s)' s company.
Other:
Description: Age S l {, t::;
I ,Ml f/v.,,,;
,
a true and correct copy of
the address indiCated above.
Height5'cj~S-'8'WeightlH-""'6 Race~SexJl1aJe Other tf~ ~
, a cOJUPetent adult, being duly sworn according to law. depose and state that I personally handed
of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at
Sworn to and subscribed
before me this ~day
of~.x.AM1Nr,200 .
Notary:
9 j .()./ /J
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NOT SERVED
On the
day of
,200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved
Unknown _ No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of ,200_.
Notary:
. By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. ~o. 12248
Two Penn Center Plaza, Suite 900 .
Philadelphia, PA 19102
(215) 563-7000
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AJlFIDAYIT OF SERVICE
PLAINTIFF
PRINCIPAL RESIDENTIAL MORTGAGE, INC.
RONALD C. EBERTS, SR.
JERI L. EBERTS
CUMBERLAND COUNTY
N 0.00-6096
DEFENDANT(S)
Type of Action
- Notice of Sheriff's Sale
SERVE AT
208 SOUTH 19TH STREET
CAMP HlLL, PA 17011
Sale Date: MARCH 7, 2001
SERVED
Served and made known to I~i- i
, V
at 8:00 . o'clockf-.m.,at;(O g
L. C (au--k , Defendant, on the ;2 n d
$ -- ) '} It- S I.. f.lJvwtf!Jub J ~
day of 0J.&..m'wr. :woi?,
(rOIl , Commonwealth
of Pennsylvania, in the manner described below:
x
Defendant personally served. ~ ;; d
Adult family~emberwith whom Defendant(s) reside(s). Relationship is , A 5 011 ;
Adult in charge :ofDefendant(s)'s residence who refused to give name or re ationship.
Manager/Clerk ofplace oflodging in which Defendant(s) reside(s).
Agent or person in charge ofDefendant(s)'s office or usual place of business.
an officer of said Defendant( s)' s company.
7Z0flJ J
~ turfs
Other:
Description:
Age6lJt5
HeightEL!:Bs' 5w eight r It /--".J "" Race -W- Sex ./l!fu.iuOther M ~
a competent adult, being duly sworn according to law, depose and state that I personally handed
f eriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
I,.
a true and correct copy of
the address indicated above.
Sworn to and SUb~d
be~{~:,:....--. ay
of 200 .
No ary:
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NOT SERVED if
On the day of
.200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I,D. No. 12248
Two Penn Center Plaz~, Suite 900
Philadelphia, PA 19102
(215) 563-7000
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Principal Residential Mortgage, Inc.
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No.2000-6096 Civil
-vs-
Ronald C.Eberts, Sf. and Jeri 1. Eberts
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Law Library
County
Levy
Postpone Sale
Surcharge
Certified mail
Mileage
Law Journal
Share of Bills
30.00
7.21
15.00
15.00
.50
1.00
15.00
20.00
30.00
1.82
18.60
187.90
25.53
$ 367.56 Pd by atty 02/06/01
Sworn and subscribed to before me
~~IP~
R. Thomas Kline, Sheriff
This L day of j~
2000, A.D. ~C~ ~~
Protlionotary
BY~JJYt-
Real Estate Deputy
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PRINCIPAL RESIDENTIAL MORTGAGE, INC.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
RONALD C. EBERTS, SR.
JERI L. EBERTS
CIVIL DIVISION
NO. 00-6096
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
PRINCIPAL RESIDENTIAL MORTGAGE. 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 information concerning the real property located at 208 SOUTH 19TH STREEL
CAMP HILL. P A 17011.
1. Name and address ofOwner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
RONALD C. EBERTS,
SR.
208 SOUTH 19TH STREET
CAMP HILL, P A 17011
JERI L. EBERTS
208 SOUTH 19TH STREET
CAMP HILL, P A 17011
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.)
Household Financial
Services
931 Corporate Center Drive
Pomona, CA 91769
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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.)
Household Realty
Corporation
25 Gateway Drive
Gateway Square, Suite 107
Mechanicsburg, PA 17055
5. Name and address of every other person who has any record lien on the property:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
NAME
LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
None
7. Name and address of every other person whom the plaintiff has knowledge who has any interest
in the property, which may be affected by the sale:
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
Tenant/Occupant
208 SOUTH 19TH STREET
CAMP HILL, P A 17011
Domestic Relations of
Cumberland County
13 North Hanover Street
Carlisle, P A 17013
I verifY that the statements made in this affidavit are tme and correct to the best of my personal
knowledge or infonnation 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.
Novernber 14. 2000
DATE
~~E~ -
Attorney for Plaintiff
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PRINCIPAL RESIDENTIAL MORTGAGE, INC.
, Plaintiff,
CUMBERLAND COUNTY
v.
No. 00-6096
RONALD C. EBERTS, SR.
JERI 1. EBERTS
Defendant(s).
November 14, 2000
TO: RONALD C. EBERTS, SR.
JERI 1. EBERTS
208 SOVTH19TH STREET
CAMP HILL, PA 17011
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED WILL BE USED FPR 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 COULECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 208 SOUTH 19TH STREET. CAMP HILL. PA 17011, is
scheduled to be sold at the S~eriffs Sale on MARCH 7. 2001 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover $treet, Carlisle, P A 17013, to enforce the court judgment obtained by
PRINCIPAL RESIDENTIAL MORTGAGE. INC. (the mortgagee) against you. rfthe Sheriffs sale
is postponed, the property will be relisted for the JUNE 6, 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 l!Je 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 aple to stop the sale by filing a petition asking the Court to strike or open the
judgment, if t!).e 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 attdlrney to assert your rights. The sooner you contact one, the more chance
you will have of stopping th~ 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. rf the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. Y oUl 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 sal<:. To
find out if this has happened, you may call (717) 240-6390.
4. rftheamount due from the Buyer is not paid to the Sheriff, you will remain the o\'lller 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 ErA VE
A LAWYER OR CANNOT i 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
i 2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
<."
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DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, together with the improvements thereon erected,
situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, bounded and described as
follows:
BEGINNING at a point on the westerly side of S. 19th Street, said point being the dividing line
between the Lots Nos. 58 and 59 on the hereinafter mentioned plan of lots; thence in a westerly
direction along said dividing line one hundred twenty (l20) feet to Lot No. 56 on said plan; thence
in a southerly direction along said Lot No. 56 sixty-two and nine-tenths (62.9) feet to Lot No. 57 on
said plan; thence in an easterly direction along said Lot No. 57, one hundred twenty (120) feet to
the westerly line of S. 19th Street; thence in a northerly direction along said S. 19th Street, sixty-
two and nine-tenths (62.9) feet to the place of beginning.
BEING Lot No. 58, Plan of College Park, as recorded in the Cumberland Counrv Recorder's Offic'~
- -
in Plan Book No.4. Page 8; and having thereon erected a single brick dwelling house known and
numbered as 208 S. 19th Street, Camp Hill.
Tax Parcel #01-22-0536-222
TITLE TO SAID PRENHSES IS VESTED IN Ronald C. Ebens, Sf. and Jeri 1. Eberts, his wife,
by Deed from Alfred R. Hess, Jr. and Arlene Rainville Hess, his wife, dated 6/9/1988. recorded
6/10/1988 in Deed Book 133 page 996.
.....-
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUN1Y OF CUMBERLAND)
NO.
00-6096
CIVIL 19
CIVIL ACTION - LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt, interest and costs due
Principal Residential Mortgage, Inc.
PLAINTlFF(S)
from
Ronald C. Eberts, Sr.
Jeri L. Eberts
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
see legal description of property
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession ot __
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GARNISHEE(S) as follows:
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and to notffy the garnishee(s) that: (a) ah alfachmEfht has been issued; (b) the garnishee(s) is/are enjoined from payin\~ any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disp~sing
thereof: ,',:,1:1',.\ ':1','
'. .
(3) If property ofthe defendant(~) not levied upon an subjecllo attachment is found inthe possession of anyone other
than a named garnishee, you are directedto notify him/herthat he/she has been added as agarnishee and is enjoined as above
stated.
Amount Due 557.855 -"8t)''-,
Interest from 10/24/00-317/0,1,$1,274.34
A 'c and costs 0'0
tty S omm "
Atty Paid $125.30
Plaintnf Paid
L.L.
S.50
Due Prothy
Other Costs
$1.00
Date:
November 17, 2000
Curtis R. Long
Prothonotary, Civil Division
by:
l~/~d- ~ ~ W
D,.puty
REQUESTING PAR1Y:
Name
Address:
Frank Federman. ESQ.
Two Penn Center Plaza Suite 900
Philadelohia. PA 19102
Attorney for~ Plaintiff
Telephone: (215) 563-7000
Supreme Court ID No.
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,)1\ ~ ~/, ~ the sheriff IeYied upon the defendant::,
interest in the real property situated in fJ. -~p:? 1..L'~.tJ i1- .- :L
Cumberland County, Pa., known and numbered as: ao, L .-ZL J'J.#j;i;),../
fl-y?;J:D and more lully described on exhibit "A" flied with
this .writ and by tillS reference incorporated herein.
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