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HomeMy WebLinkAbout03-1715 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CENDANT MORTGAGE CORPORATION, F/KJA PHH US MORTGAGE CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 A TIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 03 - I7/S (l/""c-TfIl..'\. CUMBERLAND COUNTY v. CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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 W\\i;~e court your defenses or objections to the claims set forth against you. You are warned tftlt'tryou 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 LA WYER 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 LffiERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: ??oo988592 IF TIDS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFfER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is CENDANT MORTGAGE CORPORATION, FIK.IA PHH US MORTGAGE CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: CONSTANCE M. CHICHESTER 22 SOUTHEAST STREET CARLISLE, P A 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 01/15/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1513, Page 1056. 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 03/01/2002 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. 6. The following amounts are due on the mortgage: Principal Balance Interest 02/01/2002 through 04/11/2003 (per Diem $11.69) Attorney's Fees Cumulative Late Charges 01/15/1999 to 04/11/2003 Cost of Suit and Title Search Subtotal $54,286.61 5,085.15 850.00 240.18 $ 750.00 $ 61,211.94 Escrow Credit Deficit Subtotal TOTAL 0.00 1,275.09 $ 1.275.09 $ 62,487.03 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) haslhave failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 62,487.03, together with interest from 04/11/2003 at the rate of $11.69 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. N AND P~EL~Lr/ J A / - ~.7)~ /s/Francis S. Hallinan . FEDERMAN, ESQUIRE RENeE T. PHELAN, ESQUIRE CIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff - ALL THAT CERTJUN lot of ground situate on tho West side of South Italll: Street in the Bot'Ous}1 oC CarlisI';; County .)! Cumberland, and State of Pennsylvania.. bounded and described.. [OUCNrS: ON the E-..t by South East Street: on the South by property formerly oC Mrs. Anna B. Eppley, now or formerly of Lytlia. Gris.inget; on the West by prope~ now or late of Miss E. C. Smead; and on the North. by property termerly of Burton Beam.. now or formerly of Jam.. A. Bair. CONTAINING 20 feet, more or Ie.., in &ont aD. said South 1!:ast Street, and extending in depth 60 feet to said propc.ny now or late: of Mi.. E. C. Smead. HAVING THERE')N ERD:CTEO a two story brlclc dwelling house and other improvem.ents known ~ numbered as 22 S. Ea.:lt S~eet, Carlisle, Penc.sylVN1ia. BeING THE SAMe: PREMISES wbich Julio A. Balcer, now Julie A.. Moore and. Randall K. Baker, her husband, by tbe<r Deed datecl March 30, 1994 and recorded April 5, 1994 in the Omce of the Re- ,c' carder orOecds:.n and Cor Cumberland Col.lnty'in Deed Book 103. Page 644, granted and conveyed 1U1to Fred R. Pracht, Jr. and Hope M. Pracht, his wite, Grantors herein. ,'!t!"" VERIFICATION MARC J. HINKLE hereby states that he is V.P. ofCENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pat C.S. Sec. 4904 relating to unsworn falsification to authorities. PktJl.iJ DATED1/ (J?J~3 I · 7':J ~ ~ 'Ii 'l C) ~ CJ r; (,.J ~ ~, ~~ - ;-.: . .."'1 ~ D - ~ ~ . . .- g ff i '. -- ....:) ~ -u c. ~ ~ CA..J F: ~ ;;' -. ()I ~:::.....- ( - 0' )> ' r;~: : $ , -.-, '..) ()i ) .,' .. , SHERIFF'S RETURN - REGULAR CASE NO: 2003-01715 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS CHICHESTER CONSTANCE M RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CHICHESTER CONSTANCE M the DEFENDANT , at 1020:00 HOURS, on the 17th day of April 2003 at 22 SOUTH EAST STREET CARLISLE, PA 17013 by handing to TOM WEIDNER, BOYFRIEND ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31.45 r~~ R. Thomas Kline 04/21/2003 FEDERMAN & Sworn and Subscribed to before By: me thi s 7 {J;.:: day of ~/ oJ.(J()..3 A . D . c 1 _ ~Q~ . Prothonotary ~j FEDERMAN AND PHELAN, LLP - By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION, F/KJA PHH US MORTGAGE CORPORATION 4001 LEADENHALL ROAD MOUNT LAUREL, NJ 08054 CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DIVISION Plaintiff, v. NO. 03-1715 CONSTANCE M. CmCHESTER Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against CONSTANCE M. CHICHESTER and, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 4/11/03 to 7/1/03 TOTAL $62,487.03 $958.58 $63,445.61 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ]1lP1i? )~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATU' o . DATE: 7, 7 _ {j?; l~ PRO PROTHY r?'u-~ (') f; ,"J.1 r~~, " ',' ">!. lX-,~. ~. :;:( ,.-~ :?c' ~(" -' ~-;) I "-J ::",;"1 - ::-- '0 <:::l Go) (- c::: r.- <) ~I'} ., '4:'; -..;,:' FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (7 1 ~) ~1i1-7000 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 03 -1715 CONSTANCE M. CHICHESTER Defendant TO: CONSTANCE~. CHICHESTER 22 SOUTH EAST STREET CARLISLE,PA 17013 DATE OF NOTICE: MAY 9,2003 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 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 )fl.. (;yf\ P /rR.d.fJ..{.rYHY."Y'r~ ~rank Fecterman, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR " ~ASE NO: 2003-01715 P - COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS CHICHESTER CONSTANCE M RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CHICHESTER CONSTANCE M the DEFENDANT , at 1020:00 HOURS, on the 17th day of April , 2003 at 22 SOUTH EAST STREET CARLISLE, PA 17013 by handing to TOM WEIDNER, BOYFRIEND ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.45 .00 10.00 .00 31. 45 r~~~ R. Thomas Kline .' A.D. 04/21/2003 FEDERMAN & PHEIl By: ~;J \ //IDe~~iff II ~ Sworn and Subscribed to before me this day of Prothonotary (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CENDANT MORTGAGE CORPORATION, FfKlA PHH US MORTGAGE CORPORATION 4001 LEADENHALL ROAD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 03-1715 CONSTANCE M. CmCHESTER Defendant(s). By: EPUTY If you have any questions concerning this matter, please contact: J~~ FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS 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." FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION, FOOA PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY 4001 LEADENHALL ROAD COURT OF COMMON PLEAS CML DIVISION Plaintiff, v. NO. 03-1715 CONSTANCE M. CmCHESTER Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant CONSTANCE M. CHICHESTER is over 18 years of age and resides at, 22 SOUTH EAST STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pat C.S. Section 4904 relating to unsworn falsification to authorities. JJ1.MIii 1~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff / LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate on the Wm side of South East Street in Ihe Borough. of Carlisle, County of Cumberhu1d and State of Pennsylvania, bounded and described as foUoW!l: ON tbe East by South East Street on the South by ptopetty fol"lIll:ll'Ly of Mrs. AllJla B. Eppley, now of funnedy of Lydia Grissinger; ()n tile West by property now or IlltC of Min E.C. Smead; and on the North by property fonnerly of Burton Beam, now or formerly of JlUDCs A. Baa. CONTAlNlNG 20 feet. more or less, in front on said South Basi Street and extending in depth 60 feet to said property now Of late of Miss E. C. smead. HAVING thereon erected a two story brick dwelling house: and other improvements known and numbered as 22 S. East Street, Carlisle, Pennsylvania. Tax Parcel #0321-0318-018 l1Tl.F. TO SAID PREMISES IS YESrnD IN Constance M. Chlchester, single WOO'l8n by Deed from Fred R. Pracht, Jr. and Hope M. Pracbt, his wife. dated 1I151l999 and recorded If20/1999 in Deed Book 192, Page 1073. \~ ~ ~ G --."... ~, ,r 1 ~~~ ~ . f ~ ~ ~ ~u .:i "",) '\. .... ....... ~ ~ ~ ......... tI"", J ~ -...J f ~ ~ ~ I' -.....l , -........ --...1 ~ ~ ~ n 5 ~{ ~ dl rirt: ~;';: I ~~:'"~ _J ~~l -,-.... :O."~~ 1,.--:,. :.},. - --.:> -.,~ ~ =.i FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHlLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION, FfKlA PHHUSMORTGAGECORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION CONSTANCE M. CIDCHESTER NO. 03-1715 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pat C.S. Section 4904 relating to unsworn falsification to authorities. JfIMIi< 3~A>LM-l FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Cl C) C t..-':l ::::: '"= -v " n-, Z ~ :;:-'.': co --' -< ~,~) ~;: ., ~;. .. "' , f::-:( \"j ; )>C. 0 ~'-1 :Z ::- ~. -+-\ '.:.0 -< u::> -< PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION, FfK/A PHHUSMORTGAGECORPORATION Plaintiff, v. No. 03-1715 CONSTANCE M. CIllCHESTER Defendant(s). ....../' TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $63,445.61 Interest from 7/1103 to DECEMBER 10,2003 (per diem -$10,43) $1,689.66 and Costs TOTAL $65,135.27 J~d~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. '" .... -= r- .... < =- r.S "'" '" roo.;:!; .... z ~ oz z ",< 0 0 <> .... .... U r.1~ E-< ~ E-< ~ ~tS r.1 ~ ""'", E-< U r.1 =-z '" ~ -d Zz 0< [il ~~ <I) Or.1 ~"z r.1 := i:::1 E-< ~ :2l=- 0!20 U roo. ~ O"@ '" <I) E-< '" :2l~ Uo.... == Oc:l .~ '" <I) .. .D OE-< tS:2l~ U '" ~ < E-< .. =- >. UZ .; ~ ~~ .... r.1 .. roo.~ <"'0 .. <8 = a 00 "~~ r.1 >. E-< ~ E-<U E-<= U ~~ ~ ~ <I) ~~ ~=O ~ ot: 0 g. ~~ o=-U roo. Q ~ '" p.. :2l< E-< r.16 .... ~ 8ii2 E-<~ '" .... Z =- ~ ~~ .... r.1r.1 0 U <i =lXl U ~ OJ ~ -i:i <I) E-<:2l z <I) ..t; Z~ ~ "Cl r.1 =- ~ < ....U U I LEGAL DESCRIPTION ALL THAT CERTAIN Jot of ground situate on the West side of South .East Street in dte Borough of Carlisle. County of Cumberland and State of Pennsylvania, bounded and described lIS folloWll: ON the East by South East Street on the Saudt by property fom:ll:rly of Mrs. AllII.ll B. Eppley. now or formerly of .Lydia GrissiDger; on the West by property now or late of Miss E.C. Smead; and on the North by property forml'l'ly of Burton Beam, now or formerly of James A. Bair. CONTAINING 20 feet, more or less, in front on said South. East Street and extooding in depth 60 feet to said property now or late of Miss E. C. smead. HAVING thereon erected a two storY brick dwelling house and other improvements known and numtlered as 22 S. East Street. Carlisle, Pennsylvania. Tax Parcel #0321-0318-018 1m.R TO SAID pREMrSES IS V1lSJED IN Constance M. ChIchester, single wQIIlan by Deed from Fred R. Pracht, Jr. and Rope M. Pracht. his wife, dated 1f15fl999 and rerorded 1120/1999 in Deed Book 192, Page 1073. ~00 - G .\~ c..:,..; ~ , \ --..... i . ~\ ~ I '2 ~ - ~ ~ ~ ~ cS ~ ~ cJ o r~ ~r ./ \:\ ~"'; ~ c:.~~"'( _0 - <s c ~ >{,.' ? :::3 , (---- es-i; i c' (....) r l'::::: j:::': 1-' ni., .J . ,", I ....1 '.~ '"J r--l ::-0 - ~, , ,r] ;(') ,jrr, ~ :-1 :-; -< .:Jl <::, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORP., F/K1A PHH US MORTAGE CORP. Plaintiff (s) From CONSTANCE M. CHICHESTER, 22 S. EAST ST., CARLISLE PA 17013. NO 03-1715 Civil CIVIL ACTION - LAW (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 22 S. EAST ST., CARLISLE PA 17013 (SEE LEGAL DESCRIPTON). (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (h) the garnishee(s) is enjoined from paying any deht to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify bimlher that he/she has heen added as a garnishee and is enjoined as ahove stated. Amount Due $63,445.61 L.L. $.50 Interest 7/1103 - 12/10/-3 @ $10.43 PER DIEM - $1,689.66 Arty's Comm % Due Prothy 1.00 Atty Paid $113.45 Other Costs Plaintiff Paid Date: JULY 7, 2003 (Seal) CURTIS R. LONG prothBtary J I By: . ~ f't ( De ty REQUESTING PARTY: Name FRANK FEDERMAN, ESQillRE Address: ONE PENN CENTER s SSUBURBAN STATION 1617 JFK BLVD., SillTE1400 PHILADELPIDA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 CENDANT MORTGAGE CORPORATION, FfKJA PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION CONSTANCE M. CmCHESTER NO. 03-1715 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CENDANT MORTGAGE CORPORATION, F/K/A PHH US 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, 22 SOUTH EAST STREET, CARLISLE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Narne Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET HARRISBURG, PA 17105 CITlFINANCIAL, INC. 1 VALLEY STREET, SUITE 103 CARLISLE, PA 17013 S. 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 indicate) None 6. Narne and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 22 SOUTH EAST STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department ofWeIfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pat C.S. Sec. 4904 relating to unsworn falsification to authorities. Ju1v I. 2003 DATE 3~ J~-1h>1"'" FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff (") Cl 0 C (,,) '.il ~ ,- ,J n,r c:: rn (; ,- Z , -. , .'7 ;~-l ,"- '. .....! (j) ,,' c> ~~ ~ -0 ~, Z ( ) 5 c, :..n -;. -'-j -, -c r~ =< CENDANT MORTGAGE CORPORATION, FIK/A PHH US MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY No. 03-1715 v. CONSTANCE M. CmCHESTER Defendant(s). July I, 2003 TO: CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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. 22 SOUTH EAST STREET. CARLISLE. PA 17013. is scheduled to be sold at the Sheriff's Sale on DECEMBER 10. 2003 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $63.445.61 obtained by CENDANT MORTGAGE CORPORATION. F/K/A PHH US MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be rnade at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may 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. You may need an attorney to assert your rights. The sooner you contact one, the more chance you win 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. L If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe 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 can (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 fun 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house win 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 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate on the West side of South East Street in Ibe Borough of Carlisle, County of Cumberland and State of Pennsylvania, bOlWded and described as folloW!!: ON lhe East by Soulh East Street 011 the South by property fOl111el'ly of Mrs. Anna B. Eppley, nawor formerly of Lydia OrissiDger; Oll r.he West by property now or late of Miss E.C. Smead; and on the N(lrth by property f(lnnerly of Burton Beam, now or formerly of James A. Bair. CONTAINING 20 feet, more or less, in front on said South East Street and extending in depth 60 feet to $aid property now or late of Miss E. C. smead. HAVING thereon erected a two story brick dwelling house and other improvements known and numbered as 22 S. East Street, Carlisle, Penniylvania. Tax Parcel #0321-0318-018 1TIT.R TO SAID PREMISES lS VF.8TF.D IN Constance M. Chichesrer, llingle woman by Deed from Fred R. Pracht. Jr. and Nope M. .Pracht. his wife. dated ((15/1999 and recorded 1120/1999 in Deed Book 192, Page 1073. 0 "'-'0- C) c: CD) q ~'" s ,-' en (F, L;' :::: ~ "'.- .~_! u:: . -'. ~ c. ;0 C ~ r' )> '- ~j; I -- -.-j :J1 JJ -c. 0 -< AFFIDAVIT OF SERVICE' CUMBERLAND COUNTY KMD PLAINTIFF CENDANT MORTGAGE CORPORATION, FfKlA PHH US MORTGAGE CORPORATION No. 03-1715 AGel. #0000988592 DEFENDANT(S) CONSTANCE M. cmCHESTER Type of Action _ Notice of Sheriff's Sale Sale Date: DECEMBER 10, 2003 CRVED ~ {t. Servedandmadeknownto C~<5~'" t-\ ,Q \&,~fendant,onth" /0 dayof ~y ,2003 at (;:;3", o'clock~.m., at;;;(-;;}... S ( ;;-8'6+- sf. / G..&.l-;;<:;, t~ ,Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. ...., ( I ~ ~ -t-;:. Adult family member with whom Defendant(s) reside(s). Relationship is (...:0 'Ii'-~IO "llU I 0 "y Adult in charge of Defendant(s)'s residence who refused to give name or relationship. bj 'l. ~~ e Vl'~ Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place ofbusines8. an officer of said Defendant(s)'s company. ~ Other: ,/1 .' . tv "'- Description: Age ~ Height SID Weight /80 Race INk sexl-t.- Other 5ko~\-- ~;',rt. I, /-..vc',\\ ~ \\ I G-<L ~t ' a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the N hce of Shenff's Sale m the manner as set forth herem, Issued m the caphoned case on the date and at the address indicated above. MOTARIAL SEAL d ~ 1l\;d BRABElHM.JOHANSSON. NolaIyNllG Sworn to an . su sc e Greene Twp.. Frankfln County before ml' this ~ ay t.Iy Commlsalon ExpiI8s Dee. 19.2005 Of~J\ ,200':; ~ -/' ~ Notary: "~~~: .<~ cf PLEA ATTEMP SERVICE AT LEAST 3 TIMES. INDICATE DAn:S & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 ,I Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of ' 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 JtIlL (") S -utt. nlr', -".., Zi (f) "J- -<: .,: !;=C ~-;(" ~C ~C~ L, =< c w> ,-;:) (ry -< I G.. (:-) -'it ~ ~"., i-:J ":\ ~~) " ~ :::~1 (~') C; ~('l ::.~l ~6 -< " :x N c:- .."J IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENDANT MORTGAGE CORPORATION, F/K1A PHH US MORTGAGE CORPORATION ) CIVIL ACTION ) vs. , CONSTANCE MI CHICHESTER ) CIVIL DIVISION ) NO. 03-1715 : AEtIDA VIT OF SERVICE PURSUANT TO RULE 3129 i COM MONWEALIrH OF PENNSYLVANIA COU:-JTY OF CUMBERLAND ! I ) ) SS: i I, FRANK fEDERMAN, ESQUIRE attorney for CENDANT MORTGAGE , CORPORATJON F/KlA PHH US MORTGAGE CORPORATION hereby verify that 011 July 7, 200~ true and correct copies ofthe Notice of Sheriffs sale were served by I i certj ficatc of l1lai]in~ to the recorded lienholders, and any known interested party see Exhil,;t ''A'' attache~ hereto. DATE: October 30,~ 1: JUlJ111?{j JJun(jj/) FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff II ~.. ~ I~ I:;: - - I I I ':7. - I I '~ N - ~ I 1 :;:1 0 00 -.J '" . '" ::: 'J, .. I [8" ,~ N " ,., , ~ ~ , > ~ ;:l. . ,;- iD , Z l: 3 <T ,,~ () CD ~ 9- ~ . " ~ () ~. z "'" () ;;j () - tn 0 z ~" CIl ::l 0 ~8- 2 0 0 " ~. ~ .." Z ~ 3:: 3:: ~ o ' Z CIl '. 0 z CIl ~ z 3:: tn 2- 0;; () ~ ~ ~ ~ ,. '::! ~ 3;;;' tn Z ~ ~ @ ;; - " ~ () 0 ::E () :;: tn () (;:; .~ () Z ~ () tn r ".. ~ )> ~ ::r:: -- t- r; " n z ::r:: () ;j ~ ::r:: '"' r' ::r:: ,() 0 ~ " n (3 = tT1 c:: 0 ~ en - en ::r:: . .." Z ~ ;;j < Z tT1 N "'" en "'~ )> en N tT1 0 0 o = ;<l 0 ..... .., . t- en 2 ~ o~ .." m 0 .." ~ ::!!. t"" Z ?' c:: () . m en ,. !!.~ >< )> N ;j >< c:: ~ ~ ;.: en Z N t- ~ ~ ~ 3:: '"' () en tn < Z 0 (;:; m 0 )> )> tT1 ~ )> ~ en Z ~ tT1 '"' ;; ~ .'"' 0 en " en tT1 tT1 ;d 0 z ~ s R )> tn 0 ~, tT1 () < .>< en "'" " '"' '"' tn ~ 0 ~ tT1 .'"' N en c:: 0 0 ~ n '"' Z .w ~ 3:: '"' "'~~w;! n z tT1 .>< tT1 t- Z 88,",~' )> 0 .'"' - ~i;la E: r:: ~ i.il '"' w .:::..sgo; ~ t- o Z - il " ~ . i.il .tT1 .." 0 [~.3~.t t- .." r:: "'" ::E 1:J :;.I'l3 ;::.' 0 _ .tT1 ;<l i.il )> tT1 >0 C 0 .::l 15" 0 ::r:: N 3 ...., 0 ::I ~ t- - t- ;; Er ~;;' 0 Z -.J > ~ ~~.8~ i '"' '" 0 - .G; '~8 - -.J en "'" w Z ~. _. fJ<l Ii 0 ~ )> orq-o 9. t;l" - - 0 g."g !:t g:;: w "'" < " 0 ~'~ g ;;-.g m '0 tT1 o ~" Co-' .'"' t::1 ;<l ;>ii"~~[ ''''' ~ 0 en ~:~~g >< ~ a ~!'D .::l !!e- N ~g;!~g: ~ '" 0" ::I ~ -.J tT1 5"~~ en y. .'"' ::.: :::.;; g. '" :;: () r; 3 ~ .. c:: ;l> ii" 3 ~ ~ ;<l ;<l r:: [[3:~ .0 c: - E~~~ ~ en en '" t- "....: _. g 6" c:: .tn ~~~[ - -.J .2'5 "'" ::- '.s _ .a - )> 0 v. "'" )> -.J 0 /,;~~, /~, a .-', ? ,-.. _ .'6::\ : :...... !~J :,lJ./,' cc~ i / J "~.~ ~~~~~ II """'-.00:... "",Q,,, 1:/lQ,= '" ... - = '" '" Q, '" " ., '" = ... Q, ~O::O~ _...-::J m Qr-..J('1lt;l Q..~~m ~g.g~ .p' "r1 Q )> . =Z ~~fi1'> -s~Z 1..O(\l--tj o~~"'O l.f~0"':I:: -oElt!1 OOcO"'t"""l :t:ii"~> "",,;j I:/l.Z !la.S"~ ~ ~ :t". ~ ""-cng"'O ..., E. ~ ft 3 .... "C 0 ~ 0 _.},:j~~ ~ -.." ""'. 'l"'\IVI'~ S 01.800 ~ -, :;:':3 ~":' .'"-i :::'o'>JCE 'g- ')3 .-..------.. -..* g 0 ~ w ;;::: :z: ~ ""OCP 0 --n ~r7" <:: ~~ :::p I zr'" -n cn:t:: w ") 11. ~b ".'1_ -0 -- I ~c :x (':> .,., 7"~ :i>2 ~ (5 ~ U1 ~ Cendant Mortgage Corporation flkla PHH US Mortgage Corporation VS Constance M. Chichester In The Court of Common Pleas of Cumberland County, Permsylvania Writ No. 2003-1715 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Law Journal Patriot News Law Library Prothonotary Postpone Sale Share of Bills 30.00 11.47 15.00 15.00 15.00 20.00 6.90 214.25 207.19 .50 1.00 20.00 28.90 $ 585.21 paid by attorney 03/05/04 Sworn and subscribed to before me So Answers: . ,t...> '->>~. ~1'/~r!;-" /~ ThlS~_::_ day of 1YUu.J..-J ,~~- - ?e:'-e.e /1 - R. Thomas Kline, Sheriff 2004, AD. "-f<t'" ' () 'rudJ&..., ~. J ~~ -n. BY, {J ~ Prothonotary Real Est Deputy 1.5'0 , / I:./~ <!1(;J.lJ fa,.. I 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 Joseph A. Dennison, being duly Sworn according to law, deposes and says: That he is the Assl. 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~ Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were estabiished 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 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #13 .l,fMr",,'.. .~. ..t... ...:,.. ;~:j, '~, .,< '..",' . ~\n" .'\,L":J,' :" " 't,,~k~.i'.'.'...":' ,: '~g'~:.1 ':ijf' 1; <.... ..r ",', , ,", '.. .,., ,."",,,,= --.......... .......: ClIIiIIol'MlbySailllioll__W_ "'1I"Il"'Y~!1IIlI;._1I."*1, -0\' lonntIIr It..... 0dIii0-. ....... by -' _..!III"....1( c. s..l; IIItI OI\'lIIillilllb by JIIlI"I11 '-f1 01...... .....fIlI.. \Roil, Of _A. .... mlll'AININIl21 "'" _'" ..........00 ' iii! ~ 1IaI_ "" "lIIdIi;iII,-1O Iitollliolill~.........ilMllr~ c.., Smead. , HAVING ~"... I -...... dwOIIUlc_IIIl"'~i_~ itod III1inbotaI ~22 S: I!ait -',CadI5le. _Yl_, , TuPwit032t-<<lI8-018. lTIUl 'JUSAlP ~ ;. _ in Coostan<e M. CIilc:he#, SinIIe ........ by IJe<d _FredR. lr.ondRopoM.-'hi< '!ife,daIed IITslltl;g arid _ 1/2Cll999 in .. Jl<o![Pon< m.l'aaoJ1l71 ' . ........Il.~~............. Sworn to subscribed before mfiS 19th davn~ove r 2003 A.D. NolalialSeal / [/ ~ TatTY L, AusReiI, Notary PlilIi</' { ~ (/ ~ CIty Of Hamsburg, Dauphin eo.. tf L- My CommiSSion Expires June 6,2006 NARY PUBLIC , Member. Pennsylvania AssocIalion OfNolal'W!y commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PAt 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 207.19 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have By.................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, ofthe 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 officia11egal periodical for the publication of all legal notices, and has, since January 2,1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 17, 24, 31, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 13 Writ No. 2003-1715 Clvll Cendant Mortgage Corporation. f/k/a PHH US Mortgage Corporation VS. Constance M. Chichester Atty.: Frank Federman LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate on the West side of South East Street in the Borough of Car- lisle. County of Cumberland and SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER, 2003 State of Pennsylvania. bounded and described as follows: ON the East by South East Street on the South by property formerly of Mrs. Anna B. Eppley. now or for- merly of Lydia Grissinger: on the West by property now or late of Miss E.C, Smead; and on the North by property formerly of Burton Beam. now or formerly of James ABair. CONTAINING 20 feet, more or less. in front on said South East Street and e>..'iending in depth 60 feet to said property now or late of Miss E. C. Smead. HAVING thereon erected a two stoI}' brick dwelling house and other improvements known and num~ bered as 22 S. East Street. Carlisle. Pennsylvania. Tax Parcel #0321.0318-018. TITLE TO SAID PREMISES IS VESTED IN Constance M. Chiches- ter. single woman by Deed from Fred R. Pracht. Jr. and Hope M. Pracht. his wife. dated 1/15/1999 and recorded 1/20/1999 in Deed Book 192. Page 1073. ~~).1. ~jdvv Wilt" , () NOTARiAl: SEAL LOIS E. SNYDER. Notary Public Ca~isle Boro. Cumberland COIIlly My Commission Expires M8Id15. 2005 r lisle, County t.H v.... State of Pennsylvania. bounded and described as follows: ON the East by South East Street on the South by property formerly of Mrs. Anna B. Eppley. now or for- merly of Lydia Grissinger; on the West by property now or late of lVllss E.C. Smead: and on the North by property formerly of Burton Beam, now or formerly of James ABair. CONTAINING 20 feet. more or less. in front on said South East Street and extending in depth 60 feet to said property now or late of Miss E. C. Smead. HAVING thereon erected a two story brick dwelling house and other improvements known and num- bered as 22 S. East Street, Carlisle. Pennsylvania. Tax Parcel #0321-0318.018, TITLE TO SAID PREMISES IS VESTED IN Constance M, Chiches- ter. single woman by Deed from Fred R. Pracht. Jr. and Hope M. Pracht. his wife. daied 111511999 and recorded 1/20/1999 In Deed Book 192. Page 1073. I MY"'C~mission ExpIres "'..-. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION, F/KfA PHH US MORTGAGE CORPORATION Plllintiff, v. No. 03-1715 CONSTANCE M. CmCHESTER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $63,445.61 Interest from 7/8/03-12/8/04 (per diem -$10,43) $5,423.60 and Costs TOTAL $68,869.21 ~_k~ci~ FRANK FEDERMAN, ESQUIRE One Perm Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. < ~.... o~ ~~ ~m ZZ o~ ~~ 0... u~ ~o Ou ~~ 8~ ~h~ ...::; Z;:l ....u z o .... S~ o~ ~"z o~o uo[:: tS::;~ <mo ,,;:l~ ~$o O~u ::;< ...g ~~ ~ ~ ~ ~ m ~ u a u ~ ~ ~ u ~ t; ~ u Z o .... !; u ~e ~ ~ ~.s o ~ ... ... ;~ ~~ ~~ ot: ~~ il:e tl ~ '-'J . iJj~ - (-,-.; , .. , - (''-! - "- ~ - :: 8 - "-,) ~ - ::. - ~ - , - () .;;.-) '-J '0 -J i~. D ~ G If" -- 0 '-, u, 0 -.. c: c,= ~ ~ t.-, -....:.. ,-.., eX . ~ . \.I) -.. t>r vi ~ V) 0- ...... ...... "" \.I) t-- ~ ('t) I.J) ,"'1>0- ..., .... <:> r- .... < ~ r.S .... ~ u . ... ~ ~ ... ~ m .~ 1:1 ... ] ~ p.. ~ .B =: ;., ... <l) ~ ~ ~ ~ :::: in "' <l) ~ -d ~ <l) "' <l) .D ~ "' t g. p. ~ o ~ ~ -I-- j ....c. -=:: ..J ~ I./) ~ ~ ~ ...... (") 1~ ~ - \J ~ ~ 1 (5L AU.. THA'! CERTAIN lot of ground .ilUate on the WtSt side of South East Street in the Ilorougb of Carlisle, County of Cwnberlaot:J and State of Pennsylvania, bounded and de&erlbed as follows: ON tlle East by Smull East Strec:t 011 the South by J>I'OP<:l1Y fOITllCtly of Mrs, AIl.1la B. Eppley, now or fannc:rly of Lyllia GriIlsiDger; an lIIe West by ~ now or late of Miss E.C. SIMad; l1Ild on the Nc:nth by pmpert}. formerly of IlurtDn Beam, now or fonnerly of lame. A. Bair. CONTAINING 20 feet, more or less, in front OIl said South East Street and extending in depth 60 feet to said property now 01 late of Miss B. C. Smead. HAVING thereon erected a two story brick dwelling hOlL"" IIIld other improvements knowu and numbered as 22 S. East Street. Carlisle, Pennsylvania. 'l1TJ...E..TO SAm PREMrSES1S VES]'RIlIN Constance M. Chichester, single woman by Occd from Fred R. Pracht. Jr. and Rope M. Pracht. !lis wife, d!lled 1/1511999 and recorded 112011999 in Det>:I Book 192, Page 1073. Tax Parcel #0321-0318-018 , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1715 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION, Plaintiff(s) From CONSTANCE M. CHICHESTER, (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notif'y himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $63,445.61 L.L. Interest FROM 7/8/03 - 12/8/04 (PER DIEM - $10.43) - $5,423.60 AND COSTS Arty's Comm % Due Prothy $1.00 Atty Paid $711.16 Other Costs Plaintiff Paid Date: JULY 26, 2004 (Seal) CURTIS R. LONG ,Prothono):lJY p ~ ~f2?..~. ,<Y,-r----- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PIDLADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No, 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD" smTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION CONSTANCE M. CHICHESTER NO. 03-1715 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pat C.S. Section 4904 relating to unsworn falsification to authorities. ~~J'0lL'~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~'..- ., CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION CONSTANCE M. CmCHESTER NO. 03-1715 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 22 SOUTH EAST STREET, CARLISLE, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Narne Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYL VANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET HARRISBURG, PA 17105 CITIFINANCIAL, INC. 1 VALLEY STREET, SUITE 103 CARLISLE, PA 17013 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 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 indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 22 SOUTH EAST STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pat C.S. See. 4904 relating to unsworn falsification to authorities. July 22. 2004 DATE ~ ~'- ~~.9JLJ'('I. ~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~-._"'I :1 <) CENDANT MORTGAGE CORPORATION, FfKfA PHH US MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY No. 03-1715 v. CONSTANCE M. CHICHESTER Defendant(s). July 22, 2004 TO: CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at, 22 SOUTH EAST STREET. CARLISLE. PA 17013. is scheduled to be sold at the Sheriffs Sale on DECEMBER 8. 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $63.445.61 obtained by CENDANT MORTGAGE CORPORATION. F/K/A PHH US MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C,P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the 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. 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 if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may can (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 fun 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 ofthe 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALl.. THAT CERTAIN lot of ground .ituate on the Weot side of South East Street In die Borough of Carlisle. COWlty Gf Cwnberland and Stare of l'ennSyl\'l1llia, bounded and de&cribcd as 1\Jllows: ON Ille East by SellIn East Slreet on lbe South by pI'Op<'rly formerly of MIS, Anna B. Eppley, now or fotmerlyof Lydia Orissi.ng<:r; till the We$! by pt()pCt'(y IlOW or IlIre of MiIJ$ e.C. Smead: and on the NQI'fu by pl'Qpcrl}' f(lNnCfly of Burton Beam, now or formerly of James A. Bail'. CONTAINING 10 foet, more or less, In fronl on said South f?ast: Street and extooding in depth 60 feet to said property now 01 late of Miss E. C. Smead. HAVING !hereon erected a two story briek dwelling house and other iml'rovcmeots klIown and numbered as 22 S. ,East Street. CarI.sle, Pennsylvania. nn.l1 TO SAID PREMrSES 1S VES)1ID IN Constance M. Chichester, slngIe wOll1an by Deed from Fred R. Pracbl., Jr. and Hope M. PradJt, his wife, dated 1/15/1999 and recordc;! 1/ZO/i999 in Deed Book 192, Page 1073. Tax Parcel #0'321-0318-018 , ---..-- ~> c.~ --.......~'"- AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PIT PLAINTIFF CENDANT MORTGAGE CORPORATION, FIKI A PHH US MORTGAGE CORPORATION No. 03-1715 ACCT. #0000988592 DEFENDANT(S) SERVE CONSTANCE M. cmCHESTER AT 22 SOUTH EAST STREET CARLISLE, PA 17013 CONSTANCE M. cmCHESTER Type of Action _ Notice of Sherifrs Sale Sale Date: DECEMBER 8, 2004 SERVE~ k Served and made known to ~~at-l ~ e. M, ('llc.- ~ e.~ Defendant, on the ,.-:2.L day of ~ \1 ,200.t at I" J J.., o'clock fm., at ~;7. 5o",~ f:~& 9&-. / C~ \;, s \ <::..... ,Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relalionship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: 'p,; dn f' t I wI.. M No ....,\~'>><!.-.s Descri~tion: Age ~ Height ~ Weight ;2()O Race _ Sex _ Other J !, C\Olr~ \..l Co.... l, Cdit.~, a ~~etent adult, being duly sworn according to law, depose and state that! personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. -j-- ~-lv0; h~~ ~ '" 1\\" - \J'~~ b"""e'7 W"\ Sworn to and S~3(t'qed before me this .o<t(Jay of ~l ~, 200~ No~J: '~ By' ,fti.t4.J- PLEASE ATTEMPT SERVI AT L NOTARIAL SEAL LUCLLE H. CARTY. NalIry NIle I Townshlp, F..... ~ A lley !lI1,Expiie Nov.1~ IMES. IND~T~ DATE'~ NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved _ Unknown _ No Answer Vacant 1 sl Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 j-:\ " ."~ ,.., Co:) ~: :-:J ,,-:- (-) .on -.-; C'_\ (..) Ci IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION ) CIVIL ACTION ) vs. CONSTANCE M. CHICHESTER ) CIVIL DIVISION ) NO. 03-1715 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CENDANT MORTGAGE CORPORATION. F/K/A PHH US MORTGAGE CORPORATION hereby verify that on 7/27/04 & 11/18/04 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 22, 2004 '~~rUl(L- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHB US MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION CONSTANCE M. CmCHESTER NO. 03-1715 Defendant( s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CENDANT MORTGAGE CORPORATION. F/K/A PHH US 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. 22 SOUTH EAST STREET. CARLISLE. PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. "N"ame and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET HARRISBURG, P A 17105 CITIFINANCIAL, INC. 1 VALLEY STREET, SUITE 103 CARLISLE, P A 17013 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 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 indicate) BOROUGH OF CARLISLE 53 WEST SOUTH STREET CARLISLE, P A 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 22 SOUTH EAST STREET CARLISLE~, P A 17013 Domestic Relations of Cumberland County 13 North Ha.nover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 267~5 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true: and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. November 22. 2004 DATE ~W~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "Oo-i t"" ~f ~ - - - - - - '-0 00 ....... 0'1 Vl .l>- v.; N - Ei' " - Vl .l>- v.; N - 0 (1) .. z i~ )> J:l:I'" ,<s, ;I. ( (i" CD z c: 3 C" CD ... ~c;l (i (i ''"t:I ~ (i tl '2 ~ I~ 0 0 .. " 10 ~ ~ S ii! _.- 0 ~r ~ ... en ~ ! en >- ~ ~ ~ en ... ::j ... a~ -- a -... (i (i 0 (i ~ 0"0 i Gl Ell n' trl ~~ ~ g a 00 ~ ~ q It Z .r ~ tt: ::j .. g .. ;(i 0 ~ ... m "I1 ." - en N '"t:I en ~ ~ Z N ~ q ~ en 0 en ~ 0 ~.J ... "I1 ~ .. ttl"O ~ ~ en >- .a ~ ~ ... ... f~ -< ... en ~ ! ~~ .~ ~ ~ "0 trl en " > ..., '" i 0 en ~ .~ tl 0 en ~ (i ... ~ (i i ~-< ~ s: trl N ~ ~ - - Ji: 0 0 ~v.; - (i 5 - ~ en v.; ~t:g.~;;l ~ J;; 0 5 8~';i'i! " "I1 ..... '"t:I ~ ~ "';;l~og; en ~"seQ. J;; ~ > ::I:: "'~"ff" - t;; ~ ::: [ '"t:I ....... ~ Q. _. e a. 0 ~~ (J) a _og a. > - ~a~~g v.; - en _. ~ = 0 ....... ~ ~g..8~ ~ 0 '"t:I ~ - -'g ~.. 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S ~ \00..... ......O'CI:l,"o 8 '< g.::c .tec:m cx;o&t'"" ~~~~ '"t:I~CIl~ ao.l:tt'"" (D ~ ::t. t'"" :'CI:l8'"O . c:: ..., .... a ft .@ ~ (D 0 ., 0 -::9.c;l g E. _ <II Z I.>J CC [g. cT!l <<g, CIl '" '" C>. !l Wc;l~ 8 E. t't1 :;r z -. 8..c ~ g. ~ "rj~ ~ g,g,~ ~~~ ~ ~ ~ ~ ~ ~ ~ tyj", ,..." .g~~ og{;j l~~ ~~ z~ ~ o .... ~ o '" 3: '" (JQ ~ - N - - - 0 * * * * * * * * \0 ~ I.>J N -..J 0'\ Vl 00 * * * * * * * * * * * * * * * * * * * * * * * * * * * * nuq= ~WO ~~~ C"'-lC"'-l~ t"C1-3~ l'"'.lC"'-l=X= ~OO >~~ ....=n C:C"'-l~ ....1-3 w~~ l'"'.lC"'-l 1-3~ -----~. II c}~iSPOs,.~ ~tNNCf!1;~;;', I~ C~~ ,__ ~~~'~e ." ~ z ~ -""AIIIIIIIlIIIP'_ ,r ~.~.\' " :;) -- PITNEY BOWES \ '~0 ,'\ .. 02 1A $ 00.900 ~ >/ J C 0004300377 NOV 18 2004 .". . = MAILED FROM ZIP CODE 19103 r I I I I I I I I Q>Z ....c.= ;{lC.S l' = ;;! ~ ~rC.", = ~ '" = ., c. ~~ cT- : !l '" * * I IodO~ e:=l'"'.l ;,~t::l c.1odl'"'.l ~g~ =:0> p ", ~ Iod~~ >.,Iod ~~ga =irt"C W~~ Cl" = .? C"'-l 5. .... ~ .... ~ = = I I .... o c:: '-,~" . " ,.....;) c.::> = .s:- i' ".1-.,' r-';. . ~~,EJ ).." ~,,; ~ :;:: o ..c: f',' \.0 -;;:, :::r.: a -11 -~ :t:...., rnp' -Olerl1 -~J (") 0 "J "T. 6~ Zfn o "-1 -'.",. "'i:J ~ - .. U1 " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 03--- /7/6 }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby ce ify that the Sheriffs Deed in which Secretary of Veterans Affairs is the grantee the same having been sold to said grantee on the 5th day of Ian A.D., 2005, under and by virtue of a writ Execution issued n the 26th day of July. A.D., 2004, out ofthe Court of Common Pleas of said County as of Civil Term, 2 03 Number 1715, at the suit ofCendant Mtg Com fka Phh US Mtg Com against Constance M C chester is duly recorded in Sheriffs Deed Book No. 267, Page 1824. IN TESTIMONY WHEREOF, I have hereunto se my hand ..Pt-' and seal of said office this day of ecorder fDeeds ,PA .2008 " Cendant Mortgage Corporation flkla PHH US Mortgage Corporation VS Constance M. Chichester In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-1715 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states th t on August 30, 2004 at 9:51 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Constance M. Chichester, by making known unto Tom Weidner, adult in charge, at 22 South East Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08,2004 at 12:14 o'clock P.M., he posted a true copy of the within Re I Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Constance M. Chichester located at 22 South East Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within name defendant, to wit: Constance M. Chichester, by regular mail to her last known address f 22 South East Street, Carlisle, P A 17013. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on January 5, 2005 at 10:00 o'clock AM. He sold the same for he sum of $1.00 to Attorney Daniel Schmieg for Secretary of Veterans Affairs, an Office of the United States of America. It being the highest bid and best price received for the same, Secretary of Veterans Affairs, an Officer of the United States of America of 10 0 Liberty Avenue, Pittsburgh, P A 15222, being the buyer in this execution, paid to She ff R. Thomas Kline the sum of$753.67. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 14.78 ]5.00 15.00 30.00 10.00 1.00 7.40 Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ 15.00 20.00 20.00 209.60 270.97 30.42 25.00 39.50 753.67 so~ P/p' ~ -...,~ ~~ This ~ day of ldLuuh , 1---.4- : 7 R. Thomas Kline, Sheriff 2005, A.D.l... j,:f' QIn,'Pi11, , # i . IPr thonotary , BY' . I Real Estate eputy Sworn and subscribed to before me -;) 0-" c ':,D tP ) ~ '-I fc.9-\ / ItJ)!: :J~ CENDANT MORTGAGE CORPORATION, FIKIA PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION CONSTANCE M. CHICHESTER NO. 03-1715 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION FIKlA PHH US MORTGAGE CORP RATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth s of the date the Praecipe for the Writ of Execution was filed the following information concerning the eal property located at, 22 SOUTH EAST STREET, CARLISLE. P A 17013. L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address calUlOt b reasonably ascertained, please indicate) CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, P A 17013 2. Name and address ofDefendant(s) in thejudgmenl: Same as above 3. Name and last known address of every judgment creditor whose judgment is a recor lien on the real property to be sold: Name Last Known Address (if address cann t be reasonably ascertained, please indicat ) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot reasonably ascertained, please indicate) PENNSYLVANIA HOUSING FINANCE AGENCY 2101 NORTH FRONT STREET HARRISBURG, PA 17105 CITlFINANCIAL, INC. I V ALLEY STREET, SUITE 103 CARLISLE, PA 17013 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (i f address cannot b reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and hose interest may be affected by the sale. Name Last Known Address (if address cannot b reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has y interest in the property which may be affected by the sale: Name Last Known Address (if address cannot b reasonably ascertained, please indicate) Tenant/Occupant 22 SOUTH EAST STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of m personal knowledge or information and belief. I understand that false statements herein are made su . ect to the penalties of 18 Pat C.S. Sec. 4904 relating to unsworn falsification to authorities. Julv 22, 2004 DATE ~ ll.N, !7Q dl Q Jl J'l'LJ'\Jiu FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH US MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY No. 03-1715 v. CONSTANCE M. CmCHESTER Defendant(s). July 22,2004 TO: CONSTANCE M. CHICHESTER 22 SOUTH EAST STREET CARLISLE, PA 17013 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFO OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHA BANKRUPTCY AND THIS DEBT WAS NOT REAFFfRMED, THIS IS NOT AND SHOULD NOT BE CONS AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. ATlON GEIN UED TO BE Your house (real estate) at, 22 SOUTH EAST STREET, CARLISLE, PA 17013, s scheduled to be sold at the Sheriffs Sale on DECEMBER 8, 2004 at 10:00 a.m. in the Cumberland C unty Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $6 445.61 obtained by CENDANT MORTGAGE CORPORATION FIKlA PHH US MORTGA E CORPORATION (the mortgagee) against you. In the event the sale is continued, an anno ncement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: l. The sale will be cancelled if you pay to the mortgagee the back payments, la charges, costs and reasonable attorney's fees due. To find out how much you must pa , you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strik or open the judgment, if the judgment was improperly entered. You may also ask the C rt 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 m re 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 OT ER 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 bidd r. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was gr ssly 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 i the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the wner 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 e Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedi gs to evict you. 6. You may be entitled to a share of the money which was paid for your house. A chedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days oft e sale. This schedule will state who will be receiving that money. The money will be paid out in accor anee with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed ith 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 bac , 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 OFFIC LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It ma not be sold in the absence of a reoresentative of the olaintiff at the Sheriff's Sale. The sale m t be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 Au' THAT CERL-'JN lot of ground ,ituate on the We.<t ,ide of South East Street In !he Boro h. of Cartlste. Couoty o( Cumberland and State of l'ennsylVll1lia, bonnded and described as (ollows: ON the East by South East Street on the South by pro!","y formedy of Mrs. Ann.1 B. Eppley, ()wor formerly of Lydia Qrissioget; tin \he West by property now QT late Qf Miss E.C. Smead; and n the North by property formCfly of Burton Beam, now or formerly of Jame, A. Bair. CONTAINING 20 feet, more or less, in front on said South EaSt Street and extending in depth 0 feet to said pro!",rty now or lau: of Miss E. C. Smead. HAVING thereon erected a two story brick dwelling h(l1JSC and adIer improvements kno numbered as 22 S.East Street. Carlisle, Pennsylvania. TITLE TO SAID PREMISES IS VFBTED IN Cnnstance M. Chlchester, flingle WOOl.n by D from Fred R. Pracht. Jr. and Hope M. Pracht, his wIfe. dated 1/15/1999 and recorded laGf 999 in Deed Book 192, Page 1073. Tax Parcel #0321-0318-018 , WRIT OF EXEC.UTION andlor A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-1715 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION, FIKlA PHH US MORTGAGE CORPORATION, Plaintiff (s) From CONSTANCE M. CHICHESTER, (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defend (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as garnishee and is enjoined as above stated. Amount Due $63,445.61 L.L. Interest FROM 7/8/03 - 1218/04 (PER DIEM - $10.43) - $5,423.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $711.16 Other Costs Plaintiff Paid Date: JULY 26, 2004 CURTIS R. LONG (Seal) Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQillRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale #04 On August 18, 2004 the Sherifflevied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, P A Known and numbered as 22 South East Street, Carlisle, more fully described on Exhibit "A" Date: August 18,2004 By: J 6 ch))~:tl. Real Estate' Deputy ~ t::\@ c:;r\\ c::::-;': G1'J (ftiJ filed with this writ and by this reference incorporated herein. ""U,USfHl::Jd _r.-'" i 'I :~.: [1 Z ~I.Z ln~ ";'.i! .:l..:li'i.' . ,Jj.J j . REAL ESTATE SALE No. 04 Writ No. 2003-1715 , CIvUTerm Cendant Mortgage Corp" f/kla ~HH US Mortgage Corp. , vs . , Constlince M. Chichester, ' Ally:, Frank Federman . . .DESCij'PTION '....i'.... >i.';- .....<;...,... v;..:.:.....:~' ~ ~:" ,'. ,,-j Au:: tHAt CIiRJ'AIN lot Of grO~ situate on !be West side of Sou1h East Street in !be Borough of Ca!li~e. COunty. of 'CllIl1lw1aiNf lind Stale of PenDsylWnia, lxo,ridtld Ond desCtibed as follows: . ON Ibe Eastl>y.SOuth East SlIt.!; on lb. Sou1h by ]lIIlJIelIj ~y of Mrs. AnnitB: Eppley, now or foiin-rl of Lydia ('';'~oger; on 1b.'WesJ -by Jl1Iiliedi J or late 'of MisS RC. Smead; and on !be North by propeny linmCrIy. of Burton B"'W: iwW orflirm""i ofJimes A. Bair. . CONI'AINiNG2il feet, more otkss, in fumt on said Sowh East Street and _uding in depth 60 ' : ffetl1> slid ~ n~ OJ late of Miss E,' C. ~. REAL ESTATE SALE NO. 4 WIit No. 2003.1715 Civil Cendant Mortgage Corporation. f/k/a PHH US Mortgage Corporation VS. Constance M. Chichester Atty.: Frank Federman ALL TIlAT CERTAIN lot of ground situate on the West side of South East Street in the Borough of Car- lisle, County of Cumberland and State of Pennsylvania. bounded and described as follows: ON the East by South East Street on the South by property formerly of Mrs. Anna B. Eppley. now or for- merly of Lydia Grissinger; on the West by property now or late of Miss E.C. Smead; and on the North by property formerly of Burton Beam. now or formerly of James A. Bair. CONTAINING 20 feet, more or less. in front on said South East Street and extending in depth 60 feet to said property now or late of Miss E. C. Smead. HAVING thereon erected a two story brick dwelling house and other improvements known and num- bered as 22 S. East Street, Carlisle, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Constance M. Chiches- , ter, single woman by Deed from Fred R. Pracht, Jr. and Hope M. Pracht, his wife, dated 1/15/1999 and recorded 1/20/1999 in Deed Book 192. Page 1073. Tax Parcel #0321-0318-018. . 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 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 andlor Sunday! Metro editions which appeared on the 19th and 26th day(s) of October and the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for {he Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy SALE#4 REAL ESTATE SALE No. 04 Writ No. 2003-1715 Chili Term Cendant Mortgaga Corp. flk/a PHH US Mortgaga Corp. va Constance M. Chichester Ally: Frank Federman DESCRIPTION ALL THAT CERTAIN lol of ground situate on the West. &ide of South. &t Street in the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows: - ON the East by South East Street; OD the South by propeny lonnerly 01 10m. Aona B. Eppley. now or f<mnerly of Lydia Grissinger; on theWesl by property now or late of Miss E.C, Smead; and on the North by property fonnerly of Burton Beam. now or formerly of James ABair. CONTAINING 20 feel, more or less, in front on ,aid SOIl\!t East Street and extending in depth 60 teet to saId property now or late of Miss E. C. Smead MVJNG thereon erected a twcrstory blick , cIooIII'I! home and odter impro_ ..... IlIlI_..22S.East.-~~ , ,~ --~-'I l1ILI! m SAlIl,....... is """'" in' ~M.~._byDood trom Fred R. """hi, Ir. and !lope M. """hi, hh wne. dated 1/15/1999 and rec<>rded 112il'1999 in Deod Book 192. Page IOn rAX PARCEL ji()32\.03\8.0l8. Sworn to and subscribed be NOTARIAl. SEAl Terry l. Russell. Nola Oty 01 Harrlsburg, Doup I My Commission Expires June 6, 200 TAP LlC Member, P8nnsylYaniaA9SocialioM;~ssion expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PAt 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 270.97 Publisher's Receipt for Advertising Cost ,lisher of The Patriot-News and The Sunday Patriot-News, newspapers of general vledge receipt of the aforesaid notice and publication costs and certifies that the same have By................................................................,... . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, 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, VIZ: OCTOBER 8,15,22,2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO.4 o AND SUBSCRIBED before me this day of OCTOBER 2004 WIit No. 2003.1715 Civil Cendant Mortgage Corporation, f/k/a PHH US Mortgage Corporation YS. Constance M. Chichester Atty.: Frank Federman ALL THAT CERTAIN lot of ground situate on the West side of South East Street in the Borough of Car- lisle, County of Cumberland and State of Pennsylvania, bounded and described as follows: ON the East by South East Street on the South by property formerly of Mrs. Anna B. Eppley, now or for- merly of Lydia Grissinger; on the West by property now or late of Miss E.C. Smead: and on the North by property fonnerly of Burton Beam, now or formerly of James A. Bair. CONTAINING 20 feet, more or l~~~ h-, -f..."nt nn ",,,,,in Snllt}, F::'l~t SWO 22 L SEAL LOIS E, SNYDER. Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005