Loading...
HomeMy WebLinkAbout00-06462 ~. ,~ ji!i-! FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 00 ~I."~ Ci(.Jl(~ CUMBERLAND COUNTY v. SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE **TIIIS 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. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 306487864 ",,"'"""'" .~ '- ^~"~ ~~ .^1(. 1. Plaintiff is GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 2. The name(s) and last known addressees) of the Defendant(s) are: SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 7/13/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PHH US MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1271, Page 1088. By Assignment of Mortgage dated 7/8/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 618, Page 576. 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 6/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified 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." '.~ -~ ~ ~ l' 6. The following amounts are due on the mortgage: Principal Balance Interest 5/1/00 through 9/1/00 (Per Diem $12.23) Attorney's Fees Cumulative Late Charges 7/13/95 to 9/1/00 Cost of Suit and Title Search Subtotal $54,091.64 1,516.52 2,704.00 85.04 550.00 $58,947.20 Escrow Credit Deficit Subtotal 0.00 208.60 $ 208.60 TOTAL $59,155.80 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. 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. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $59,155.80, together with interest from 9/1/00 at the rate of$12.23 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. /s/~,r~ F~FEDER1L\N,ESQUTIRE Attorney for Plaintiff . '" - ..:; '~lIlMl~~' GMAC Mortgage Corporation P.O. Box 85071 San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 Servicing G,...,.. .... ...... Mortgage Dme: August 14, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an officialnotice that the mort2a2e on your home is in default. and the lender intends to foreclose. Snecific informa'tio'n about the nature of the default is nrovlded in the attached na2es. The HOMEOWNER'S MORTGAGE ASSISTANCE P,ROGRAM CHEMAP) may be able to heln to save your home. This Notice explams how the nr02ram works. To see ifUEMAP can heln. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THKDATE OF THIS NOTICE. Take this Notice with vou! when you meet with the , Counse6n2 A2encv. The name. address and nhone number of Consumer Credit Counse6n2 A2encies servin2 your County are listed atthe end of this Notice. If vou have anv auestions, yOU may call the Penn~lvania UOUU2 Finance A2encv toll free at 1.800.342.2397. (Persons with impaired hearin2 can call (717) 780.1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECT A SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFlCACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER EI,EGIBI,E PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCKPROGRAM" EL CUAL PUEDE SAIN AR SU CASA DE LA PERDIDA DEL DERECHO A REDIl\-DR SU IDPOTECA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: SUSAN J. PALMER 222 BRIAN DR ENOLA, PA 17025 MAILING: 1706 PENN ST HARRISBURG, PA 17102-2345 306487864 N/A GMAC Mortgage LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: EXHIBIT A ,,' - ~~ ~-- -~, ~"j ~" j -~.~4~~~~~ GMAC Mortgage Corporalion P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 Servicing ~..",A'" Mortgage Date: August 14, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an offidal notice that the mort2a2e on vour home is in default. and the lender intends to foreclose. Spedfic information about the nature ofthe default is provided in the attached pa2es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save ,'our home. This Notice explains how the pr02ram works. To see ifHEMAP can help, vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet with the Counselin2 A2encv. The name. address and phone number of Consumer Credit Counselin2A2encies servin2 vour Countv are listed at the end of this Notice. If vou have anv questions. vou mav can the Pennsvlvania Housin2 Finance A2encv toll free at 1.800.342.2397. (Persons with impaired hearin2 can call (717) 780.1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit CounselingAgency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you rmd a lawyer. LA NOTIFICACION 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 IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: SUSAN J, PALMER 222 BRIAN DR ENOLA, PA 17025 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT I,ENDERlSERVICER: 306487864 N/A GMAC Mortgage EXHIBIT A" ^ ~ - ,~-'<"".. c ;,',,',;' HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPI,Y \\-1TH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE EUGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAill,T HAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROl" IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGEP AYMENTS, AND IF YOU MEET OTHER ELIGIBILIlY REQIDREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a tempomry stay offoreclosure 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 ofthe consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DAlE. TIlE PART OF TIllS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DAlE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit cOlmseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.The names. addresses and telellhone munbers of designated conSluner credit counseling agencies for thecOlmtv in which the llrollertv 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 lmable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowners Emergency Assistance Program Application with one of the designated consumer credit cOlmseling agencies listed at the end of this Notice. Only consumer credit cOlmseling 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 you face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LEITER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available fimds 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 Agen,,>, has sixty (60) days to make a decision after it receive.s your a]lplication. During that time, no ~oreclosu!" pro~eedmgswill be pursued against you if you have met the tJme reqmrements set forth above. You wiII be notifieddrrectly by the Pennsylvania Housing Finance Agency of its decision on your application. EXHIBIT A """"..,,"<~~ , ~~ 'm' u '~ iUlm~~~p NOTE: IF YOU ARE CURRENTIS PROTECTED 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. (If you have med bankruptcy you can still appl~' for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! it uo to date). NATURE OFTHE DEFAULT -- The MORTGAGE debt held by the above lender is on your property located at: 222 Brian Dr Eno1a, PA 17025 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: June 1, 2000 through August 1, 2000. See attached Exhibit for payment breakdown. Monthly Payments Late Charges NSF Inspections Other Suspense 1,630.77 42,52 0.00 0,00 0.00 TOTAL AMOUNT PAST DUE: 1,673.29 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable): HOW TO CURE THE DEF AUL T -- You may cure the default within TIlIRlY (30) DAYS of the date ofthis notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1, 673 . 29 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE TIlIRlY (30) DAY PERIOD. Pavments must be made either bv cash. cashieI's check. certified check or monev order made pavable and sent to: GMAC Mortgage Corporation ATTN: Payment Processing P.O. Box 780 Waterloo, IA 50704-0780 You can cure any other default by taking the following action within TIlIRlY (30) DAYS of the dale of this letter: (Do not use if not applicable.) Not App Ii cab 1 e IF YOU DO NOT CURE THE DEF AUL T -- If you do not cure the default within TIlIRlY (30) DAYS of the date of this Notice, the lender intendsto exercise its ri!!hts to accelerate the mort~ate debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may ose the chance to pay the mortgage in monthly installments. IHull payment of the total amount past due is not made within TIlIRlY (30) DAYS, the lender also intends to instmct its attorneys to start legal action to foreclose noon vonr mortl!3!!ed Dronert\'. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. Ifthe 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, if legal proceedings ~re started against against you, you ~1I have. to pay all reasonable attorney's fees actually incurred by the lender even Ifthey exceed $50,00. Any attorney s fees will be added to the am01mt you owe the lender, which may also include other reasonable costs, Ifvou cure the default within the THIRTY (30) DAYS oeriod. vou wJ1I not be required to Dav attorney's fees. eXH\B\T A '.. . - - ~, ~ " ~-, ......,.,;-~~~._~J, OTHER LENDER REMEDIES -- The lender may also sue you personally for the lmpaid principal balance and all other sums due ,mder the mortgage. RIGHT TO CURE THE DEFAm~T PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the TIlIRTY (30) DAY period and foreclosure proceedings have beg>m, vou still have the right to cure the default and Drevent the sale at anv time UD to one hour before the Sheriff's Sale. You mav do so bv Davinl! the total amOlmt then Daist due. Dlus anv late or other chames then due. reasonable attornev',S fees and costs connected with the foreclolmre sale and anv other costs connected with the Sheriff's Sale as sDecified in writinl! bv the lender and bv Derforriliril! anv other requirements under the mortl!al!e. Curing your default in the manner set forth in this notice ~ restore your mortgage to the same position as if you had never defaulted. EARIJEST POSSIBI.E SHERIFF'S SM.E DATE .- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice \lfthe actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amOlmt needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: GMAC Mortgage Corporation 401 Mile of Cars Way National City, CA 91950 Phone Number: Fax Number: Contact Person: (800) 850-4622 (619) 470-5579 Collection Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownershil' 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 mayor may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, chaIges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied, YOU MAY ALSO HAVE THE RIGHT, TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTIlER LENDING INSTI11JTION TO PAY OFF TIllS DEBT. TO HAVE THIS DEF AUL T CURED BY ANY TIlIRD PARTY ACTING ON YOUR BEHALF. TO HAVE TIlE MORTGAGE RESTORED TO TIlE SAME POSITION AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE TIlE DEFAULT. (HOWEVER, YOU DO NOT HAVE TIllS RIGHT TO CURE YOUR DEF AULT MORE TIlAN TIlREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT TIlE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OlllER LAWSUIT INSTI11JTED UNDER TIlE MORTGAGE DOCUMENTS, TO ASSERT ANY OTIlER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIlE LENDER. TO SEEK PROTECTION UNDER TIlE FEDERAL BANKRUPTCY LAW, CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUN1Y IS ENCLOSED EXHIBIT A ", ~ -.~ " iirIIl;JljiIU\\!~i;jm.k EXHIBIT June 1, 2000 July 1, 2000 August 1, 2000 @ @ @ 543.59 543.59 543,59 EXHIBIT A "*"i PENNSYL VANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming.Clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 WiUiantsport, P A 17703 (570) 326'{)587 FAX (570) 322.2197 CCCS ofNortheastem P A 201 Basin Street WilliantSport, P A 17703 (570) 323-6627 FAX (570) 323-6626 31 W. Market Street POB 1127 Wilkes..-Barre. PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 CCCS of Northeastern P A 1631 South Athenan St, Suite 100 State College, P A 1680 I (814) 238-3668 FAX (814) 238-3669 COLUMBIA COUNTY 1400 Abington Executive Park Suite I Ctarks Summit, PA 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665--(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631--(Call Before Faxing) (570)836-4090 Tunkhannock Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20. Street Erie, PA 16510 (814) 898-0400 FAX (814) 898.1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA !7102 (717) 541-1757 Urban League of Metropolitan Harrisburg N.6lbStreet Harrisburg, PAl 710 1 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League. Inc, 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 3rd Street . Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 . (717)243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle Sl Gettysburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYL VANIA BULLETIN, VOL. 29, NO. 23, JUNE 5. 1999 EXHiBiT A ,~ "-~ """""~ ~. ~ ~="' .L ---' ".,,,,.i,""~.........~~~ ALL THAT CE&"l'Al.N unit: ill che proper-c)' known. named and ;j,dencified in r:.he Declar- acion ?~an. referred eo belOW' as Wesc.....ood V.illsse Condonl:l..n:l..um loca~ed it'! use. Pennsboro Township, Cu~berland Couney, Commonwealeh of Pennsylvania, which has here'tofore been SubtJl1t:t:'ed to che provisions of t.he Unit Property Act 'of Pennsyl- vania, Ac~ ot JulY 3, 1963. P.L. 196. by the recording in the Office of ehu Re- corder of Deeds of Cumberland Count-y, Pennsy1.vanis. of a nQcl.oracion Creating and 2stabli$h1ng Wescwood Villase Cond~min1um d8c~d January 29, 1975, and recordeu on January 29, 1975, in MiscellaneQus Book 213, Page 283. and amended by 8 cer- t8~n Firs~ Ame~dmenc CO Declaration Creating and Est~bliah~ng Wes~""'ood V~llage Condominium dated Hey 28. 1976 and recorded on June 22, 1976, in M1scellanaou$ Book 222. Page 729, and a certain Second Am~ndmene eo Dec18r8~ion Creae~na and Eseabl1.sh1n& Wes'Cwood Villaa,e Condominium da1:.d .July 21. 1976, and recorded on July 26, 1976. in M1scel18neo~B.Book 223, Page 343. ~nd certain Third Amend~.nt eo Declara~ion Creaeing and Establishing Westwood V~llege Condominium dated June 9, 1978, and recorded on June 23, 1978~ in Miscellanoou$ Uook 236, Page 225. snd a ~artain Fourch Amendmenc eo Deelsration Creating and Establishing Westwood Village Condo~1nium da~~d June 13. 1978, and recorded on June 23, 1978. in Mis- eel1eneoua Book 236, Pase 250. and a ~ert:ain F~f~h Amendmen~ ~o D.~larat1on Creseing and Establishing Westwood Vil1~ge Condominium da'ted January 9, 19'9. end recorded on ~anuary 23, 197~. in Miscellaneous Beok 240. Page B84. and e cerC81n S~x&h Amenamenc eo Pecla~aeion Cre8e~n8 end Estab~~sh1n8 Wesevood V~l~_8e Condo- min;ium dated March 1. 1979. and 'r-.corded March 12. 1979. ;in M:j.8c=:el~aneous Book 241, P8se e36. and a eer~a1n Seveneh Am~ndmen~ co Deolar8~ion C~ea~ing end Es- ~ablishinB We$~wood Vi1~a2e Condominium daten November 8, 1919. and recorded NovembQr 27, 1979. in M~seellaneous Book 249. Pase 323. and a_cer~e1n EiShch Amendme~C to DQc1ara&1on Creating snd Escablishing Westwood Vi~la8~ Condom1n1um dated September )4. 1~$2. and recorded December 14. 1982, in M~sce1~eneous Book 282, Page 3%3. and a Code of Reaulations of Wee~wood Villaga Condominium dD~ed January 29. 1975. end recorded on JanuarY 29, 1975. ~n M~scellaneous Book ~13. Page 328, and amended by a certain Firs~ Ame~dment co Code of Re8ula~~on8 of Westwood V~11s8e Condom~nium daCed May 28. 1976 and record&d on June 22, 1976, in MiscellSrtQous aook 222~ Page 737. and nec18rac~Dn Plen gf Westwood_ Villsse Condominium dated January 29, 1975, and recorded on January 29. 1975. in P1an Book 26. Page 13. and amended by a certain Firsc Amendment co Declara~~on plan of Wescwood V~llaae Condominium dated Ju1y 21, 1976, and reeo~ded on July 26. 1976, in Plan Book 28, Page 72. and amended by a certain Second ~endmBnt to Declara~~on Plart of Westwood Village Condominium daced June 16, 1978. and record- ed June 23. 1978. in Plan 5uok 33. Pase 28,' and -amanded by a certa~n Third Arnend- mBllC ~o Deeloraeion Plen of Westwood V1~lagq Conuomi.nium dated .January 9. 1979, and recorded .Janus.ry 23, 1979. in 'Plan Book 34, Page 100. and amended by a c:er- eai~ Fourch AmGndmen~ ~o Deelarat1Qn" Plan o! We8c~ood Villase Condominium dated March 1. 1979, aod racor4ed Mar~h l2. 1979, ~n P~an Sook 35. Page 3. and emended by a ~ere~1~ Fifth Amendmenc to De914ra~Lon Plan ,of Westwood Village Con~om1n~um da&ed November 8, 1979. end recorded Ngvembe. 27, 1919 in Plan Sook 37, Psae 7. be1~B designsted on aaid DeclarBc1~n Plan of We~ewood Village Condo~~nium es Un1c No. L29-F3. Build1ns No. 10. Block. No. 5, known as 222 Br~an Orive. Enola. Ease Pennsboro Townsh~p. Cumberland County. Pennsylvania, as mor~ fully deserioed in such Declaration Pl~n and Declsratiort Creae~ng and Escablishins Wesc~ood Vi1laSQ Coftdom~n~uM. as the serna 6P?ears of ~eeord as set foreh above. ~n~Lud~n& any a- mendmen~s chereeo. TOGETH~R with a proportionate undiv~ded in~erest in the COmMon Elemenes (as defined in such Declaration) of eiShe hundred fifty chousandehs per- c;en:c (0.850:1:.). UNn~R AND SUBJECT to re5~rieciQns of .eeord. BEING THE SAME PREMISES which t)CNB BANK. N.A., a Na~~onal Banking assoeiat~on. by Deed dated March 6. 1991 and recorded in the Off1ce of the Recorder of DeedS in and for Cumberland COUft~y in Deed !ook Z34, PaB8 764. granted and convey~d uneo Frank M. K1ndlar, single m~n. the said Frank M. K1ndl.r has Sift~B in~ermarr~ed wieh Carmella K~ndlmr who joinS in this conveyance to relinqu~ah all right, in~eres't and title in said property. ~1~~~"HNt~-'lim11'i"'''11,;n,1ill'~J.iil);!;l~~I~",:;,~,.j"l'l"",~U;,iJ,itil;';,i'd';;,,~,",~lIlr;Ji!@il/Mr:iJliIl"'- "'."' ~~~li_l4!lll!IIUi"N.-.;&m.!!i!!..!II.!ll"j,iIllitli&;I; ..," "If.JIlIn ~w - OM_~;".llill . ..-L ~ 'j " , -~.... .--';'~ <-< < .'= ._.c_ ~ - ^'-~,f_ VERIFICATION SillRLEY 1. EADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC MORTGAGE CORPORA nON mortgage servicing agent for Plaintiff in this maller, 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. DATE: q! r!ffd /U/ .;"..,' """,1-,. .,,~~ "'"","" llIt .~l.-.~ ",*'~-~_~.ifif{IlI-W' ~' ~~:f..-d9~tJ~rn: ~ ~j-!l!#~ilil e_ ~ . -llJl(i'IiliIItit - "~-~"'"". ~......~ ~~....;~, II I' I, 1 :j , t ~ ~ -kl. ~ ~ 0 0 08 ~ C> -n I'rt c v:> -1 ~ :!: ." ~ . "Va.:: r'l1 '1" C/) 0 8 (TIfT! -U '-ol-n ""- - q Z:J~ '" ~:'~6 C\ 0 ZC;:. N (/J:tC;.. - -'< L- =-?";'ri ~ R yO > '-':rJ "f r ~- QCJ eo -- rsrn ~ <So S? -"-1 >{= 55 J ~ W 1-:1 =< ,~ ~-~ -- =~ -, -if~.gK-<1 , SHERIFF'S RETURN - OUT OF COUNTY t CASE NO: 2000-06462 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PALMER SUSAN J R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PALMER SUSAN J but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On October 10th , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 10.00 Surcharge 9.00 DEP. DAUPHIN CO 25.50 .00 62.50 10/10/2000 FEDERMAN & PHELAN ~ R. homas Kline Sheriff of Cumberland County - Sworn and subscribed to before me this 11 1& day of (JJa;;L ;> 2irVV A.D. ~a~,~ prothonotal:Y " 'J&\,., ( @iiitt of t1r~ ~4~riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 1710 1 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania GMAC MORTGAGE CORPORATION vs County of Dauphin PALMER SUSAN J Sheriff's Return No. 2192-T - -2000 OTHER COUNTY NO. 00-6462 AND NOW: October 9, 2000 at 9:52PM served the within MORTGAGE FORECLOSURE upon PALMER SUSAN J by personally handing to HER 1 true attested copy (ies) of the original MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 1706 PENN STREET HARRISBURG, PA 17102-0000 Sworn and subscribed to So Answers, Jf~ before me this 5TH day of OCTOBER, 2000 ~'~: ~~ ( PROTHONOTARY .. Pa. By Deputy Sheriff Sheriff's Costs: $25.50 PD 09/28/2000 RCPT NO 141647 TORO , , ,'"--- - _..c;",,'-_-,;.b"_,'_ ;.-r._, 5'.::"~b' , In The Court of Common Pleas of Cumberland County, Pennsylvania GMAC Mortgage Corporation VS. Susan J,-Palmer No. 20-6462 Civil Now, 9/25/00 , 20 () C , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to exe.cute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ;/:d - . r~~~~-~ Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made known to the contents thereof. So answers, Sheriff of County, PA Swom and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDAVIT $ $ .~ .,,- _,,, .' t_,-, FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900, Two Penn Center Plaza (? 1 ~) ~1i1- 7000 Attorney for Plaintiff : COURT OF COMMON PLEAS GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 : CIVIL DIVISION : CUMBERLAND COUNTY vs. SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 : Number: 00-6462 CIVIL TER.t\1 snr.r.F.STTON OF RF,CORn CHANr.F. RF.. PARAr.RAPH#~ OFTHF COMPT.ATNTTNMORTr.Ar.F. FORF,n,OSTJRF. TO THF PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief that the information in paragraph #3 of the Complaint in Mortgage Foreclosure is: On 7/13/1995 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PHH US MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book Number 1271, Page 1088. By Assignment of Mortgage recorded 9/9/1997 the mortgage assigned to CAPSTEAD INC. which Assignment is recorded in Miscellaneous Book No. 556, Page 709. By Assignment of Mortgage recorded 7/8/1999 the mortgage assigned to PLAINTIFF which Assignment is recorded in Miscellaneous Book No. 618, Page 709. Date: Kindly change the information on th~ d October 18, 2000 /vf 12 eft},....-.-v~ Frank Federman Attorney for Plaintiff cc: GMAC MORTGAGE CORPORATION A TTN: FORECLOSURE DEP ARTMENT - LOAN # 306487864 SUSAN J. PALMER ~i ."~~'f"illl'1~:~\~I&iiifuiti1!;'&lliill.~~~~Iil"'--"~,,,,";a'~ -.... ~ ,~.~:.. li .... p' .~ ~~ ~ ("') c: ~p (/\.," -<'> ~~ ~s:) "j -, C~) C-=:l c::!- C"', --j l~0 - .. ,-',"fl ,~3';~~ $ -<; ':...,) .t:iIl'~- ~~.."" ~..~~-<,~.~-_... ~""'c ,... " >FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff VS. : CIVIL DIVISION SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 : NO. 00-6462 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 SUSAN J. PALMER 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 511/00 TO 11/13/00 $59,155.80 $2.409.31 TOTAL $61,565.11 I hereby certify that (1) 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. 4~4de/!~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: AJI>-, , Ifa ()[:()() I1JIfI/f'./1 Iff}, ~fJ~~~ PRO PROT **THIS FIRM IS A DEBT COLLECTOR AITEMPTING 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 CONSffiUED TO BE AN AITEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** " ,i~;ui>m~~ ~'~~..~ ~ ~ ~ -, ~ ..~"'" "~"a " > ,. ~. .,,,,",,,,_.,,~ '~: ,- - ,FEDERMAN AND PHELAN ,Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF "', GMAC MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY SUSAN J. PALMER Defendant(s) NO. 00-6462 FILE COpy TO: SUSAN J, PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 DATE OF NOTICE: OCTOBER 31. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff J~'. . . 'f . '.-" . . FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION SUSAN J. PALMER : NO. 00-6462 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 ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant SUSAN J. PALMER is over 18 years of age and resides at 1706 PENN STREET, HARRISBURG, P A 17102-234. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to lIDsworn falsification to authorities. 41r&x JG-:i:tAt/l~ FRANK FEDERMAN Attorney for Plaintiff . r .~ . "'- "fi ' , -~, - (Rule of Civil Procedure No. 236 - Revised) GMAC MORTGAGE CORPORATION : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION SUSAN J. PALMER : NO. 00-6462 Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on NOVEMBER J(J', ,2000. By ..,fJJfftO" fr1.~ I DEPUTY If you have any question~ concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIlAT 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. ** -";l-..-ill:-df-,,'.,,;c,.;<cYN'-^,'W,,>1o,_Je,;J31'" ~~~'j)-~r#,":yo14!;.g:).u...~tl.tmJi~tl!i;~_;~~~'k;;;;(~l': c ~ --::r- t:- '3; ;;::, ~ - JIl J'f AM.ij- ~ 0 1;. - - 'V 0 -C --,J. Q ~ w - -e.: - "& -~..::,~- ---'" --c , C G ....- 'S:4 $ ~ ~ 3 '" ::> - (') c -ori fi'lrr1 2:T,; zc ~~:~; r::;C ~ zQ --u ;l>c 2~ ::< '\ ~ "i;-- :> ~ -, -" co C' (") "n :::: c-'?; ,,!- ---:;':'::' . '".-.. v' -::;~ -""-.j(,J '::':""'1", -,-L<j \_-) -- ,-0 C)r-n ~ ~ -0 J:;;: c:> (..,) , . ili Ii' ri ~j ~ I 1 , I: Ii I Ii t: l [: Ii I I ;::'~,~"-,~ ( . ,-. ~ "-'^,",', ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 00-6462-CIVIL SUSAN J. PALMER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $61.565.11 Interest from 11/13/00 - 03/07/01 $1.153.68 and Costs (per diem - $10.12) $ 62.718.79 TOTAL ~,:r~ ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. ~. ilr ~~""';"J,"" I~-~ .'g~lltH::J~~~~,'liiWL~~t]\1tlf'" JIl "' -.. . , - <"~ ~- ","","',.;;',' ...,. "" N , N Q .... I:"- .... "",< 1'o1i:l. ~" "",P:: ",>;;> z~ Z'" ...;:$ ~~ Z ~:= O~ Z 0 .......,. "" "'~ 0 ... N <...:< "'" , ... >;;> N 1'01;;>< "'" Q "':<'" ~ U .... .,;;j i:l.Z ~~ I:"- <l.l Zz 0 P:: P::!;;1:< ~ 01'01 ~ ~ 1'01 = Q '" 1'o1~i:l. en ~ ~i:l. ... 0 ~ . <l.l ~ . 0 ~ Oc::l ~~~ ,D 0 O~ U <l.l ~ "'" .. 0 1'01 .; ;J~ S 0 UZ ~~~ N ...>;;> ~ ... ...; OJ a. ~~ ... '" ~ 00 Z ~~~ "",U iJ < p:::n g. <l.l tl '" 01:: ~ f-< p::~ "'~< >;;>~ >;;> ... 0 >;;>1:"-:= ~ 0 '" 1'01~ "''''' 8~ ~ i:l."-' ..c: ... Ui ~ 1'011'01 U U en < ~ <l.l ~~ .i::j ~ ~ <l.l - iJ .~ Z>;;> ... "'U ~. '-j li1 !:,1 I" ii Ji 1.'11.1.. ~ Ii ,-: II Ii ~1 Ii ]J t1 II 11 1 I 'I ... "' ~'-: - - '"~. ' '" '-"~- ,- ,-- "~.. " ~ '" "~,~-."' ,,--, .-! "I f ... DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan, referred to below as Westwood Village Condominium located in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, P.L. 196. by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania. of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Miscellaneous Book 213, Page 283, and amended by a certain First Amendment to Declaration Creating and establishing Westwood Village Condominium dated May 28, 1976 and recorded on June 22, 1976, in Miscellaneous Book 222, Page 729, and certain Second Amendment to Declaration Creating and Establishing Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Miscellaneous Book 223, Page 343, and certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9, 1978, and recorded on June 23, 1978, in Miscellaneous Book 236, Page 225, and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village !Condominium dated June 13, 1978, and recorded on June 23, 1978, in Miscellaneous Book 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9, 1979, and recorded on January 23, 1979, in Miscellaneous Book 240, Page 884, and a certain Sixth Amendment to Declaration creating and Establishing Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Miscellaneous Book 241, Page 836, and certain Seventh Amendment to Declaration creating and Establishing Westwood Village Condominium dated November 8, 1979, and recorded November 27, 1979, in Miscellaneous Book 249, Page 323, and a certain Eighth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated September 14, 1982, and recorded Decembe~ 14, 1982, in Miscellaneous Book 282, Page 323, and a Code of Regulations of Westwood ViIIageCondomiriium dated January 29, 1975, and recorded on January 29, 1975, in miscellaneous bo.ok 213 Westwood village condominium dated May 28, 1976 and recorded on June 22, 1976, in miscellaneous book 222, page 737, and declaration plan of Westwood Village condominium dated January 29, 1975, and declaration plan of Westwood Village condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 13, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on July 26. 1976, in Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded June 233, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declar;ition Plan of Westwood Village Condominium dated January 9, 1979, and recorded January 23, 1979, in Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3, and amended by a certain Fifth Amendment to Declaration Plan of Westwood Village Condominium dated November 8, 1979, and recorded November 27, 1979 in Plan Book 37, Page 7, being designated on said Declaration Plan of Westwood Village Condominium as Unit No. L29-F3, Building No. 10, Block No.5, known as 222 Brian Drive, Enola, East Pennsboro Township, Cumberland County, Pennsylvania, as more fully described in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto, together with a proportionate undivided interest in the Common Elements (as defined in such Declaration) of eight hundred fifty thousandths percent (0.850%). RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Susan J. Palmer, single woman by Deed from Frank M. Kindler and Cannella Kindler, husband and wife dated 7/13/95, recorded 7/17/95, in Deed Book 125, Page 197. H ,,' -~.,' ""~~&lI,gjj;~rJ.~l!!liit-t"""'" -""""'''''''''''''''~~~m,'t~t. _ , ,,~ -~. , }i .~ ~ J:- '" ~ ~ ~ ~ ~ _~'N~ .=_^,_. ~ ~'''''' ~ >-- I) t fj) l:::; ~ !J ~ ~ f ~ , , = I ~'"' __, , ~"'~,, .. , f'~ c., () () 6Jp:! t-:b ~ ~ fl<:Z: ~ ...0.'1 JU o VI '1 () d () I - .. , ... ... - -, ,,' ,-- - - ,~ .- ",-" ~- ^ ~ ~ .- " ~ ._-,-,";-,~I""'".'--~~' o c s:: ""'0("1) mrn :z: :-:0 zr' ~~: \<0 )>0 ;So Pc :z =< -itIilJiilliIii~ Cl Ct W "-j c') C:Y -n , ";'1,"-; w -')\'--' v -~ :,:<C) :";:~~ ,- .::;;; 50 -< I>? ':J1 co - .-, :'1 !I ... ... , ~-~=~ ~ " . ~ " -j ~ ' :a", '" , GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS SUSAN J. PALMER CIVIL DIVISION Defendant(s). NO. 00-6462-ClVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 222 BRIAN DRIVE, ENOLA, P A 17025. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SUSAN J. PALMER 1706 PENN STREET HARRISBURG, P A 17102-234 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None .~ ..1- , " " ~"-'- ~ W" ," . 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address C3l1Ilot be reasonably ascertained, please so indicate.) Mellon Bank, NA 10 S. Market Square Harrisburg, PLA 17101 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address C3l1Ilot 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 C3l1Ilot be reasonably ascertained, please so indicate.) Westwood Village Condo association 820 Lee Lane Enola, P A 17025 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 C3l1Ilot be reasonably ascertained, please so indicate.) Tenant/Occupant 222 BRIAN DRIVE ENOLA,PAI7025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 11. 2000 DATE I't~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~{;;jj;,.' L81~'''' -., < -.M~!i1I~!!j!l!~IillIilt!>,*~tifii!!~*","-"'~"" _< _~~d~ _H"_'~ ~ -, ""'..... .-.'...... 0 (.'::J (..) C-, 0 <' -n "OED 0 ,) m-n p, z' C) -n :D , zr;:: ~.~;~ C/J~ w ge ;g ''1'" ~--;-f ~o 8'~ ~- -'-' )>c 1'0 ~ ':'Ti j;! no J:) -< ( -" ii.i 1.1 \~! Ii! ,.1 I' I) il ','_I',' I I., I' Iii i.1 1:1 [I II I I ,I ! " ','.'~~ J. ,"ul, , ,-~ ~'- FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION SUSAN J. PALMER NO.00-6462-CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that lhe 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. FEDERM rney for Plaintiff - .~~~~~-- ~oo~~ ,~..:,..;J""", ' " - " ." ;"1 I" ;,! 1" ,~I ti 'I I I , , 0 0 0 c: a ...,.., s: Cl "'OCD 1"1 ;- ;.~- ~.:.-.J !flrn n :0 "., zc;::, _,---;C"'" Ge) ,- (J)..;:: ~:~~; 5;) -<./.:, ~o -C' , " ~o ::t: g~~ >0 r:? ~ _oj tn > "XI co -< -a i_ , ,-~ ~ ,- "", . " GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No.00-6462-CIVIL SUSAN J. PALMER Defendant(s). December 6, 2000 TO: SUSAN J. PALMER 1706 PENN STREET HARRISBURG, P A 17102-234 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 222 BRIAN DRIVE, ENOLA., PA 17025, is scheduled to be sold at the Sheriff's Sale on MARCH 7, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by GMAC MORTGAGE CORPORATION (the mortgagee) 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 MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ~..."~ ~~ . . ~~ - --~ >1' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe 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 amolmt due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe 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 maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 -,~"..,""",,~ ._~ - I '~ __ '~'.~"""~""a;; .. DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan, referred to belof,v as Westwood Village Condominium located in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, P.L. 196, by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Miscellaneous Book 213, Page 283, and amended by a certain First Amendment to Declaration Creating and establishing Westwood Village Condominium dated May 28, 1976 and recorded on June 22, 1976, in Miscellaneous Book 222, Page 729, and certain Second Amendmentto Declaration Creating and Establishing Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Miscellaneous Book 223, Page 343, and certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9, 1978,ap.d recorded on June 23, 1978, in Miscellaneous Book 236, Page 225, and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Miscellaneous Book 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9, 1979, and recorded on January 23, 1979, in Miscellaneous Book 240, Page 884, and a certain Sixth Amendment to Declaration creating and Establishing Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Miscellaneous Book 241, Page 836, and certain Seventh ,Amendment to Declaration creating and Establishing Westwood Village Condominium dated November 8, 1979, and recorded November 27, 1979, in Miscellaneous Book 249, Page 323. and a certain Eighth Amendment to Declaration Creating and Establishing Westwood Village CondolI)iniumdated September 14, 1982, and recorded December 14, 1982, in Miscellaneous :Book282, Page 323, and a Code of Regulations of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in miscellaneous book 213 Westwood village condominium dated May 28, 1976 and recorded on June 22, 1976, in miscellaneous book 222, page 737, and declaration plan of Westwood Village condominium dated January 29, 1975, and declaration plan, of Westwood Village condominium dated January 29, 1975, and recorded on January 29, 1971s in Plan Book 26, Page 13, and amended by a certain First Amendment to , Declaration Pial). of Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Plan Bbok 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded June 233, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condornlinium dated January 9, 1979, and recorded January 23, 1979, in Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3, and amended by a certain Fifth Amendment to Declaration Plan of Westwood Village Condominium dated November 8, 1979, and recorded November 27, 1979 in Plan Book 37, Page 7, being designated on said Declaration Plan of Westwood Village Condominium as Unit No. L29-F3, Building No. 10, Block No.5, known as 222 Brian Drive, Enola, East Pennsboro Township, Cumberland County, Pennsylvania, as more fully described in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto, together with a proportionate undivided interest in the Cornmon Elements (as defined in such Declaration) of eight hundred fifty thousandths percent (0.850%). RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Susan J. Palmer, single woman by Deed from Frank M. Kindler and Carmella Kindler, husband and wife dated 7/13/95, recorded 7/17/95, in Deed Book 125, Page 197. _~j!:~ifiikhH\i\!~1dIili.....@;~,-"-"~"- J. .. " ~ "' ~~ - ~, , . ,- ~ - O~ -"-, " .. 'Ii ~ , I I i r.; ! , [ M f! , ~ I ! I' , I ~ 0 CJ 0 C 0 ""{1 s: 0 -octJ r:t1 mm '" z:u Zt;' e' (f)d::~ (".:; . -.<L j~-, ,<C ---~, "~." ~v ~~~ ~o ::1: ,-0 N >-c u Z; 0-< :n ~ =< <.0 -< ~1Il - .~ """ -- ~L -'-. ~ '," -~,};i , PROOF OF SERVICE CD - f.:.4f...:2.. (Requll$ting Agent) FAST SERVE 351 ECHO VALLEY LANE NEWTOWN SQUARE, PA 19073 (Plaintiff) GMAC MORTGAGE CORPORATION (Defendant) SUSAN J. PALMER (Type of Document) NOTICE OF SHERIFF'S SALE (Witness Fee) (Case No. & Jurisdiction) 00-6462-CIVIL, CUMBERLAND COUNTY, PA (To Be Served On) SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102 (Accepted By) SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102 (Date Served) 12-23-00 (Time) 9 30 AM (Process Servers Name) NATHANIEL P. RAFFERTY (Process Server's Report) Description: []Malc .d1White Skin .,..LJIiemale [ ]Black Skin [ ]Brown Skin []Yellow Skin [ Red Skin -f1Hlack Hair [ ]Brown Hair [ ]Blonde Hair [ ]Gray Hair [ ]Red Hair []WhiteHair [ ]Balding [ ]Moustache [ ]Beard []Glasses [ ]14-20yrs [ ]21-35yrs .ef]3O-50yrs [ ]51-65yrs []Over 65yrs [ ]Under 100lbs --UlOO-1301bs [ ]13l-1601bs [ ]161-200lbs [ lOver 200lbs []Under 5' [ ]5'0"-5'3" ~4"-5'8" []5'9"-6'0" []Over6' sworn7~ subscribed before me this I day of ,j( OQ/.. '~""~-'-"'-'dL ~iI!r.i!l;~:2l'lW ',^,_M~"''''~~~'~' -~~~~~- 'w L~..~....., _I"". j" 0 0 0 C -n ~ , ~___-i ~c;J :;;; ~A~ :t! lTi % 'r z.::r; N ~gg Z~ en - <.11 0 2b ..-i_ ""0 " '< .-~11 ~O :Jt 96 z'1TI :pg ~ 0 ~. ;:"' ?5 ...J '< (, h I . I'; I: I: f: I: " ,_"j,',' - l ''''''"0 , ~"-- , ,';f SALE DATE: MARCH 7. 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE CORPORATION No.: 00-6462-CIVIL vs. SUSAN J. PALMER AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 222 BRIAN DRIVE. ENOLA, PA 17025. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed), and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February 1, 2001 '_^f~'~." ~ ~., ~ "~ , , , " .:o,~>. GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS SUSAN J. PALMER CIVIL DIVISION Defendant(s). NO.OO-6462-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 222 BRIAN DRIVE. ENOLA. P A 17025. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 2. Name and address ofDefendant(s) in the judgment: NM1E LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None b ~_ ~~- -~, ,', -,= ;L.. - ~" ~'-""~,, 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.) Mellon Bank, NA 10 S. Market Square Harrisburg, PLA 17101 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.) Westwood Village Condo association 820 Lee Lane Enola, P A 17025 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 222 BRIAN DRIVE ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 1 L 2000 DATE ~~- FRANK FEDERMAN, ESQUlRE Attorney for Plaintiff .., l' ,~ - ~~ ..' -j ~ ~" - <, 'o~"" . ~ DATE: 12/06/00 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) SUSAN J. PALMER PROPERTY: 222 BRIAN DRIVE ENOLA, PA 17025 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 7, 2000, at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street. Carlisle. PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH i"",r..x-, ~, =. ' ~~ - - < > ~..., t""' o 0 S- O _ 0 W~e:.. - - - - - - Ie 00 ...., 0- V> .0- w N - t""'Z V> .0- w N - 0 --0 i<l3 2.g- 0'- '< 0 :> "'~ " 0 o' 0 0. " ~ Z 0 3 0' ~ "''"' >.:l ;;:: -0 "'''' ~::E Z o 0 Wo "'i"l . Kg, t"I I '" "'z =i"l 3 ~ Z .. f-' z~ => t"Vl 0 ~ f-' Oi"l i"l'" 0 0.0 0 2:;z ~ ag. I !:lVl i"l::E :> ::l >.., 0. .,,0 t-< =::l t"0 0. o - '" Zo ;; ~ 0 ~ =C"l ~g ~ - ~ III Oc"l 0'" ~ 0 ..., o' >~ 2:;C"l j;l..: .0 =>0 .?:I ~ o 0 . zt" ~;a i"l- o ~ 0> 0 ~ :z: zt" .~ ~::l .. > O~ ~ :>- i"lz . 0 >-" :<:10 Z'" t"C') 0. :t.: 0 VlZ 0 )>i"l ." ~ ..,Vl t" "Oc"l g ,.. en ~O )> >0 0 m'" 0 _z 9i 3 ~ 0:: i"l"'l "O 0 " - rt ..,c"l > ""0 0 o~ ::t ~O :> .. e - 0. .... ~ ;;:: c"l~ ..., "'> "" ~~ = III >= '" Vl ~ ." H ~i"l '" Vl ~ ~ 0 z '" -~ "l rt Vl> - . > 3 en t"Z 0 .i"l0 .., 0 .g - ~ "Oc"l 0 '" 0 III >0 Z 0 H 0 '" ::ie ,,' S' . =2 OQ ::<: -.., III w...: H H ..... '" cr " H OQ . "' :>- >-" ...., >-" 0 >-" R C'l ." ~ " ~ -- - . - . , ':.';~~~l _~(';~/ I , I e-.,f:'f"--...":J l- rr~ ! :; ~~'~- ." "'--. c:..',) c-_ 0 '- 0 I I I'~ ~~~ --", "'--'~~~'j!l>\' a>z . Q. ., VlQ.= g ;: l'll Q. '" ., " '" = .. Q. l .....,"'l -"'i"l =. '< - -0", ~~~ "" ~ -= 'E.= =. n > ~tDZ "O;;'l(o >~~ :-c~ --;;trj = Nt" N~~ 5. ;; Ie = = ~~lilliiil!f~i;MWili&i;JffiIM~-";:",...,,,m~M!;,,~<A;\!";-"~'fu.4.1i;;W:&Ilf;:mil'5io'Ml1h00;;{IA~~i\IRdJ!lj:Jlilli<il"Lll1ir:~ -" '''"!1iOIJ~1'''-'''''' ~~" ~ ,-,-,,' ~,"c ..~ -'.' - . 1! Ii ~j ::] n ~i " Ii jl !l :i 0 Ci ;~11 C -~ ..." ~ -U rr r"l [Tl q=; OJ r-'-- 2: ("_: 1-'-1 .- -,- ,...., " '0 (0 ,",,> ('-:~~b -< C) ~ ~IJ ;~~l~ '> l-:'- c.,. L.. 0 :> c s'? u --I Z )0> ::;:I (J\ ~ r STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55, Robert P Ziegler I, ______________________________________________________________________________Ilecorderof Deeds in and for said COWlty and State do 'hereby certify that the Sheriff's Deed in which ________________ Federal National Mtg Assoc . ____________________________________________________________________________________ 6 theg<antee the same having been sold to said grantee on the __nnZj:.h._____n______________________________ day of J'1"I_c11__________n____nn_n__________ A. D., ' 0_1____, Wlder and by virtue of a WriL__n______n_ Execution . 13th ______________________nn_____________n _______ISSUed on the ________n ___n_____ __ ____ ____ __n___ Dec 2000 . day of __________________________ A. D., _____> out of the Court of Cornman Pleas of sa.d CoWlty as of Civil 2000 -___________________________ --.---- --___ ________ -- ____ ___ __ ___ __________ ____ _______ TeI'tll, : Number -------~~.?-~--, at the suit of ___n9~~_~!.'.~_~~_:.~_____________________________n___n______ . Susan J Palmer ___________________________________agalnst____________________________________________________ 5 247 319 duly recorded in Sheriff's Deed Book No. _n_________, Page ____________. Correctiove Deed for 241/144 IN TESTIMONY WHEREOF, I have hereunto d and seal of said office this dQ{~-- day _dt2t!L ,I ,." ,=,_,- 0/' ,. '--. ~- - ~-. ,,-, , .--,"^', , , " STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler . ~ ---------------------------------_____________________________________________Ilecorderof Deeds in and for said COiJnty and State do hereby certify that the Sheriff's Deed in which _____n_____n__ Fwaeral Natl Mtg Assoc . ____________________________________________________________________________________ ~ thegranree the same having been sold to said grantee on the ___d____"C!~____________________n____n______ day of March < n_nn____h_hn______h______n__hn A. D., ' 01 d db.' f . _____, un er an y virtue 0 a wnL_____________ Execution . 13th ___ d_ n______h_____n_hn_____ ___ __ h___ _____ISSUed on the ______n___h ___ ____ __ __ __ __ __ __ _____ day of _______ItE2.~__________n___ A. D., -n.?_9QId of the Court of Cornman Pleas of said County as of Civil 2000 ~ ________ _____ ________ _________.,.__________ __ _____ __ _______ ___ __________ __ __ __ __ __ _ Term, : 6462 . GMAC MTG Corp Numher ______________, at the SUit of __n__h_h___________n___n_________h_h_____n_n_____nn_ Susan J Palmer ________ ___ _____ __ _____________ __ __ against___ ________________________ ____ __ __ __ __ __ ____ __ __ ___ is duly recorded in Sheriff's Deed Book No. __n~~_l____, Page ____nl~.4:.__. IN TESTIMONY WHEREOF, I have hereunto -:--tL set my hand and seal of said office this iIC?___.____ day --. ----wh----- ~.~.., rl~_( -tlJ- --- --- -- ----- . r of Deeds ,~tf""Cum\IIIlaIIdCounlr.c.-. " .' 'nil' __l\Iaflnl--.ol_- '. . . ~~ ~~~ - ~"'~ -" ~ ~ !1!l>!' , GMAC Mortgage Corporation -vs- Susan J. Palmer In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-6462 Civil R. Tholl1!is Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry fort)1e within named defendant to wit: Susan J. Palmer, but was unable to locate her in his bailiwick. Hie therefore deputized the Sheriff of Dauphin County, to serve the above Real Estate Writ Notice Poster and Description according to law. Dauphin County Return: And now January 17,2001 at 8:48 PM sewed the within Real Estate Writ Notice and Description upon Susan J. Palmer by personally handing to her a true and atteSted copy of the original Real Estate Writ Notice & Description and making kno"\^'ll unto her the contents thereof at 1706 Penn Street, Harrisburg, Pa. So answers: J. R.Lotwick Sheriff Dauphin County, Pennsylvania. Dawn 1. Kell Deputy Sheriff who being duly sworn according to law, says on January 4, 2001 at 4:09 o'cloc~ P. M. EST, she posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of Susan 1. Palmer located at 222 Brian Drive, Enola, Cumberland! County, Pennsylvania according to law. R. Thom*s Kline Sheriff, who being duly sworn according to law, says he served the above Real Estate WritJ!..lotice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant to wit: Susan J. Palmer by regular mail to her last knownadclress 1706 Penn Street, Harrisburg, Pennsylvania. This letter was mailed under the date of January 22,2001 and never returned to the Sheriffs Office. R. .T1~omas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7, 2001 at 10:00 o'clock .. A.M., E.S.T., and sold the same for the sum of$1.00 to Attorney Robert Liberman for Federal National Mortgage Association. It being the highest bid and the best price received for the same federal National Mortgage Association, of 1900 market Street, Suite 800, Philadelphia, P A, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of$1491.29 it being costs. Sheriff s Costs Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Out of County Dauphin County Law Journal 30.00 29.24 15.00 15.00 30.00 10.00 .50 1.00 9.30 1.10 15.00 20.00 9.00 25.50 "' 688.55 Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed "' .~~ L.._ ~ 515.07 25.53 25.00 26.50 1491.29paid by attorney 3-14-01 Sworn and subscribed to before me This ~ W;? day of ~...1 ] <- 2001 AD. Prot 0 onotary ~/~-., R. Thomas Kline, Steriff" BY~n~ .Ji.~ Real Estate Deputy .~~ 00 ~ -, ~Ilil' ~M ..;0,<10 \ ,J0l Ck-31 ~ ;) .J.-. ~ /tJ1'1J.( ~. ~~JIa"K \ ? " " . GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS SUSAN J. PALMER CIVIL DIVISION Defendant(s). NO. 00-6462-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 222 BRIAN DRIVE, ENOLA. PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) SUSAN J. PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~--" ~ -'- ,- -, " ",' --, l.' <., - -, "~ " . " 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.) Mellon Bank, NA 10 S. Market Square Harrisburg, PLA 17101 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.) Westwood Village Coudo association 820 Lee Lane Enola, P A 17025 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, whicWmay be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 222 BRIAN DRIVE ENOLA,PAI7025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsificaiion to authorities. December 1 L 2000 DATE I/~ ~- FRAJ{KFEDE~,ESQlmRE Attorney for Plaintiff '"""- 0" Ul!' . r. .. - GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No.00-6462-CIVIL SUSAN J. PALMER Defendant(s). December 6, 2000 TO: SUSAN J.PALMER 1706 PENN STREET HARRISBURG, PA 17102-234 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA TrON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 222 BRIAN DRIVE, ENOLA, PA 17025, is scheduled to be sold at the Sheriff's Sale on MARCH 7, 2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the propertywill 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 be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for !Sood cause. 3. You may also be able to stop the sale through other legal proceedings. ~"." '< ~, " ' It: ";: ... ,'. '~ ~ . You may need an attorney to. assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2 I 5) 563- 7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will"be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .... ; " .- DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan, referred to below as Westwood Village Condominium located in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania., which has heretofore been submitted to the provisions of the Unit Property Actof Pennsylvania, Act of July 3, 1963, P.L. 196, by the recording in the Office of the Recorder of Deeds of Cumberland County ,Pennsylvania, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Miscellaneous Book 213, Page 283, and amended by a certain First Amendment to Declaration Creating and establishing Westwood Village Condominium dated May 28, 1976 and recorded on June 22, 1976, in Miscellaneous Book 222, Page 729, and certain Second Amendment to Declaration Creating and Establishing Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976. in Miscellaneous Book 223, Page 343, and certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9, 1978, and recorded on June 23, 1978, in .'vliscellaneous Book 236, Page 225, and a certain Fourth Amendment to Declaration Cre::lting and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Miscellaneous Book 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9, 1979, and recorded on January 23, 1979, in Miscellaneous Book 240, Page 88+, and a certain Sixth Amendment to Declaration creating and Establishing Westwood Village Condominium dated March 1. 1979, and recorded March 12. 1979, in .'vliscellaneous Book 241, Page 836, and certain Seventh Amendment to Declaration creating and Establishing Westwood Village Condominium dated November 8,1979, and recorded ;-Jovember 27,1979, in Miscellaneous Book 249, Page 323, and a certain Eighth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated September 1+, 1982. and recorded December 14, 1982, in Miscellaneous Book 282, Page 323, and a Code of Regulations of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in miscellaneous book -213 Westwood village condominium dated May 28, 1976 and recorded on June 22, 1976, in miscellaneous book 222, page 737, and declaration plan of Westwood Village condominium dated January 29, 1975, and declaration plan of Westwood Village condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 13, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated Julv 21, 1976, and recorded on Julv 26, 1976, in Plan Book 28, Page 72, and amended by a certain Se~ond Amendment to Declaration' Plan of Westwood Village Condominium dated June 16, 1978, and recorded June 233, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condominium dated January 9, 1979, and recorded January 23, 1979, in Plan Book 34-, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3,and amended bv a certain Fifth Amendment to Declaration Plan of Westwood Village Condominium . ~ dated November 8, 1979, and recorded November 27, 1979 in Plan Book 37, Page 7, being designated on said Declaration Plan of Westwood Village Condominium as Unit No. L29-F3, Building No. 10, Block No.5, known as 222 Brian Drive, Enola, East Pennsboro Township, Cumberland County, Pennsylvania, as more fully described in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium. as the same appears of record as set forth above, including any amendments thereto, together with a proportionate undivided interest in the Common Elements (as defined in such Declaration) of eight hundred fifty thousandths percent (0.850%). RECORD OW?>o""ER TITLE TO SAID PREMISES IS VESTED IN Susan 1. Palmer, single woman by Deed from Frank M. Kindler and Carmella Kindler, husband and wife dated 7/13/95, recorded 7/17/95, in Deed Book 125, Page 197. ~ " -,- -~-~ ~ . ~ ~. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEA~::rH,oF PENNSYLVANIA) COUN1Y OF CUMBERLAND) NO. 00-6462 CIVIL TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumber land COUNTY: To satisfy the debt, interest and costs due GMAC Mortqaqe Corporation PLAINTIFF(S) from Susan J. Palmer, 1706 Penn Street, Harrisburg, PA 17102 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Leqa1 Description ", '1;< . l" .~~. r "",' ~ ,I:".',JI ,;!,l, '::L.i'J :, _' ','J ' r,:J}I-";"" (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession 01 -:,.., ;,; ..J~~ GARNISHEE(S) as follows: '. . and to notify Ihe garnishee(s) that: (a) an allachmeht'has been issued; (b) Ihe garnishee(s) is/are enjoined from paying any debt to or for the account of Ihe defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; , ,- . ' . . ", -.', . - ','" " \ ,,_. (3) II property ofthe del~ndant(s) notlevied upon an. subject to attachment is found in the possession 01 anyone other than a named garnishee, you areiJired'edto notify himlherthathe/she has been added as a garnishee and is enjoined as above stated. L.L. Due Prothy Other Costs $.50 $1. 00 Amount Due $61,565,11 1m ffi from 11/13/00-3/7/01 $1,153.68 ere (yeL (J",.llU - $10,12) Atty's Comm % Atty Paid $134.50 Plaintiff Paid Date: December 13, 2000 Curtis R. Long Prothonotary, Civil Division L2a'--;',L 2. ~o>/M'rl' J Deputy '"--bY. : REQUESTING PAR1Y: Name Frank Federrran, Esq. Address: One Penn Center at Suburban Station, Suite 1400 philadelphia, PA 19103 Attorney lor: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 ~/I!il~~J>lii:ili~~~_~~@-,ti(~~tii)j'4tl'::J,,,,_jj;..~iii";;::-B!fr""'nf."It&mfi ...J.~ --_ ~'b"'."''':'' - ~ ... . , REAL ESTATE SALE No.4'~ REA'L-mATE-SAlE-No;"42 W!itNo.2.~ ClvllTerm . GMAC Mortgage Corporation ... Susan J: Palmer Atty: Frank Federman , DESCRIPTION ALLJ'HAT CERTAIN unit in the property known named and identifitiJ in the Declaration Plan' referred to below' 'as Westwood Vmag~ Condominium located in East PennsboIO To~'t1shlpt Cumberland County, Commonwealth of Pennsvlvania, which has heretofore been : submitted to the provisions of the Unit Property : Act of Pmnsylvania, Act of Jul}' 3, 1963, r L 196, bV , the reco.rding in the Office oi the Recorder of i Deeds of Cumberland County, ~nnsvlvania, of d Declaration Creating and Establishing Weshl/ood Village Condominium dated Januarv 29, 1975, and recorded on January 29, 1975, in Miscellaneous B?<Jk 213, Page 283, and ame~ded by "_ certain , fU'St Amendment to D~daration Creating and establishing Westw. on Village Condominium 9ate~ May 28,.1976 andrec(lrded on June;U, 1976, In l\.-fiscellaneou5 Book 222, Page 729, ana certain Seccmd Amendment to Declaration Creating and , Establishi.ng W~twoo~ Village- Condominitlm -dat{!d July 2-1, 1976, and recorded on Julv 26, 11)76 in Miscellaneous Book.~, Page 343, and certai~ ~jrd .i\n.1endm.ent ro tlecIaraHon Creating and , l::..,tablt~hmg \\'e&wOM Vll~lge Condomrnium , dated June 9, 1978, and recorded on June 23, 1978 in Miscellaneous B;0ok 236, 1lagc 22.5, and ; certain Fourth Amendment to Declaration - Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Miscellaneous Book 2.36, Page 250, and a certain FjiIb Amendment to Declaration ~r-e~ti~g and Establishing Westwood Vill.1gl' Conaonnmum dated January 9, 1979, and re'cllrded on January 23, 1979, In Miscellaneou5 Book 240, Page &34, and a certain Sixth Amendment to Declaration cre~tfng and Establishing W'cstwood Vlnage Condominil1m dated !\:larch 1, 1979, and recorded March 1" 1979, in Mi5telJanef/us Book 2-!1, Page 836, and ' ".ertain Seventh A_-rnt!ndment, to Dedaraiinn . '~~Jting Jnd Establishing ~\'~~m'ood VilJagl,' --0 ':OOdwillniUlIl....-l'iaEeiL Nm'ember __8, 1m, _and_ .':::~I?M~-N~~e~~; '1,7.1919~ lrtMls.:ellaneQus- ,': '~k. ;4-9. Pa~e 513i anq .'l certain Eighth ...'.Amendmenf to DI?darJtion Creannf" and i, ..:::~J:?Ii~~Nl!g ~'estwv.od \fjl!a.pc.. C,on,dQ~1n!um -".,~~d September 14, 1981;' and tec:ordM- ~,ei:ember 14, 1982, in Miscellaneous Book. 182.- . - Page 323, and a ~~dc o~ Regulations of Wes(:Wood ' Village CQndOmmlUm aatl'd Januarv 29, 1971iJ and - ,: recorited on Januaro.> '19, 1975, in miscellaneous book 213 WestwoodYdlage Condominium dated M,ay 28, 1976 and recorded on June- 22,. 1976, in ml5cell~neous book 2?2, page?37, and declaration plan at Wesh\'ood Village Condominium dated January 29,1975, and declaration plan of Wl!5~9od Village Condominium dated January 29,19"" and recorded. on January 29,1975 il1 Plan Book 26, Page 13, and 'amended hy a ~rtdln First Amendment to Declaration Pum of Wesh\'ood Village CondominiuOJ dated July 21, 1976, and recordedon]uly26, 1-976, in Plan Book28 Page 72 and ame~ded by a certain Second Amendment oc: Dedara!lOn. Plan of Westwood Village CondoIDltIrum dated June 16, 1978, and recorded Jun\! ..23, 1978, in I?l~~ Book. '23, Page 2&, ana amended by a (edam Third Amendment to Declaration Plan or Westwood Vitlage Condominium dated }anuarv 9, 1979, ilnd "'. corded January 23, 1979, in Plan &ok 34, Page 100, ana amended by \l 'Cl'rtain Fourth Amendment to Dedaratlon Plan ot Westwood Village Condominium dated March 1, 1979 and recorded foJ!arch 12, 1979, in Plan Book 35, P;gc 3, ,~nd arn~aed by J c~rtain Fifth Amendment to Declarahon Plan of W~5-twood Village Condominium dated November a 1979 Jnd ;;ro~ed NQ~ember 27, 1979 in Plan Book 3i, Page I, bt!mg deSlgnated on said Dedar,1tion Plan of W~stwoodViJ[age Condoininium as- Uni1 No_ L2q- F3,: Duilding No. '10, Bloci< 5, known as 222 Brian Dme, Enola, East PennsboTO Township Cum~"erlan~ County, Pennsylvania, as more fun; d('scnbed m sum Dt!clarJtion Plan and ~edaration Crea.H~g iind Estab1i~hing W~stwood 'lllage CondommlUm, as the ~amc apyears of Tf(oid as set .forth Jbore, indudin.:;: 3ny am~ndrnents t.l1ereto, toge.ther Wtt.h j propottioIldte I.lndhided interest in the Cmnmon Elements (as defined in such Declaration) oj eight hundred fifty thousandths perCfUt lO.8505). ' RECORD OWNER - TIllE TO 5AlD PREM[>"ES IS VESTED IN Su"'. J. ,Palmer, $:nI/le worn,1ll by Deed from Frank M. Kindler ana Ciinne)Ja Kindler. husband and wife .dated7f13{9_5,recorded 7/17/95, in Deed Book 125 Page.I97. ' ,,'.~- "~-~ -~ ~. 'tln , ' #"-- , '" THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Ass!. 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 Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since: That the printed notice or pUblication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 30th day(s) of January and the 6th and 13th day(s} of February 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, piace 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 i Misc'ellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE # 42 Notarial Seal Teny L. Russell, Notary Publi Harrisburg, Dauphin Coun My Commission Expires June 6,2 TARY PUBLIC Member, Penn.yivanie Association 01 Notarie'My commission expires June 6, 2002 " CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 . Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 513.57 1.50 515.07 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... J' iii "'"'I " -',~~~", l!lM> EMATE 8:$LE N0. 4& Writ No. 2000-6462 Civil GMAC Mortgage Corporation vs. Susan J. Palmer Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN unit in the property known, named and identi- fied in the Declaration Plan, referred to below as Westwood Village Con- dom1nium located in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been subIIJ.jt- ted to the provisions of the UIl1t Property Act of Pennsylvania. Act of July 3. 1963. P.L. 196. by the recording in the Office of the Re- corder of Deeds of Cumberland County, Pennsylvania. of a Decla- ration Creating and Establishing Westwood Village Condominium dated January 29. 1975, and re- corded on January 29, 1975. in Miscellaneous Book 213. Page 283. and amended by a certain First Amendment to Declaration Creating and establishing Westwood, Village Condominium dated May 28. 1976 and recorded on June 22. 1976. in Miscellaneous Book 222. Page 729. and certain Second Amendment to Declaration Creating and Establish- ing Westwood Village Condom1n1um ! dated July. 21. 1976. and recorded .. on July 26. 1976. in Miscellaneous Book 223. Page 343. and certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9. 1978, and recorded on June 23, 1978. in Miscellaneous Book 236. Page 225. and a certain Fourth Amendment to Declaration Creating and Establ1shlng Westwood Village CondomJnlum dated June 13. 1978. arid recorded on .June 23, 1978, in Miscellaneous Book 236. Page 250. and a Certain Fifth Amendment to Declaration Creating and EstablIsh- ing Westwood Village CondomJnlum dated January 9. 1979. and record- ed on January 23, 1979. In Miscel- laneous Book 240, Page 884. and a certain Sixth Amendment to Decla- ration Creatlng and Establlshlng westwood Village Condominium dated. March I. 1979. and recorded March 12. 1979, in Miscellaneous Book 241. Page 836. and certain Seventh Amendment to Declaration creating and Establisb1ng westwood Village Condominium dated Novem- ber 8. 1979. and recorded Novem- ber 27. 1979. in Miscellaneous Book 249. Page 323. and a certain Eighth Amendment to Declaration Creating ~Ii --,--"",~,,,=, - ~~"""'''iill;, -"' and Establishing Westwood Village CondoIIllnium dated September 14 1982, and recorded December 14: 1982. in Miscellaneous Book 282. Page 323. and a Code of Regula- tions of Westwood ViU.age Condo- minium dated Januazty 29. 1975. and recorded on Janu~ 29. 1975. in miscellaneous bOOK 213 West- wood village condomihium dated May 28. 1976 and recor~ed on June 22, 1976. in miscella{1eous book 222. page 737 and declrration plan of Westwood Village cg~dom1nium dated January 29. 19715. and dec- laration plan ofWestwoocj Village con- doIIllnium dated Janua1jY 29. 1975. and recorded on JanuatY 29. 1975 in Plan Book 26. Page 13, and amended by a certain ptst Amend- ment to Declaration PI~ of West- wood Village CondOmiriium dated July 21. 1976. and recorded on July 26. 1976. in Plan Book 28. Page 72. and amended by a certain Sec- ond Amendment to De~tion Plan of Westwo0d Village Condominium dated June 16. 1978. and rec0rded June 23. 1978. In Plan Book 33. Page 28. and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condo- minium dated January 9, 1979. and recorded January 23. 19i79. in Plan Book 34. Page 100, and amended by a ce:rtain Fourth AmJndment to Declaration Plan of We~twood Vil- lage Condominium dated March 1. 1979. and recorded March 12. 1979. in Plan Book 35. Page 3. and amend- ed by a certain Fifth Amendment to Declaration Plan of Westwood Vil~ lage Condominium dated November 8, 1979. and recorded November 27. 1979 In Plan Book 37. Page 7. being designated on said Declara- tion Plan of Westwood Village Con- dominium as VIllt No. L29-F3, BUild- ing No. 10. Block No.5. known as 222 Brian Drive, Enola. East Penns- boro Township. Cumberland Coun- ty. Pennsylvania, as more fully de- scribed in such Declaration Plan and Declaration Creating and Es- tablishlng Westwood Village Condo- minium. as the same appears of record as set forth above, 1nclud1ng any amendments thereto. together with a proportionate undivided in- terest in the Common El€iments (as defined In such Declaratio\n) of eight hundred fifty thousand~s percent (0.850%). RECORD OWNER TITLE TO SAID PREMISES IS VESfED IN Susan J. Palmer. single woman by Deed from Frank M. Klndler and Cannella Klndler. hus- band and wife dated 7/13/95. re- corded 7 {17 195.ln Deed Book 125. Page 197. -,-- " - -. .- "Ijj_r-~~,- . . , -- ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : 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 the said Cumberland Law Journal on the following dates, V1Z: JANUARY 19, 26, FEBRUARY 2, 2001 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~!:!~ SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY. 2001 I'IOT ARlAl Al Notary Publi< lOl6E.5I'M>U. -. . . PI. c...... 10.0. Cvmbe<\iInd County. . lAy Com_on Expire. March 5. 2001