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HomeMy WebLinkAbout00-07824 C.P. 45-P PRAECIPE FOR WRIT OF EXECUTION OJommottfueaIt~ of Jettttili\!htattia COUNTY OF CUMBERLAND PNC BANK, NATIONAL ASSOCIATION COURT OF COMMON PLEAS Term, 19 2000-07824 P ... NO. STEWARD H. HARTMAN, JR. PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY, I ssue Writ of Execution in the above matter: Amount due $ 15,939.76 I nterest from 1/27/01 $ $ (Costs to be added) PIULIPS, CURTIN & DiGIACOMO ttomey(s) fOT PlaintifHs) J. DiGIACOMO, ESQUIRE SUITE 300, 1211CEESTNUT STREET PHILADELPHIA, PA 19107 (215) 563-7700 Mortgage Foreclosure Ground Rent (Rem) 5--46 (Rev. 1/80) ~',~ ~1 " I", 1 I . , = ~~-~.. _.~'" ' , 0 0 0 -ro. ~ ''1 (J ..... :x --'...: ~ , -GQ "'0 OJ :". 'T-,.,_ 1t -GQ 0 vt G,., ---- ~fT1 :;0 " ;:= ,~ ,.. ~ "-0 ~. ,~ Z::D kJ~ ':'-- t ~~ w C> l.J C, C) ~ VJ <Y1 ~ g roc ~ () C) 0 Co 0 () ~() '"t) "\1- 0 I :Jl: ':?(') \ I , );:0 !2 I~ -, ~ ism ~ 0 b'j ~ ~ N 9 , :n " , q" W -< " " ~)~ , ~ , " H--( "". -~,""~ -~~ "i0_'''''I'\''''!-_~''''~';C',iQr''''''",,'iiH'''P.:C~K';;I''''''!'Fm;T'''''W''''eF",,~f''''-"~"';"f~I:il "',- ," '"'. ~~~mJ'~~_I'l!~""" , 11"1'-4-',,, "'"~'~"",p'wrPC:-;;"~:'''''1O''''1",1''F''''''F:-:'''"'Y',''--~~~;;-''"T--~;T" ";',fl'~?~P''''''r')W''''~M'!~ PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300,1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P 3129.1 AFFIDAVIT STATE OF PENNSYLVANIA: SS COUNTY OF PHILADELPHIA: LOUIS J. DiGIACOMO, ESQUIRE being duly sworn according to law, deposes and says that she is attorney for the Plaintiff herein and makes this affidavit for and on its behalf, being duly.authorized so to do and avers as follows: The names and last known address ofthe real owner or reputed owner of premises 401 E. Coover Street, Mechanicsburg, PA 17055 is Steward H. Hartman, Jr., 401 E. Coover Street, Mechanicsburg, PA 17055. The name and last known address of the Defendant in the above captioned matter is Steward H. Hartman, Jr., 401 E. Coover Street, Mechanicsburg, PA 17055. Notice of Owner's Rights with respect to Sheriff's Sale has been delivered to the Sheriff of Cumberland County, and he is to served the Notice of Owner's Rights upon the owner by personal service; a true and correct copy of said notice being, ched hereto. ,& Sworn to and subscribed be~ re me this PcFrJay of 001. ~ NOTARIAL SEAL MARY e. CURTIN, Notary Public CiIy at !'h\1adelphia, Phila. County My Commission E"pires Se t 14. 2002 '--"1'7,,_ ... II' PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO.2000-07824P NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEWARD H. HARTMAN, JR. 401 E. COOVER STREET MECHANICSBURG, PA 17055 STEWARD H. HARTMAN, JR. C/O JAMES BACH, ESQUIRE 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 Your property at 401 E. Coover Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on Friday, June 6,2001 at 10:00 a.m. in the Sheriff's office in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania to enforce the Court judgment of $15,939.76 PNC Bank, National Association obtained by PNC Bank, National Association, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to PNC Bank, National Association, N.A. the amount of the judgment plus costs. To find out how much you must pay, you may call LOUIS J. DiGIACOMO at (215) 563-7700. 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 2 on how to obtain an attorney). "'om "'I' .. - Ii, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price by calling LOUIS J. DiGIACOMO at (215) 563-7700. '! 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value.of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened you may call the Sheriff's Office at (717)240- 6399. 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 has never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time the buyer may bring legal proceedings to evict you. 6. You may be entitled toa share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on July 6,2001. 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 July 6, 2001. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (800) 990-9108 2 ,;"-,, . w ",Y"' > II Ii l ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos. I and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or formerly of James L. YOImg; thence along said Young land, South 72 degrees 48 minutes West, 76,23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 13 L07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to Lot No.2, Block "B", at the point and place of Beginning, BEING Lot No, I, Block "B", in the Plan of Blackburn Village, as recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanicsburg, Pennsylvania. BEING Parcel No, 17-24-0789-010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H. Hartman dated 10/1/1986 and recorded 10/10/1986 in Cumberland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, PA 17055, -~ " , ~" = r .', o c: s: fRO) 2W 2:C v..)~> -< 7 ke~f ~o ",,0 -c:: 2: ~ '" CJ o "1"'/ :!t ;;r-", :" ::;::.:l i' fiE :~~::E9 ,-, t ~~~.~ ;;;:f:~ ~~ i:~ ::0 -< c...' v :z ~ N <...> ,~, !,..,~~~"~~IdW!!_"~_~,~"",, ~,"Ml~"Vl!'m:.wmliWJl':3'AIl~1'''f::I'i!;jt,-9f7-M"""i'R''ffl",M\V';;;''!(~IF'''~'''~''l1:~';~~!m"I!EI'Wf~"l~';'~liI'r~f'lT.!~~'N~ I I PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300,1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P AFFIDAVIT PURSUANT TO RULE 3129.1 LOUIS J. DiGIACOMO, attorney for Plaintiff in the above action, sets forth as ofthe date the praecipe for the writ of execution was filed the following information concerning the real property located at 401 E. Coover Street, Mechanicsburg, PA 17055, legal description of which is attached hereto as Exhibit "A". 1. Name & Address of owner(s) or reputed owner(s): NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) Steward H. Hartman, Jr. 401 E. Coover Street, Mechanicsburg, PA 17055 2. Name & Address of Defendant(s) in the judgment: NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) Steward H. Hartman, Jr. 401 E. Coover Street, Mechanicsburg, PA 17055 0_,_ 3. Name & Address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) PNC Bank, National Association Consumer Loan Center, 2730 Liberty Avenue Pittsburgh, PA 15222 4. Name & Address of the last recorded holder of every mortgage of record: NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) PNC Bank, National Association Consumer Loan Center, 2730 Liberty Avenue Pittsburgh, PA 15222 Household Finance Consumer Discount Company 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 5. Name & Address of every other person who has any record lien on their property: NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) None. 6. Name & Address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME ADDRESS (if address cannot be reasonably ascertained, please so indicate) None. 7. Name & 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 None. ADDRESS (if address cannot be reasonably ascertained, please so indicate) 2 '-"" , ~ I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: rfyo( VL~d~E Attorney for Plaintiff 3 ,-ow... ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos. 1 and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or formerly of James 1. Young; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23,44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to Lot No.2, Block "B", at the point and place of Beginning. BEING Lot No. I, Block "B", in the Plan of Blackburn Village, as recorded in the Cmnberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No, 401 East Coover Street, Mechanicsburg, Pennsylvania. BEING Parcel No. 17-24-0789-010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H. Hartman dated 101111986 and recorded 10/10/1986 in Cumberland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, P A 17055. EXHIBIT "A" -", ~'" - ,,~- il II I PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 :CUMBERLAND COUNTY :COURT OF COMMON PLEAS Ii Attorney for Plaintiff vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P CERTIFICATION I HEREBY CERTIFY that I am the attorney of record for the Plaintiff in this action against real property, and further certify that the Plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including but not limited to (a) Service of notice on Defendant (b) Expiration of 10 days since the service of notice (c) Defendant's failure to request or appear at meeting with mortgagee or Consumer Credit Counseling Agency (d) Defendant's failure to file application with the Homeowners Emergency Assistance Program I FURTHER AGREE to indemnify and hold harmless the Sheriff for any false statements given herein. ',' , II II PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEWARD H. HARTMAN, JR. 401 E. COOVER STREET MECHANICSBURG, PA 17055 STEWARD H. HARTMAN, JR. C/O JAMES BACH, ESQUIRE 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 Your property at 401 E. Coover Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Friday, June 6, 2001 at 10:00 a.m. in the Sheriffs office in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania to enforce the Court judgment of $15,939.76 PNC Bank, National Association obtained by PNC Bank, National Association, NA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to PNC Bank, National Association, NA the amount of the judgment plus costs. To find out how much you must pay, you may call LOUIS J. DiGIACOMO at (215) 563-7700. 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 2 on how to obtain an attorney). if 11 I YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price by calling LOUIS J. DiGIACOMO at (215) 563-7700. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Sheriff's Office at (717) 240- 6399. 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 has never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on July 6,2001. 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 July 6,2001. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (800) 990-9108 2 ".--,- - - II ... I ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos, I and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or fonnerly of James L. YOlU1g; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to Lot No.2, Block "B", at the point and place of Beginning, BEING Lot No.1, Block "B", in the Plan of Blackburn Village, as recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanicsburg, Pennsylvania, BEING Parcel No. 17-24-0789-010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H, Hartman dated 10/1/1986 and recorded 10/10/1986 in Cumberland County in Deed Book F 32 page 795, Commonly known as 401 East Coover Street, Mechanicsburg, P A 17055. Iii J , ...1' \ 0 C> 0 C -n s: :t: -Ow ;;:.~ mrn :;:0 ~ Z:r.:: hl ZC 'T: Cl)d;; w ;(',:1 --~, >3 ~~~ ~c; -0 >c) ~ (~:;~~?5 z' --0 ry tjrTl Pc Z -~ :< N 5s (.:. -< ~--, ~~ ","~JE!_~ '~~~ilffl'I'-~~ll'~~o>l~_-l~ ,,~~ _-~~~I'l~~~;f,M~~f}'l<_-"W~';'F"!'l1' "~"'''"'''~",\;i:''f,,,,'~I.#\'~~t\lii~:>'I:'t';;;if~~''~!jJW1;,"-9''';WfF'''''I,*,;;h!'9iW'~-"WI";O~i1i~ff,!r . , . PHILIPS, CURTIN & DiGIACOMO By: PHILIP G. CURTIN, ESQUIRE Identification Number: 52324 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P AFFIDAVIT OF SERVICE UNDER RULE 3129.2 STATE OF PENNSYLVANIA: SS COUNTY OF PHILADELPHIA: PHILIP G. CURTIN, being duly sworn according to law, deposes and says that notices with reference to the sheriff's sale to be held on June 6, 2001 have been mailed to the following creditors as per the attached certificate of mailing (PS Form 3817) on May 3,2001 : Name Address Household Finance Consumer Discount Company 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 ~~ HILI . CURTIN, ESQUIRE Sworn to and subscribed before me thi~ay of N~l OWOr. N(i~[ Cd: ~ NOTARIAL SEAL MARY E. CURTIN. Notary Public City of Philadelphia, Phila. County Mv Commission E,oiros Soot. 14, 2002 >'-~" _" ,1,,,<,, , Jjm - , J' u.s. POS AL SERVICE CERTIFICATE OF MAIL! G MAY BE USED FOR DOMESTIC AND INTERNATIONAl MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received Flam: One piece of ordinary mail addressed to: 25 GATEWAY DRIVE, SUITE 1'n7 MEOIANICSBURG, PA 17055 PS Form 3817, Mar. 1989 . - (-- P~--;/<..", rn 1J ~. " >> .., 117 = "- I~"n:::~~~ CD,l ,) .">!';".'-''''''''~"f;~ ~:r!~i I ~. ~ till 1 m III....J'U **....,********* I, 1 Jlll ""''''''''''' -",,< - , "," .' ~-,~"" '" .,' . -L-.< (') C "... .;;..'""- -eel::; rnjT\ Z:r., ~~ LC' )>' C Z =< - IIIII~TIi'il!n , o o " _.~'''' :~~ (::0- \..0 ~ -<:.: :f1 .t,:- F!!Im.~~""",~ifi!l~~~"-~'Flji!M~'~I'i'fOI!fflt~~I!I'"~F-i!"l-'WI""1''I\''''I'.-''-f''m"'';\""';'"'llj1i1lli'll!mll~I~~~~~~~~!~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-07824 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PNC BANK NATIONAL ASSOC VS HARTMAN STEWARD H JR DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HARTMAN STEWARD H JR the DEFENDANT , at 0014:11 HOURS, on the 16th day of November, 2000 at 352 S SPORTING HILL RD MECHANICSBURG, PA 17055 JAMES BACH (ATTORNEY FOR by handing to DEFENDANT) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Additional Comments --- SEE ATTACHED ACCEPTANCE OF SERVICE FORM Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers;....,/, A7!i,;;j ~~p.>Nttr~ R. Thomas Kline me this /4.k-' day of 11/17/2000 PHm::: =~^: ,:'A~MO ~'-H Deputy Sheriff Sworn and Subscribed to before AQU_<MA-~ .26v0 A. D . q-r._Q~~ rothonotary , \:11" "'" ._~ .....~._................~____~_~~"..~~...""""....~.......,;.__."....._,",o""..,,,.._"'..,,._..........-.,,..""""""'_~__"'-x..'.;:;.'L'%-:>.,"'''"_':"'''"..,..,.____~........"...,..:.;....~<V.',-...,'..;.:":.;..;,~.,.:.;-=,'''.,_'''""" " .' ACCEPTANCE OF SERVICE I accept service of the Notice and Complaint in Mortgage Foreclosure (on behalf of Steward H. Hartman, Jr. and certify that I am authorized JI- l'h- 00 Date' . I to do so.) 352 South Sporting Hill Rd., Mailing Address ,,-,,~-- -, ',""\"- ." - - ~. ~1J Mechanicsburg, PA 17055 r_, ,'-, C'" ~ ae:/4,,~ .. , . Karen S. Coates, Esquire Thomas, Thomas & Hafer, LLP Attorney LD. # 52654 305 North Front Street p, 0, Box 999 Harrisburg, P A 17108,0999 (717) 237,7121 Attorneys for Defendants WALTER GOOD and SARAH GOOD, h/w, IN THE COURT OF COMMON PLEAS CUMBERLAND CTY., PENNSYLVANIA Plaintiffs v. CIVIL ACTION - LAW NO. 00-7825 - CNIL JOHN SOPENSKY, PAUL JOHN SOPENSKY, EMILY SOPENSKY, and PAUL SOPENSKY, Defendants JURY TRIAL DEMANDED AND NOW, this 28th day of December, 2000, I, BARBARA A. ONORATO, a Legal Assistant at the law fIrm of Thomas, Thomas & Hafer, LLP hereby certify that I sent a true and correct copy of the foregoing Request for Production of Documents of Defendants Directed to the Plaintiffs, by placing a copy of the same in the United States Mail, fIrst class, postage prepaid, to the following: Jeffrey M. Rosenbaum, Esquire Rosenbaum & Associates, P. C. 1818 Market Street Suite 3200 Philadelphia, PA 19103 Date: December 28, 2000 ~v~, Barbara A. Onorato Legal Assistant ,-".- ''"_._ry"T", -,",,7"~-- - ._"~,,._. ,_,," _' ^'_..~' . -_c_'r-_- ~ - ~.' ,",',~ .~.-,-,-' ,,' ^ ." . ~. '-~.', " '- . . PNC BANK, NATIONAL ASSOCIATION CONSUMER DISCOUNT COMPANY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. STEWARD H. HARTMAN, JR., Mortgagor and Real Owner NO. 2000-07824 Defendant IN MORTGAGE FORECLOSURE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Leon P. Haller and Purcell, Krug ~ Haller as attorney for Household Finance Consumer Discount Company, in the above captioned action. PURCELL, KRUG & HALLER BY'~ Le n P. Haller 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Plaintiff Dated: July 26, 2001 ~ , ~'. ,,_", ,'_'.,,-, _,' '_ _-.'_0- _ ~. .~, ~,-~ " ., . . PNC BANK, NATIONAL ASSOCIATION CONSUMER DISCOUNT COMPANY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. STEWARD H. HARTMAN, JR., Mortgagor and Real Owner NO. 2000-07824 Defendant IN MORTGAGE FORECLOSURE RESPONSE OF HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY TO PLAINTIFF'S EXCEPTION TO CUMBERr.AND..COUNTY SHERIFF'S SCHEDULE OF DISTRIBUTION AND NOW comes Household Finance Consumer Discount Company ("Household") by its attorneys, Leon P. Haller and Purcell, Krug & Haller, and represents as follows: i Household takes the ~osition that the Sheriff's Schedule of Distribution is correct. The judgnl~mt in this case had not been amended nor had a Petition for Reassessment of Damages been filed. Accordingly, plaintiff is stuck with receiving its judgment amount plus interest at the rate of six (6%) percent from the date of judgment. See Chase Home Mortqaqe Corp. v. Good, 537 A2d 22 (Pa.Super. 1988). See also Union National Bank v. Cionqoli, 595 A2d 179 (Pa.Super. 1991). WHEREFORE, it is requested that the Plaintiff's exceptions be dismissed. Dated: July 30, 2001 ~C~L'R Xeon P. aller '---- 1719 North Front Street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Household Finance Consumer Discount Company :!\ . . . CERTIFICATE OF SERVICE I, Leon P. Haller, hereby certify that a true and correct copy of the foregoing Response of Household Finance Consumer Discount Company to Plaintiff's Exception to Cumberland County Sheriff's Schedule of Distribution was forwarded to the following individuals by regular U. S. Mail, first class service, postage prepaid, on July 30, 2001, addressed as follows: Philip G. curtin, Esquire Philips, Curtin & DiGiacomo Suite 300 1211 Chestnut Street Philadelphia, PA 19107 Dated: July 30, 2001 1 I 1 I I ,I - ~ ,""" --,L,. o"H,-,-,:,. ,,,,,,,_.~',, ,., "__~,, '~_'~ "',~, _ ..<., ____0 ,,,_I _" . ,_. .~ i: i- fi i , , " l! " , n I: 11 , i~ i [, i I, i: I I i I I I , I ), --,,~ r ;^ , " II II ,I I! . PNC BANK, NATIONAL ASSOCIATION VS. STEWARD H. HARTMAN, JR. MORTGAGOR AND REAL OWNER CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 2000-07824 P PRAECIPE FOR JUDGMENT Enter judgment in favor of Plaintiff and against Defendant Steward H. Hartman, Jr. (only) for want of an Answer. (X) Assess damages as follows: Principal of said mortgage debt due and unpaid Interest from 11/25/99 to 10/13/00 at 10% per annum ($3.56967 per diem) Foreclosure search Late Charges Appraisal Attorneys fees (which are reasonable, authorized under the mortgage and/or actually incurred by Plaintiff as provided in S 406(2) of Act 6 of 1974 (41 P.S. S 406(2)) AMOUNT DUE $ 13,029.31 1,156.57 250.00 30.00 150.00 $ 800.00 $15,415.88 Interestfrom 10/14/00 to 01/26/01 @ 10% ($3.56967 per diem) $ 374.82 Costs expended: Prothonotary - complaint Sheriff Postage TOTAL 45.50 100.00 3.56 $ 149.06 $15,939.76 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I CERTIFY THAT A COpy OF THE NOTICE REQUIRED BY PA R.C.P. 237.1 WAS SERVED UPON DEFENDANT STEWARD H. HARTMAN, JR. BY FIRST CLASS MAIL POSTAGE PREPAID ON DECEMBER 14, 2000. A TRUE, ~,N,D~," ,,0 CT COPY OF SAID NOTICE IS ATTACHED HERETO AS EXHI~"./?t;/ ~ \ . 'JATTO NEY OR LAINTIFF LOUIS J. DiGIACOMO - 1.0.#03866 AND NOWJdo.2<T ,2001, judgment is entered in favor of PNC Bank, National Association and against Defendant Steward H. Hartman, Jr. (only) by Default for want of an Answer and damages assessed at the sum of Fifteen Thousand, Nine Hundred and Thirty-Nine Dollars ($15,939.76) and Seventy-Six Cents as per the abov ertification. .. I PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS VS. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER I 401 E COOVER STREET i MECHANICSBURG, PA 17055 I II TO: STEWARD H. HARTMAN, JR., I 401 E COOVER STREET \ MECHANICSBURG, PA 17055 I i 1 :NO. 2000-07824 P STEWARD H. HARTMAN, JR. C/O JAMES BACH, ESQUIRE 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 DATE OF NOTICE: DECEMBER 14, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE.IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (800) 990-9108 l EXHIBIT "A" PHILIPS, CURTIN & DiGIACOMO . i :""<l"~_ II,. - ~ "-,[~ ~, PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 VS. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 NO. 2000-07824 P AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA: SS COUNTY OF PHILADELPHIA: LOUIS J. DiGIACOMO, being duly sworn according to law, deposes and says that Defendant Steward H. Hartman, Jr. is not in the military or naval service of the United States of America as defined in Section 101(1) ofthe Soldiers' and Sailors' Civil Relief Act of 1940, and further that: (a) Defendant Steward H. Hartman, Jr. is over 21 years of age, resides at 401 E. Coover Street, Mechanicsburg, PA 17055. v:? Sworn to and subscribed before me this 26th day " J NOTARIAL SEAL " MARY E. CURTIN, Notary Public City of Philadelphia, Phila. County L~~~n _E};pir~s _Sept. 14,2002 . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY P~OTHONOT"'RY To: STEWARD H. HARTl'f..AN, JR. 401 E. COOVER STREET MECHANICSBURG, PA17055 PNC BANK, NATIONAL ASSOCIATION CUMBERLAND COUNTY COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR. N 2000-07824-P o. NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary Ga Judgment by Default o ~oney Judgment o Judgment in Replevin o Judgment for Possession o Judgment on Award of Arbitration o Judgment on Verdict o Judgment on Court Findings IF YOU HAVE ANY ATTORNEY QUESTIONS CONCERNING THIS LOUIS J. DiGIACOMO, NOTICE, PLEASE CALL: Esquire (Insnr "ltom.,.' s NDm.J at this telephone number: (215) 563-7700 5-60 <21 (Rn. .I7Bl :'"~, ~ 'C . ~" - ,1!!;",~~_."",'I!!!!:ml ~ ~-' ,.,., 'w ~ ~ (Q f? :-() ~ li::. ri:. 8 [lC\~~) r (i' .:j F l ~ ~ :e - f' ~ ~ ~. , .~." ~'"" MlI~-~m,~'!I''lJ1l';m'f ...,."..J!,,_ (') ~ -rJ CD lT1n, ~p~ cn;~' -<~ Gl:, ~c~ ~(-"" ..1-'>- '-- z: :::.2 . T--'.- U!!!fl!r~l,_"",.,~_",o,,., <::> o 'Tj <.- :::: ,"'- ..,., r-::: .-:~,:; f=.q ;""iX- .~.:-! C.J ~~ ""-> 5:J .-< r" ID &-0 ."',.- .-- t:2 :.n ,,' ,- ,..,~ PHILIPS CURTIN & DI GIACOMO BY, LOUIS J. DiGIACOMO, ESQUIRE IDENTIFICATION NO. SUITE 300 1211 CHESTNUT ST REET ATTORNEY FOR 03866 PHILADELPHIA, PENNSYLVANIA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 VS. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS DIVISION TERM, No. 10 - 7t6;).'/ ~ CIVIL ACTION - MORTGAGE FORECLOSURE "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 this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further nolice for any money claimed in the complaint or for any other claim or relief requ<ast<ad by th<a plainti11. You may lose money or property or other rights important to you. "YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOt) CAN GE"f LEGAL HELP. CUMi3ERLAND COUNTY BAR ASSOCIATION 2 LIBERrY AVENUE CARLISLE, PA 17013 1-800-990-9108 "AVISO "Le han demand ado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias, de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demand as en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. "LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SEAvrCIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ASSOCIACION DE L1CENDIADOS DE FILADELFIA SEAVICIO DE REFENCIA E INFORMACION LEGAL One Reading Center FlIadelfia, Pennsylvania 19107 Teleifono: (215) 238-1701" II 1. The Plaintiff is PNC Bank, National Association organized under the laws of the United States of America with its registered office at PNC Bank, National Association, Consumer Loan Center, 2730 Liberty Avenue, Pittsburgh, PA 15222. 2. Defendant Steward H. Hartman, Jr., the mortgagor and real owner of the premises described in Paragraph 5 below, resides at 401 E. Coover Street, Mechanicsburg, PA 17055. 3. On August 8, 1996, Steward H. Hartman, Jr., executed and delivered a mortgage upon premises hereinafter described to PNC Bank, National Association, which mortgage is recorded in the Recorder of Deeds of Cumberland County, Pennsylvania in Mortgage Book 1337, Page 109 on August 20, 1996 which mortgage is incorporated herein by reference. 4. The said mortgage has not been assigned. !'j' 5. The premises subject to the said mortgage is 401 E. Coover Street, Mechanicsburg, PA 17055, as more fully described in Exhibit "A" attached hereto and made a part hereof. j::: ,'I 6. The said mortgage is in default because the monthly installments of principal and interest thereon due on November 25, 1999, and on the 25th day of each month thereafter are due and have not been paid and by the terms of the said mortgage upon 11 failure to make such payments when due the whole of said principal and all interest due thereon, together with all recoverable sums and attorneys fees is collectable forthwith. ~- "-,' , 7. The following amounts are due on the said mortgage: Principal of said mortgage debt due and unpaid Interest from 11/25/99 to 10/13/00 at 10% per annum ($3.56967 per diem) Foreclosure search Late Charges Appraisal Attorneys fees (which are reasonable, authorized under the mortgage and/or actually incurred by Plaintiff as provided in S 406(2) of Act 6 of 1974 (41 P.S. S 406(2)) AMOUNT DUE $ 13,029.31 1,156.57 250.00 30.00 150.00 $ 800.00 $15,415.88 8. The Combined Notice has been sent to the Defendant by regular and certified mail pursuant to the provisions of P.L. 1248 No. 160 (35 P.S. Section 1680 et seq.) on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 1692 et seq. (1977), Defendant may dispute the validity of the debt or any portion thereof. If Defendant does so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will "'I ~:i 'I il obtain and provide Defendant with written verification hereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, "~'I Counsel for Plaintiff will send Defendant the name and address of the original creditor if c: ~" .'l different from above. WHEREFORE, the plaintiff demands judgment against the Defendant in the sum of , ;:1 $15,415.88 plus interest from 10/13/00 to the date of judgment at the rate of 10% per annum ($3.56967 per diem) and costs and for foreclosure and sale of the mortgaged premises. " >', ~ : l I:! "'I ii i B COMO ~ i ':'1 ~,i ,'] ~'I , 2 . ,~ VERIFICATION I'Michael J. Emerling being an Officer of PNC Bank, National Association, and authorized to make this statement, hereby verify that the facts in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understands that the statements made herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsifications to authorities. Dated: 10 1231 00 PNC BANK, NATIONAL ASSOCIATION . , --:-"" ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos. 1 and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or formerly of James 1. Young; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to LotNo. 2, Block "B", at the point and place of Beginning. BEING Lot No.1, Block "B", in the Plan of Blackburn Village, as recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanicsburg, Pennsylvania. BEING Parcel No. 17-24-0789-010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H. Hartman dated 10/1/1986 and recorded 10/10/1986 in Cumberland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, PA 17055. EXHIBIT "A" - ~I ^~ -. (:OllSumer Loan Center ::i"JO Liben\" :henue I'irt5bur~h, P..\ 1 S:.::::: PNCBANK Date of this Notice: April 20, 2000 Steward II. Hartman Jr. 40 I E. Coover St. Mechanicsburg, P A 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help save your home. This Notice explains how the program works. To see ifHEMAP can help, you must MEET Willi A CONSUMER CREDIT COUNSELING AGENCY WITIIIN 30 DAYS OF THE DATE OF TIllS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The 1llllI1e, address and phone number of Consumer Credit Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGffiLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME: Steward H. Hartman Jr. PROPERTY ADDRESS: 40 I E. Coover St., Mechanicsburg, P A 17055 LOAN ACCT. NO.: 040-03-048006307249 ORIGINAL LENDER: PNC CURRENT LENDER/SERVICER: PNC Bank, NA EXHIBIT "B'I "-~- ^ " 1_ I , ~, Consumer Loan Center ~i30 Libem. .-\venue Pimbm:;h. P.\. 152~'2 PNCBANK HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGmLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGmILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face- to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TillS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOUMUST BRING YOUR MORTGAGE UP TO DATE. UIE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT', EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES --If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end ofthis Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. I :1 'I APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so. you must fill out, sign and file a completed Homeowner's Emergency Program Application with one of the designated consumer counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. EXHIBIT "B" ":~",,"'f "', < ~ I II Consumer Loan Center '2730 Liben\' Axenue Plltsbur~r;, P.1. 15~~2 PNCBANK AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings wiIl be pursued against you if you have met the time requirements set forth above. You will be notified directly by the pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you cau still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brinll it up to date): NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 40 I E. Coover St., Mechanicsburg, P A 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONIHL Y MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments in the amounts of$353.88 for each ofthe months from November 1999 through March 2000. Other charges (explain/itemize): Late Charges for $30.00 TOTALAMOUNTPASTDUE: $1,780.91 HOW TO CURE THE DEFAULT - You may cure the default within TIIIRTY (30) DAYS of the date of this notice BY PAYING TIlE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1,780.91, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIffi THIRTY (30) DAYS PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: PNC Bank, NA 2730 Liberty Avenue, 2'd Floor Mailstop: P5-PWLC-02-I Pittsburgh, PA 15222 :i ii Ii :i . IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within TIIIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rif(hts to accelerate the mortf(af(e debt. lbis means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within TIIIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortf(af(ed property. '; ~ i IF THE MORTGAGE IS FORECLOSED UPON - The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Uyou cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney fees. EXHIBIT liB" 1 " , .", _f ~'" ,~-, - . 1- ~ < Consumer Loan Center ~730 Libert\" .--\\"t:'nlle f'iltsbur~h. P.-l, I S~~2 PNCBANK OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE - If you have not cured the default within the TIllRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any tiIlle up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with Sheriff's Sale as specified in writing by the lender and by perfonning any other requirements under the Illortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSmLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six months from the Date of this Notice. A notice of the actual date ofthe Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. ~: HOW TO CONTACT 'fIlE LENDER: Name of Lender: PNC Bank, NA Address: 2730 Liberty Avenue, 2nd Floor, Mailstop: P5-PWLC-02-I, Pittsburgh, PA 15222 Phone Number: (412) 762-8994 or 1-800-878-0027 Contact Person: Joe Amoroso ['I f: 1i [: , v' EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. YOU MAY ALSO HAVE THE RIGHT: · TO SELL THE PROPERTY TO OeTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTI1UTION TO PAY OFF TIllS DEBT. · TO HAVE TIllS DEFAULT CURED BY ANY TIllRD PARTY ACTING ON YOUR BEHALF. · TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE TIIAN TIIREE TIMES IN ANY CALENDAR YEAR.) · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Very truly yours, EXHIBIT "8" cc: I ~ Class u.s. Mail, postage prepaid CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (see attached) Jacob Talton PNC Bank, National Association r't~~, ~ "_,~ . I I I' ~I I :i 1'1 " l' -~~"""'" CUMBERLAND COUNTY " URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717)234-5925 FAX #(717)232-4985 YWCA OF CARLn;LE 301 G. Street Carlisle, PA 17013 (717)243-3818 FAX #(717)243-3948 CONSUMER CREDIT COUNSELING SERVICE OF WESTERN P A, INC. 2000 Linglestown Road Harrisburg, P A 171 02 (717)541-1757 FINANCIAL SERVICES UNLIMITED 117 West 3rd Street Waynesboro, PA 17268 (717)762-3285 EXHIBIT liB" . - "" ,- 1-' , ~~ t .. ~ 0" i'Q "t3~a:~ '''' lii.. j'l!~ ~~ '15 .!!!:J: $ l6 ~ Olu. "" ~"6 ii,. go! ~5:B - '" 0" Jo;S oaf , ~ ~ i ~ ~ :s;: ~ .E ~ , ! 00 , . . " " '" ~ ~ . " " ,,~ ~g. ;e n~ ) 0 . ~ .~ ~~ ~~ 'm"';: "8"~.l'! :e~ -!o i~Gi 0:0_0 o DC ! 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'-< ~~^-, , ,," .~ _'''''''~ ~ '"~l,~,.,\""J"~!iE!J;Ri~!J!!'I'i'~'1i~li'!'I'1'~;"'__'J!"~"lr'ifJ!-;IJ!jI,,,,,fif!~1F<:'iI~'q',~<,""lljl');\1"<>:I!l'!!!W,-.J:~IH!:1;;1''',:";,,,-[,,,~._''''',,;;-,>;J''1!!'''i''''\~''''P>',!',",r'h,,]}@),~!'''':HiI~'''''__'qt:W~'''''''P,~-!'_<lP'''"'''il'-,!'<':i'-:"n~fg'l/,ill;'~\\'~ll~' '[ . PHILIPS, CURTIN & DiGIACOMO By: PHILIP G. CURTIN, ESQUIRE Identification Number: 52324 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 UBERTY AVENUE PITTSBURGH, PA 15222 'JUt 1 6 20iH tP Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P PLAINTIFF PNC BANK. NATIONAL ASSOCIATION'S EXCEPTION TO CUMBERLAND COUNTY SHERIFF'S SCHEDULE OF DISTRIBUTION SALE NO. 26 Pursuant to Pennsylvania Rule of Civil Procedure No. 3136(d) Distribution of Proceeds. Plaintiff PNC Bank ("PNC")is serving the following Exception on the Sheriff of Cumberland County for transmittal to the Prothonotary of Cumberland County and the Exception is as follows: GENERAL EXCEPTION PNC's central Exception to the Sheriffs Schedule of Distribution for Sale No. 26 is that PNC is not made whole for its first mortgage priority lien on the subject real estate at 401 E. Coover Street, Mechanicsburg, PA 17055. PNC protected its full lien in interest at the June 6, 2001 Sheriffs Sale by having local counsel John Ogden, Esquire personally appear at the Sale and bid up to $29,193.00. The Second Mortgagee Household Finance was advised prior to the sale that PNC would cease its bidding at $29,193.00 which PNC did and Household Finance began its bidding at that point and bid the property up until there was no more third party bidding to the final bid price of $71 ,000.00. At the final bid price of $71 ,000.00 Household Finance purchased the property as Second Mortgagee. The Schedule of Distribution for Sale No. 26 which is attached hereto as Exhibit "A" credits PNC's Writ Number 2000-7824 in the amount of $16,510.00. This is the Judgment amount plus costs but the Judgment amount is $10,573.44 deficient. The actual principal mortgage balance at the time of Judgment was $23,602.75 not .;''P'=1ll'f'.1IIll ~ 'II Ii I Ii ,.,~,.,.,.~,~,~ $13,029.31 as listed on PNC's Complaint in Mortgage Foreclosure. It is PNC's position that Second Mortgagee Household Finance is in no way prejudiced by this Exception since they were formally advised prior to the June 6, 2001 Sheriffs Sale of PNC's total and correct lien amount and were formally advised at the Sheriffs Sale of PNC's correct lien amount when local counsel for PNC bid the property up to $29,193.00. In fact, Household Finance requested and received PNC's final bid price prior to the Sale so it could calculate its final bid which was never reached by a third"party bidder. If the Schedule of Distribution is allowed to remain Household finance would be unjustly enriched to the detriment of PNC. Attached hereto and marked Exhibit US" is a true and correct copy of PNC's computer print-out statement on this mortgage account. This mortgage statement reflects the correct principal and interest amount due and owing at the time of Judgment and was the amount used to calculate our final bid price at the Sheriffs Sale of June 6, 2001 of $29, 193.00 and was the amount provided to Second Mortgagee Household Finance prior to and at the Sale of June 6, 2001. WHEREFORE, PNC respectfully requests that the Schedule for Distribution Sale No. 26 be amended to include PNC's correct first mortgage priority lien in the amount of $26,512.70. Respectfully submitted, P LIPS, CURTIN & DiGIACOMO BY: '''6~ PHILI G. CURTIN, ESQUIRE Attorney for Plaintiff, PNC Bank, National Association Dated: -:r(f) / () I " . ., .,JIMII!IIIlI I' , ~y~, , I I [, Ii i 'I " II " "'-',~I~..- VERIFICATION PHILIP G. CURTIN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~~ PHILIP G. CURTIN, ESQUIRE DATE:~ ,"- ., "1 1!\111!11!1 1-1 -" SCHEDULE OF DISTRIBUTION SALE NO. 26 Writ No. 2000-7824 Civil Term PNC Bank, National Association VS Steward H. Hartman, Jr. 40 I East Coover Street Mechanicsburg, PA 17055 Date Filed - July 6, 2001 Sale Date - June 6, 2001 Buyer - Household Finance Consumer Discount Company Bid Price - $71,000.00 Real Debt Interest Writ Costs " i', I Total $15,939.76 464.1 0 106.20 $16,510.06 DISTRIBUTION Amount Collected Legal Search Sheriff s Costs Credit Writ No. 2000-7824 Civil Term Credit Writ No. 2000-6377 Civil Term Total Ii I !' I, '-I Refund of Advance Costs I"~ _,I c,~"'-~~ ~,- $72,620.00 200.00 2,229.18 16,510.06 53.680.76 $ 0.00 $ 1,000.00 ~o.An~ ~ ~ -,,- -<: ~ ~ --e;;. lU' R. Thomas Kline, Sheriff BY q~Snifth Real Estat Deputy EXHIBIT itA" ,'. " ~ ,. II r-I TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 26 Held Wednesday, June 6, 2001 Date: June 6, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000inclusive.. Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: ListedUnder Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2001, and recorded ,2001, in Cumberland County Deed Book ,Page RECITAL: BEING the same premises which Jayne C. Hartman and Steward H. Hartman, her husband by Deed dated October I, 1986 and recorded October 10, 1986 in the office of the Recorder of Deeds in and for Cumberland County in Carlisle, Pennsylvania in Deed Book "F", Volume 32, Page 795 granted and conveyed to Steward H. Hartman, Jr. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accnrate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of 30 feet wide Chestnut Street and 30 feet wide Coover Street 6. Conditions, easements and restrictions shown on or set forth on the Plan of Lots in Block "B" of Blackburn ViUage recorded in Plan Boom 5, Page 26. 7. Mortgage in the amount of $25,000.00 given by Steward H. Hartman, Ir. to PNC Bank National Association dated August 8, 1996 and recorded August 10, 1996 in Mortgage Book EXH\BIT "A:' ~~o, " c~ < -11 "11- 1337, Page 1092. , Complaint in Mortgage Foreclosure filed by PNC Bank National Association as Plaintiff against Steward H. Hartman, Jr. as Defendant in the Office of the Prothonotary of Cumberland County to file no. 2000-7824. Default judgment entered January 29, 200 I in the amount of $15,939.76. 8. Mortgage in the amount of $75,999.69 given by Steward H. Hartman, Jr. to Household Finance Consumer Discount Company dated July 29, 1997 recorded August 4, 1997 in Mortgage Book 1397, Page 593. Complaint in Mortgage Foreclosure filed by Household Finance Consumer Discount Company as Plaintiff against Steward H. Hartman, Jr. as Defendant in the Office of the Prothonotary of Cumberland County to file no. 2000-6377. Default judgment entered March 12, 2001 in the amount of $89,969.89. 9. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $1,390.24 at the time of the Sheriff Sale. 10. Rights granted to Pennsylvania Power and Light Company and Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 148, Page 268. 11. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 12. Real estate taxes accruing on and after July 1, 2001 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding Hous.eBiII 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. .-L1 Ro ert G. Frey, Agent Note: This Title Report shall not be valid or bin until countersigned by an authorized signatory. EXHIBIT IlA" "',,,~- ~- ~ n - REAL ESTATE SALE NO. 26 Writ No. 2000-7824 Civil PNC Bank. National Association vs. Steward H. Hartman, Jr. Atty.: Louis J. DIGiacomo ALL THAT CERTAIN piece or par- cel of land situate In the Borough of Mechanicsburg, County of Cumber- land and State of Pennsylvania, more particularly bounded and described as follows, to Wit: BEGINNING at a point on the North side of East Coover Street (50 feet Wide), at the division line be- tween Lots Nos. 1 and 2, Block "B" , of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 m1nutes West along said division line. 145.94 feet to land now or for- merly of James L. Young; thence along said Young land. South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street. South 17 degrees 41 minutes East. 131.07 feet to a point; thence along a curve to the East hav:i.p.g a radius of fifteen (IS) feet. an arc distance of 23.44 feet to a po:lI1t on the North side of East Coover Street; thence along the North side of East Coover Street. North 72 degrees 48 min- utes East, 60.12 feet to Lot No.2. Block "B". at the po:lJ1t and place of Beginning. BEING Lot No. I, Block "B", In the Plan of'Blackbtun Village, as re- corded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanics- burg. Pennsylvania. BEING Parcel No. 17-24-0789- 010. TITLE APPEARS to be vested In Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Stew- ard H. Hartman dated 10/1/1986 and recorded 10/10/1986 In Cum- berland County In Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg. P A 17055. EXHIBIT "A" ~"PJt-~ .~ " " --> Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, says on April 16, 2001 at 6:45 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Steward H. Hartman located at 40 I E. Coover St. Mechanicsburg, Cumberland County, Pennsylvania, according to law. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 12:52 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Steward H. Hartman Jr., by making known unto James Bach, power of attorney, at 352 S. Sporting Hill Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 12:52 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Steward H. Hartman Jr., c/o James Bach, esquire, by making known unto James Bach at 352 S. Sporting Hill Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to the within named defendant to wit: Steward H. Hartman, Jr. by regular mail to his last known address, 401 E. Coover St. Mechanicsburg, PA. This letter was mailed under the date of April 19, 2001 and returned to the Sheriffs Office on 4/30/01 with forwarding time expired. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to the within named defendant to wit: Steward H. Hartman, Jr. by regular mail to his power of attorney, James M. Bach, at his last known address, 352 S. Sporting Hill Rd. Mechanicsburg, P A. This letter was mailed under the date of April 30, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given, he exposed the within described premises at public venue or outcry at The Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock A.M., EDST. He sold the same for the sum of$71,OOO.OO to Attorney Carl Ledebohm for Household Finance Consumer Discount Company, it being the highest bid and best price received for the same. Household Conswner Discount Company of961 Weigel Drive, P.O. Box 8604, Elmhurst, lL 60126, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $72,620.00. Sheriffs Costs: Docketing Poundage $ 30.00 1420.00 EXHI BIT "A" ~, . ~W"," Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Legal Search Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed 15.00 15.00 30.00 10.00 .50 1.00 15.50 1.06 15.00 20.00 200.00 307.25 272.28 25.09 25.00 26.50 $2429.18 paid by Attorney Terrence McCabe 7-06-01 Sworn and subscribed to before me This Day of ,,S,o,A,!?rs: ~~ I'-~-'~~ _ - A R. Thomas Klin , Sheriff BY Qtt~ Jmd;A Real E ate Deputy 2001, A.D. [~'ll\,~,,", , _'~' ", EXHIBIT I4A" , ~ 1_1 ~" THE P A TRIor NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation 'organized and eXisting under tbe iaws of the Commonwealth of Pennsylvania, with its principal office and piace of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of I.lli Patriot-'News and The Sundav Patrlnt-Newsnewspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesafa; that The Patriot-News arrd The SundaY- Patriot-News were established March 4th. 1854, and September 18th, 1949, respectively, and all have been continuousty published ever since; That the printed notice or publication which is securely attached hereto Is exactly as printed and published in their regular daiiy andlor Sundayl Metro editions which appeared on Ihe 24th day(s) of April and the 1 st and 8th day(s) of May 2001. That neither he nor said Co'mpany is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as 10 the time, place and character of publication are true; and That he has personal knowiedge 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 duiy recorded in the office for the Recording of Deeds in, an'd for said County of Dauphin in ~jscellaneous Book -.M", Volume 14, Page 317. (1 ,. '-/.- " ...............................,.....r.......H............................"......................... Sworn to and. subscrib&dbefore me ;?J.s9st day o~-a 2?9A.D. N~t,",,1 Stal l::7 t~ U\uSll'Oll, Not.~ PtlbIic }' ;; .,;::' l<<y~==__~2002 'NOTA PUBLIC ~~r..fperrf~~)~tll;wI,4)\~ My commission expires June 6, 2002 PUBLICATION COPY SALE 1126 .. ~ P. \ , ;'.is:J.:hi~..., l\' , ,;::,)rt~(;11i ~ _0 ". . tJi\:Jf~"'< , . ~ ~ A&l1l:YAt..-ti'fAiN~ ff ~ ~r p<in:et ){land sil}!atr'inr tii~ tforoll of ~fecttnotcsbV.~ )1 ClWiitt..Jr,:'i]l)1'bSJ-. <t:-.'Qll "SJlle.,,~. . MlI)W@'a~j'a;l"mo~,,1'~thcUl~~y ~ou~~e4 ~p,d \ c:t~aioro <IS folfows. to. Wit., ~ f.2<'-" I BEyiNNl&G .1. pofnl on Ihe Noith~idp'or",,1 coover ~I -, (Sured Wid'), .1 $e iiiWon line b. ..~ ;Nos.nnifl:~lll&Ii'B"Of.lhe , ~e-ilf""a-pr'-"I'-f ~ tbenc~ .~.... .,......I,!'~,O..'~tninTI?e.s:':~est-:~on 'SiIi.d .No ees - ,_ - . .~._.""'._ "g--,[ . ~\~~?,/~,~~;eli!~4.,po\f;or,!s.rmtl~~ Of: a ngrtf!en. . ~e 4foil.f! ': ~)fa~ng I~n. ~: SOt!_ _,' e"h..~..~i~'~r,~Yf.~!B1:~~r\o tn~lr t;frPpt thf1ntE' ~l\onir:tlie 'F--'l~ ,SIde of CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 270.78 1.50 272.28 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News. and The $un9~v Patriot-News n>>wspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By..................... ...... ....~..nn.... ..... ................... EXHIBIT IIA" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 5&7, approved May 16, 1929), P. 1.1784 STATE OF PENNSYL VANIA : ss, COUNTY OF CUMBERLAND : Roger.M. Morgenthal, 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 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 ofthe said Cumberland Law Journal on the following dates, VIZ: APRIL 27, MAY 4,11, 2001 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 26 I Rater M. Morgenthal, Editor Writ No. 2000.7824 Civil PNC BaDk. National Association vs. Steward H. Hartman. Jr. Atty.: Louis J. DiGiacomo ALL THAT CERTAIN piece or par- . eel of land situate 1n the Borough of Mechanicsburg. County of Cumber- land and State ofpermsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet Wide). at the division line be- tween Lots Nos. I and 2. Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees ,,.. __"___"-__ "11~~" ,,1,......... ^~~N A.......ir..'r"l SWORN TO AND SUBSCRIBED before me this 11 dayof MAY. 2001 NOTARIAl. SEI\!. !.(l,$ E. s....'YDI".:R, HoiaIy Pul!Iil: ~,&m ~ CllIlIlIy , MyCmm~: ~'Mlm:i! 5, 2005 EXHIBIT "A" ,-''';;,r;,,,,~,_,,,, _~~, ~ .~'^'''''I\!I _ '"1"",w,,' rlfl r" Philip Curtin Fro= Lynn Stacey Rothenberg Sulljed: S. Hartman 40-3-48006307249 PNCBANK Dote: 7/12/1 reL: (412) 762-l3l7 Below is a picture copy of our financial screen of the above account in questions. The amount in red is the actual principal balance in question. PYF ACLS OKDM PAYOFF DATA INQUIRY LROT 07//2/01 13:43 CFN NFN DIS 00040 003 000000048006307249 NXT ..... CUR R E NT..... PAYOFF: 24,587.37 GOOD THRU: 07/12/2001 NEXT : DOILAR/DA: CLS DATE: INT DATE: 03/01/2000 INS DATE: 03/0112000 MINIMUM: PENALTY : FRONT FEE: TO PROjECT PAYOFF... ENTER DATE: REASON: _ LOG HISTORY: PAYOFF: COMMENT: " . BALANCE : INTEREST: INSURANCE: LATE CHRG: RESERVE : EXTENSION: DUE GOV'T: RECUR FEE: EXPENSES: NOTE DAT: STOP/INT: INS: DLR: PAST DUE: 23,602.25 768.70 94.60 30.00 08/13/1996 2,094.23 SHORT NAME: HARTMAN S TYPE : 456 STATUS : REC CD: 3 STOP ACC: 2 ACC CD: II DIRECT: D REBT CD: DELAY: TERM: DAY/BASE: I REPAY: I SPLlTIER: RATE/APR: .10000 NOTE AMT: SCHED BL: DUE DATE: II/25/1999 DUE AMT : 353.88 COILATL: 048oo6307249A EXHIBIT liB" , .,. ~ ,- r" " . lff~lliO:~IilffiluIlOfu<I~""~'<)''''_''''';E''"":_i;ili,h'''!-J"'(m,~:m&.;,~~iiI!ij"""",,,.b."","-"',,-U-k:,,-,j!.c"-,,-,,'.d$;:~:"':';;~~' "'"'o,;",,,,"'_'::'Oi'{,J!.!-"~_(;'&"',,,:/lli.All1ll1il1j!!li!lMi(X~R~(ft:';;'I~----',,"_i"'''''~""'lw~~~JI!:r!i1.illii.~lIjji.imilllll.I.*lijjllll..lIiilllllili..lillllllll!il$I." OFrlur CU.l'" '~IF 'j :'! :Ir: 0;-' 1'-" '.,: ,0.'"'dFF . (:;)l'~TY JUL 13 IQ 21li!1 '01 ."-: "" ',- ;-. PEr"i;-f'~~\-'I! V , ,..,} I ~ "ni,'--\ r-,. <:,~ r:~ L-'.' ,. ("",_I ~) -'-} n ._~",,_~,J ~ _ ~ , > -" ~-~~. ',~ ,- " PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-07824 P vs. STEWARD H. HARTMAN, JR. Defendant o R D E R AND NOW, this J.~,J day of o~ , 2001, IT IS HEREBY ORDERED in accordance with the Motion and Stipulation attached thereto, the Sheriff's Schedule of Distribution shall be amended to provide that PNC Bank, National Association, be paid $21,510.06 and Household Finance Consumer Discount Company be paid $48,680.76. The Exceptions to the Sheriff's Schedule of Distribution shall be marked as withdrawn. J COrl~ n-.'cltbt'-b ~ CudrJu ~ JJm IO!J.~/O/ rUua.Jilly Q,ooU -b tf./.t .JJ~Uuk c4!cc /O/-UY61 ~ ;,~.. ',--'}-"'''''' _ ,C , ~ < ~, (~W:ii""""-. , ..:m.jil<llllW ~JI ~~ if~~;J!oSiffl!Iio!M~~.~-->" '-,,-,. .. J;ail:!l)W~ - .""..........'"..-."<!ll ~ l:jLt:I)-'{)I=rJCE ,y -, d- "."",..., '''''''''')TIRY l.i:" j :"-1.: ~.-, "_"I < '-'-:'_)11.:;" I,i\ 01 OCT 22 Pr\2:07 CUMBEFii..Ar'JD COUNTY PENNSYLVANIA tIT. PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-07824 P vs. STEWARD H. HARTMAN, JR. Defendant CONSENT MOTION TO SETTLE AND APPROVE STIPULATION PERTAINING TO OBJECTIONS TO SHERIFF'S SCHEDULE OF DISTRIBUTION AND NOW comes HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY (hereinafter "Household") by its attorneys, Leon P. Haller and Purcell, Krug & Haller, and represents as follows: 1, On July 6, 2001, following Sheriff's Sale of property held June 6, 2001, the Sheriff of Cumberland County had filed a Schedule of Distribution (copy attached hereto and made a part hereof as Exhibit "A") wherein Plaintiff is scheduled to receive the sum of $16,510.06 and Household to receive $53,680.76. 2. On or about July 12, 2001, Plaintiff, PNC Bank, National Association, excepted to the Sheriff's Schedule of Distribution. 3. Household filed a response, claiming that the Sheriff's Schedule of Distribution was correct. 4. The parties have agreed, pursuant to original Stipulation attached hereto and made a part hereof as Exhibit "B", that the Sheriff's Schedule of Distribution be amended as follows: (a) PNC Bank, National Association, will be paid $21,510.06. (b) Household will be paid $48,680.76. -~c ~ .,-, ",' - ",.".,. _ _ "~"":,,,,,'_~,,','''''''"' ' , '"-"" /~ ~- -, ,_'.'_" . c_, >'-1 ..: " 'f-- ",", , _ L___ . ><_, -, ' , J WHEREFORE, it is requested that Order be entered directing distribution in accordance with the within Motion. PURCELL, KRUG & HALLER BY:~ ~ P. Haller 1719 North Front street Harrisburg, PA 17102-2392 (717)234-4178 Attorney ID #15700 Attorney for Household Finance Consumer Discount Company Dated: October 17, 2001 - 2 - ,,-"'~ , , '''_~__, " ,_ c_ ",-, _, _', _" , ~, '" - I' ,';' - ,,-, ;,~ --.""" '" .-, " _ ~ ~~-- --- - VERIFICATION I, Leon P. Haller, counsel for Household Finance Consumer Discount Company, hereby verify that the facts contained in the Motion to Settle and Approve stipulation pertaining to Objections to Sheriff's Schedule of Distribution are true and correct to the best of my knowledge, information and belief, based upon the information provided by my client, Household Finance Consumer Discount Company. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. L~ Dated: October 17, 2001 ." '=, ,,,. h_~", ", ", ,,_ ,<. - -' ~,-,,~"/, "- ,~;, , ,. 07/19/01 /' , 13:12 ' MCCRBE,WEISBERG&CONWRY,pC ~ 717 234 1206 . NO. 857 (;>13 SCHEDULE OF DISTRIBUTION . SALE NO. 26 . l-./l/~O ~~ ^ 0 ~.\D . \ \n \)\)\} 1\\ I'\)(\X. 0~ Date Filed - July 6, 2001 Writ No. 2000-7824 Civil Term PNC BlIIIk, National Association VS Steward H. Hartman, Jr. 401 East Coover Street Mechanicsburg, P A ) 705S Sale Date -June 6, 2001 Buyer - Household Finance Consumer Discount Company Bid Price - $71.000.00 - Real Debt Interest Writ Costs Total $15,939.76 464.10 106.20 $16,510.06 DISTRIBUTION AmOUllt Collected . Legal Search Sheriff's Costs Credit Writ No. 2000-7824 Civil Term Credit Writ No. 2000-6377 Ci>>il Tenn Total 572,620.00 200.00 2.229.18 11 u 16,510.06.. p~~ . 53.6110:76 .;: ,J?L $ 0.00 I Refimd of Advance Costs $ 1.000.00 . So An~~s.:....- ~~ -c~U' R. Thomas Kline, Sheriff .. fN~ f: ~! <h, ()h~ e,I,'4YJ BY Q~ Snit t:tL Recl1 Esta Deputy. EXHIBIT "A" , ;,&-,~ - - -- ,- . ,~-- , r , .~ II " 'I I i , PHILIPS, CURTIN & DiGIACOMO By: PHILIP G. CURTIN, ESQUIRE Identification Number: 52324 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P STIPULATION It is hereby stipulated and agreed by and between Philip G. Curtin, Esquire, attorney for Plaintiff PNC Bank ("PNC") and Leon P. Haller, Esquire, attorney for Household Finance Consumer Discount Company, ("Household"), each having expressed authority to enter into this stipulation that: 1. PNC will Withdraw its Exceptions to the Sheriff's Schedule of Distribution filed in connection with the June 6, 2001 Cumberland County Sheriff's Sale. 2. In consideration of PNC Withdrawing its Exceptions and foregoing its pursuit of additional legal remedies Household hereby agrees to file a Motion to Amend Sheriff's Schedule of Distribution with a proposed Order reducing Household's Distribution by Five Thousand ($5,000.00) Dollars and increasing PNC's Distribution by the same Five Thousand ($5,000.00) Dollars. IN WITNESS WHEREOF, the partie through their counsel, hereby sign this Stipulation: PHILI G. CURTIN, ESQUIRE Attorney for NC Bank, National Association Dated: ( C/ / I (lZ,1 LEO . HALLER, ESQUIRE Attorney for Household Finance Consumer Discount Company EXHIBIT "B" 'O!,_~._. '" I r~ 'I - >ll . ;"-,,, ~ -"'~ " 7"" C,-~_' "WMW""iI1n'"I'"l!J 0 a C 0 -o~ ::::> "q li1r~ C') ,. , 2-~.-~ -I - :"2J :;? -', (i5 :l::' I'~"'f j'$ <,:: 0.) i.:;} ..;;;:-t.::' :~~,~ :!~ ~> , Zl---:; .::3;-; !? ., );r) " c~ co s;~ 2: c'5 .".' :;! '~..0 -. . ,,)..'- <..J ex) -< ^, ,~:lIl'1I~ll'1!fiW~~II-ffi""''llj1'''lIij!;"tl-~'!\li1!;'Ef~<i',",I"ni'q{WJrw,r~~,'f~.'l!liit,*j,';lI;m",",1>~>'!~".--,t~~~,"\~'f"'\;''''',,,,p;'r~W''''1,W_Rji;!iillli!Wfflti'!'~~''''!\''{it.f'>'U"''''''''-,!,''l'::'''i'i~F'~'~~'''''''~'''4~~'{f: STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _____________________________________________________.________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ______n________ Household Fianace consumer'Discount Co ------------------.--------.--------------------____________________________________ ~ thegr.antee 6th the same having been sold to said grantee on the ---___________________________n_______________ day of June' 01 . n______.____________n_______n________ A. D., r ___n' under and by virtue of a wriL_____________ Execution . 13th n__________________________________n_n_____n ISSued on the ___________________n_______n____n_ March A 01 . . day of __________________________ . D., _n__' out 01 the Court of Cornman Pleas of saId County as 01 Civil 2000 -------------------------- ----".-- ----- n_ _____ __ __ _______ _____ ____ ____ n__ n _____ Tenn, : Number _______L!!.~L, at the suit of m___~~~_.!l_~~~_!:._~m__m_______________~_______________m_ Steward H Hartman Jr ------------------ ------------- -- -- against_ --- -___ __ _____ _ __ _____ ____ ____ ____ ____ ______ _______ is 248 4438 duly recorded in Sherifrs Deed Book No. ___n_n____' Page u____u____. IN TESTIMONY WHEIlEOF, I have hereuuto set my hand and seal 01 said office th~ _____<3_1:.__ day 01 ------__Q.~_________n_ A. D., ,;LO 0 I __~--J}-~~;;~ ~~~h.,..,/!IrmIt;~.. 1Ilt",.....,..._ :(\~_!Ill ~" -'.< .", --< - ~ ^ .~ 1'-- " , .. PNC, National Association VS Steward H. Hartman, Jr. In the Court of Common Pleas of Cumberland County, Pennsylvania No.2000-7824 Civil Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, says on April 16, 2001 at 6:45 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Steward H. Hartman located at 401 E. Coover St. Mechanicsburg, Cumberland County, Pennsylvania, according to law. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 12:52 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Steward H. Hartman Jr., by making known unto James Bach, power of attorney, at 352 S. Sporting Hill Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on April 18, 2001 at 12:52 o'clock PM EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Steward H. Hartman Jr., c/o James Bach, esquire, by making known unto James Bach at 352 S. Sporting Hill Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to the within named defendant to wit: Steward H. Hartman, Jr. by regular mail to his lastknown address, 401 E. Coover St. Mechanicsburg, P A. This letter was mailed under the date of April 19 , 200 I and returned to the Sheriffs Office on 4/30/01 with forwarding time expired. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a pendency of the action to the within named defendant to wit: Steward H. Hartman, Jr. by regular mail to his power of attorney, James M. Bach, at his last known address, 352 S. Sporting Hill Rd. Mech'jITicsburg, P A. This letter was mailed under the date of April 30, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given, he exposed the within described premises at public venue or outcry at The Court House, Carlisle, Cumberland County, Pennsylvania, on June 6, 2001 at 10:00 o'clock A.M., EDST. He sold the same for the sum of$71,000.00 to Attorney Carl Ledebohm for Household Finance Consumer Discount Company, it being the highest bid and best price received for the same. Household Consumer Discount Company of961 Weigel Drive, P.O. Box 8604, Elmhurst, 1L 60126, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $72,620.00. Sheriffs Costs: Docketing Poundage $ 30.00 1420.00 ~",,,~,,,=~., _ T.... " '. l-t -'- Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Legal Search Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed , 15.00 15.00 30.00 10.00 .50 1.00 15.50 1.06 15.00 20.00 200.00 307.25 272.28 25.09 25.00 26.50 $2429.18 paid by Attorney Terrence McCabe 7-06-01 ~~~"'<A?". R. Thomas Kline, ~eriff ./ BY~~ Real Es te Deputy Sworn and subscribed to before me This ~ Day of m&h/ 2001, A.D. 0r. a M';;w,14' - ~~""""""''''J!~~ ~ ~~ 30' ~ \, 1-1 2,t./4 I ~ .lfJ>l ~I . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEA!...JH OF pENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7824 CIVIl1ljX TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due PNC Bank. National Association PLAINTIFF(S) from Steward H. Hartman, Jr., 401 E. Coover Street, Mechanicsburg, PA 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description : ":1; '; ~ ~. . ' , . r. .Ii~~l ~~ ~~inrl' )~. u ,"j, i :(', i ;~f~? _.'~M""""""-""",~~_"_ --.-' (2) You are also directed to attac,~~!~~(~roP~~~~f.t~e,~~fe~~:~,~(~~,\~~: IWJ,d ~~~~~tMlJ.Imsion of .';" "( ~.:~;'--; "o.r.':,: " GARNISHEE(S) as follows: and to nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other thana named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Atty's Comm Atty Paid Plaintiff Paid % L.L. Due Prothy Other Costs $.50 $1.00 Amount Due $15,939.76 Interest from 1/27/01 $106.20 Date: March 13, 2001 Curtis R. Long Prothonotary, Civil Division ~Q~ 0 2. ~D/?/~) Deputy REQUESTING PARTY: Name Louis J. DiGiacorro, Esq. Address: Suite 300, 1211 Chestnut Street Philadelphia. PA 19107 Attorney for: Plaintiff Telephone: 215-563-7700 Supreme Court ID No. 03866 ~",l","","H"O,,,,,,,:..,," ",,~ --- , -~~- III .. fll ~, REAL ESTATE SALE No. :20 JfI ~ 10; JOG I the snentt levied upon the defenua, : , Interest In the real property situated in1JWzj.ul//1J..fL4iJcI?} t!J4i'(}(/#V 6umberland County, Pa., known and numbered as: /.fO! liisf (bv<!.A Jf. ~UCsb()(}and more tully described on ExhftJit "A" flied with this writ and 'bY 1IIIt.18fnnce iftCOrpOrated henIIn. _:711 ~ 15; 2aJ/ By: 9dt Svy.iA .0 ~U7lSlLuu16 ~6 c.,\\~ . ~ ,,\ ).,~.,,'~-5: ':J .....\ 1\\\ ...(,~" f,\ ll.'"tt- . ~~ \J~ ~.\.. ..'i;",~e~O \l\ ~, ./...'.:\,:> \U' .'. <};:"!I~ ~. v;",\lj;;~ 1>"''\. ~9-"'?~ _ ~ _ _",}r~~~~';1jJ~-~J'J__ , ~.".,' ~~"..,_~~.!(r.'~l!I!i~...... _~-1Ii _~PJ~"i.ffi"M,;;m""""lff!':_"""''''''R''!'f7j~,-~')j'!!~;'''''~~~l'*f''~''l''W!\[WN>!~~I'flID~~rrJfl!ll!!flt' '""~ (;""oJ c;:;:jl c;:;;] = (5!) liW 'i!,--~'..... "" SCHEDULE OF DISTRIBUTION SALE NO. 26 Date Filed - July 6, 2001 Writ No. 2000-7824 Civil Term PNC Bank, National Association VS Steward H. Hartman, Jr. 401 East Coover Street Mechanicsburg, PA 17055 Sale Date - June 6, 2001 Buyer - Household Finance Consumer Discount Company Bid Price - $71,000.00 Total $15,939.76 464.1 0 106.20 $16,510.06 Real Debt Interest Writ Costs DISTRIBUTION Amount Collected Legal Search Sheriff s Costs Credit Writ No. 2000-7824 Civil Term Credit Writ No. 2000-6377 Civil Term Total $72,620.00 200.00 2,229.18 16,510.06 53.680.76 $ 0.00 Refund of Advance Costs $ 1,000.00 SOAn~ ~ - ."..r;.(lt:p~ . R. Thomas Kline, Sheriff BYC}(J~ Jvijfj,. Real Estate Deputy --,," . 'I 'I r. ]. TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 26 Held Wednesday, June 6, 2001 Date: June 6, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive. Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2001, and recorded ,2001, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Jayne C. Hartman and Steward H. Hartman, her husband by Deed dated October I, 1986 and recorded October 10, 1986 in the office of the Recorder of Deeds in and for Cumberland County in Carlisle, Pennsylvania in Deed Book "F', Volume 32, Page 795 granted and conveyed to Steward H. Hartman, Jr. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of 30 feet wide Chestnut Street and 30 feet wide Coover Street. 6. Conditions, easements and restrictions shown on or set forth on the Plan of Lots in Block "B" of Blackburn Village recorded in Plan Boom 5, Page 26. 7. Mortgage in the amount of $25,000.00 given by Steward H. Hartman, Jr. to PNC Bank National Association dated August 8, 1996 and recorded August 10, 1996 in Mortgage Book "':'R>I ~ , _",e_ 'I: ""4 L 1337, Page 1092. Complaint in Mortgage Foreclosure filed by PNC Bank National Association as Plaintiff against Steward H. Hartman. Jr. as Defendant in the Office of the Prothonotary of Cumberland County to file no. 2000-7824. Default judgment entered January 29, 2001 in the amount of $15,939.76. 8. Mortgage in the amount of $75, 999.69 given by Steward H. Hartman, Jr. to Household Finance Consumer Discount Company dated July 29, 1997 recorded August 4, 1997 in Mortgage Book 1397, Page 593. Complaint in Mortgage Foreclosure filed by Household Finance Consumer Discount Company as Plaintiff against Steward H. Hartman, Jr. as Defendant in the Office of the Prothonotary of Cumberland County to file no. 2000-6377. Default judgment entered March 12, 2001 in the amount of $89,969.89. 9. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $1,390.24 at the time of the Sheriff Sale. 10. Rights granted to Pennsylvania Power and Light Company and Bell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 148, Page 268. II. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 12. Real estate taxes accruing on and after July 1,2001 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. .il Ro ert G. Frey, Agent Note: This Title Report shall not be valid or bin until countersigned by an authorized signatory. 1i:,~ ,_" "'_." ,_ _ >-"" i< " .. , , .. . , ,. REAL ESTATE SALE NO. 26 Writ No. 2000-7824 Civil PNC Bank, National AssoCiation vs. Steward H. Hartman, Jr. Atty.: Louls J. DiGiacomo ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Mechanicsburg, County of Cumber- land and Slate ofPennsylvanla. more particularly bounded and described as follows. to wit: BEGINNING at a point on the North side of East Coover Street (50 feet Wide), at the division line be- tween Lots Nos. 1 and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or for- merly of James L. Young; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet. an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 min- utes East, 60.12 feet to Lot No.2, Block "8". at the point and place of Beginning. BEING Lot No.1, Block "B", in the Plan of-Blackburn Village. as re- corded in the Cumberland County Recorder's Office in Plan Book 5. Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street. Mechanics- burg. Pennsylvania. BEING Parcel No. 17-24-0789- 010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Stew- ard H. Hartman dated 10/1/1986 and recorded 10/10/1986 in Cum- berland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, PA 17055. C{,,_,~ ~~,~ Ii """" ~ II " ')- " [ PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300,1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO. 2000-07824 P 3129.1 AFFIDAVIT STATE OF PENNSYLVANIA: SS COUNTY OF PHILADELPHIA: LOUIS J. DiGIACOMO, ESQUIRE being duly sworn according to law, deposes and says that she is attorney for the Plaintiff herein and makes this affidavit for and on its behalf, being duly authorized so to do and avers as follows: The names and last known address ofthe real owner or reputed owner of premises 401 E. Coover Street, Mechanicsburg, PA 17055 is Steward H. Hartman, Jr., 401 E. Coover Street, Mechanicsburg, PA 17055. The name and last known address ofthe Defendant in the above captioned matter is Steward H. Hartman, Jr., 401 E. Coover Street, Mechanicsburg, PA 17055. Notice of Owner's Rights with respect to Sheriff's Sale has been delivered to the Sheriff of Cumberland County, and he is to served the Notice of Owner's Rights upon the owner by personal service; a true and correct copy of said notice being . ched hereto. .. /-/' ~' , ~ /. {.M..., / LOUI Sworn to and subscribed bef re me this tJf:rJay of 001. _N.'. .. NOTAAIALSEAL '~-'- l WIRY E. CURTIN, Notary Public City of Philadelphia, Phila. County - My Commission E}.;eirs~s Sa t. 14. 2002 ~ "' -1' ... 11 . " PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DiGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN GENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS vs. STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO.2000-07824P NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEWARD H. HARTMAN, JR. 401 E. COOVER STREET MECHANICSBURG, PA 17055 STEWARD H. HARTMAN, JR. C/O JAMES BACH, ESQUIRE 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 Your property at 401 E. Coover Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Friday, June 6,2001 at 10:00 a.m. in the Sheriffs office in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania to enforce the Court judgment of $15,939.76 PNC Bank, National Association obtained by PNC Bank, National Association, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to PNC Bank, National Association, N.A. the amount of the judgment plus costs. To find out how much you must pay, you may call LOUIS J. DiGIACOMO at (215) 563-7700. 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 2 on how to obtain an attorney). ,~~nr- ,~,~ . ,-',"''''''''', , .. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price by calling LOUIS J. DiGIACOMO at (215) 563-7700. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Sheriff's Office at (717) 240- 6399. 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 has never happened. 5. You have a right to remain in the property until the full arnount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on July 6,2001. 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 July 6, 2001. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (800) 990-9108 2 :;, ~ ~ _", _ _"I,f~ II =~ 1':0'39~d [17: n ',001': S.] "'~W " .... .r 1.1 ''t " PHILIPS, CURTIN & DiGIACOMO By: LOUIS J. DIGIACOMO, ESQUIRE Identification Number: 03866 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS VB, STEWARD H. HARTMAN, JR.. MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 :NO, 2000-07824 P NOTICE OF SHERIFF'S SALE Of= REAL PROPERTY TO: STEWARD H. HARTMAN, JR. 401 E. COOVER STREET MECHANICSBURG, PA 17055 STEWARD H. HARTMAN. JR. C/O JAMES BACH, ESQUIRE 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 Your property at 401 E, Coover Street, Mechanicsburg. PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 6, 2001 at 10:00 a.m. in the Sheriff's office in the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania to enforce the Court judgment of $15,939,76 PNC Bank, National Association obtained by PNC Bank, National Association, N.A. against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVE:NT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1, The sale will be canceled If you pay to PNC Bank, National Association, N.A, the amount of the judgment plus costs. To find out how much you must pay, you may call LOUIS J. DiGIACOMO at (215) 563-7700, 2. You maybe 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 2 on how to obtain an attorney). zel -d ,..-- . " " ,.. Wl:::I t:>Z:: 1: 1 l0-gt-'CIt::lW I, ~0'~:JtJd z?:,t 100e Sl ~~W . . . ... " . 'f'. ., tr. YOU MAY STILL BE ABLE TO sAVE You~ PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price by calling LOUIS J, DiGIACOMO at (215) 563-7700, 2, You may be able to petition the Court to sat aside the sale if the bid price was grossly Inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out If this has happened you may call the Sheriffs Office at (717) 240- 6399. . 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 has never happened. 5. You have a right to remain in the property until the full amount due Is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time the buyer may bring legal proceedings to evict you. 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on July 6, 2001. 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 July 6, 2001. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWTER AT ONCE. IF YOU DO NOT HAVE A LAWTER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (800) 990-9108 2 :::a-d W~ sZ=tt to-St-~~w ;\ ,,~-, -,-, ,~, ","'-" '--, I, ,- I 1,1, ~ . , . ~. I' .,. " ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos. I and 2, Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or formerly of James L. Young; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to Lot No.2, Block "B", at the point and place of Beginning. BEING Lot No. I, Block "B", in the Plan of Blackburn Village, as recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanicsburg, Pennsylvania. BEING Parcel No. 17-24-0789-0 I O. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H. Hartman dated 10/1/1986 and recorded 10/1 0/1986 in Cumberland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, P A 17055. . / -' , " ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the division line between Lots Nos. I and 2, Blook "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line, 145.94 feet to land now or formerly of James L. Young; thence along said Young land, South 72 degrees 48 minutes West, 76.23 feet to Chestnut Street; thence along the East side of Chestnut Street, South 17 degrees 41 minutes East, 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 minutes East, 60.12 feet to Lot No.2, Block "B", at the point and place of Beg inning. BEING Lot No. I, Block "B", in the Plan of Blackburn Village, as recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 401 East Coover Street, Mechanicsburg, Pennsylvania. BEING Parcel No. 17-24-0789-010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Steward H. Hartman dated 1 Oil/I 986 and recorded 1011 0/1986 in Cumberland County in Deed Book F 32 page 795. Commonly known as 401 East Coover Street, Mechanicsburg, P A 17055. :~._1'f11 ~,!I - '" Il .... r_ ' -...~,... 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 James L. Clark being duly SWorn according to law, deposes and says: That he is the Acounts Receivable Manager 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 Th e Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 24th day(s) of April and the 1 st and 8th day(s) of May 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, 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{iSCellaneous Book "M", V;~:~i;~::: ,;;;;~~;;;;;;;;;;;;t;;;;~~;,m;;;;;;;;;;m; SA L E #26 No\l~a'Seal 7/,' I- TtW;~. ~~",II, == l<\'V~r=.MIeU0ll2 NOTA PUBLIC ~.~~~IGit__ My commission expires June 6, 2002 . CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Totai $ 270.78 1.50 272.28 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... ~,~~1li'Il~ _,' ."" ,'~ . ""- ,.-. ". ~1:'::SlATt:SALENo,26- ~:;-~;o~r!f,lti;a7ll24 .. . PIlc:S,.\<, National ~ ~ _-----A&_~latlt:~!'~----- -'I-- u__ _.,.$tewardH.Hartman,Jr, =-'".~~~,~'- ~ --- ---- -'DESCRII"'1JuN "-- "- ALL THAT CERTAIN piece (If. parcel of land ~ate ~_ the BOT_O'-!rh, of MecnanksbUJg, e -DE Cumherral1.Q ~aru:l Stile .J1i ~n~l~ama. mro:e...part~cutanyoounaeCr-and -- =Jlescribe.us foJlo\\-'s, to\.'.1t: ~Gafapolntontlle Noitn side of East -COO\'erStre.el(50Ieetwi.del,at the division line hglween Lots. No.s. _1 and 4 Block NBN of the hereinafter. mentioned Plan of t.Qts; thence -.North ,17 degrees 12 minutes Wes.t along said ~!1h_1si9~J4l_~tJ~--,9~ ~~~ _tei land_ n~ orf5?~er!}-, ~P<iT_YQID)g;Jhtllc~n&~a_idYQung rand, ~1ith JJ- ~4.e8!:~e~ 4S minutes \Vest, 76.23 feet to. 3J1estiiU.[Sltee.l;.JhetlctL;no~lhe__E~&l side of __ ~CSJNe.l:-S6U1h 17 de~rees 41 minutes ~sUJ!]'Ife:eUo a point; fhence along a curve __ ~.<i.th~~A\iDg a radius o!Nt~~I1J15)_ ~et,_ an ~di5.Eanceot!t# feel ID_a-pOtnt 01'1 Hie Nonn 3icle ar--E'as[:<:oot'er Street; thence. along the NQrt)L.side of East Coover Street. North i2 ~~ 48,.minutes Eas-t. 6OJ2 feel to tot No. 2. ~~fiE':arffii;-pointind pra:ceomG~1NG, = BE!NGl1il No. L Block "B.... in the _Plan of ~ 61\d.h.lillL Village, as recorded in the Cumberland County R~oraer's Office in PI,m _ nook 5, Page 26. ::.HAVTh.TG tb,gr~Qn ~re~t~g_.u.ingle brick dwellil1g ~_ kn,QWl'L~SJ\O;,,_ #ll.i~R_C~:er__!ilice~ = Mechanicsburg. Penrisvl\~ijfa. - - - - ~ -,_RWGThrcclNo.1Zc&.0ib:1f-Q10. - =TI1l.E APPEARS_tQ_be. \'Csledilt_Stewilrd R , Fiajtrrwt. Jr. by Deed from Jayne C. Hartman and -Ste\\'Ma H. Hartman dated lO/1f1986 and ~t~_"f\QflQJ19%:il] ~~be~~~n;L(o~.!)~' in. "1!.OlBwI.'t2Z~19S. - ~i..-"li1@Jl,_arjlJ..,~rcoQ\:~r_ -~;- ~~l1alli~t~.~~ ~:;o~-~_---- _.. _ _~~ , . . " ,-1 . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe 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: APRIL 27, MAY 4,11, 2001 Afliant 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. Rok~al, Editor SWORN TO AND SUBSCRIBED before me this 11 day of MAY. 2001 " 'NOTARIAL'SEAl . LQIS E. SNYDER, NoIaJy Public CaIlisIe.Boro, CurnbeJiiIid COuntv , My CorIImlss/D11 Expns'MarchS, 2tlO5 ;"~";1!11!~~, = >, II ~" -" ~- ~ C' REAL ESTATE SALE NO. 26 Wrtt No. 2000-7824 Civil PNC Bank, National Association vs. Steward H. Hartman, Jr. Atty.: Louis J. DiGiacomo ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Mechan1csburg, County of Cumber- land and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side of East Coover Street (50 feet wide), at the dlvlslon Une be- tween Lots Nos. I and 2. Block "B" of the hereinafter mentioned Plan of Lots; thence North 17 degrees 12 minutes West along said division line. 145.94 feet to land now or for- merly of James L. Young: thence along sald Young land, South 72 degrees 48 minutes West. 76.23 feet to Chestnut Street: thence along the East side of Chestnut Street. South 17 degrees 4 I mJnutes East. 131.07 feet to a point; thence along a curve to the East having a radius of fifteen (15) feet, an arc distance of 23.44 feet to a point on the North side of East Coover Street; thence along the North side of East Coover Street, North 72 degrees 48 min- utes East, 60.12 feet to Lot No.2. Block "B", at the point and place of Beginning. BEING Lot No. I. Block "B". in the Plan of Blackburn Village. as re- corded in the Cumberland County Recorder's Office in Plan Book 5, Page 26. HAVING thereon erected a single brick dwelling house known as No. 40 1 East Coover Street. Mechanics- burg, Pennsylvania. BEING Parcel No. 17-24-0789- 010. TITLE APPEARS to be vested in Steward H. Hartman, Jr. by Deed from Jayne C. Hartman and Stew- ard H. Hartman dated 10/1/1986 and recorded 10/10/1986 in Cum- berland County in Deed Book F 32 page 795. Commonly known as 401 East' Coover Street, Mechanicsburg, PA 17055. ,,",' '-;>', .' r - PHILIPS, CURTIN & DiGIACOMO By: PHILIP G. CURTIN, ESQUIRE Identification Number: 52324 Suite 300, 1211 Chestnut Street Philadelphia, PA 19107 (215) 563-7700 PNC BANK, NATIONAL ASSOCIATION CONSUMER LOAN CENTER 2730 LIBERTY AVENUE PITTSBURGH, PA 15222 vs. j , : STEWARD H. HARTMAN, JR., MORTGAGOR AND REAL OWNER 401 E. COOVER STREET MECHANICSBURG, PA 17055 TO THE PROTHONOTARY: I I Attorney for Plaintiff :CUMBERLAND COUNTY :COURT OF COMMON PLEAS :NO. 2000-07824 P PRAECIPE Please satisfy the Judgment entered in the above-captioned matter upon payment of your costs. Dated:~ ~Rl _" ~ PHILIPS, CURTIN & DiGIACOMO BY:~~ PHILIP G. CURTIN, ESQUIRE Attorneys for Plaintiff, PNC Bank, National Association ;%i - ~~'''',~=.,.,.- - ~ -~-. ,-^ T .." "U. m- " ~lror C) :'::,.'1 C) C' ^;"j ~ l::J ,-,.~ '~'::i rnn z ", I ~~ ~~:~"- ,.0' G~~-~- ,'- ~f -, , -:-:1 :;<~ -,.,.. ~ ~~. ,,, :.( .1;:'" ~~I~~'""'''''~~"'1l'I1'~I'm;IW{jf>ti~%!'R''1fl'<j[>i'f--'''''''W,''-''''~''''_'''''-.~'r';!",--1';F>)%",,,,,.t,,,,,cTJ"'3P'_-f!';'_lfi:B~"4~~'\7i~~m;'i'i't'''''~FF,~-WI"";"i"~l']"Ri'!~*'lf'~rr_~~!~'",~",;,