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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
MARTIN E. BAILEY AND
MELANIE R. BAILEY
(Mortgagor(s) and Real Owner(s))
Term
No. CO -1"1J.1 Gu: (/~
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
CIVIL ACTION: MORTGAGE
FORECLOSURE '
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
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 the 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 tor 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 '1'0 OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE VSTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, BE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. paR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD
U ofROS'DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
81 NO CDNDCE A UN ABOGADO, LLAME AL llLAWYER REFERENCE SERVICE1' (8ERVICIO DE REFERENCIA DE ABOGADOS),
215~238-6300 .
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
S Irvine Row, Carlisle, PA 17013
(717) 243-9400
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COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate
Drive, PTX B-35, PIano, TX 75024-3632.
2. The name(s) and address(es) of the Defendant(s) is/are
MARTIN E. BAILEY, 35 N. Middlesex Road, Carlisle, PA 17013 and
MELANIE R. BAILEY, 35 N. Middlesex Road, Carlisle, PA 17013, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On July 31, 1996, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
SIGNET MORTGAGE CORP., which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County in Mortgage Book 1336,
Page 195. By Assignment of Mortgage dated August 9, 1996, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 532, Page 175. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
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 May 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 4/ l/OO
through 10/31/00 at 8.000%
Per diem interest rate at $13.47
Attorney's Fee at 5%
of Principal Balance
Late Charges 5/ 1/00-10/31/00
Monthly late charge amount at $22.49
Costs of suit and Title Search
$ 61,470.58
2,869.11
3,073.53
134.94
560.00
Escrow Balance Credit
Monthly Escrow amount $95.20
$ 68,108. 16
113.03
$ 67,995.13
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
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. The within mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such; is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $67,995.13, together with interest at the rate of
$13.47, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
McKEEVER
, Jr., Esq.
-. JJ U' LCMll ~G;Bl:.\.~ /l(c;R~'}€RTY (215)6277;34
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VERIFICATION
I. BRANDONSCIUMBATO, as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date: 10 /17 100
BRANDONSCIUMBATO. VICE PRESIDENT
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Leila! Description:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLV ANlA, WITH THE IMPROVEMENTS ERECTED THEREON, BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A STONE IN THE MIDDLE OF A PUBLIC ROAD LEADING FROM THE TURNPIKE TO CARLISLE
SPRINGS ROAD; THENCE BY SAID ROAD, NORTH 37 DEGREES WEST 77 FEET TO A STONE IN THE MIDDLE OF
SAID PUBLIC ROAD; THENCE BY LAND NOW OR FORMERLY OF W. F. GLADFELTER, NORTH 74 DEGREES
EAST 176 FEET TO A POST, THENCE SOUTH 37 DEGREES EAST 61 FEET TO A 12 - FOOT ALLEY; THENCE BY
SAID ALLEY, SOUTH 69 DEGREES WEST 174 FEET TO THE PLACE OF BEGINNING.
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-07424 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
BAILEY MARTIN E ET AL
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
BAILEY MARTIN E
the
DEFENDANT
, at 0013:45 HOURS, on the 25th day of October ,2000
at 35 NORTH MIDDLESEX ROAD
CARLISLE, PA 17013
by handing to
MELANIE R. BAILEY (WIFE)
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
surcharge
18.00
3.10
.00
10.00
.00
31.10
So Answers:
~~IV~~e
R. Thomas Kline
me this /~
day of
10/26/2000
GOLDBECK, MCCAFFERTY, MCKEEVER
By: IAJ~,I
~e~ff
Sworn and Subscribed to before
7~ .2An.ri) A. D.
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othonotary
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-07424 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
BAILEY MARTIN E ET AL
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
BAILEY MELANIE R
the
DEFENDANT
, at 0013:45 HOURS, on the 25th day of October ,2000
at 35 NORTH MIDDLESEX ROAD
CARLISLE, PA 17013
by handing to
MELANIE R. BAILEY
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers: 4-
r~1''''- .4.:
R. Thomas Kline
10/26/2000
GOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and Subscribed to before
By:
~~
me this JAY
day of
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rothonotary /
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
plaintiff
vs.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner(s) )
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
Term
No. 00-7424 Civil Term
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR
THE PURPOSE OF COLLECTING THE DEBT.
Enter Judgment in favor of Plaintiff and against MARTIN E. BAILEY and
MELANIE R. BAILEY by default for want of an Answer.
(X)
Assess damages as follows:
Debt
$
68.796.25
Interest 4/ 1/00 to 12/12/00
Total $
(Assessment of Damages attached)
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS
ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM
THE COMPLAINT.
r certify that written notice of the intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be entered and
to his attorney of record, if any, after the default occurred and at least
ten days prior to the date of the f'ling of this praeci e. A copy of the
notice is attached. R.C.P. 237.1
AND NOW Ds; r' I c:2. J ~~ , Judgment is
entered in favor of COUNTRYWIDE HOME LOANS INC., and against MARTIN E.
BAILEY and MELANIE R. BAILEY by default for want of an Answer and damages
assessed in the sum of SIXTY EIGHT THOUSAND SEVEN HUNDRED NINETY SIX
DOLLARS AND 25 CENTS ($68,796.25), as per the above cert' ication.
.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC. IN THE COURT OF COMMON PLEAS
7105 Corporate Drive
PTX B-35 OF CUMBERLAND COUNTY
PIano, TX 75024-3632
Plaintiff CIVIL ACTION - LAW
VS. :ACTION OF MORTGAGE FORECLOSURE
MARTIN E. BAILEY AND MELANIE R. Term
BAILEY (Mortgagor(s) and Record No. 00-7424 Civil Term
Owner(s) )
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
ORDER FOR JUDGMENT
Please enter Judgment in favor of COUNTRYWIDE HOME LOANS
INC., and against MELANIE R. BAILEY and MARTIN E. BAILEY for
failure to file an Answer in the above action within (20) days
(or sixty (60) days if defendant is the United States of America)
from the date of service of the Complaint, in the sum of SIXTY
EIGHT THOUSAND SEVEN HUNDRED NINETY IX DOLLARS AND 25 CENTS
($68,796.25) .
I hereby certify that the above names are correct and that
the precise residence address of the judgment creditor is 7105
Corporate Drive, PTX B-35, PIano, TX 75024-3632 and that the
name(s) and last known address (es) of the Defendant(s) is/are
MELANIE R. BAILEY, 35 N. Middlesex ad, Carlisle, PA 17013;
MARTIN E. BAILEY, 35 N. Middlesex ad, Car's e P 701;
FERTY & M
Y: Joseph A. Goldbeck,
Attorney for Plaintiff
.
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ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal balance $ 61,470.58
Interest from 4/ 1/00 through 12/12/00 3,434.85
Attorney's Fee at 5% of principal balance 3,073.53
Late Charges 179.92
Costs of Suit and Title Search 560.00
$ 68,718.88
Escrow Balance Deficit 77.37
$ 68,796.25
AND NOW, this /;2.~ day of U~~ C2
damages are assessed as above.
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TO: MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
plaintiff
vs.
MARTIN E. BAILEY AND MELANIE R. BAILEY
(Mortgagor (s))
(Record Owner(s))
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-7424 Civil Term
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
DATE OF THIS NOTICE: November 15, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JotJeph -A. (Jotdbeck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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TO: MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
vs.
MARTIN E. BAILEY AND MELANIE R. BAILEY
(Mortgagor (s))
(Record Owner(s))
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 00-7424 Civil Term
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
PATE OF THIS NOTICE: November 15, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JOdeph j4. (JoIJbeck, Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Fa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant. MARTIN E. BAILEY, is
about unknown years of age, that Defendant's last known residence
is 35 N. Middlesex Road, Carlisle, PA 17013 and is engaged in the
unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions
of the Soldiers' and Sailors' Civil Relief Action of Congress of
1940 and its Amendments.
Date:
4339149 - BAILEY,MARTIN E.
""
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant, MELANIE R. BAILEY, is
about unknown years of age, that Defendant's last known residence
is 35 N. Middlesex Road, Carlisle, PA 17013 and is engaged in the
unknown business located at unknown address.
2. That Defendant is not in the Military or Naval Service of
the United States or its Allies, or otherwise within the provisions
of the Soldiers' and Sailors' Civil Relief Action of Congress of
1940 and its Amendments.
Date:
4339149 - BAILEY,MELANIE R.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner(s) )
35 N. Middlesex Road
Carlisle, PA 17013
Term
No. 00-7424 Civil Term
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$
68,796.25
Interest from 4/ 1/00 to
12/12/00 at 8.000% $
(Costs to be added)
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Lel!sl Description:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF:
CUMBERLAND AND STATE OF PENNSYLVANIA, WITH THE IMPROVEMENTS ERECTED THEREON, BOUNDED
AND DESCRIBED AS FOLLOWS:
BEGINNING AT A STONE IN THE MIDDLE OF A PUBLIC ROAD LEADING FROM THE TURNPIKE TO CARLISLE
SPRINGS ROAD; THENCE BY SAID ROAD, NORTH 37 DEGREES WEST 77 FEET TO A STONE IN THE MIDDLE OF
SAID PUBLIC ROAD; THENCE BY LAND NOW OR FORMERLY OF W. F. GLADFELTER, NORTH 74 DEGREES
EAST 176 FEET TO A POST, THENCE SOUTH 37 DEGREES EAST 61 FEET TO A 12 - FOOT ALLEY; THENCE BY
SAID ALLEY, SOUTH 69 DEGREES ",~S:r 174 FEET TO 11m PLACE OF BEGINNING.
TAX PARCEL #21-17-2696-036
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
VS.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner (s) )
Term
No. 00-7424 Civil Term
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., 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:
35 N. Middlesex Road, Carlisle, PA 17013
1. Name and address of Owner(s) or Reputed Owner(s):
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
MELANIE R. BAILEY
35 N. Middlesex Road
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Carlisle, PA 17013
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS - CUMBERLAND COUNTY
P.O. Box 1055
Meadville, PA 16335
PA DEPARTMENT OF PUBLIC WELFARE - BUREAU OF CHILD
SUPPORT ENFORCEMENT
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105
4. Name and address of the last recorded holder of every mortgage
of record:
HARRIS SAVINGS BANK
235 N. Second Street
Harrisburg, PA 17105
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true
and correct to the best of my personal knowledge or information
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and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authoritie .
K Me
BY: eph A. Goldbeck, Jr.,
Attorney for Plaintiff
DATED: December 11, 1998
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner (s) )
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
Term
No. 00-7424 Civil Term
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
Your house at 35 N. Middlesex Road, Carlisle, PA 17013 is
scheduled to be sold at Sheriff's Sale on March 7, 2001, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $68,796.25 obtained by COUNTRYWIDE HOME LOANS INC.
against you.
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 COUNTRYWIDE HOME
LOANS INC., the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
~
.
improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice below 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 NOT TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid price
by calling the Sheriff of Cumberland County at (717) 240-6390.
2. You may be able to petition the Court to set aside the sale
if the bid price was grossly inadequate compared to the value of
your property.
3. The sale will go through only if the buyer pays the Sheriff
the full amount due in the sale. To find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a 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 thirty (30) days from the
date of the Sheriff's 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(aao) 990-910a
Legal Services Inc.
a Irvine Row, Carlisle, PA 17013
(717) 243-9400
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GOLDBECK McCAFFERTY & McKEEVER
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner(s) )
Term
No. 00-7424 Civil Term
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am
the attorney of record for the Plaintiff in this action, and I
further certify that this property is not subject to Act 91 of
1983 insofar as it is an FHA insured loan.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for P2aintiff
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
m~ by:
( ) Personal Service by the Sheriff's Office/ ~(...." alL.." ! J.Hot (copy of
return attached) .
) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) .
Certified mail by Sheriff's Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached).
Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached}.
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the s
penalties provided by 18 P.S. Section
herein are subject to the
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TO:MARTIN E. BAILEY
35 N, Middlesex Road
. ,
Carlisle, PA 17013
CUMBERLAND
SENDER:
REFERENCE:
GOLDBECK MCCAFFERTY & MCKEEVER _
December 11, 1998
BAILEY, MARTIN E. /
CWO-OB6!
PS Form 3800, June 200'// 7/01 -
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
RUSePCoesta."pl StervfiOcer POW'6J. '(\t\
ii \~ ~i
Certified Mail .~\ '~~~~~ ""/
./~, / /
No Insurance Coverage Provided ' <j -- .-
00 Not Use for International Mail
?1Db ~5?5 129~ D~19 ~22?
TO:MELANIE R. BAILEY
35 N. Middlesex Road,
carlisle, PA 17013
CUMBERLAND
SENDER:
REFERENCE:
GOLDBECK McCAfFERTY & MCKEEVER.
December 11, 1998
BAILEY,MARTIN E. /
CWD'086!
PS Form 3800, June 20or}( 7/01 .
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No lnsurance Coverage Prolltded
00 Not Use for Internatlonal Mail
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Countrywide Home Loans Inc.
-vs-
Martin E. Bailey and Melanie
In the Court Of Common Pleas of
Cumberland County, Pennsylvania
No. 2000-7424 Civil
- Michael E. Barrick, Deputy Sue i , who being duly sworn according to law, says on January 5, 2001
at 9:02 o'clock A.M. EST, he served a true copy of real estate Writ Notice Poster and Description in the
above entitled action upon one of the within named defendants to wit: Martin E. Bailey by making
known unto Melaine Bailey, wife at 35 North Middlesex Road, Carlisle, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true and attested
copies of the same.
Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on January 5, 2001
at 9:02 o'clock A.M.ESTR, he served a true copy of Real Estate Writ Notice Poster and Description in
the above entitled action upon one ofthe within named defendants to wit: Melaine R. Bailey by making
known unto Melanie Bailey at 35 Middlesex Road, Carlisle, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and attested copies ofthe same.
Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law says on January 5,2001
at 9:02 o'clock A.M.EST he posted a copy of Real Estate Writ Notice Poster and Description on the
property of Martin E. Bailey and Melanie R. Bailey located at 35 Middlesex Road, Carlisle, Cumberland
County Pennsylvania according to law.
R. Thomas Kline, Sheirff, who being duly sworn according to law, says he served the above Real
Estate Writ Notice Poster and Description in the followillg manner: The Sheriff mailed a notice of the
pendency of the action to one of the within named defendants to wit: Martin Bailey by regular mail to
his last known address 35 North Middlesex Road, Carlisle, Pennsylvania. This letter was mailed under
the date of January 8, 2001 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real
Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the
pendency of the action to one of the defendants to wit: Melanie R. Bailey by regular mail to her last
known address 35 North Middlesex Road, Carlisle, Pennsylvania. This letter was mailed under the date
of January 8, 2001 and never returned to the Sheriffs Office.
soan?,~""",~~
R. Thomas Kline, Sheriff
Byj(;rJ;J' Jtj7J;;
Real Estate Deputy
"
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
Plana, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
vs.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner (s) )
Term
No. 00-7424 Civil Term
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., 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:
35 N. Middlesex Road, Carlisle, PA 17013
1. Name and address of Owner(s) or Reputed Owner(s) :
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
MELANIE R. BAILEY
35 N. Middlesex Road
-"""
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'~-'-" -.
~ilii.",
Carlisle, PA 17013
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE
BUREAU OF CHILD SUPPORT ENFORCEMENT
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105
DOMESTIC RELATIONS - CUMBERLAND COUNTY
P.O. Box 1055
Meadville, PA 16335
DOMESTIC RELATIONS
PO Box 320
Carlisle, PA 17013
MIDDLESEX TOWNSHIP MUNICIPAL AUTHORITY
35 N. Middlesex Road
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage
of record:
HARRIS SAVINGS BANK
235 N. Second Street
Harrisburg, PA 17105
SECRETARY OF HOUSING & URBAN DEVELOPMENT
PO Box 23999 Lenfant Plaza Station
Washington, DC 20026
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
"""' ~,
, ~,
..~;--
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
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. Section 4904 relating to
unsworn falsification to authorities.
DATED: January 24, 2001
J
"
Countrywide Home Loans Inc.
-vs-
Martin E. Bailey and Melanie R. Bailey
~~.
~$t..'~:>ii*FM"",
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No.2000-7424 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Posting Bills
Advertising
Law Library
County
Levy
Postpone Sale
Surcharge
Certified mail
Mileage
Law Journal
Patriot News
Out of County
Share of Bills
Sworn and subscribed to before me
This '111./ day of ~
2000, A.D. ~ (2 ~/~
P othonotary
30.00
10.57
15.00
15.00
.50
1.00
15.00
20.00
30.00
3.24
3.10
200.30
169.59
25.53
$538.83 Pd by atty 03/06/01
1&rin~_~A<~~~~
R, Thomas Kline, Sheriff
BY$t;,,//;Jl:tz-
Real Estate Deputy
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,;\ ~---:;-~ -=-~ --;;
,
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
Plaintiff
:ACTION OF MORTGAGE FORECLOSURE
VB.
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner(s))
Term
No. 00-7424 Civil Term
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
COUNTRYWIDE HOME LOANS INC., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., 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:
35 N. Middlesex Road, Carlisle, PA 17013
1. Name and address of Owner(s) or Reputed Owner(s):
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
MELANIE R. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
2. Name and address of Defendant (s) in the judgment:
MELANIE R. BAILEY
35 N. Middlesex Road
~"'f"'-=~~"""""'~"--~~~~~~~~____'='"'" ~"",,,,,,,~'.:,,,,,. ~_,,~
~ - ~~".=---
, -- - - - - - - - -- - --:: - - ',,,- - - -=- - -=- ---- - - - - .- -
- =------- - -""""'", - ""
,,=-~---~-=' w ""'.., --- ~"" ~~-~ ~~=~~---~~~ ,_!l~ -!I "~~. --"_'L~~_=-_, ~.,.~\il1ili;j _ -' :
Carlisle, PA 17013
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS - CUMBERLAND COUNTY
P.O. Box 1055
Meadville, PA 16335
PA DEPAR~MENT OF PUBLIC WELFARE - BUREAU OF CHILD
SUPPORT ENFORCEMENT
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105
4. Name and address of the last recorded holder of every mortgage
of record:
HARRIS SAVINGS BANK
235 N. Second Street
Harrisburg, PA 17105
5. Name and address of every other person who has any record
interest in or record lien on the property and whose interest may
be affected by the sale:
6. Name and address of every other person of whom the plaintiff
has knowledge who has any record interest in the property which
may be affected by the sale.
7. Name and address of every other person of whom the plaintiff
has knowledge who has any interest in the property which may be
affected by the sale.
(attach separate sheet if more space is needed)
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. Section 4904 relating to
unsworn falsification to authoritie .
BY:
DATED: December 11, 1998
".
r"'"""':~""flC'itti:
"
..
.. ..
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
Plana, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
MARTIN E. BAILEY AND MELANIE R.
BAILEY (Mortgagor(s) and Record
Owner (s) )
35 N. Middlesex Road
Carlisle, PA 17013
Defendant(s)
Term
No. 00-7424 Civil Term
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
MARTIN E. BAILEY
35 N. Middlesex Road
Carlisle, PA 17013
Your house at 35 N. Middlesex Road, Carlisle, PA 17013 is
scheduled to be sold at Sheriff's Sale on March 7, 2001, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $68,796.25 obtained by COUNTRYWIDE HOME LOANS INC.
against you.
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 COUNTRYWIDE HOME
LOANS INC., the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
_0
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improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice below 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 NOT TAKE P~ACE.
1. If the Sheriff's Sale is not stopped, your property will be
sold to the highest bidder. You may find out the price bid price
by calling the Sheriff of Cumberland County at (717) 240-6390.
2. You may be able to petition the Court to set aside the sale
if the 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. ro find out if this has
happened, you may call the Sheriff of Cumberland County at (717)
240-6390.
4. If the amount due from the Bhyer is not paid to the Sheriff,
you will remain the owner of the property as if the sale never
happened.
5. You have a 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 thirty (30) days from the
date of the Sheriff's 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 schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house back, if you act immediately after the sale.
yOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, FA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, FA 17013
(717) 243-9400
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Lel!al Deseriotioll:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE TOWNSHIP OF MIDDLESEX, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLV ANlA, WITH THE IMPROVEMENTS ERECTED THEREON, BOUNDED
AND DESCRiBED AS FOLLOWS:
BEGINNING AT A STONE IN THE MIDDLE OF A PUBLIC ROAD LEADING FROM THE TURNPIKE TO CARLISLE
SPRINGS ROAD; THENCE BY SAID ROAD, NORTH 37 DEGREES WEST 77 FEET TO A STONE IN THE MIDDLE OF
SAID PUBLIC ROAD; THENCE BY LAND NOW OR FORMERLY OF W. F. GLADFELTER, NORTH 74 DEGREES
EAST 176 FEET TO A POST, THENCE SOUTH 37 DEGREES EAST 61 FEET TO A 12 - FOOT ALLEY; THENCE BY
SAID ALLEY; SOUTH 69 DEGREES WEST 174 FEET TO THE PLACE OF BEGINNING.
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 35 N. Middlesex Road, Carlisle, PA 17013.
SOLD AS THE PROPERTY OF Martin E. & Melanie R. Bailey.
TAX PARCEL # 21-17-2696-036.
.~ I
I.
1-,
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h' - -" tiJ:~.
WRIT OF EXEClf):'~ and/or ATTACHMENT
- ,,'-~
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO,
00-7424 CIVIL TERM
CIVIL ACTION -LAW
TO THE SHERIFF OF
Cumberland
COUNTY:
To satisfy the debt; interest and costs due Countrywide Home Loans Inc.
PLAINTIFF(S)
from Martin E. Bailey and Melanie R. Bailey (Mortgagor(s) and Record Owner(s)
1~ N M;nnl~q~v Rn~n. r~rliql~r pn 17n11
DEFENDANT(S)
(1) You are directed 10 levy upon the property of the defendant(s) and to sell See Leqal Description
(2) You are "Iso directed to attach the property of the defendant(s) not levied upon in the posses8ion of
GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
deb! to or tor the account of, the defendant(s) and trom delivering any property of the defendant(s) or otherwise disposing
thereof; ..,
(3) If property1lfthe ~efend;;intfsJ 1l0Ueviedupon an subjectto attachment is found in the possession of anyone other
than a named garnishee, you are directed to notify hilTVherthat he/she has been added as a garnishee and is enjoined as above
stated.
%
L.L.
Due Prolhy
Other Costs
$.50
$1. 00
Amount Due
$F;Rr7% ?S
Interest 4/1/00 to 12/12/000 at 8.000%
Atty's Comm
Atty Paid
Plaintiff Paid
$1l9.10
Date:
December 12r 2000
Curtis R. Long
Prothonotary, Civil Division
<-by: 4.......~_P.~r~~
Oeputy
REQUESTING PARTY:
Name ,Tm,,"ph A. ('.,01 rJhp<"'k. ,Tr.
Suite 500 - The Bourse Bldg.
Address: IllS. Iu.:kp=l1\l=l'-'''' Mall Ba" L
philadelphia, PA 19106 "
Attorney for: plaintiff
Telephone: 215-627-1322
Supreme Court ID No, 16132
JWl!lil!lil~JI';uh:j' Jj!<!mi<iI!.~t~_iiliiH'lit.lW8W~Ili!!IlIl;~~t.Mt#'!I'ijili'-~"'4'Y&i8>l'Jm)~~'1~~";""'" ",,'~,I-' --" ~ -li"'-'-" """'""" r _ ~""''"'lI~-_. '. ;~... ",,~~~
. ,.
.
REA[ 'ESTATE SALE No~?1~.' -
, 12... H .J.e..... J J . ~ the sheriff levied upon the defenaams
interest in the real property situated in /Y11:_l..lt_~.y /LJ'2UvI4.d:r-
.
Cumberland County, Pa., kno\i'n 'mct numbered as: 3$1() AH .J..lt~e.,.f U
(}.Ja~f)~
, ana more hw ,leiser/oed on Exhibit "A" flied with
this writ ana by this reference incorporated herein.
l?,te: .I{4;j", .L)~ ~ By:, /?Z. u ,A.7It'
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