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HomeMy WebLinkAbout00-07720 . MIDFIRST BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW vs. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER ACTION OF MORTGAGE FORECLOSURE --rL6. 00. 17:Lo Ci;;d. T ~ Defendants TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 claim in the Complaint of for auy other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE lCOUR1HOUSESQUARE CARLISLE, PA 17013-3387 717-249-3166 AVISO LE RAN 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 A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDAD U OTROS DERECHOS lMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-249-3166 :'-10 ~- , - I. --~- ',.....,..,." Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK, vs. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER I 719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff '0 HI ""'I ~~I Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MIDFIRST BANK, vs. CML ACTION - LAW Defendants ACTION OF MORTGAGE FORECLOSURE lZo.lJV. 77020 ~ T.u.- TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, MIDFIRST BANK, is an Oklahoma Corporation, whose address is 3232 WEST RENO OKLAHOMA CITY, OKLAHOMA 73107. 2. Defendant, TIMOTHY M. BLOSSER, is an adult individual, whose last known address is 1669 QUAIL DRIVE, CARLISLE, PENNSYLVANIA 17013. Defendant, HELEN T. BLOSSER, is an adult individual, whose last known address is 1669 QUAIL DRIVE, CARLISLE, PENNSYLVANIA 17013. 3. On or about, April 23, 1991 the said Defendants executed and delivered a Mortgage Note in the sum of $64,900.00 payable to GMAC MORTGAGE CORPORATION OF PA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1009, Page 686 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION and was recorded in the aforesaid County in Book 436, Page 672. The Mortgage was subsequently assigned to NATIONSBANC MORTGAGE CORPORATION and was recorded in the aforesaid County in Book 502, Page 1008. The Mortgage was further assigned to MIDFIRST BANK and was recorded in the aforesaid County in Book 596, Page 861. The said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 1669 QUAIL DRIVE, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "B" attached hereto. '-'~ ,~ -~, ,~ "'."~I . 6. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on October 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $56,263.52 Interest at $13.87 per day From 09/01/1999 To 11/0112000 (based on contract rate of9.000%) $5,908.62 Accumulated Late Charges $221.41 Late Charges at $32.94 Per Month for 14 months $461.16 Escrow Deficit $1,493.65 $2,813.18 Attorney's Fee at 5.0% of Principal Balance $67,161.54 **Together with interest at the per diem rate noted above after November 1, 2000 and other charges and costs to date of Sheriff s Sale. 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 that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces ofthe United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. 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. ''"ii'' , , ~ . WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 9.000% ($13.87 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff s Sale and for foreclosure and sale of th, property wi""" d,,,"ood. By' ~~ '" P ELL, G & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) ,,;;, - " 1--- ~ "', !.,,"~ ,;,.., Multistate Lj ;2. ~ 'b 9!:? '3' t/ Inan No: 1-573680-22 \ '= NOTE , ~~,'I!~ FHA Case No. 441-427979 703 1991 [Dale] J PA 17013 1669 QUAIL DRIVE CARLIS LE IProperlyAddressj APllIL 23, t. PARTIES "Borrower" means each person signing at the end of this Note. and the person's successors and assigns. "Lender" means GMAC MORTGAGE CORPORATION OF PA and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender. Borrower promises to pay the principal sum of SIXTY-FOUR THOUSAND NINE HUNDRED AND 00/100 *********************************** Dollars (U.S. $ 64,900.00 ), plus interest, to the order of Lender. Interest will be"charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of NINE AND 00/100 per cent ( 9.000 Ofo) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED B~rrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security- Instrument." That Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4, MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on JUNE 01, _1991 . Any principal and interest remaining on the first day of .MAY 20 21 , will be due on that date, which is called the maturity date. I (B) Place Payment shall be made at 8360 OLD YORK ROAD ELKINS PARK, PA 19117-1590 or at such other place as Lender may designate in writing. (C) Amount Each monthly payment of principal and interest will be in the amount of $ 522.20 . This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge -to this note for payment adjustments If an allonge providing for payment ~djustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ~ o Adjustable Rate Allonge o Growing Equity Allonge o Graduated Payment Allonge o Other 5. BORROWER'S RIGHT TO PREPAY . Borrower has the right to pay the debt evidenced by this Note. i~ whole or in part, without charge or penalty, on. the first day of any month. 6. BORROWER'S FAILURE TO PAY . (A) Late Charge for Overdue PayineDts If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(q of this Note by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR AND 00/100 per cent ( 4.00 O!o) qttlpeoverdue amount of each payment. (B) Default w ., I If Borrower defaults by failing to pay in full any monthly payment, then~Lender may, except as limited by regulations of the Secretary in tbe case of payment. defaults, require immediate payment in~.fu'1i of tbe principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's r:ights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by Hun regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note. Such fees and costs shall bear interest from the date of disbursement 'at th; same rate as the principal of this Note. ill~~llllllil~I~IIIII\\lil\~\\I~\\lili~II\1 90500308575000000011504-49392Dll0 AI' '" .' ~ E~h~bil GMACFMU.NI/2.CRn.12l89Jlr FHA Multlstlte Filled Rite N&le . 6/89 -.., ~ "-." Loan No 1-573680-22 v..... f. .~ l~i 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or. by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(8) or at a different address if Borrower is given a notice l:!f that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep aILof the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or. endorser of this Note is also obligated to do these things. Any person who takes over these.obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person ~ridivi"~aIJY o~, ,a,~qst i\t!\ sig,p.atQricrs together. Anyone person signing this Note may be required to pay all of the amount~ under this Note. , . ,. " ~~ ,., '"'.l;~, "", , , ' '" J BY SIGNING BELOW, Borrower accepts and agrees to the terms and d in this Note. (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower ~:"V , '. GMACFMU.N2I2.CRev.12189Itr Prlge2o/1.jJ ~...,. > .' . . SCHEDULE A ALL THAT CERTAIN lot or tract of ground situate in Nor~h Middleton Township, Cumberland County. Commonwealth of Pennsylvania, more pllrt:lcularly shown on a certain plan en~itled "Final Subdividon Plan of Se~tion It S~eet 2 of 3 '~e6S8nt Run Estates fo~ Hetlaneo, Ine., North Middleton Townuhlp, Cumberland County, Pennsylvania Sea let 1""50" April 9, 1975 Re'lised, April 30, 1975 by Gerrit J. 8et. Associates, Inc., &ngi~eers & Surveyors, & East HlIin Street, Shiremanstown, Penneylvnaia, which plan i8 filed ~n Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: ZEGINNING at a point at the western right-of-way line of Quail Drive, said point also being at the dividing line of Lots '38 and '39 as shown on a Plsn ot Recording of Pheasant Run Eatates, Section 1, Plan Book 29, Page 7; thence from sald point of beginning. along the aforesaid western rightwof-way line. South 18 degrees 01 ~inute 11 seconds Weat 40.50 feet to a point; thence by same by a curve to the right, 8.. radius of 15.00 feet, distance of 23.56 feet to a point at the northern rIght-of_a)' line of PheaS4nt Drive (South); thence by . aforeaa1.d northern right-of-way Une, North 71 degrees 58 minutea 43 seconds West 31.05 feet to a point; thence by sallie by a curve to the left, s radius of 360.00 feet, a distance of 70.33 feet to a point; thence by seme, North 83 degrees 10 minutes 21 seconds West 11.50 feet to 8 point at the centerline of a 10.00 foot easement; thence by aforesaid easement centerHne, North 06 degrees 49 minutes 39 seconds East 65.83 feet to a point at the southern property line of Lot qJ8; thence by aforeaaid southern line, South 71 degrees 58 minutes 4J seconds East IqO.OO feet to a point. being the place of Beginning. BEING Lot q39 of Pheasant Run Estates. Section I, recorded in Plan Book 29, Page 7. BEING KNOWN AS 1669 Quail n~ive. BEING the same premises. which Douglas B. Brown and Donna R. Brown, by Indenture bearing date the 23rd day of~April A.D. 1991, and intended to be forthwith reeorded in the Office for the Reeording of Deeds in and for the County of Cumberland, Commonwealth of Pennsylvania, granted and conveye~ unto the aaid Hortgagor, in fee. UNDER AND SU&JECT to certain re&tri~tion& now of record. THIS MORTGAGE being intended to be s Purchase Money Mortgage under the provisions of the Lien Priority Law aa amend'ed. ''S', ~.~. BooK 1009 rAtE 600 'tK0wrr Y:;;ii ... I' ~ QCT-12-2000 09:30 PURCELL,KRUG,HRLLER 717 234 7512 P.07/07 . COMP ANY NAME: MlDFIRST BANK. VERIFICAT.ON I verify that the statements made in the foregoing Complaint are true and correct. 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 lUl.J:i!l( 26, 2000 By~i (kw Title Ttlad Burr Vice President TOTAL P.07 ii/:~. ~~~I I SHERIFF'S RETURN - REGULAR CASE NO: 2000-07720 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS BLOSSER TIMOTHY M ET AL ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BLOSSER TIMOTHY M the DEFENDANT , at 0011:50 HOURS, on the 14th day of November, 2000 at 1669 QUAIL DRIVE CARLISLE, PA 17013 by handing to TIMOTHY BLOSSER a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit SurchaTge 18.00 3.10 .00 10.00 .00 31.10 So ;;~~e R. Thomas Kline 11/15/2000 PURCELL, KRUG & HALLER me this /AF day of By:~~~;;t~~ Deputy Sherl Sworn and Subscribed to before ~op,,~,;un;--o A.D. ~c2~~ rothonotary , .W~ , , .0. , SHERIFF'S RETURN - REGULAR > CASE NO: 2000-07720 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MIDFIRST BANK VS BLOSSER TIMOTHY M ET AL ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BLOSSER HELEN T the DEFENDANT , at 0011:50 HOURS, on the 14th day of November, 2000 at 1669 QUAIL DRIVE CARLISLE, PA 17013 by handing to TIMOTHY BLOSSER (HUSBAND) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~~,<~~ R. Thomas Kline 11/15/2000 PURCELL, KRUG & HALLER me this lAY day of BY:~~~~~ Deput Sherlff Sworn and Subscribed to before AQ;o~ ;Lg-y-o A.D. ~Q~~ , othonotary . '\:!!!:;:~ ? ~,~ ....... ~-" -i}::tL"'I . , I MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS_ CIVIL ACTION - LAW NO. 2000 07720 TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the plaintiff and against Defendants TIMOTHY M. BLOSSER AND HELEN T. BLOSSER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $13.87 from 9/1/99 to 11/1/00) Accumulated late charges Late charges ($32.94 per month to 11/00) Escrow Deficit 5% Attorney's Commission TOTAL $56,263.52 $ 5,908.62 $ 221.41 $ 461.16 $ 1,493.65 $ 2,813.18 $67,161. 54** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL,u_~~ & U4R By ~~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 I:IHOME\MKFIDOCS\CUMBERLAIBLOSSER.P .,~ . . . I-~. ~ ~ " ~ . MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT Tb PA. R.C.P. 237.1 I hereby certify that on FEBRUARY 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ~,.~ p t'~, ~, " , . 1\hoI;IRST BANK Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-7720 CNIL TIMOTHY M. BLOSSER AND HELEN T. BLOSSER : CNIL ACTION LAW : IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: February 21, 2001 TO: TIMOTHY M. BLOSSER 1669 QUAIL DRNE CARLISLE, PA 17013-1245 HELEN T. BLOSSER 1669 QUAIL DRNE CARLISLE,PA 17013-1245 TillS 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. 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 ruDGMENT 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION CARLISLE, PA 17013 717-249-3166 By LEON p, HALLER, Attorney for Plaintiff LD. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 ,[!.~(#, - , ~..,..~ '.~ . 1'- ,--~ f'-' ."0 ~ MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on ~ /3- d-.tIV I the against you in the above- $67,161.54 and for the sale and foreclosure of your property located at: 1669 Quail Drive, Carlisle, PA 17013 Dated: 3- 13~ol cu~ R /r ....' PROTHONOTARY~ Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Timothy M. Blosser 1669 Quail Drive Carlisle, PA 17013-1245 Helen T. Blosser 1669 Quail Drive Carlisle, PA 17013-1245 I:IHOME\MKRDOGSIGUMBERLA\BLOSSER.N T"'<<!l. oM ~_ . . -I -1fIIIlIQiJI ~~' 0' _,,_. '_1<_,' "_."'_'~,_' . .,._ ~ ~ .'. i \. i : \ . , \ \ \\\i -- "'\ \'~ Ir- . L f~ 'I .:r- ~ 01 -(, e ~ "" ~_ "'",-,. <;"",,,,,,-,,,~L"_ ,. C .. W'~ >..:, ........ 0- ~ -.J C><\I - .~, _\ Uu\ ~\ ,_I. ~~' ~ ~ ~u C) ~ ,. ...;. ~ ( ~ r ~ -,..S) ;'f "" I " U- (). -..... ~ - u ~ ._l' ,,' " \ r (') C) 0 C -on ;:. :;;: "--:<! . -un:; 5.:~ :-;";1' jl1n1 ?:J Z:T~ --.:; b:2 ~~;~ w :-~2'y ~'.:-~ (")- r:::Cj -0 ~'+t :Pn ::J;: Po ;:;(:5 2rn r:- 0 ;P-c .. S; ~ '0 Iv ~ _;lM~~,~ l1'!j;Il~~~~"""'~~~~5lIt~_"'""r~,W'iP~,r.gTmmlJ!':""Tl:",~;-,,,-gr"":-"')"'!F",'-';""l;fj'"'~.'1'!n'fu~"'l"!IflIt_"~"""I'~wn'r:',,,,-"YI'i'","~l.;;WI~~1lI'MHf~~~ ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2000 07720 MIDFIRST BANK, PLAINTIFF TOTAL AMOUNT / OF JUDGMENT $67,161.54' Interest at $13.87 per diem to sale date $ 3,009.79 Late charges at $32.94 per month to sale date $ 197.64 Escrow Deficit $ 2,000.00 TOTAL $72,368.97* VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS *SALE DATE: WEDS.,JUNE 6, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the tioned case. Date: March 9, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA 5S COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1669 QUAIL DRIVE, CARLISLE, PA 17013. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY $ ~~, ~~ , 'I ~~~ -~T1 .' ~Tl"'ii1 .. ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Commonwealth of pennsylvania, more particularly shown on a certain plan entitled "Final Subdivision Plan of section I: Sheet 2 of 3 Pheasant Run Estates for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania Scale: 1"=50' April 9, 1975 Revised: April 30, 1975" by Gerrit J. Betz Associates, Inc., Engineers & Surveyors, 6 East Main Street, Shiremanstown, pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: BEGINNING dt a point at the western right-of-way line of Quail Drive, said point also being at the dividing line of Lots #38 and #39 as shown on a Plan of Recording of Pheas~nt Run Estates, section I, Plan Book 29, Page 7; thence from said point of beginning, along the aforesaid western right-of-way line, South 18 degrees 01 minute 17 seconds West 40.50 feet to a point; thence by same by a curve to the right, a radius of 15.00 feet, distance of 23.56 feet to a point at the northern right-of-way line of Pheasant Drive (South); thence by aforesaid northern right-of-way line, North 71 degrees 58 minutes 43 seconds West 31.05 feet to a point; thence by same by a curve to the left, a radius of 360.00 feet, a distance of 70.33 feet to a point; thence by same, North 83 degrees 10 minutes 21 seconds West 11.50 feet to a point at the centerline of a 10.00 foot easement; thence by aforesaid easement centerline, North 06 degrees 49 minutes 39 seconds East 65.83 feet to a point at the southern property line of Lot #38; thence by aforesaid southern line, South 71 degrees 58 minutes 43 seconds East 140.00 feet to a point, being the place of BEGINNING. BEING Lot #39 of Pheasant Run Estates, Section I, recorded in Plan Book 29, Page 7. TOGETHER with the right, in common with others, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING subject to a Declaration of Covenants recorded in Misc. Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. BEING THE SAME PREMISES WHICH Douglas B. Brown and Donna R. Ott, formerly Donna R. Brown, by deed dated 4/23/91 and recorded in Deed Book B-35, Page 655 granted and conveyed unto Timothy M. Blosser and Helen T. Blosser. TO BE SOLD AS THE PROPERTY OF TIMOTHY M. BLOSSER AND HELEN T. BLOSSER ON JUDGMENT NO. 2000 07720. PARCEL: 29-17-1583-105 .- ~ ~ I I I, i i I' , I Ii Ii II I i, " Ii L.,- <::> l'- .. ~ , [ I i ---.. 1-- \-.Sl , I - \-- [ C I I I --., I 9---- ~ ~I -c.. . (:J ..~ ~ .- ., ". ~) ~) r 0 0 r, C u =. -fJ '~ -off: ::l;: .-< [flIT: 7;i::~... -'I' J' ~t~; ::;" ~';:i~ "':"im (~) -:J\-:;:! -<,,~ :-e~~ <CJ '" ~O -~"... ~.i.. ,-)--.- ::;;;::-0 "-:'7 C) ~ ..J.-"'C <;- fjlTJ :z: -~ ~ .0 -....: '--.,\j - ~ -'- r" :0 ~~"~ -< -- ^^ C c' "~~~~M!~f.li!~~1W =IIIJiil'irf:f\LJ\ ,~J!,~!~.)f,'r_'I',~m~n-':'r"''''"''''r~r'>1't'''''''.i]'~:"'{*'''~ill\i~m.l';"'w'"':"'~,,,w;>!V'Tm_'~'h~~!lI~"'" t:0 \ " 'W""" ~ ",,~ "J. MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1669 QUAIL DRIVE, CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Timothy M. Blosser 1669 Quail Drive Carlisle, PA 17013 Helen T. Blosser 1669 Quail Drive Carlisle, PA 17013-1245 2. Name and address of Defendant (s) different from that listed in (1) above: in the Judgment, if SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Commonwealth of pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales P.o. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Bureau of Compliance Dept. 280946 Harrisburg, PA 17128-0946 Commonwealth of Pennsylvania Department of Labor & Industry Labor & Industry Building 16th Floor Harrisburg, PA 17120 Commonwealth of pennsylania Office of Chief Counsel Unemployment Compensation Review Board 909 Green Street Harrisburg, PA 17102 , ~. ~- , " . ""~""~ ,A. 4 . Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Linda B. Baer 6 Ramsgate Drive Hummelstown, PA 17036 Edward N. Baer 6 Ramsgate Drive Hummelstown, PA 17036 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 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: TENANTS IF ANY ... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, 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. Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 9, 2001 1 1- "~ -- ~ '" ~ ,.1!llf1JllDl!'!!ll' ......~ ;;~~. v ,"J~ fnp- b~ L-C ~~~ r-..,~.., .--~ ~C) !':-=:O ::Pc ~ o r ~ "," \it ""-. ,,'h',t Cl o -n :-~:! :';-lP i-3:b '~a ~ - -~ ::r:P ::;..""J w -0 :z s;;- ., o 10 ._~~~~ ! ~lIi!rI~~'~:W_~~~~~"O'Hf"''''''f0'lj'_';'-;_<!~''Y'''i~.~1'1Hl''''''I~-%J!'''fmI>l~ifil'H''1~~~'lIlI~! ~ MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 6, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1669 QUAIL DRIVE CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 07720 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property TIMOTHY M. BLOSSER AND HELEN T. BLOSSER :_~.. - " ~I \ . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the .Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious def~nse against the person or company that has entered judgment agalnst you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This --'~~~"'"r__' r___ petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 OJ:.;!'_,", I ~ -I . . / ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Commonwealth of Pennsylvania, more particularly shown on a certain plan entitled "Final Subdivision Plan of section I: Sheet 2 of 3 Pheasant Run Estates for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania Scale: 1"=50' April 9, 1975 Revised: April 30, 1975" by Gerrit J. Betz Associates, Inc., Engineers & Surveyors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: BEGINNING at a point at the western right-of-way line of Quail Drive, said point also being at the dividing line of Lots #38 and #39 as shown on a Plan of Recording of Pheasant Run Estates, section I, plan Book 29, Page 7; thence from said point of beginning, along the aforesaid western right-of-way line, South 18 degrees 01 minute 17 seconds West 40.50 feet to a point; thence by same by a curve to the right, a radius of 15.00 feet, distance of 23.56 feet to a point at the northern right-of-way line of Pheasant Drive (South); thence by aforesaid northern right-of-way line, North 71 degrees 58 minutes 43 seconds West 31.05 feet to a point; thence by same by a curve to the left, a radius of 360.00 feet, a distance of 70.33 feet to a point; thence by same, North 83 degrees 10 minutes 21 seconds West 11.50 feet to a point at the centerline of a 10.00 foot easement; thence by aforesaid easement centerline, North 06 degrees 49 minutes 39 seconds East 65.83 feet to a point at the southern property line of Lot #38; thence by aforesaid southern line, South 71 degrees 58 minutes 43 seconds East 140.00 feet to a point, being the place of BEGINNING. BEING Lot #39 of Pheasant Run Estates, Section I, recorded in Plan Book 29, Page 7. TOGETHER with the right, in common with others, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING subject to a Declaration of Covenants recorded in Misc. Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. BEING THE SAME PREMISES WHICH Douglas B. Brown and Donna R. Ott, formerly Donna R. Brown, by deed dated 4/23/91 and recorded in Deed Book B-35, Page 655 granted and conveyed unto Timothy M. Blosser and Helen T. Blosser. TO BE SOLD AS THE PROPERTY OF TIMOTHY M. BLOSSER AND HELEN T. BLOSSER ON JUDGMENT NO. 2000 07720. PARCEL: 29-17-1583-105 .=~. ~ I I >~ !ifiII'Il."'~ 1lII'!'lH_~~!l<lfflll!W'lIlll!!!l~~<fI~;lll'!~.~J~., ~ 0 a 0 c <- -'1 ~m ::J: ~.:~J ~ ;u fi, :D r- c/)~> Go ~r)f:3 -<6.c:.' ~..:~(~J ~::=c) ."':) ZC) ~ <?~ "",n ~'C: c- Om 2::"": :::> ~ =< ,..., -< ~ ~~,U~i);~-llin"!i_lI!"'J~j;;;~,"'r:"1'W':'''-~~Nr;r.-i1!~~~~~~~'$W_'''''''~,o.~, I..!" . Midfirst Bank VS Timothy M. Blosser Helen T. Blosser In the Court of Common Pleas of CumberlandCounty,Pennsylvania No.2000-7720 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Law Library County Mileage Levy Certified Mail Surcharge Postpone Sale Law Journal Patriot News Share of Bills 30.00 10.40 15.00 15.00 .50 1.00 3.10 15.00 1.30 30.00 20.00 146.05 238.06 22J12... 550.50 paid by attorney 05-21-01 Sworn and Subscribed To Before Me This 50:: Day o~~ , 2001 A.D. ~Q~}I', :~ P 0 onotary ~~~ ~. Th~mas Kline, Sh~riff By ~a;:;zeri~ I.ao ch. 31Ob_>1 L- iI:J.,,~5 ." .- ~"-~I'. " .~ ~_,...F, MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 , j IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1669 QUAIL DRIVE, CARLISLE, PA 17013: 1. Name and address of the Owner(s) or Reputed Owner(s): Timothy M. Blosser 1669 Quail Drive Carlisle, PA 17013 Helen T. Blosser 1669 Quail Drive Carlisle, PA 17013-1245 2. Name and address of Defendant (s) different from that listed in (1) above: in the Judgment, if SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support/Sheriff Sales P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Bureau of Compliance Dept. 280946 Harrisburg, PA 17128-0946 Commonwealth of Pennsylvania Department of Labor & Industry Labor & Industry Building 16th Floor Harrisburg, PA 17120 Commonwealth of Pennsylania Office of Chief Counsel Unemployment Compensation Review Board 909 Green Street Harrisburg, PA 17102 ."=-~.,. ......, ~ , 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Linda B. Baer 6 Ramsgate Drive Hummelstown, PA 17036 Edward N. Baer 6 Ramsgate Drive Hummelstown, PA 17036 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of in the property and UNKNOWN every other person who has any record whose interest may be affected by the 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: TENANTS IF ANY .., Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, 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. /G/' '//~;7 ,-_.//--/.. /; Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 9, 2001 rh. . --, , .,'-" "..........,,". 11 ~ - -" MIDFIRST BANK, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, DEFENDANTS CIVIL ACTION - LAW NO. 2000 07720 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 6, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner'S Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1669 QUAIL DRIVE CARLISLE CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 07720 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: TIMOTHY M. BLOSSER AND HELEN T. BLOSSER - ~- -::. ~~- --I" . - ~-'~-I .. ,- ,~~"' C'1," ''S'.'''', _ ' 1 '0 - ----""-;\"',;-:{\;:_:',;:;;,6",; ,'See-< __ .;:!':.:;S_i~:'''': . . , WRITOF,EXECUT;ON and/hr ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7720 CIVIl.XHl TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Midfirst Bank PLAINTIFF(S) from Timothv M. Blosser and Helen T. Blosser 1669 Quail Drive, Carlisle, Pa. 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell 1669 alia;] Drive. Carl isle. Pa. 17013 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ::Wi ';!~ :!ii -. GARNISHEE(S) as follows: and to notny the garnishee(s) th'll:i~~al,an a!tachment has been issued; (b1lhe gar~i~hee(lll, io/~.r;~ enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property onlle defendaht(s) or otherwise disposing thereof; (3) If property oflhe defendant(s) not levied upon an subjecllo attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due Interest at Interest Atty's Comm Atty Paid ~ll 9. 10 Sh7,lh1~4 $13.87 per diem $ ~ . (lOg 79 L.L. $0.50 to sale date Due Prothy Other Costs ~1.00 Late charges at 532.94 Der month % Plaintiff Paid to sale date 5197.64 Escrow Deficit $2,000.00 Date: MArICh 11. ::>001 Cllrr;s R. T,nnq Prothonotary, Civil Division by: ().'t'" O. ~ REQUESTING PARTY: Deputy Name f,pnn P. HAllpr. F:F:q. Address: 1719 Nnrt-h Pmnt- St-rppt- Hsr.ri~~lrg. Pa 17102 Attorney for: Plaintiff Telephone: (717) 234-4178 Supreme Court ID No. 15700 'l~.~ "1 - "I ....., "~J!h"€-'i~[$_;~~J.f,)!$&!-l)it'~~ifj}:Y~~'g~&~~liq!Mt~i?(-%1;&;:t)!f~':t}'/~0J?'J.:"'~ i , REAL ESTATE SALE tw. ( c:=) CUi) CUi) c::::::J &e> &iVV ".. 11{ ~ 1(;1 ;lDO/ the sheriff levied upon the detenoi:;, interest in the real property situated in il~ f/tJ"d.df.e.iPL /~ 6umberland County, Pa., known and numbered as:l&&9 Q/.J.-w Ot. t~ and more fully described on exhibit "A" filed with this writ and by this reference incorporated heretn. !late: 11~ /(P,:20ol By: t(4 ~ Dep~.2~ VINVf,lJ.SHN3d TJc....'i';f8 10. Wd EO Z 51 HIM A.Llinto (I,. "Jdi'lnO lUIll3HS 3111 :10 3:)1:1:10 - 1I!lI!l~ ~_"",,,~MI"!1i!l'~~" _ ~"""".~~l'f1!"l'~~:-'i<':""'"'~tfl1:l.l:'f-""_'1'i"~~~~fBili'~~''';,~~~;jll''li~~Hm''\ij~~,R'l~_'.r"''''~Rl'!lI~J .~~, rIfl Leon P. Haller Purcell, Krug & Haller 1719 N. Front Street Harrisburg, PA 17102-2392 (717) 234-4178 lhaller@pkh.com Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW MIDFIRST BANK, VS. NO. 2000 - 07720 TIMOTHY M. BLOSSER AND HELEN T. BLOSSER, Defendants IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Please mark the judgment entered against the Defendants satisfied of record. BY: Leon P. Haller ID #15700 Attorney for Plaintiff DATE: October 13. 2004 !re'll -r-""l ._,"'"