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Home My WebLink About00-08426 --"~,,~~ I_~ ,',-,I , i ,'I ~l;" ,~ ~, I , ! BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENE;FICIAL MORTGAGE CO OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs, ACTION OF MORTGAGE FORECLOSURE 71.0, OV - ? I{:U" Cw:J { v-. RICHARD p, LONG AIKA RICHARD B. LONG AND BARBARA A. LONG Defendants TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims setforth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIrE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-249-3166 A VISO LE RAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO, PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA, RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUlR CON EL PROCESO SIN SU P ARTICIP ACION, ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300, CUMBERLAND COUNTY LAWYER REFERRAL SERVICE I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-249-3166 ""'" ,,,,.'~~r.t - . "', ," , f ,l "'W!ii., BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE RICHARD P. LONG NKJA RICHARD B. LONG AND BARBARA A. LONG Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 ns.c. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, P A 171 02 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff ~, ,__~,"L.,^ ~ ",I.~, "',,,,,,, olIIdl/;,J" ' BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs, ACTION OF MORTGAGE FORECLOSURE 7Zb. fJV - 1'1 :z r... CLvd I..R-<-- RICHARD p, LONG A/KIA RICHARD B. LONG AND BARBARA A, LONG Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA, is a Corporation, with an address of 961 Weigel Drive, Elmhurst, Illinois 60126, 2. Defendant, RICHARD P. LONG AlK/A RICHARD B. LONG, is an adult individual, whose last known address is 335 9TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. Defendant, BARBARA A. LONG, is an adult individual, whose last known address is 335 9TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. 3. On or about, March 5,1999, the said Defendants executed and delivered a Mortgage Note in the sum of $94,262.24 payable to BENEFICIAL CONSUMER DISCOUNT COMP ANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYL VANIA, which Note is attached hereto and marked Exhibit "A". 4, Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1525, Page 149 conveying to original Mortgagee the subject premises. The Said Mortgage is incorporated herein by reference. 5, The land subject to the Mortgage is: 335 NINTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. ~,-- " ,,'.I , - ,-. I" '",", '~"'~ '~""~ Ci. A-<iii~", 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July 1, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $85,000.00 Interest at $34.84 per day From 06/01/2000 To 1/01/2001 (based on contract rate of 13.494%) $7,455.76 Late Charges at $53.96 Per Month for 7 months $377.72 Attorney's Fee at 5.0% of Principal Balance $4,250.00 $97,083.48 **Together with interest at the per diem rate noted above after January 1,2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualifY for Mortgage Assistance. ~-"""r ~., - - ,,,",',I I", "I ,j ~ ";;'11 ' WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 13.494% ($34.84 per diem), together with other charges and costs including escrow advances incidental thereto e date of Sheriff's Sale and for foreclosure and sale of the property within described. By: PU L,KRUG HALLER Leon P. Haller, E ire Attorney for PI . tiff J.D. # 15700 ' 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) .~~ =~I ... , , "w'';;,,' .~ ~ 't _ LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 3) .' . 'LENDER (called "We", 'Us". "Our") BENEFICIAL CONSUMER OISCOUNT COMPANY O/B/A BENEFICIAL MORTGAGE CO'OF PENNSYLVANIA .. 4910 CARLISLE PIKE/i/l04 MECHANICSBURG PA 11055 BORROWERs (called "You", "Your") LONG. RICHARO P SS# 202421423 LONG, BARBARA. A SS# 355500905 335 9TH ST NEW CUMBERLND PA 11010 LOAN NO: 111114-506444 ~. EFFECTIVE DATE YOU ARE GIVING US A SECURITY INTEREST IN THE REAL ESTATE LOCATED AT THE ABOVE ADDRESS. REQUIRED INSURANCE. You must obtain insuranco for tet'~ of loan CO?OTi.ng soouri1)' for this loen as indicated by the word "YES" below, Daming us as Loss Payee: YES Title insurance on real estate security. YES Fire and extended coverage insurance on real estate seeudty. You may obtain any required insurance from anyone you choose and may assign any other policy of insurance you own to cover the security tor this 10811. (Se$ "Security" paragraph above for description of security to be insured.) N TICE: 10-17-98 RE SI 1ST MTG $50K . THE FOLLOWING PAG S CONTAIN ADDITIONAL CONTRACT TERMS. 'tiBt;ilA~.II.III1I. PABS580l ORIGINAL "",...." ",I - '~ "im;Ai--' . LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) '. PAYMENT. In return for your loan described below, you shall pay us the Amount Financed including the Fee (all shown on page one) pllllj Interest,in monthly payments as stated on page one. You may pay more at any time. You will pay at our business address or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement againSt all, or any, Borrowers, but not in a combined amount greater than the amount owed. Each payment will be first applied to Finance Charges at the Contract Rate shown on page one for the actual time unpaid and the remainder to your unpaid Principal. For purposes of computing Finance Charges, a month shall be considered any period of 30 consecutive Pays. , DATE ON WHICH INTEREST BEGINS. If you do not cancel this loan, the date on which Interest begins: payment dates, and effective datJ of insurance purchased are postponed by the number of days from this contract's date to date you receive this loan. I . , PAY-oUTS. You: agree to pay-outs of Amount Financed"as shown on Truth-In-Lending disclosure form. If pay-outs change because lokn closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to covbr additional pay-outs. I PREPAYMENT. You may prepay any or all of your loan at any time. If you fully pay before the final payment due date, the amount you oj.,e will be reduced by unearned credit insurance charges. . . I PREPAYMENT IlENALTY. If you prepay the entire outstanding balance.of your account at any time within five (5) years of ttie contract date, and your accoUllt is cancelled (including a releaSe of the Deed of Trust on your real estate), you agree to pay a prepaym'ent penalty equal to not more than 6 months advance daily interest (computed at the Contract 'Rate shown on page on~) on the unpaid balance as of the payoff date. No prepayment penalty will be imposed: (a) at the time this loan is refinariced by another loan with us; (b) for prepayment by proceeds of any credit insurance or acceleration after default; or (c) afte~ five years from the contract date. . ' LATE CHARGE.lIf you don't pay any payment in full in 10 days aft.. e' r it's due, you will also pay 5%of the unpaid amount of such payment: .. , ' I ..,--" ' , BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insuffi~ent funds or is otherwise disho*ored. Y ou'agree that we may deduct this charge (roma monthly payment. , , SECURITY. There is a mortgage on your real estate, located at your, address shown on page one unless a differenl'address is stated. You agree to give us a security interest ill the real estate as described in the MortgagelDeed of Trust. PROPERTY INS~RANCE: A. YOUR OBLIGATION TO INSURE. You shall keep the structures located on the real property securing this loan insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss payable endorsement. If inSurance covering the real property is cancelled or expires while the loan is outstanding and you do not reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in the real property as outlined below. B. LENDER'S RIGHT TO PLACE HAZARD INSURANCE. You authorize us, at our option, to obtain coverage on the Property in an amount not greater than the outstanding balance of principal and interest on the loan or,if known to be less, the replacement value of the Property, in the event that )Iou fall to maintain the required hazard insurance outlined above or fail,to provide ai:lequate proof of its existence. You autborize us to charge you for the costs of this insurance and a"d the iosurance charges to your loan. The Insurance charges will be added to the unpaid balance of the loan which accrues interest at the Contract Rate. The addition of the insurl\nce charges due might increase the amount of your final installment. The c<ist of Lender placed hazard insurance might be higher than the cost of standard insurance protecting the property. The Len~er placed insurance will not insure the contents of the property or provide liability coverage. The' insurance might not be the lowest cost coverage of its type available and you agree that we have no obligation to obtain the lowest cost coverage. We or an affiliated company might receive sOme benefit (I.e. commission,service fee, expense reimbursement, ew.) from the placement of this insurance and you will be charged for the full cost of the premium without reduction for any such benefit. If at any time after we have obtained this insurance, you provide adequate proof that you have subsequently purchased the required coverage, we will cancel the coverage we obtained and credit any unearned premiums to your loan. NOTICE: THE FOLLOWING pAGE CONTAINS ADDITIONAL CONTRACT TERMS. 10-17-98 RE SI 1ST MTG S50K + PAB65802 ORIGINAL III~IIIII! IIIIIIIIIII~~ IlIi Iml ~11111I1I~1I1~lllllllllllm 11I11~l!lm 11111 I~IIII"II~IIIII --~ ~ ~- L~ "J b......,. ~". ~\',:- LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) ... DEFAULT. If you don't pay on time or fail to keep any required insurance in force. or if permitted in the event of defaul! under the Mortgage, (1) all your payments may become due at once and, (2) without notifying you before bringing suit, we may sue you for the entire unpaid balance of Principal and accrued Interest and (3) any judgment in our favor may include our reasonable attorney's fee and court costs as determined by the, court. You agree that, should We obtain judgment againErt you, a portion of your disposable earnings may be attached or garnished (paid to US by your employer), as provided by Federal law. You agree to pay interest on any judgment at the Contract Rate. EXCHANGE OF INFORMATION. You underErtand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, includ.ing but not limited to credit reports and insurance information, with any of our affiliated corpora1iions, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request which contains your full name, Social SecurHy Number and Address to us at P.O. Box 8602, Elmhurst, IL 60126. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor VehiCles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. .' OPTIONAL INSURANCE. Optional Credit Insurances and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. .. APPLICABLE LAW. This loan is made at an agreed rate authorized by Section 501(a), Part A, Title V, Public Law 96-221, also known as SectiQrl 173f-7 (a), Title 12, United States Code (USC). This loan also may qualify as an "alternative mortgage transaction" under the Alternative Mortgage Transactions Parity Act Section of the Garn-St. Germain Depository Institutions Act of 1982, Sections 3801 to 3806, ,Title 12, use. ANY ADVANCE OF FUNDS PURSUANT TO TillS CREDIT LINE ACCOUNT AGREEMENT AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY DEF AUL T, RESULT IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS SECURITY FOR YOUR LOAN. YOU HAVE RECEIVED A COMPLETE COpy OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. (SEAL) (SEAL) (SEAL) WITNESS: ~~~ 10-17-98 RE $1 1 ST MTG S50K + PAB65803 ORIGINAL 1IIIIIIIIIIIIIIIIImlum ~~"~. "" ,,,~I o:L' '''"=;-.; " '.,' ,i;,i ' , --, ""~\,,,,::,.,:, ' , ,,',' , , ' ..,,,_:.::.:::.:.;:::;::.,;::::,;:,;.;;.c;.-'-___:,;,<::..,.''~,,.;~"_'''_...::~.,_....~~~,,'''~,~,;,,;..;>>,,:.;,~~~:~"',<l<'''-,.......;.;.8~,...~\,..~'''"-.-....':.c.'~'''''>3',.;,'' '. ALL THAT CERTAIN PROPERTY SITUATED IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF . PENNSYLVANIA. BEING MORE FULLY OESC~IBED IN,A FEE SIMPLE DEED DATED DB/30/1985 AND RECDRDED 09/03/19B5. AMONG THE LAND RECORDS,OF THE COUNTY AND STATE SET FORTH ABOVE. IN VOLUME L-31 AND PAGE 705, TAX PARCEL ID: 26-24-0811-218 10-01-98 MTD FilE COPY 111111111110111111 Olnlllll~llm~~III~II~ I~I ~III~~II ~~II~III~U~ ~I PA001251 ',- 0....,."... E"i 'bi~ .. .. 5 ,...;............... "~~ ;,;,,:1 "~ ~. q ~lll"~~' VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ':1 Date: December 4, 2000 .47 /' Leon P. Haller, Esquire ;'i ~",,,,,, ~_l ~~~,-,-~.."""""",, ; SHERIFF'S RETURN - REGULAR CASE NO: 2000-08426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DIS CO VS LONG RICHARD P ET AL DOUGLAS DONS EN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LONG BARBARA A the DEFENDANT , at 0013:25 HOURS, on the 7th day of December, 2000 at 335 9TH ST NEW CUMBERLAND, PA 17070 by handing to BARBARA A. LONG a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So .Answe~.: .. ~~ l.~ 11;.",e .. I :J". .. R. ~Thomas Kline , 01/08/2001 PURCELL, KRUG & HALLER Sworn and Subscribed to before fo me this .t.<I~ day of ~ ~I A.D. pO~~ othonotary By: (j) "'Ii Q,.,.. Deputy Sheriff " ~," I,' '..,,,1 I', i!Sl --~<lllo! SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-08426 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DIS CO VS LONG RICHARD P ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT LONG RICHARD P A/K/A LONG RICHARD B but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to , LONG RICHARD P A/K/A LONG the within named DEFENDANT RICHARD B DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, RECEIVED NO ADDL' INFO FROM KAREN PRIOR TO EXPIRATION DATE OF' 1/5/01. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 10.54 5.00 10.00 .00 43.54 S~~r~ R. Thomas Kline . Sheriff of Cumberland County PURCELL, KRUG & HALLER 01/08/2001 Sworn and subscribed to before me this .l'" '2 day of ~ ~ protlio otarf' ~,~ .....1 ; , . I 'c ~ .' "''''.....J~ ,~ '" --",,-",, ", ;, ,_L ;iiI\$.\:O '. BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff . ACTION OF MORTGAGE FORECLOSURE vs. RICHARD P. LONG A/KA RICHARD B. LONG AND BARBARA A. LONG 'J'&, 60, 'j'L/J-.e- ~ Ib- Defendants ~ TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgmeut may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE TIllS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. " CUMBERLAND COUNTY LAWYER REFERRAL SERVICE I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-249-3166 A VISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUlR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES, LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERV1CIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE I COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-249-3166 TRUE COPY FROM RECORD In TestImotly Whereof, I here ufltlJ $et my haM and the ~ of said C!)ll(l at Carlli>lfl. Fa, This j ~ ~y :!1'XJ), ~ - ~ .- . ('}'1-'- ,'~~:, j {f,c~ ~notary 1f; "I , 0' ~.,.""",' BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE RICHARD P. LONG A/KIA RICHARD B. LONG AND BARBARA A. LONG Defendants ~ THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debtis owed. Unless the Debtor, within thirty (30) days after your receipt Oftllis notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the jlndersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff ,,"-, , ~,I . . ~. s....,--, ,,.'.,,:', "~-'" BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW Ys. ACTION OF MORTGAGE FORECLOSURE RICHARD P. LONG A/KIA RICHARD B, LONG AND BARBARA A. LONG Defendants ~ COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA, is a Corporation, with an address of961 Weigel Drive, Elmhurst, Illinois 60126. 2. Defendant, RICHARDP. LONG AIKIA RICHARD B. LONG, is an adult individual, whose last known address is 335 9TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. Defendant, BARBARA A. LONG, is an adult individual, whose last known address is 335 9TH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. 3. On or about, March 5,1999, the said Defendants executed and delivered a Mortgage Note in the sum of $94,262.24 payable to BENEFICIAL CONSUMER DISCOUNT COMP ANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1525, Page 149 conveying to original Mortgagee the subject premises. The Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 335 NINTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. ,". '" ,,,I , j ~ '" ~"lIlib~"" 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on July I, 1999 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $85,000.00 ! i:l Interest at $34.84 per day From 06/01/2000 To 1/01/2001 (based on contract rate of 13.494%) $7,455.76 Late Charges at $53.96 Per Month for 7 months $377.72 i , el I 'I I i I :J i 'I: j ;1 i,1 :,' :,1 I , i:l ~ Attorney's Fee at 5.0% of Principal Balance $4,250.00 $97,083.48 **Together with interest at the per diem rate noted above after January 1,2001 and other charges and costs to date of Sheriff, s Sale. j i , i I 'i " " !:i 'I ';1 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in thatthe original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any . way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. II. The Defendants have either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. .,J , I , " '., """ WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for tlle aforementioned total amount due together with interest at the rate of 13.494% ($34.84 per diem), together with other charges -' and costs including escrow advances incidental thereto e date of Sheriffs Sale and for foreclosure and sale of the property within described. y/ .~' By: / PU L,KRUG HALLER Leon P. Haller, Es uire Attorney fof Plaif1.tiff J.D. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) ]'- .,',",-. ~ ~, II'Ik',","'; II .' . LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 3) c LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY DrBrA BENEFICIAL MORTGAGE CO OF PENNSYLVANIA ~ 4910 CARLISLE PIKE/#104 MECHANICSBURG PA 17055 BORROWERS (called "You", "Your") LONG. RICHARO P SS# 202427423 LONG, BARBARA A SSl! 355500905 335 9TH ST NEW CUMBERLND PA 17070 LOAN NO: 711714-506444 'lI" EFFECTIVE DA if YOU ARE G I V I NG US A SECUR /TY I NTEREST I N THE REAL ESTATE LOCATED AT THE ABOVE ADDRESS, REQUIRED INSURANCB. You must obtain. insural\oe for ter~ of loan covering securi1Y for this loan as indicated by 1hc word "YES" below, naming us 8& Loss P8Y~: YES Title insurance on real estaw security, YES Fire and extonded. covenge inSUr8D.CfS on real estate securhy. You may obtain any requ.ired insurance from Bnyono you choose and may assign any other tx>licy of insurance you own to cover the security for this loan. (See llSecurity" paragraph above for description of security to be insured.} 1~,...,~O:IC~ THE :,:~,"NG peiij;~1~;;;':;.:RMS PABS580\ ,.,~ .m.,r'~I,1i4I I" ",I ,~, ,~ ~."j~J " "~, .~'"'-'-"""W>..M,L , , LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for your loan described below, you shall pay us the Amount Financed including the Fee (all shown on page one) pllllj Interest, in monthly payments as stated <in page one. Vou may pay more at any time. You will pay Dot our business address or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a combined amount greater than the amount owed. Each payment will be first applied to Finance Charges at the Contract Rate shown on page one for the actual time unpaid and the remainder to your unpaid Principal. For purposes of computing Finance Charges, a month shall be consid~red any period of 30 consecuti ve ~ays. DATE ON WHICH INTEREST BEGINS. If you do not cancel this loan, the date on which Interest begins: payment dates, and effective dat~ of insurance purchased are postponed by the number of days from this contract's date to date you receive this loan. I , PAY-oUTS. You: agree to pay-outs of Amount Financed'as shown on Truth-In-Lending disclosure form. If pay-outs change because lo~n closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to cov&- additional pay-outs. I PREPAYMEr,T. rou may prepay any or all of your loan at any time. If you fully pay before the final payment due date, the amount you owe will be reduced by unearned credit insurance charges. . ' I . PREPAYMENT ~ENALTY. If you prepay the entire outstanding balance of your account at any time within five (5) years of tlie contract date, and your account is cancelled (including a release of the Deed of Trust on your real estate), you ~gree to pay a prepaym'ent panalty equal to not more than 6 months advance daily interest (computed at the Contract Rate shown on pageon~) on the unpaid balance as of the payoff date; No prepayment penalty will be imposed: (a) at the time this loan is refinartced by 1ll10ther loan with us; (b) for prepayment by proceeds of any credit insurance or acceleration after default; or (c) afte~ five years from the contract date. . , ' LATE CHARGE.11f you don't.. pay any payment in full in 10 days afte. r it's due, you will also pay 5% of the unpaidamount ohuch payment.,'. .. " . , ...., BAD CHECK CHARGE. We; will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise disho~ored. You 'agree that we m'ay deduct this charge from, a monthly payment. , , SECURITY. There is a mortgage on your real estate, located at your,address shown on page one unless a different'address is stated. You agree to give us a security interest in the real estate as described in the MortgageJDeed of Trust. ' PROPERTY INSl!RANCE: A, YOUR OBLIGA nON TO INSURE. You shall keep the structures located on the real property securing this loan insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss payable endorsement. If inSurance covering the real property is cancelled or expires while the loan is outstanding and you do not reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in the real property as outlined below. B. LENDER'S RI6HT TO PLACE HAZARD INSURANCE. You authorize us, at our option, to obtain coverage on the Property in an amount not greater than the outstanding balance of principal and interest on the loan or, if known to be less, the replacement value of the Property, in the event that you fail to maintain the required hazard insurance outlined above or fail,to provide aC:lequate proof of its existence. You authorize us to charge you for the costs of ,this insurance and add the insurance charges to your loan. The Insurance charges will be added to the unpaid b~lance of the loan which accrues interest at the Contract Rate. The addition of the insurance charges due might increase the amount of your final installment. The cqst of Lender placed hazard insurance might be higher than the cost of standard insurance protecting the property. The Len!ier placed insurance will not insure the contents of the property or provide liability coverage. The' insurance might not be the lowest cost coverage of its type available and you agree that we have no obligation to obtain the lowest cost coverage. We or an affiliated company might receive Beirne benefit (i.e. commission,service fee, expense reimbursement, etC.) from the placement of this insurance and you will be charged for the full cost of the premium without reduction for any such benefit. If at any time after we have obtained this insurance, you provide adequate proof that you have subsequently purchased the required coverage, we will cancel the coverage we obtained and credit any unearned premiums to your loan, '. NOTICE: TIlE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 10-17-98 RE SI 1ST MTG S50K + PAB65802 ORIGINAL Im~mmllmll~III'llllml~ -, ,.',',',";,.,,['" " , ..--I 1" 'J ,..~ __, ~"'" ~~< LOAN REPA YMENT AND SECURITY AGREEMENT (Page 3 of 3) ... DEFAULT. If you don't pay on time or fail to keep' any required insurance in force, or if permitted in the event of defauli under the Mortgage, (I) all your paymeots may become due at once and, (2) without notifying you before bringing suit, we may sue you for the entire unpaid balance of Principal and accrued Interest and (3) any judgment in our favor may include our reasonable attorney's fee and court costs as determined by the court. You agree that, should we obtain judgment against you, a portion of your disposable earnings may be attached or garnished (paid to us by your employer), as provided by Federal law. You agree to pay interest on any judgment at the Contract Rate. EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, includjng but not limited to credit reports and insurance information, with any of our affiliated corpora~ons, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request whicb contains your full name, Social Security Number and Address to us at P.O. Box 8602. Elmhurst, IL 60126. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you~ You agree that our supervisory personnel may listen to telephone calls between you and our repr~entatives in order to evaluate the quality of our service to you. OPTIONAL INSURANCE. Optional Credit Insurances and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ' APPLICABLE LAW. This loan is made at an agreed rate authorized by Section 501 (a), Part A, Title V, Public Law 96-221, also known as Section 173f-7 (a), Title 12, United States Code (USC). This loan also may qualify as an "alternative mortgage transaction" under tbe Alternative Mortgage Transactions Parity Act Section of the Garn-St. Germain Depository Institutions Act of 1982, Sections 3801 to 3806, Title 12, USC. . ANY ADVANCE OF FUNDS PURSUANT TO THIS CREDIT LINE ACCOUNT AGREEMENT AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY DEFAULT, RESULT IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS SECURITY FOR YOUR LOAN. YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. (SEAL) (SEAL) (SEAL) WITNESS: ~JN~ 10-17-98 RE 51 1ST MTG B50K + PAB55803 ORIGINAL 1111I1I1~1I1111111~IUllmllllmlll~ 1I1111111111WIIIIlIIIIIIIIIIIIIli IIIIIIIIIII~IIIIIIII l _ miillii - '1IIlIl!;1~ 1mI!l- -B'!o)l -!"JI~~~"M~~!~~~1i.~!1 w,,1 "~ ~''''''!~ . " " ~', "_ - k','" __"_ .-..,., " '- -~'~.. - ,,~'-" ,.'~ ',. ~'" -',.,.. . '. ~,..",..~,,,,-'~ ~'-"""'~;"" ,','" ~''''''~' ALL THAT CERTAIN PROPERTY SITUATED ~N THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA. BEING MORE FULLYDESC~IBED IN,A FEE SIMPLE DEED DATED 08/30/1985 AND RECOROED 09/03/19B5, AMONG THE LANO RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE. IN VOLUME L-31 AND PAGE 705, TAX PARCEL 10: 26-24-0811-218 10-01-98 MTG FILE copy 11I~11111~ 1IIIIInllllmlllll~m~m~~I~ln 1~11~~lIlm I~IIM WIII~ 111~Wlllllll PA001251 I: I" 1" i , !'; "--- ........... . ---.--,..:-".- EQ1i'bit '.6" -"" , ~ "I, ,'c ~', ~!Rlll~billiill.ki,' . VERIFICATION I, Leon P. Haller, Esquire, hereby swear and affirm that the facts' contained in the . foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: December 4, 2000 Leon P. Haller, Esquire 'u' ~,I ~'. _' ~^7 '." I'" '~ .liiilil.!>&_bl''''~''' , BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : NO. 00-8426 CIVIL TERM RICHARD p, LONG A/KIA RICHARD B. LONG AND BARBARA A. LONG Defendants : CIVIL ACTION - LAW : IN MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the complaint on the above captioned matter. DATE: February 9, 2001 PURCELL, KRU~ LER BY Leon P. Haller 1719 North Front Street Harrisburg, P A 171 02 Attorney for Plaintiff Attorney 10# 15700 .~ . , ~, SHERIFF'S RETURN - OUT OF COUNTY '- (. CASE NO: 2000-08426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DIS CO VS LONG RICHARD P ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LONG RICHARD P A/K/A LONG RICHARD B but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, pennsylvania, to serve the within COMPLAINT - MORT FORE 1st , 2001 , this office was in receipt of the On March attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge DEP. YORK CO 18.00 9.00 10.00 43.46 .00 80.46 03/01/2001 PURCELL, KRUG S R. Thomas~li~e ~ . ..... ,... Sheriff of Cumberland County & HALLER Sworn and subscribed to before me this ,j-tb day of ~ ~( A.D. 01~..a ~ r Prothonotar ~. " .~, ~c I" ~"t -" .'-;;... ~ .~ J!i,. '""t '''~j~ "~ COUNTY OF YORK . ... OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 . 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN Reins. Not & Complaint 1, PlAINTIFFISJ Beneficial Consumer Discount Co. 3, DEFENDANTISJ Richard P. Long, a/k/a Richard B. Long, et. al. SERVE { 5, NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC, TO SERVE OR DESCRIPTIOIj, OF PROPERT T . Richard P. Lonq, a/k/a Richard B. Lonq 6, ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO" CITY, BORO, TWP, STATE AND ZIP CODE AT 700 Salem ~ Rd, # 67, Etters, PA 17319 7, INDICATE SER~' "~P!"$!jlNAL or N IN CHARGE ~PUTlZE Currtbll;iIiiUIil\1il.d NOW L 11 'j/6l:1 .~. . _ 1.9 I, SHERIFF OF~ cqu P .. 'I:",...k COUNTYtoexe to law. Tills ~ -~.... , iIieIliIgll!lllllliil.at,* request and risk of the plaintiff. , 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: et. a1. POSTED 0 OTHER , e sheriff of cording NH Cumberlpnd Attempt 3 times and return to Cumberland Co. as per atty. PAID BY ATTY NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Arry depu1y sherifl levying upon or atlaching any property under wi1hin writ. may leave same wit/1out a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, withoutliabillty on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME AND ADDRESS of AlTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED Leon P. Haller /KLH, 1719 N. FRONT ST., HARRISBURG, FA 17102 (717) 234-4178 12. SENO NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). 2/14/01 14. Date Received 13. I acknowledge receipt of the writ or complaint as indicated above. J. LUDWIG 2/16/01 15. Expiration/Hearing Date 3/16/01 RESIDENCE ( ) POSTED ( ) POEt ) SHERIFF'S OFF ( ) SEE REMARKS NO because I am unable to locate the individual, company, corporation, etc, named above. RVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 22, REMARKS: (6oJ ~re.. A('~'';! ).0,1- fc,d'()'C('<) lC",)Y\ 6~1 f 16rt:- Co, 0<:> o 41. AFFIRMED and subscribed to before me this 26TH S 42. day of FEE 44. Signature of De . She jff 45. Signature of or County Sheriff R WILLIAM M. HOSE ~P:U 2/26/01 43, MY COMMISSION EX IR 50, I ACKNOWLEDGE R OF AUTHORIZED 1, WHITE - Issuing Autho ignature of Foreign un Sheriff URE 49. Date 51. Date Received en 5 Office 4. BLUE - Sheriff's Office -'C:;'~"",~ ~~ ~ "~"'~" . ~ ~ "'.'1 ~ ~ . . - ,- U1 I/O ~_~ )~w.;~~m~l ~,~~~,~,..,.~, 1I],~1JI.I!~~;;r.:~"$#.E-i-~:<!r~ '~."fub'i' i"j,i\;j*,!R'ii'1fi'~~"s!:Jj':!i'i~)~!tj-"" "F/(f 'i' ~'i'~',i\' , ,\ /!/,.... C r-" , f::./) '? v. . f Sf; '.,'/"/ [fI/r- '1\ p 'rf' " 11 I fe . ~) /)ril ,/ 7 Os """'~i'",'"'''' ": ~";''','' '"-'< ',"~' ~'~:'-::"H"" ~''''-I '~''f"I';.Ji'i~(.~'''i'*.;f~,,*~''' ,,' ~ , ~~',,;;,:''; COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., Y6RK, PA 17401 ").., SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETUf/i\1 I ' .", r- 1. PLAINTIFF/SI Be:lef5 r-:; 61' 3, D~FENDANT/SI Ric.r',3-;,~'C~ D.. C\)n:n1rw:::c,~ Dl_SCC'I.,'n'l- C (" t . Mor~ RoeirorecloslJre { 5, NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC, TO SERVE OR DESCR'PTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD, S. 6 ~~D'~~~~ ~~RE;T'OR '~~~nj;H B~f ~~~~R,~~~"'N~~ ~~, B~RO, ~~S+ATE AND Z'P CODE AT -ioo S;8'Len~ kT~ Rr]~ -# 67, E+--I:>?':-s? PA '731,S 7, .~, ~"Q....!Ill!1>>"'~ Q'~I!,I.l!e!l\\\~I'!GE l!iDEPUTIZ{~Um~~.'ilIlilI(! J 01STCUl.SS'<1"'I~ o POSTED J_;';e":>~;C ........ ....... >. . _, "!"~I,S~l'{JFFQCOU~TY,!,,A,dOher<;!l>ydl>p'utizethesheri~of ee.,;...e,c.';);:;';;, .::,..,: e..~/," ". : ....: ..' _ '.', "., COUNTYJpexecute thiS Wnt and mak.e return thereof accordmg t~rllW.'\iI!iilt;aIlf)iifil'trCilIl:lli!l'ng'lnadeaUtre'teque$tand risk Of the plaintiff. . '. XXX'\\( " SHERIFF OF.. ' COUNTY 8. SpeCIAL INSTRUCTlONS 'OR ,OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: C vm h e -; 1, a ,1 d '[,1'Ynq, a /k I B p.l(,~'?ld ,;, ,4 E', r ('n~J: et" a 'J, ~ F,;~,:,n',:: '" Not & CC'mnJaint' 0. OTHER ~,'~-;:e:.:;iT'rjt --; ti.mes 21nrl rei'vrn to Cumt)(0r1i.'Hltl (n. as per ai:tv.. PAlD BY A'TTt NOTE:'~ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying 'upon or attaching any property under within writ may leave same without 'a watchman, in custody of whomever is found in possession, after notifying person ,of levy or attachment, without liability on the part of such deputy or the sheriff 10 any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof 9. TVPE'NAME ANQ-AODRESS of ATtORN~/ORIGINATC>R,and SIGNATURE ~ '7, 10. TELEPHONE NUMBER 11. DATE FILED 'eon P" Ha]ler/KLH, 1719 N.\FRONT ST.,'HARRISBURG, P1\17102 in7! 234'"4178 12. seND NOTIC~OF SERVICE COPY TO. NAME AND ADDRESS BELOW: (This area must be completed if' notice is to be mailed). 2/1.4/'Y; SEE REMARKS 22, ReMARKS, P. l- I ,~. i' "i( I- J ~}' .t-c! I _" ,- ~ {,v "'~lll r \ I. "l y(,.i{ f I ,- I ..- , ~.",\...' }C{.JV, 41. AFFIRMED and subscribed to before me this 26TH 44. Signature o1....,..<)j ,#,7 De . Sheriff : /':;~l.-'~ t 45. Signature of i'Q~ CO,unty Sheriff~ J?OB: W/.r~LI1u\1 M~ 46. Signature of Foreign Coun'Stlerlff ~IGN"'T!lRE i;L ,~~ , sO' ANSWER. L. /'1 _ ID:'~ t i ,(,' r".\"~'\.-\,, " "'\'J I ;' , '/ t'i ) ,,/,,-, 47D'llo.)~ 3/.='/ 48. Date HOSE 2/26/01 49. Date 51. Date Received ,Sfj~rM~,bffrce tt BLUE - Sheriff's Office - "",,'~:'-'-~ ~~". .-"..- , " I." --'-' '.....- L 1..- 1iii,.1{" SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-08426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DIS CO VS LONG RICHARD P ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: LONG RICHARD P A/K/A LONG RICHARD B but was unable !;Q.c'Ylica'te Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE/REI 23rd , 2001 , this office was in receipt of the On March attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Dauphin Co 6.00 9.00 10.00 29.25 .00 54.25 03/23/2001 PURCELL, KRUG '~==:: R. Thomas Kli, Sheriff of Cumberland County & HALLER Sworn and subscribed to before me this J ,} tt.- day of ~ ~( A.D. Cf,/lL () IwdO,,-, ~~ Prothonotaty j,l "I ,-" ~ '. -JdUl!. 'f @ffitt of tq~ ~4~~iff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Ralph G, McAllister Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania BENEFICIAL CONSUMER DISCOUNT CO vs Connty of Dauphin LONG RICHARD P Sheriff's Return No.0561-T - -2001 OTHER COUNTY NO. 00-8426 AND NOW: March 13, 2001 at 1:30AM served the within COMPLAINT IN MORTGAGE FORECLOSURE upon LONG RICHARD P A/K/A RICHARD B. LONG to HIM by personally handing 1 true attested copy (ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at DAUPHIN COUNTY SHERIFF'S OFFICE, RM. 104 FRONT & MARKET STREETS HARRISBURG, PA 17101-0000 Sworn and subscribed to So Answers, Jf~ before me this 13TH day of MARCH, 2001 StrpIwnJ 6-. r+)aN4wJ ( Sheriff of Dauphin County, Pa. PROTHONOTARY By ~()/1/)~) Jill/~Ph) Deputy Sheriff Sheriff's Costs: $29.25 PD 02/26/2001 RCPT NO 146917 LS 4 ~-'~ Tr; . ....dn:rbe Court of Common Pleas of Cumberland County, Penn.sylvania Beneficial Consumer Discount Company, et. al. . h . VS. . R1C ard P. Long,et. al. Serve: Richard P. Long, a/k/a Richard B. Long No. 00-8426 Civil Now, 2/15/01 ,20 0 () , I, SHERIFF OF CUivfBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin COlll1ty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . .. ~K~~~-' Sheriff of Cum her land County, PA Affidavit of Service Now, , 20~, at o'clock M, served the . within upon at by handing to a copy of the original and made lmown to the contents thereof So answers, Sheriff of County, PA . ?O , - COSTS SERVICE MILEAGE AFFIDAVIT $ Sworn and subscribed before me this _ day of $ ',", -~ BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $34.84 from 6/1/00 to 1/1/01) Late charges ($53.96 per month to 1/01) 5% Attorney's Commission $85,000.00 $ 7,455.76 $ 377.72 TOTAL :;; 4,250.00 $97,083.48** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, By PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERlA\lONG.P ill!" ,~" "~:'nl~lIioiif.-w,~m',jM'i!JiOO!:ltQl~'1-~~'i.jjli"""i,"-"",rn'L,""",;!~,,;~,,'~,"<i...MiiI;!Ili.~i?c.1L ~'," '~i/rlii!l"'~"'~l~' ' .. ~., ,.... ~~ . W ~: V\ )(, IS .." I:, '() ~ ..! ^ " "~J,,,,,~,> "" <.~.. ~.,"""'[ . I., c \, fJ ~"" ' ~. k' ('" , lJ o b i ~ !r , ~ f. o - \:\) v, -:;, '" '; ;fJ J .. -() 't, , " ,~'~, ,. i .,1,_'">;,,;,,, "' '"'~.~'t~ I ) BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P.LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on rJ."'" /.z..:Mo I again t you in the the above- $97,083.48 and for the sale and foreclosure of your property located at: 335 NINTH STREET, NEW CUMBERLAND, PA 17070 Dated :C)111 ,_ /:?. ;Leo( ~ ;2 j;.. PROTHON~J; Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 K:\MKF\DOCS\CUMBERLA\LONG.N F'-"- ;' "J J ... ". ~~ ~~ c"":j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2000 8426 PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA, PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS TOTAL AMOUNT ,,/ OF JUDGMENT $ 97,083.48 Interest at $34.84 per diem to sale date $ 8,605.48 Late charges at $53.96 per month to sale da~e $ 377.72 Escrow Deficit $ 2,000.00 'TOTAL $108,066.68* *SALE DATE: WEDS. ,SEPT. 5, 2001 (PROTHONOTARY'S Plaintiff At torney Sheriff This Writ USE) (") ~ -00 rnni Z:7~,1 zc: ~~i !2,C )>0 :;?;Cl )>e: ~ C) ~;.~ '- ,-' ':""-! , r=- __,i',', -;2": ,,"":,':':) t"-"l , i.> -T, "'1 '~~f"~ :::., '10' ':0 -< ~,~ -" -". - ., :fl .-1 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution Date: June 11, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 in the above captioned .--;6 Leon P. Haller PA I.D. #15700 case. WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: SS To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 335 NINTH STREET, NEW CUMBERLAND, PA 17070. Gl~ t? ~~, L~ PROTHONOTARY/CL K' CIVIL DIVISION BY CJ"'h O. ~ , DEPUTY Date: , ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New cumberland, Cumberland. County, Pennsylvania, being bounded and described according to a survey made by Ronald S. Raffensperger, R.S., dated February 29, 1980, as follows, -to wit: . BEGINNING at an iron pin on the Northwesterly side of Ninth Street, 50 feet wide, at .the dividing line between Houses 335 and 337 Ninth Street; said point being measured 145.0 feet to Oak Alley, thence along the dividing line between 335 and 337 Ninth Street; North 47 degrees 00 minutes West, 100 feet to an iron pin on the Southeasterly side of an alley, 10 feet wide; thence along said alley, North 43 degrees 00 minutes East 22.50 feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; . thence along said di- viding line South. 47 degrees 00 minutes East, 100.0 feet to a point on the said side of Nilith Street; thence along said Ninth Street South 43 degrees 00 minutes West 22.5 feet to a point, the place of 13ECINNING. BEING the Eastern 13.5 feet of Lot No. 36 and the ~Iestern 9 feet of Lot No. 35 on the plan of Seven Maples No.1, as recorded in the Cumberland County Recorder's Office in plan Book 1, Page 94. HAVING THERERON ERECTED a dwelling house knOlm and numbered as 335 Ninth Stree.t. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated A~gust 30, 1985 and recorded September 3, 1985 in Deed Book L-31, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long. TO BE SOLD AS THE PROPERTY OF RICHARD P. LONG (A/K/A RICHARD B. LONG) AND BARBARA A. LONG ON CUMBERLAND COUNTY JUDGMENT NO. 2000 8426. PARCEL: 26-24-0811-218 IUllil9ll!ll!l~~~~~m;i-~d!l1MlW~W~~,"ilim&G:,Mrd;l""\\,,%,,-,,,~;,;,t.dli>rU!~_'" '"' ~. f~ ~ g l-.; "" ""' ju '<I , ,"',-~" <,~ _,;~~,'_"'~ ,J ~ ,., .I.""""",., ",....."..~ ' d ,~"~~"~' "..!!IB&:I1IIIiII ~ f(, "- v "- ,.- ~ l.~ '8 <> !.., , '" ,0 .. <:; '0"''-; @ "\ '^-." " r '!'- ",'",,0 I., , ~ j .. ~~:OD\ .'.2 'd ~ g ~ ~ "',,j""4!,',;'H'<,..\=.i.. ;j' =~ r; ,~ BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on MAY 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. -4 Leon P. Haller PA I.D. Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 By #15700 -':I I '"",: ' IIilliIiliii " " ''''l>Ialll!d~", A , BENEFICIAL CONSUMER DISCOUNT COUMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff Vs. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8426 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: May 21, 2001 TO: RICHARD P. LONG A/K/A RICHARD B.LONG 335 NINTH STREET NEW CUMBERLAND, PA 17070 RICHARD P. LONG A/K/A RICHARD B. LONG GIANT 130 OLD YORK ROAD NEW CUMBERLAND, PA 17070 BARBARA A. LONG 335 NINTH STREET NEW CUMBERLAND, PA 17070 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A lJ\.WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 By Leon P. Haller Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, PA 17102 717-234-4178 . . BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 335 NINTH STREET, NEW CUMBERLAND, PA 17070: 1. Name and address of the Owner(s) or Reputed Owner(s): Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Beneficial Mortgage Company 4910 Carlisle Pike Suite 104 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record " ~ ~ "1IW; < 4 lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falaifieation to authoritia". ~ Leon P. Haller .. PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 11, 2001 ~~_iiilm~~~ifu?10H,Ejj~~i!Ik~~~Z".,.&.:t~A,Ai~I''''<'t''r..,j;,'e'';N''~~';f;;I~lir' flfjjm IJIlliiliM.'~~'~''"'' !~,~,,;"H.tTD',', ",.J~,~~, A"~",,',_',,~=' 0__ ,~~ ..'<c."' e' ""1"",,,- '\'", ",~,,,I ",I ,", "~,_ L" . ""'~i"""'"" 2 ~ ;:{?fb 2r---. --,:: :ii 055 0<:"' ~~" ~,-,' Pc, <cc ~- ) .....c ~ .~ .~ " <::> c -q '- c:: ;--tl:: :'.' {\;, :}J ~'" ~~~:i~ '::::f h :i:J -:: _0" - - l&: - - , ^' ,_ ,0', <--'n '.....if.k" i . BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RICHARD B. LONG VS. P. LONG A/K/A RICHARD AND BARBARA A. LONG, DEFENDANTS CIVIL ACTION - LAW NO. 2000 8426 NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 IN MORTGAGE FORECLOSU~ C -~ ~. ""\':J(.rJ- fi-U',': ~ i~:'_~~ ~),". ~C} ~C "".0 .Y'C :::, -<. c:, ~. \_~ 'n ~ r:: ~z: ''.j--:-;-;: 'j '~ r....) - - !j~~ ::':,;",11 ~~~ ~:J ::<. y": TAKE NOTICE: :TI ('0 That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 335 NINTH STREET NEW CUMBERLllliD CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME(S} OF THE OWNER(S} OR REPUTED OWNERS of this property is: RICHARt> P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG ~," '.' = "l '. 'J > ~~ , A SCREDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days ot the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This .~"""-- ~-~- - ,,'" ~ , ".' "<,'0"--'", 0 '~__.",,,' . "I; 'iiI~ r petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 , ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland, Cumberland. County, pennsylvania, being bounded and described according to' a survey made by Ronald S. Raffensperger, R.S., dated February 29, 1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, 50 feet wide, at the dividing rine between Houses 335 and 337 Ninth Street; said point being measured 145.0 feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North 47 . degrees 00 minutes West, 100 feet to an iron pin on the Southeasterly side of an alley, 10 feet wide; thence along said alley, North 43 'degrees 00 minutes East 22.50 feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; thence along said di- viding line South 47 degrees 00 minutes East, 100.0 feet to a point On the said side of Ninth Street; tl;1ence along said Ninth Street South 43 degrees 00 minutes West 22.5 feet to a point, the place of BEGINNING. BEING the Eastern 13.5 feet of Lot No. 36 and the Western 9 feet of Lot No. 35 on the plan of Seven Maples No.1, as recorded in the Cumberland County Recorder's Office in plan Book 1, Page 94. HAVING THERERON ERECTED a dwelling house known and numbered as 335 Ninth Street. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated August 30, 1985 and recorded September 3, 1985 in Deed Book L-3l, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long. TO BE SOLD AS THE PROPERTY OF RICHARD P. LONG (A/K/A RICHARD B. LONG) AND BARBARA A. LONG ON CUMBERLAND COUNTY JUDGMENT NO. 2000 8426. PARCEL: 26-24-0811-218 '. " BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to-wit, this day of , 2001, upon consideration of the Plaintiff's Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED the posting of the Handbill on the subject premises at 335 Ninth Street, New Cumberland, PA 17070 by the Sheriff thirty (30) days before the Cumberland County Sheriff's Sale, the mailing of Notice by ordinary and Certified mail to the Defendant's last known address and the publication of the notice of the Sale of the subject premises as required are sufficient notice to the Defendant of the SeptemberS, 2001, Sheriff's Sale to satisfy the notice requirements of Pa. R.C.P. 3129.2; and, it is further ORDERED that the subject premises shall be sold-by the Sheriff of Cumberland County at the S:"Qtemb-"'E__"'Jn~~_l,nnSf1erg_f-'-"~.sale ... ~r../-.~ ....... ~) C1/1d .-t,cv~ .~ y}rG.- > .......~ I }./~.4' .., " ~ ::(Jjf!f&:'~~rd< ,OIIYfj~ d~ 0'3' :r~~-..~~?b .......... -t:L-i-LL.-L; ;Li.}h."..: rv A~ ~~ ~ !far i.... pv /~~ uJC:;1f/ III,..,. .jJJ~ tv~ nJ!-.!Lv 17 o...~ l'}1t!~W ',C:I'- : /-&td ~ /?). UJldi~~ '"...... ~... .--,... ',' ','" i BY ..t'~ "'~., ,J " - ,o~<, '~, _.__.~'~~ '. J BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129(b) (2) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Beneficial Consumer Discount Company, D/B/A Beneficial Mortgage Co. of Pennsylvania, through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against Certain property owned by Defendants located at 335 Ninth Street, New Cumberland, PA 17070. 2. Defendant Barbara A. Long was served with the Complaint, December 7, 2000 at the property and also served with the Notice of Sale July 9, 2001. Defendant Richard P. Long a/k/a Richard B. Long was served with the Complaint February 23, 2001, at the parking lot of the Giant Food Store located in New Cumberland, Pennsylvania. However, the Sheriff's office has been unable to serve Defendant Richard P. Long a/ka/ Richard B. Long with the Notice of Sale at the property, or at any new forwarding addresses for the Defendant. The plaintiff believes that the Defendant has no interest in the property and has no desire to oppose the Sheriff's Sale. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, the Department of Transportation, Credit Bureau, and also by attempting to obtain a phone number for the Defendant, but no new information has been received from any of the sources. 4. The Sheriff heretofore posted the Defendant's property with a Notice of Sale or Handbill. Notice of Sale was also sent by ~~ . ~ ~ ~ - ~"', >. ordinary and Certified mail. Sufficient notice has, therefore, been given to the Defendant. 5. Plaintiff believes that service by mail in accordance with Rule 430 (as allowed by Rule 3129(B) (2) (ii) (A) will be ineffective and that a Special Order of Court is required. 6. The Notice of Sheriff's Sale scheduled for September $, 2001 will be published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale. 7. Plaintiff requests an Order approving service by copy of the Notice of Sale or Handbill on the most public property under P.R.C. P. 3129. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. posting a part of the BY Leon aller Attorney for Plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 ", J O~,: '__~ -" i'o - ~ "'""-"M :&II'jc. '. BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in .".1 mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant Richard P. Long a/k/a Richard B. Long in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. The Defendant was not found at the address provided. X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listings. >"~ ~ ~ '" J" ~ ,. ~iIl,~,; '. x That he contacted TRANS UNION Credit Bureau, a national service, with respect to the location of the Defendant. Defendant was not found at the address provided. credit The X That he has conducted a search of the Pennsylvania Department of Transportation's records with respect to the location of the Defendant. Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. PURCELL, BY: Leon P 1719 North Front Harrisburg, Pa. (717)234-4178 Street 17102 Attorney for Plaintiff Attorney ID# 15700 Sworn to and subscribed before me on this C ~ day of ~ ' 2001 ~p~ (Notary) NOTARIAL SEAL SHARON P. DUNN, Notary Public City of Harrisburg Daupl:in County M C ml'ss'lon CVO'I"O '","" ," 1001 Y om ' u", ,Co ,~"':',,:' - - _0' '~ " ~~--",', "4., .". " Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS Richard P. Long a/k/a Richard B. Long and Barbara A. Long In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8426 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on July 9, 2001 at 3:54 o'clock PM EDST, he served a true copy of Real Estate Writ, Notice and Description in the above entitled action upon one ofthe within named defendants to wit: Barbara A. Long, by making known unto Barbara A. Long, at 335 Ninth Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states on July 9, 2001 at 3:53 P.M:, EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Richard P. Long a/k/a Richard B. Long and Barbara A. Long, located at 335 Ninth Street, New Cumberland, P A 17070, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 one of the within named defendants, to wit: Barbara A. Long, by regular mail to her last known address of 335 Ninth Street, New Cumberland, P A 17070. This letter was mailed under the date of July 31, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Richard P. Long a/k/a Richard B. Long, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice, Poster and Description, according to law. DAUPHIN COUNTY RETURN: I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, thatI made diligent search and inquiry for Richard P. Long a/k/a Richard B. Long the defendant named in the within Real Estate Writ, Notice, Poster & Description and that I am unable to find him in the County of Dauphin, and therefore return same NOT FOUND, August 10,2001. 3029 Locust St., Harrisburg, PAis a vacant apartment. Post Office has nothing on file. So answers: J. R. Lotwick, Sheriff of Dauphin County, PA. S9-MS~s: . r~;u""(IC~~ R. Thomas Kline, Sheriff B~()(~ }ATHc R al Estate eputy AK'''''" ,.......,,~~ I I " ' ~" ,,', 'i". '<!~" """, .' " . 455 Linden Street, Allentown, PA 18102 RR 3, Box 2025, Effort, PA 18330-1901 "'Allentown Office: 610-395-8741 Pocono Office: 570-992-2425 e-mail: mkrotz@earthlink.net >~. t:""':~ ,~ ~ CONFIDENTIAL ~NVESTIG~::rll4QJNS I Loss Prevention . Asset Searches'. Business Intelligence Insurance Fraud . Skip-Tracing . Missing Persons Background Investigations . Wttness InteNiewing Undercover Investigations . Personal Protection Pre-employment Investigations . SUNeillance Process SeNics . Litigation Support INVESTIGATIONS & lEGAl SUPPORT SERVICES s ~ Caption LONG To: BARB VILLARIAL Date: 08/28/01 Court Term GIVEN Your File No. NOT GIVEN CI Doc. No. 00-822 Known Information (Supplied by Client): t:=----- -~~;:! :~~~ S~' Lo~~=~:=~:=~~=:=:=-- I-;_~~~~~~~~~~~~===:::=-==::==- .---::::~:~~~:] "L___gi~Y!State/zit1__~~w CUMBEL~, PA 17070 ===1 i . ~~.j ---------,...-..,-.------- -----.-.--".--'-'--...'-,-------..-,-------...-----....-.-----1 I SSN: ! 202-42-7423 355-50-0905 i !_._...____.____.___._____1-_ ___.___________.__ __________.__ _ _.__"_"........"__~ INVESTIGATION REPORT Subject Identifiers (Obtained from Public Records) Investigation Sources Listed on Page 2 i:::-...---.-------~~CHARD-.P. LONG......--...-----.---rBARBAAA:'..A~.-LONG--...------.--------J D~C)_~~!_l?ecurity Number:" j 202 -42 -74 2 3-------------...-....-.-----l355~50~O-9 0 5---------------.-1 , ' t ----..---"-.-.-.-.---------------....-----r.-----..----..._.___.__.__n__n__n'_______._______..__J ~~-===:= ;::~~; :::; I ~~~~~:~~}A....=~==:==-==~=::::.=H:~~~~:i~?~:=====:=:===~::=::=~=='.I -,,-----'---..-'--- -------,--..---,--,--- T---'...--'------.-"--'------------'-i I Driver's L 3 ! NO RECORD FOUND I 1-.. -.--------.-----.-.-------------".j.-.------.---.-.--.------------.-...-....----.-1 L 5t VANIA -------------......----]J'~<?-~ APPL~~~~,,~______._._._____.J 1-----FileCre 09/72! ,m_._..n._.__n______ ._____._________ .__._____._.____ .......-----,-..-.--~ " Last Record 04/00 I ,,-,--,-----_.._------ --,-,,-,------------------_.- -,...---..------...---------....-,--..,---...----...---,' MOST CURRENT ADDRESS(ES) Most recent address obtained from public records: NEW ADDRESS FOUND Address': ,-'---'--'---- I .,--'------- ---.-"-'----------'--...,-'---'------.......,----, : Defendant #1: 3029 LOCUST ST, HARRISBURG, PA 17109 i :--;--.----j)efendant#2: i 335 9TH ST, NEW Cm.1BERLAND, PA 17070 ----'-----.-------------.------------.1 L,;{____________ I ......__.__________________._________._._______._._.____...____.___...____._._____...i ,c.:relep~C)n~...~ir~ctory Search5: . . _____...________._______._...___..__._____________..___.__.______..... ! ,O'e, 'Defendant#1: i (717)No Record Found i C_,:::_ D-cl~;:;-da;;t tt2: I (717) No R~~~::"!..!:?~i:T:===_==.=.=_=:::..::===:==-._._~:.=:.-::::=====:==~::.-==j , - 1 Obtained from Consumer Credit Report Header File. DMV records arl1 not accessible for purposes of SkipTracing. See notice on page 2 under Department of Motor Vehicle Operator Information, . 2 Original date subject's record is listed in Consumer Credit Report Header Fiies. 3 Date most recent address was reported in Consumer Credit Report Header Files. , Most recent address found after reviewing all address sources, 5 As listed with A T& T directory assistance or from Info USA telephone database (listing most recent record), ~., ~ "I ..I " , ,~~,' -! ~W.,," ~_C!~.:'~~!~_ CR!DIT '!EPORTING A~~_,?_! SE~~.c:_t1_ i RICHARD: I I 3029 LOCUST ST, HARRISBURG, PA 17109 i PO BOX 3131, HARRISBURG, PA 17108 i BOTH: i 335 9TH ST, NEW CUMBERLAND, PA 17070 REPORTED ON TRACK 2 ON 04/00 , ,,,""".._..,,_._-,,----------_._-_.._._._.._.~-_._.._--_.-.-...,,---- ' Information Sources: Consumer Credit Reporting AgenciessearchEiCi inciudedTransUnl"n(Cre,iTfHeader-"1);-Experi"n-----' (Credit Header 2), Equifax (Credit Header 3), and proprietary information sources including magazine subscription services, national telephone white pages and insuranc~J.ecords. ..._____..___..__.______...___._..__._..._..._.."_m.._---'.-.""..".'"'.--'1 i ~ " , REPORTED ON TRACK 2 ON 07/01 REPORTED ON TRACK 2 ON 11/00 UNITED STATES POSTAL SERVICE - Postal Regulation 39 CFR 265.6(d)(6)(ii), ,_!t_~q!l_est for Chan9~ of Address. Re~,!I!s: ______ ! 17109 AND 17070 PENDING '-"-;/Cerliiied copy attached P_~~~IC RECORDS SEARCHED - State and National Records - See page 3 if records were found l--- Bankruptcy Court Records Searcl,'TN~-- R~;;;:ds Fou~d ------------:--------------------:-----1, [~_~~~~I Security Death Index searct;rr:'"o ~<::~~ Found __-=--=~==~__________~=] , 1Sankruptcy records search conducted using subject's social security number in all states found in subject's address history, " 'Social Security Death Index Search is nationwide, VOTER REGISTRATION RECORDS SEARCHED ,--- ------ ------J ----------------------------------- ---. ; County; I DAUPHIN COUNTY, PA Reference: 1717-255-2793 I - -~- -------'--+- ~_._---- ---------------.---_.._------ ------_.. .-----., L_________ Results I RICHARD IS REGI_STEIl.~?- AT ~OVE ~DRE~~___.___________,_ ____________________.-1 DEPARTMENT OF MOTOR VEHICLE OPERATORS INFORMATION "TfJe Federal Driver's Privacy Protection Act (DPPA) effective9/13/97/imits access to driver and vehicle information. A signed release from the driver, or a notarized statement of intended use by an authorized requester is now needed to libtain driver and vehicle information. Driver and vehicle information is no longer available for skip tracing purposes. AFFIDAVIT OF GoOD FAmlINVESTlGATION Affiant is the principle of CONFIDENTIAL INVESTIGATIONS which performs investigative services and states that he has made . a good faith investigation by performing each of the stated searches, , Lyerify, under penalty of perjury, that the foregoing is true and correct, to the best of my knowledge. I understand that fi;llse statements herein are made subject to the penalties relating to unsworn falsification to authorities. Affiant: \! Sworn and subscribed before me this of 20_, day , Megan Krotz Investigator \;:; i j"'!:<;,,:',"':" )!:'11\'-:' "\'\;;\: C:,<;~T i)',,\ " ",';jeT I,: j, '<,;r,:-iT,i,;~ Se,tf1~ ;:: '-:C,1I,'\I ,;,f M(,,(T.~; ", cnf'i'D ~'!i'" 'j :',~; ,::<;;.i:i;.';~:: C4,'~":;2(\G~ ,~,'; ':})X,'i,2-: 5;r0,,'.-!fJ:?.;:~>;,'::t) 1':\ '" '\1 Jifl.jjlgJ~Oii",*;;l""'li.!Ii!<iiR~ii\t.~~~!*MW~""fR''''''-~G.'''i'Ji.,,,",,,,,,';:,lk'''H;ijcidrr,,,~~a!:J~ I -,:E- - ._~,~t "~".,,_.,.~, _~ . ~ ~ ~ < , "I' 1-" _",,<,,".,..,' Hn" "", U~" I", - ~a~_ ~ , o' ",.., ,. 0 '--," C1 ~,~:; , 1 :/) ~ "1:;1 " p1 , """ r, ! '0 'q Z I ., /. (Ii. " " ~ ,0 . (--' r , /~ N >') i-I'l >' C -;:\ Z ." > ~'-' :::2 .,--:;, -, .'--,~ - ~ -.....,j" , 0<', '''i;1;},' ,"", .";\. , SEP 0 4: ZOD#J BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff .' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, : Defendants IN MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to-wit, this day of , 2001, upon consideration of the Plaintiff's Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED the posting of the Handbill on the subject premises at 335 Ninth Street, New Cumberland, PA 17070 by the Sheriff thirty (30) days before the Cumberland County Sheriff's Sale, the mailing of Notice by ordinary and Certified mail to the Defendant's last known address and the publication of the notice of the Sale of the subject premises as required are sufficient notice to the Defendant of the September 5, 2001, Sheriff's Sale to satisfy the notice requirements of Pa. R.C.P. 3129.2; and, it is further ORDERED that the subject premises shall be sold by the Sheriff of Cumberland County at the September S, 2001 Sheriff's Sale as advertised and scheduled. BY THE COURT J .~,...~. - , I'. - ~;- ~""""""~""'t'-- ~. :"it' BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. '. RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants CIVIL ACTION - LAW NO. 2000 8426 CJ ,- :i IN MORTGAGE FORECLOSURE C) ~; ufo;': Q:; i~: : L.. ' ~~.~..~ ~~~":_1 >c) q; 2~~ :;-.: ~ ., :n n" ';j MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129(b) (2) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE i"-.) .'0 :;J '" =< Plaintiff, Beneficial Consumer Discount Company, D/B/A Beneficial Mortgage Co. of Pennsylvania,through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by Defendants located at 335 Ninth Street, New Cumberland, PA 17070. 2. Defendant Barbara A. Long was served with the Complaint, December 7, 2000 at the property and also served with the Notice of Sale July 9, 2001. Defendant Richard P. Long a/k/a Richard B. Long was served with the Complaint February 23, 2001, at the parking lot of the Giant Food Store located in New Cumberland, Pennsylvania. However, the Sheriff's office has been unable to serve Defendant Richard P. Long a/ka/ Richard B. Long with the Notice of Sale at the property, or at any new forwarding addresses for the Defendant. The Plaintiff believes that the Defendant has no interest in the property and has no desire to oppose the Sheriff's Sale. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, the Department of Transportation, ,Credit Bureau, and also by attempting to obtain a phone number for the Defendant, but no new information has been received from any of the sources. 4. The Sheriff heretOfore posted the Defendant's a Notice of Sale or Handbill. Notice of Sale was also property sent by with c= ' ~~.I .., " - -, - ,,- -"';.1 ~k tJ.i;.: ......,. . '-i~ ordinary and Certified mail. Sufficient notice has, therefore, been given to the Defendant. 5. Plaintiff believes that service by mail in accordance with Rule 430 (as allowed by Rule 3129(B) (2) (ii) (A) will be ineffective and that a Special Order of_,court is required. 6. The Notice of Sheriff's Sale scheduled for September 1, 2001 will be published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale. 7. Plaintiff requests an Order approving service by copy of the Notice of Sale or Handbill on the most public property under P.R.C. P. 3129. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. posting a part of the Leon P. aller Attorney for plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 BY " ~. '- ~- .,- ,~ -~"'-'" ~, '> ~ BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN as Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant Richard P. Long a/k/a Richard B. Long in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. The Defendant was not found at the address provided. X That he has attempted to'locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listings. That he contacted TRANS UNION Credit Bureau, a national service, with respect to the location of the Defendant. Defendant was not found at the address provided. X That he has conducted 'a search of the Pennsylvania Department of Transportation's records with respect to the location of the Defendant. ""i<lI ~ , . " .'-' ~. ,"i~ X _c~, ,,_~" '.' _ -, io.tj~, credit The Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. PURCELL, BY: Leon P 1719 North Front Harrisburg, Pa. (717) 234-4178 Street 17102 Attorney for Plaintiff Attorney ID# 15700 Sworn to and subscribed before me on this ~ ~ day of ~ ' 2001 ~~'l P ~'-"'- (Notary) ~"-'~--~~---'~--~ \!:. NOTP.H!/\L ~3Ef:..L _... . ' SH!l.RON I:: Ft~h~~G l i:ii ~~;"~~:~;"C_..,_,' ..."]l~~L ",",""e-'~'-~~ ,~- ~ L '''> :"';~;,: -~. ,'>". Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS Richard P. Long a/k/a Richard B. Long and Barbara A. Long .. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on July 9, 2001 at 3:$4 o'clock PM EDST, he served a true copy of Real Estate Writ, Notice and Description in the above entitled action upon one of the within named defendants to wit: Barbara A. Long, by making known unto Barbara A. Long, at 335 Ninth Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states on July 9, 2001 at 3:$3 P.M.', EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Richard P. Long a/k/a Richard B. Long and Barbara A. Long, located at 335 Ninth Street, New Cumberland, P A 17070, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 one of the within named defendants, to wit: Barbara A. Long, by regular mail to her last known address of 335 Ninth Street, New Cumberland, P A 17070. This letter was mailed under the date of July 31, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Richard P. Long a/k/a Richard B. Long, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice, Poster and Description, according to law. DAUPIDN COUNTY RETURN: I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that! made diligent search and inquiry for Richard P. Long a/k/a Richard B. Long the defendant named in the within Real Estate Writ, Notice, Poster & Description and that I am unable to fmd him in the County of Dauphin, and therefore return same NOT FOUND, August 10,2001. 3029 Locust St., Harrisburg, PAis a vacant apartment. Post Office has nothing on file. So answers: J. R. Lotwick, Sheriff of Dauphin County, PA. In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8426 Civil Term ?~S~~t:~j R. Thomas Kline, Sheriff B'fir:r:y io;~ R al Estate eputy ..a~....""".... .." '"',' '~"" liIild~ ~-'~'-llIII'_~"_lJi~J; " "'"" . 455 Linden Street, Allentown, PA 18102 RR 3. Box 2025, Effort, PA 18330-1901 ,( Allentown Office: 610-395-8741 Pocono Office: 570-992,2425 e.mail: mkrotz@earthlink.net '''-' ~~':~ ~~ ~ CONFIDENTIAL ~NVEST~@~,YI1!j1[1l1~ Loss Prevention. Asset Searches -.'SusirieJss"/ntelligence Insurance Fraud .. Skip~ Tracing" Missing Persons Background Investigations .. Witness Interviewing Undercover Investigations . Personal Protection Pre--employmfi1nt Investigations .. Surveillance Process Service . Litigation Support INVESTIGATIONS & lEGAL SUPPORT SERVICES ~ I Caption I LONG I- I i To: 1 BARB VILLARIAL , , [" Date: I 08/28/01 _I Court Term No. I NOT GIVEN I Your File No. I NOT GIVEN -t--- CI DOC.: NO.1 00-822 ---1 -j , --,-----,-~j i ,I Known Information (Supplied by Client): i I I f .; , .-- 1 , , ---- Name: RICHARD P. LONG BARBARA A. LONG . -,,- Address: 355 9TH ST SAME City/State/Zip: NEW CUMBELRAND, PA 17070 SSN: 202-42-7423 . 355-50-0905 INVESTIGATION REPORT Subject Identifiers (Obtained from Public Records) Investigation Sources Listed on Page 2 [:~ Name: I RICHARD P. LONG L BARBARA A. LONG ~ ._.._..i ----J ==J I 'I ----i 1 _i --.I [ Social Security Number:, , ----. -.. 202-42-7423 355-50-0905 --,.._---,-------_.._-- i State of Issue: PENNSYLVANIA ILLINOIS '. i ---- -------- ~. Year of Issue: 1967 - 1969 . 1970 - 1971 01/26/1954 -, I Year of Birth: 05/1954 r Driver's License No ': -- . ---- 16204933 NO RECORD FOUND I" State of Issue: , PENNSYLVANIA NOT APPLICABLE l- I " File Creation Date2: 09/72 I 09/72 I , - I. Last Record Found On3: 07/01 04/00 MOST CURRENT ADDRESS(ES) Most recent address obtained from public records: NEW ADDRESS FOUND Address4: [ Defendant!iJ3029 LOCUST ST, HARRISBURG, PA 17109 I.~ Defendant #2: 1335 9TH ST, NEW CUMBERLAND, PA 17070 . Telephone Directory Search5: I:, Defendant#1: (717)No Record Found t- , Defendant #2: (717)No Record Found i".. , ; ,_____,_____J -=-==--j 1 Obtained from Consumer Credit Report Header File. DMV records are not accessible for purposes of Skip Tracing, See .' notice on page 2 under Department of Motor Vehicle Operator Information. . 2 Original date subject's record is listed in Consumer Credit Report Header Files. 3 Date most recent address was reported in Consumer Credit Report Header Files, 4, Most recent address found after revieWing all address sources. 5 As listed with A T& T directory assistance or from Info USA telephone database (listing most recent record). - --~,~. ,. ,- ~ ~' ,........ I;;ifi:" ,: ,...",., CONSUMER CREDIT REPORTING AGENCY SEARCH [ RICHARD: 1'3029 LOCUST ST, HARRISBURG, PA 17109 I PO BOX 3131, HARRISBURG, PA 17108 \ BOTH: i TH [,335 9 ST, NEW CUMBERLAND, PA 17070 REPORTED ON TRACK 2 ON 04/00 I Info~ation Sources: Consumer-Credit Reporting Agencies searchedfncluded TransUnlon (Credit Header 1 ),Experian--' (Cred.t Header 2), Equifax (Credit Header 3). and proprietary information sources including magazine subscription services, national telephone white pages and insurancE! records. "-----~-----...-h.....-.......--_..l REPORTED ON TRACK 2 ON 07/01 REPORTED ON TRACK 2 ON 11/00 UNITED STATES POSTAL SERVICE - Postal Regulation 39 CFR 265.6(d}(6}(ii), Request for Change of Address Results: i 17109 AND 17070 PENDING C._ '/Certffled copy attached ---------~ , -1 PUBLIC RECORDS SEARCHED - State and National Records - See page 3 if records were found !Bankruptcy Court Records Search'l No Records Found '. i 'Social Security Death Index Searchrl No Records Found . :. 1Sankruptcy records search conducted using subject's social security number in all states found in subjecfs address history. ". 2Sacial Security Death Index Search is nationwide. J VOTER REGISTRATION RECORDS SEARCHED , r . County: DAUPHIN COUNTY, PA i' . Results RICHARD IS REGISTERED Reference: AT ABOVE ADDRESS 717-255-2793 'J I .-1 DEPARTMENT OF MOTOR VEHICLE OPERATORS INFORMATION 'The Federal Driver's Privacy Protection Act (OPPA) effective 9/13/97/imits access to driver and vehicle information A $,igned release from the driver, or a notarized statement of intended use by an authorized requester is now needed to bbtain driver and vehicle information, Driver and vehicle information is no longer available for skip tracing purposes. ~_vrrOF GoOD FAITH INVESTIGATION Affiant is the principle of CONFIDENTIAL INVESTIGATIONS which performs investigative services and states that he has made a good faith investigation by performing each of the stated searches. , I,,)/erify, under penally of perjury, that the foregoing is true and correct, to the best of my knowledge. I understand that fplse statements herein are made subject to .the penalties relating to unsworn falsification to authorities. Affiant: \! . Megan Krotz Investigator Sworn and subscribed before me this of 20_. day ~;.: ;---.- , ,. ~. f,... ' , . '-'~-', -::-;.."l~,)_\-,,' ; " ,,":",;:1",' b' "CF <o,,,,;;!'":;' C~c:.;;~\'\, C";;'/l,"('r',I;,; "_ 1),'r\';; ".:..' 'j;;,'\ ::-'::~:'i: 0-::" ~A:(~': '::(::1.;': ....... ;t\~\ i'1;-2-: !::r;~: ;;''S(. ,2:.~2~:: i;'\ ./ u, ~- , ,~~ " - ,. ~~~. '_1il'~I'"-'!iI~, ~-, ."i~ SEP 0 4 2001 tJJ BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, : Defendants IN MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to-wit, this day of , 2001, upon consideration of the Plaintiff's Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED the posting of the Handbill on the subject premises at 335 Ninth Street, New Cumberland, PA 17070 by the Sheriff thirty (30) days before the Cumberland County Sheriff's Sale, the mailing of Notice by ordinary and Certified mail to the Defendant's last known address and the publication of the notice of the Sale of the subject premises as required are sufficient notice to the Defendant of the September $, 2001, Sheriff's Sale to satisfy the notice requirements of Pa. R.C.P. 3129.2; and, it is further ORDERED that the subject premises shall be sold by the Sheriff of Cumberland County at the September 7, 2001 Sheriff's Sale as advertised and scheduled. BY THE COURT J ,.* ~h" - ,-, ~" " -~ . !i!JtiillJllbj,~~\;" l;;,,". BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. . .. RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE o c ~ -P2~J rlle-,-, ?:~; .c:_r' Cn> ~~~ C/) r-q -''0 (-, (-,1 :TI MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129(b) (2) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE .~-. ' -,-' 5:-~~~.' ,1'...1 ~.c ---' plaintiff, Beneficial Consumer Discount Company, D/B/~ '..~) , ::n -< Beneficial Mortgage Co. of Pennsylvania,through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. Plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by Defendants located at 335 Ninth Street, New Cumberland, PA 17070. 2. Defendant Barba,ra A. Long was served with the Complaint, December 7, 2000 at the property and also served with the Notice of Sale July 9, 2001. Defendant Richard P. Long a/k/a Richard B. Long was served with the Complaint February 23, 2001, at the parking lot of the Giant Food Store located in New Cumberland, Pennsylvania. However, the Sheriff's office has been unable to serve Defendant Richard P. Long a/ka/ Richard B. Long with the Notice of Sale at the property, or at any new forwarding addresses for the Defendant. The Plaintiff believes that the Defendant has no interest in the property and has no desire to oppose the Sheriff's Sale. 3. Plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, the Department of Transportation, .Credit Bureau, and also by attempting to obtain a phone number for the Defendant, but no new information has been received from any of the sources. 4. The Sheriff hereto+ore posted the Defendant's a Notice of Sale or Handbill. Notice of Sale was also property sent by with ,.^},-~'.~~ -~ ~-~ ~~ ~ ~,"j J l. . ',i ~. ~, o"~,. ordinary and Certified mail. Sufficient notice has, therefore, been given to the Defendant. S. Plaintiff believes that service by mail in accordance with Rule 430 (as allowed by Rule 3129(B) (2) (ii) (A) will be ineffective and that a Special Order o~~~ourt is required. 6. The Notice of Sheriff's Sale scheduled for September 7, 2001 will be published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale. 7. Plaintiff requests an Order approving service by copy of the Notice of Sale or Handbill on the most public property under P.R.C. P. 3129. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. posting a part of the BY Leon P. aller Attorney for Plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 -.':",-~""'" ~ -~, ~ , -' ,- """""',......._rJ,1Iot~, ~-, ,'i" BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant Richard P. Long a/k/a Richard B. Long in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. The Defendant x was not found at the address provided. That he has attempted to"locate persons of similar name to the Defendant, however he has not been able to locate any. That he contacted Directory lssistance for any new listing for Defendant, however, there are no new listings. x ~~ - "-_'I. J, L" ~ ~ ~ 1iI11liBii1-'-":' -~ ~illll__'Y.' " ,',,' That he contacted TRANS UNION Credit Bureau, a national service, with respect to the location of the Defendant. Defendant was not found at the address provided. X That he has conducted 'a search of the Pennsylvania Department of Transportation's records with respect to the location of the Defendant. credit The X Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. PURCELL, & HALLER BY: Leon P 1719 North Front Harrisburg, Pa. (717) 234-4178 Street 17102 Attorney for Plaintiff Attorney ID# 15700 Sworn to and subscribed before me on this ~ ~ day of ~' 2001 ~~'lP~ (Notary) r------"-~--'-~ . ~, . , ..... '" '~~!:" f~ ' , _'l~-.lOTp,hU\L ~:,~":..-....L "",' ., ' 1 (".W'("\! I' "Ci'::'; ,ill .,m ~., . 9,!ty,;~f..,..". ,:.... .'.', ,'/:.[~~~i!~ l l'li1/0V'I'I,;,:-,:.;',j' : ,. '-', ...\yJ~ l : J _,_~~_..:=.:.:_:_,__".~.__~'"''' __',' ~'L..,..~_~l ,,,1'[.... - ~ -=~..""'...~ ,L-' c _. l...." '''''';'_ ~l --~~>,,<IL~~_" \:l;, "~' Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania VS Richard P. Long a/kJa Richard B. Long and Barbara A. Long -' In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8426 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, says on July 9, 2001 at 3:54 o'clock PM EDST, he served a true copy of Real Estate Writ, Notice and Description in the above entitled action upon one of the within named defendants to wit: Barbara A. Long, by making known unto Barbara A. Long, at 335 Ninth Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn acc'ording to law, states on July 9, 2001 at 3:53 P.M:, EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description upon the property of Richard P. Long a/k:Ia Richard B. Long and Barbara A. Long, located at 335 Ninth Street, New Cumberland, P A 17070, according to law. R. Thomas Kline, Sheriff, who being duly swom according to law, states 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 one of the within named defendants, to wit: Barbara A. Long, by regular mail to her last known address of 335 Ninth Street, New Cumberland, P A 17070. This letter was mailed under the date of July 31, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Richard P. Long aIkIa Richard B. Long, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice, Poster and Description, according to law. DAUPHIN COUNTY RETURN: I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for RichardP. Long a/k:Ia Richard B. Long the defendant named in the within Real Estate Writ, Notice, Poster & Description and that I am unable to find him in the County of Dauphin, and therefore return same NOT FOUND, August 10,2001. 3029 Locust St., Harrisburg, PAis a vacant apartment. Post Office has nothing on file. So answers: J. R. Lotwick, Sheriff of Dauphin County, PA. , ,s.g.~?s: r~';l.'.~~~~' R. Thomas Kline, Sheriff By~J;c:4r ~~111~ R al Estate eputy ."~""""",,,,,", .~ - , .'-' -"~'..i. '~~-ltiITI - ~J ...." "'" . 455 Linden Street, Allentown, PA 18102 RR 3, Box 2025, Effort, PA 18330-1901 ,(A1lenlown Office: 610,395-8741 Pocono Office: 570-992,2425 e.mail: mkrotz@earthlink.net >~. ~~:~ ~~ ~, CONFIDENTIAL ~NVESTi@ii./il;\cii;I(Q)I!'iI~" Loss Prevention . Asset Searches . Business''/fiMlligence Insurance Fraud . Skip-Tracing . Missing Persons Background Investigations . Witness Interviewing Undercover Investigations . Personal Protection Pre-employment Investigations . Surveillance Process Service . Litigation Support INVESTIGADONS & lEGAl SUPPORT SERVICES ~ I Caption LONG I To: BARB VILLARIAL 1-' Date: 1~/28/01 Court Term No. ! NOT GIVEN _II Your File No. I NOT GIVEN -----------1 CI DOC.:!'l.~' I 00-822 , " Known Information (Supplied by Client): I Nam~ RICHARD P. LONG r- Address: 355 9TH ST '! City/State/Zip: NEW CUMBELRAND, PA 17070 SSN: 202-42-7423 ,~ARBARA A. LON~_ i~AME _~==:--' 355-50-0905 ----, ~ INVESTIGATION REPORT Subject Identifiers (Obtained from Public Records) Investigation Sources Listed on Page 2 I ;" , Name: I RICHARD P. LONG IBARBARAA:--i,ONG ; Social Security Number' I 202 42 7423 ::]355-'50 0905 --------~l , . - - - - " ------------~-- I " State of Issue: PENNSYLVANIA ILLINOIS , -- f-C-----'-'-'-"-'-----'--'_____j ~ Year of Issue: 1967 - 1969 1970 - 1971 Year of Birth: 01/26/1954 05/1954 ~ Driver's License No': 16204933 NO RECORD FOUND I State of Issue: PENNSYLVANIA ' NOT APPLICABLE I ," File Creation Date': 09/72 09/72 I 1- - I Last Record Found On3: I 07/01 04/00 I MOST CURRENT ADDRESS(ES) Most recent address obtained from public records: NEW ADDRESS FOUND Address': ! Defendant #1: 3029 LOCaST ST, HARRISBURG, PA 17109 , Defendant #2: 335 9m ST, NEW CUMBERLAND, PA 17070 , Telephone Directory Search5: ~ " Defendant #1: I (717) No Record Found L D,efendant#2: , (717)No Record Found I I i -------' 1 Obtained from Consumer Credit Report Header File. DMV records are not accessible for purposes of SkipTracing. See " notice on page 2 under Department of Motor Vehicle Operator Information. , Z Original date subject's record is listed in Consumer Credit Report Header Files, 3 Date most recent address was reported in Consumer Credit Report Header Files, 'Most recent address found after reviewing all address sources. 5 As listed with A T& T directory assistance or from Info USA telephone database (listing most recent record). ~--~- ~, ~~ . , J "" ~, .:"'~1~.II!lI!lt11.",li: ,"", ,">, ,_c::ONSUMER CREDIT REPORTING AGENCY SEARCH i RmHARD: ,--- I 3029 LOCUST ST, HARRISBURG, PA 17109 , i PO BOX 3131, HARRISBURG, PA 17108 I BOTH: L,~35 9Tl1 ST, NEW CUMBERLAND, PA 17070 REPORTED ON TRACK 2 ON 04/00 , Information Sources: Consumer Credit Reporting Agencies searched included TransUnion (Credit Header1}, Experlaii----. (Credit Header 2), Equifax (Credit Header 3), and proprietary information sources including magazine subscription services, national telephone white pages and insuranc'~, !'ilcords. REPORTED ON TRACK 2 ON 07/01 REPORTED ON TRACK 2 ON 11/00 UNITED STATES POSTAL SERVICE - Postal Regulation 39 CFR 265.6(d)(6)(ii). .~equ_est for Change of Address Results: 117109 AND 17070 PENDING '''',Certified copy attached -----------1 ....J PUBLIC RECORDS SEARCHED - State and National Records - See page 3 if records were found [., ~ankruPtcy Court Records Search 1 No Records Found '. ,---- L;:>ocial Security Death Index Search' No Records Found 'Bankruptcy records search conducted using subject's social security number in ail states found in subjecrs address history, 'Social Security Death Index Search is nationwide. 'I .J VOTER REGISTRATION RECORDS SEARCHED [, County: DAUPHIN COUNTY, PA 1""-" Results RICHARD IS REGISTERED AT i Reference: ABOVE ADDRESS I 717 -255-2793 ----] "--- I DEPARTMENT OF MOTOR VEHICLE OPERATORS INFORMATION The Federal Driver's Privacy Protection Act (DPPA) effective 9/13/97Iimils access to driver and vehicle information. A signed release from the driver, or a notarized statement of intended use by an authorized requester is now needed to dbtain driver and vehicle information, Driver and vehicle information is no longer available for skip tracing purposes. AFFlDAvrr OF GOOD FAmllNvEsnGAnaN Affiant is the principle of CONFIDENTIAL INVESTIGATIONS which performs Investigative services and states that he has made , a good faith investigation by performing each of the stated searches. i l.)Ierify, under penalty of perjury, that the foregoing is true and correct, to the best of my knowledge. I understand that f1;llse statements herein are made subject to the penalties relating to unsworn falsification to authorities. Affiant: v Sworn and subscribed before me this of 20_. day , Megan Krotz Investigator 1,:_: I f:,.;.I_"- ',",:t-",:,'. ",~r.i~,\.' ' -:,:11,_;,', ''',';,'::: 1 i', . \,' ':'cn SeEu@ i.:;: i,: ,I <','::I-,,~:~(,.;' :'~C.~I\' d M.-'l('\,i,t: ',';'r':':; 0.:.-,,. i.,."\ "~"'::'!: ;::';. ;),!'(}'; !.i'!i.;'~ - .>(:('1'$< J.;:f>;;~r:..:;,:~:::5 ;:~ i I f:! , -, ~ ,;~ " """,,-, -.,~~ "'" ,- 0' ",. ',,'~," ~-,' ~""",_~__",,_,,",lI\I!lI~_ ,~ jUTfilf ,-,-, .,,'~ ~--,,, "-.n"l_~~'" ~h~' ';\C'.t ,., ",~,,"1'IIH'{ " -i\')"",!',t, ~('~ '1 {.. p;,J, :,: (\4 . " CU\'! \ ",-ru -' ""_I, r'~"''''''''1 r'r)..;\\l\ 1 ',L.' :,rr';' ;~;\'l^ '-';-~'I},'{,:,{0!j"' \\\1'\ \-'Cl\ll'h-", " , ~,_"IT''''''C~~0~';''~i'''C'I\'\<''''''''-~'"iTIi'i'''$''W,P,f''l~~~~ijf.~'i1'N~i;~~llllJ1i:;;rm'1l1~~" Ii' - ! i .."'."'........ 11/ ~ M ~ ~G .'~ .'0 .<> .... '<> :cr(.0t~1;1?;~{i0~J%1i1[;;~fA~rl~~1k~~~1f1l1~~~iY~:f.1]:I- ];-;' -T"::;""'" '--,' ~ -.'''; '",-", ~ ~ ..... ~ ~~1~ o .;j ...::;. r:: "-J . V) ~ ~~~ ~ ~~ \)-. ~ ~ 1 h 0; _v l., ("(") ~ ~~ ~~ o,'i ~':"i~~';;f;'{g'~~7a~~~~~;4~ml~~\@1~~ ~j1k1}'!,~l'{~~~)1'~42i~?~51lf',\~~~z~1'-€:i\'J~>--.i " I -'--"--1 , , --';" ,-j ".-0-"-""'1' '~ - ,', -"-, .""..Jt.ll._.... 0:: III ...J >->- ...J a:lD <( N U'\o I I- 0) W l') UJ- W N w~ l.(l a: , Uw l- N Wa: C) l/} 0 Za. :J I- f'o a.Z 0:: z ~W 0 ~ ,(W ~ ,",lD a: UJUJ . U. CJ W<( ...J l: a: ell: ...J I- :J ~W III a: m UJel U 0 ~ O~ 0:: z a: a.UJ :J 0) a: 00 a. j;: <( za. l: ~~lf1l~~~.JJ!ii~if@!{;fJ4~fJ&'~~;;jE~E~ !,'"",}" '. " i 1 , -; BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B, LONG AND BARBARA A. LONG, DEFENDANTS > - '~_._, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U,S, Mails at Harrisburg, Pennsyl vania on , a true and correct COpy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with D,S, Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as "'fallows: Richard p, Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A, Long 335 Ninth Street New Cumberland, PA 17070 Beneficial Mortgage 4910 Carlisle pike Suite 104 Mechanicsburg, PA / Company 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By_ 4- PURCELL, KRUG & LLE Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 " , . .., '-M...... , . , JOHN W, PURCELL HOWARD B. KRUG LEON p, HALLER JOI-IN W, PURCELL JR BRIAN J. TYLER JILL M, WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 2344178 FORECLOSURE DEPT, FAX (717) 234,1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 Beneficial Mortgage Company 4910 Carlisle pike Suite 104 Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. By: against the said yo ave an g notified of YOU ARE FURTHER NOTIFIED that the lien you hold real estate will be divested by the sale and that opportunity to protect your interest, if any, by said Sheriff's Sale. *'~ i BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO ~ENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 335 NINTH STREET NEW CUMl:lERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG ..L'- c . ~ -, .< , '-ll'';';_ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUS~ YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights, If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVIC~: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This . -. ' ,- , M .-' ,"" _J " ,;~""i"~ _, bd,,,,,,, 0 iIi!I~ petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~ ~"''''''=~~~-, 'ill" -~IIM~,c ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland, Cumberland county, pennsylvania, being bounded and described according to a survey made by Ronald S. Raffensperger, R.S., date~ February 29, 1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, 50 feet wide, at the dividing ~ine between Houses 335 and 337 Ninth Street, said point being measured 145.0 feet to oak Alley, thence along the dividing line between 335 and 337 Ninth street, North 47, i degrees 00 minutes West, 100 feet to an iron pin on the Southeaster1yi side of an alley, 10 feet wide, thence along said alley, North 43 degrees 00 minutes East 22.50 feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; thence along said di- viding line South, 47 degrees 00 minutes East, 100.0 feet to a point on the said side of Nint,h Street; thence along said Ninth Street South 43 degrees 00 minutes West 22.5 feet to a point, the place of BEGINNING. BEING the Eastern 13.5 feet of Lot No. 36 and the Western 9 feet of Lot No. 35 on the Plan of Seven Maples No. I, as recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 94. HAVING THERERON ERECTED a dwelling house known and numbered as 335 Ninth Street. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated August 30, 1985 and recorded September 3, 1985 in Deed Book L-31, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long. TO BE SOLD AS THE PROPERTY OF RICHARD P. LONG (A/K/A RICHARD B. LONG) AND BARBARA A. LONG ON CUMBERLAND COUNTY JUDGMENT NO. 2000 8426. PARCEL: 26-24-0811-218 'IJ ~ "~ , .~ 7HIa ~SJS :LPI"lnlf ... 71ab 11575 :L,"" 1J1I".. TO: BARBARA A LONG 335 NJNTIf STREET NEW CUMBERLAND PA 17070 TO: RICHARD P LONG A!KIA RICHARD B LONG 335 NINTIf STREET NEW CUMBERLAND P A 17070 -.ofl' SENDER: SENDER: REFERENCE: REFERENCE: , PS Form 3800 June 2000 RETURN Postage RECEIPT C rtif'ed SERVice e r Fee Return Receipt Fee Restricted Denvery -~~ Total Postage & Fees US Postal Service US Posial Service Receipt for Certified Mail P Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail NQ Insurance Coverage Provided ~ Do Not Use for International Mail Re: Beneficial v. Long Cumberland Sales 9/5/01 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Barbara A, Long 335 Ninth Street New Cumberland, PA 17070 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Beneficial Mortgage Company 4910 Carlisle Pike Suite 104 Mechanicsburg, PA 17055 T'I._ _, "~. "- ~ ...."i'"," ,.-"'--"-' ~~, s~&'li""", ",tS,~ .#.."-, ",^ ' , >, y rnll0s I'""",l'''',u '.",',,'. ." e " '" '\ u_ " 1'."- " ), 17f1r .l ' , '\~~:(l:;:;:!\<j:,~:,~:" "" ~=t. }: t.:=- ~.2. >, ~5" ~ . .~~\Sti().",:: -",1' U.S.lrGS1ASE : ... ~"f:.""f~ :: ;l:JUl'3'OI (i) : ,i,.. ::: 0 J 5 :: : ?BMET&i\ 6763Sb-5 . " i'lil\l~ilil :,1 ,.,t u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service ~r.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (f(;:-'SdSf) ...t5.......-:- A'^ "'I'" rn>,' "',> ~ 1,..,l}(j \'~: '7, ~ " ":. \ 'c \,e,\ lnr ' <":~:;"'~__~"~ <' ,0, ""..,..,~l/yl_!'.--1" ' "...,,,.'-'. i(j~~miiMOOJ1!]~OOli;@.~I%'~j,"",;\\'i~,*""",-"",,~'4';"""'-""i<;-~jf'!iE~..I!IIl~ < ~ '" _ ~ Le "~,, ~, . >=, ~_""I ,'_~., ~"'_ 'A__~ _ 1!IiI1IIUJlfalWMli'~~ , ~ ~-" " ,-~ .~,,'" , , (') C~) c> C -r, ....~~ (fJ ,-:,'('U rTl PI:!;, -'0 2~~:f'1 Z s: T -~ Ci) 'D -i.:,. -<: .::.~ ('...... l% G -' .. >..: 2 , , s;,: ce; ; , L.. ~ --' -< t-0 -, ..- iI ,..,,-, .. -"d '" _"_ '_""-' '- " '1Iii-.-, BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE ORDER OF COURT AND NOW, to-wit, this ZS'.day of $7'""'" w , 2001, upon consideration of the Plaintiff's Motion for Service pursuant to special Order of Court, it is hereby ORDERED that the Motion is granted; and, it is further ORDERED the posting of the Handbill on the subject premises at 335 Ninth Street, New Cumberland, PA 17070 by the Sheriff thirty (30) days before the Cumberland County Sheriff's Sale, the mailing of Notice by ordinary and Certified mail to the Defendant's last known address and the publication of the notice of the Sale of the subject premises as required are sufficient notice to the Defendant Richard P. Long of the October 10, 2001, Sheriff's Sale to satisfy the notice requirements of Pa. R.C.P. 3129.2; and, it is further ORDERED that the subject premises shall be sold by the Sheriff of Cumberland County at the October 10, 2001 Sheriff's Sale as advertised and scheduled. COu;/L ~ r<~ ~J.~ - """ _, ,_, _ ~.,~ '''' 'w "~ ~, _1!ffl1'lI1 ~~- fj~~,,~ "--'-<'-", ,-~ -.~ '" ,~,~, ',,- ~~ "'-".' 1.- --",-' nrT--~~-1 .~, ~' n"^'-~1iiljiiTJIl1 UiJll= Jilin 0 c:- C,) ,'- ~ .'n -0[11 u, rn,,:-., .''T1 Z=t1 v 6'5 I;: ;"0 , _....--~":: (.T, r.::t5 i>r~_ - " Zc" >2 c:5 ~,=) :;;:: r:-- ::r.~ :;:i '0 :n ~-< o ~ _ '~_','~ ~,,_.,.~_ ,~__ UUJl!!.~<!:of"~'"I'3"H"""";O:-'io""'''"",~'f.,'''''~~'i1'1','''l\i'miWi~!$~m!~~lf"':~:1~~\I!flffi'I~jlilifl!l'!~ Il ,.' , ~-'-, - ~ ^ " j.~ BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE MOTION FOR SERVICE OF NOTICE OF SALE IN REAL PROPERTY ACTION IN ACCORDANCE WITH RULES 3129(b) (2) OF PENNSYLVANIA RULES OF CIVIL PROCEDURE Plaintiff, Beneficial Consumer Discount Company, D/B/A Beneficial Mortgage Co. of Pennsylvania, through its counsel, Leon P. Haller, Esquire hereby respectfully submits: 1. plaintiff has brought a mortgage foreclosure action whereupon it seeks to foreclose against certain property owned by Defendants located at 335 Ninth Street, New Cumberland, PA 17070. 2. Defendant Barbara A. Long was served with the Complaint, December 7, 2000 at the property and also served with the Notice of Sale July 9, 2001. Defendant Richard P. Long a/k/a Richard B. Long was served with the Complaint February 23, 2001, at the parking lot of the Giant Food Store located in New Cumberland, Pennsylvania. However, the Sheriff's office has been unable to serve Defendant Richard P. Long a/k/a Richard B. Long with the Notice of Sale at the property, or at any new forwarding addresses for the Defendant. The Plaintiff believes that the Defendant has no interest in the property and has no desire to oppose the Sheriff's Sale. 3. plaintiff has conducted an investigation in order to determine the whereabouts of the Defendant, through its attorney, by attempting to obtain a forwarding address from the post office, the Department of Transportation, Credit Bureau, and also by attempting to obtain a phone number for the Defendant, but no new information has been received from any of the sources. 4. The Sheriff heretofore posted the Defendant's property with a Notice of Sale or Handbill. Notice of Sale was also sent by . ~' ,," liliill:ililiU& ordinary and Certified mail. Sufficient notice has, therefore, been given to the Defendant. S. Plaintiff believes that service by mail in accordance with Rule 430 (as allowed by Rule 3129(B) (2) (ii) (A) will be ineffective and that a Special Order of Court is required. 6. The Notice of Sheriff's Sale scheduled for October 10, 2001 was published in the legal journal and a newspaper of general circulation for three weeks to sale, which provides ample published notice of sale. 7. Plaintiff requests an Order approving service by posting a copy of the Notice of Sale or Handbill on the most public part of the property under P.R.C. P. 3129. WHEREFORE, Plaintiff requests that your Honorable Court approves service as above set forth. BY Leon aller Attorney for Plaintiff 1719 North Front Street Harrisburg, Pa. 17102 (717) 234-4178 -~ -j "I L'- ,~ " " ~. /-;" -;:1 BENEFICIAL CONSUMER DISCOUNT COMPANY, D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2000 8426 RICHARD P. LONG A/K/A RICHARD: B. LONG AND BARBARA A. LONG, Defendants IN MORTGAGE FORECLOSURE AFFIDAVIT OF REASONABLE INVESTIGATION COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Leon P. Haller, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff in the above action in mortgage foreclosure, that he has personal knowledge concerning the facts set forth in the attached Motion for Service of Notice of Sale pursuant to Rule 3129, that he has authority from the Plaintiff to make this affidavit, and that the facts set forth in the affidavit are true and correct to the best of his knowledge, information, and belief, to wit: That he has attempted to confirm the whereabouts of the Defendant Richard P. Long a/k/a Richard B. Long in the above case, by conducting a reasonable search, which search included one or more of the following as indicated by a checkmark: X That he has contacted the U.S. Postal Service to obtain the last known mailing address or any forwarding addresses. The Defendant was not found at the address provided. X That he has attempted to locate persons of similar name to the Defendant, however he has not been able to locate any. X That he contacted Directory Assistance for any new listing for Defendant, however, there are no new listings. d, , "~ , ~.." x That he contacted TRANS UNION Credit Bureau, a national service, with respect to the location of the Defendant. Defendant was not found at the address provided. credit The X That he has conducted a search of the Pennsylvania Department of Transportation's records with respect to the location of the Defendant. Leon P. Haller further deposes and says that after attempting to locate the Defendant by conducting a reasonable search as indicated above; he has been unable to confirm the Defendant's whereabouts and location. BY: Leon 1719 North Front Harrisburg, Pa. (717) 234-4178 Street 17102 Attorney for Plaintiff Attorney ID# 15700 Sworn to and subscribed before me on this 11 day of ~,\-, 2001 ~lN\cY'\ p~ (Notary) NOTARIAL SEAL ?HAAON P. DUNN, Nctary PlJbllc Ci1y of Hamsburp Dauphin Countj My CommISSion Expires Nov, 3, 20iJl ..,: , " ;.. '.:J,"~-".".J~it . 455 Linden Stree~ Allentown, PA 18102 RR 3, Box 2025, Effort, PA 18330,1901 "'Allentown Office: 610,395,8741 Pocono Office: 570,992,2425 e.mail: mkro1z@earthlink.net >~. cD{.') ~'IIJ ,~ l:I Loss Prevention '*'Assef''$earches 'l'Biisiness7iiteJj]gen'ce Insurance Fraud" Skip-Tracing" Missing Persons Background Investigations .. Witness Intetviewing Undercover Investigations .. Personal Protection Pre~employment Investigations .. Swvei/lance Process Setvice .. Litigation Support INVESTIGATIONS & lIGAl SUPPORT SERVICES .<'epMt Caption LONG Court Term No. NOT GIVEN To: BARB VILLARIAL Your File No. NOT GIVEN Date: 08/28/01 CI Doc. No. 00-822 ~~.!~~,~~!f)!.'~,!~!f),I:',{~~!'.e!~~~,~y-_~/!-'~Il,t):,,,_,, 1""_""""~~~El,:,_I,~~~~~~~",~,:",~?~~",,,,,,_,"",:::,~'::,::::,L~~~~~~::,~~':::~~~~':":::,:,:::,:::",-,:~',:::::::::::::::::,- I Address: i 355 9TH ST i SAME [:::::=~~~J.~~~:~~:~IJ:~~~~~~~~:i~:~~:~~::::~~'::~~:~::!=:::::::,:::::::-::::::::::::::::::::I:i:~:~,:~:;:~_~~i~,i~::::::::::-,::::::::-:-'-,:-,-,::::::-::::,::::'-:,:_~_::::=::--::_:-,j INVESTIGATION REPORT Subject Identifiers (Obtained from Public Records) Investigation Sources Listed on Page 2 1'.--..-..-..-.-.-.-.--.-----..-.---'.-'--.'---.......--...-.,,----.-..,-,-,-~"'----,.-------..,.-'---...-.-....-.-...-.-.-.--......,.,-.,.,-.,.,-.,.............--...-. ..---.-.---.....---......'''..--..--.-....-...-.-,...-..-....,.,.,-.....,.........-.-...-.-.-...............,..,..,..,..,.......,................... i Name: i RICHARD P. LONG ARBARA A. LONG .. i [~~~:i~)=~::~~I;~~~~~~~~H:~:~~~~:~t~~~i.-:::::::::::::.-:::::::::::::::::::::::::::::::iJ~~~:~~~~:!:~~::::::::::::::::::::::,::::::::-::::::::::::::::J 1 Yearoflssue: 11967 - 1969 ; 1970 - 1971 I !..-'....--..--.-.-.--....-.--....--.--.----------.-T...-.-...,--.-....-............-...,..,..,-..,..,..,.,..,.,..,..,..,..-,.----....--....-.-.-....-.-....-....................,..-,..,..,..---,.-......_........._..L__~..,..,..,..__,,,........_._._._._............,_..,------..,..-~--.....-_...-.-.",..,---..,-.,--,.--,.---...--...-..........-......j 1....,"",..,__,_y~~~..C?L~i.!!~:J~y~.!i,~~9~~___,__..,""'"..,""'_"__,__"",..,..,'+~,~,~,~:~_..____,___,__,_"",_..,___________..,_,] ! Driver's License No: i 16204933 : NO RECORD FOUND I !---'----"'--....si'ateo'-,ssue-:-rPENNSYLVANii"'-----'-----'-'-"-'-""""'-'----"'---'rN'OT--APPLICABLE"-------'---..,......,'-"-----'; ,..---'---..-'---'-..'------'........'....--..2-..-1----..----..---....---,'-........,..........,-....,-,....-......-....-..---..-..............,........"-....'--..----,-,............-..'-..--,---..----,-....,-..-,..,........,......,-..--........,-....,....,..,..,! I File Creation Date: , 09/72 i 09/72 I r"LasTRecorci'Fouii-(j'oii'3:i'o'i7o'i""""--""'-'-'-'--"""""""'-"'-104700'----"'-",..,'-..-'--'-'--'-,-,-..--"'~ "."............,....._..._......_,...__._.,..,...._....._..._..."...._..........."._........"...."......................................,..,..,..,_.._,..,........,.....,..,..,.....,......_............_......................................".....,.....,..,..,..,...._...............l_."._._._...__.......................____,.,.........._.."........_............."."'_..,__......_..,..,..,....._.__.._____...._."...._._............._... ,Ii MOST CURRENT ADDRESS(ES) Most recent address obtained from public records: NEW ADDRESS FOUND Address4: #1: 3029 LOCUST ST HARRISBURG, PA 17109 Defendant #2: 335 ST, NEW CUMBERLAND, PA 17070 Telephone Directory Search5: [::::~~::D6!~iicI~T!Er_T?:~S~?=:~~9:~~~::~~~~~:::::::::::'::::::::::::::::::::,:::::::::::::::::::::::::::::::::::::::::::::::::::::::::'::'::::'::::"":~ i Defendant #2: ) (71 7) No Record Found I l.____,_,_,__.._.._..,___....,..,..........,....,....,.._......,_..___,_...._,..,_..___.._........_...._..__.._.._...._,,_......................,........,......,..,....................___...._,_.._..___............,..................,....,....,_...................._..,_....,_............,_.._..,'_........,......... 1 Obtained from Consumer Credit Report Header File, DMV records are not accessible for purposes of SkipTracing, See notice on page 2 under Department of Motor Vehicle Operator Information.. 2 Original date subject's record is listed in Consumer Credit Report Header Files, 3 Date most recent address was reported in Consumer Credit Report Header Files, 4 Most recent address found after reviewing all address sources, 5 As listed with A T& T directory assistance or from InfoUSA telephone database (listing most recent record), , >' ","" ",J ,- .' -, ,____~"'_'_'.:;;;Jc',"; Ai , II' CONSUMER CREDIT REPORTING AGENCY SEARCH ["'RlcHARo;"""""""'"'-'''''''''''''''''''''''''''''''''''''"""""''''''~:::a:'''''''''''''''''''''''''''''' [3029 LOCUST ST, HARRISBURG, PA 17109 ~ i PO BOX 3131, HARRISBURG, PA 17108 i BOTH: L~,~"~"",9T~~,~,!"""'~,1'::~,c:::?~,I::~,::~!:~~,,'~!:,,,,,~,2?,2?"""""""",,,,,,,,,,,,,,,,,,,,,,,..,,,,,,,,,,,,::!';POR TE D, ON TRACK 2 ON 041 0 0 i Information Sources: Consumer Credit Reporting Agencies searched included TransUiiJo;;"(Cre'(jli'Header'if'Expeiian.."'..'.... (Credit Header 2), Equifax (Credit Header 3), and proprietary information sources including magazine subscription services, national telephone white pages and insurance records, REPORTED ON TRACK 2 ON 07/01 REPORTED ON TRACK 2 ON 11/00 '-....-"'"1 I , , UNITED STATES POSTAL SERVICE - Postal Regulation 39 CFR 265,6(d)(6)(ii). '''~!lq~!ls.!,f<<>.~,9,~,!I,':',g,!l,~!,A.c:J,,<!,~!ls.s.~!l,s.,~,I!s.:,..,'',,""" """"""""'," 117109 AND 17070 PENDING ".'.'7Ceiiifleci"copy"iifiaciiiia-''''--'-'--'.'.'''''"'"'"''''-._".m....."."."..."........_._...._,......_."'"."'"'"....................................-....".......,.."""'..--....................,..-...."",,,,,,,,,,...-- I ...".........-.".".".".........................! PUBLIC RECORDS SEARCHED - State and National Records - See page 3 if records were found [:~,"~:~,~Eilp}~iC?U~,~~~~~~i~~~i~t{I~~::~~~~~~~::!:~~~:~:::':::::::::::::'::=::=::,':::::::::::,::::"::":="':,'::::""'::,, .J 1 Social Security 'Death Index Search2 1 No Records Found ,.. ..",....,............, ".. i..__,.._,_"'"'"''''..'"'"'"'.,_.,__.,.,.....__.....'"."._._.___,_,",",__,.,",.,.....,.,...._..._._._.",..__.__.J..,..,_..,..,.._,_..,_..._..........................................._..,..,.."".....,............................'''."..._.._..,.....,..,.............................".,,_........._......_...,......,..,..,..,..,..,..,....."...............'.._..,.._,"_..._................................ ....._.......,,__._,..............,..........._ 1eankruptcy records--search conducted using subject's social security number in all states found in subject's address history. 2Soclal Security Death Index Search is nationwide. VOTER REGISTRATION RECORDS SEARCHED ~,~;, DAUPHIN COUNTY, PA RICHARD IS REGISTERED I Reference: I 717 255-2793 AT ABOVE ADDRESS DEPARTMENT OF MOTOR VEHICLE OPERATORS INFORMATION The Federal Driver's Privacy Protection Act (DPPA) effective 9/13197/imits access to driver and vehicle information, A signed release from the driver, or a notarized statement of intended use by an authorized requester is now needed to obtain driver and vehicte information. Driver and vehicle information is no longer available for skip tracing purposes, AFFIDAVIT OF GOOD Fj\ITH INVESTIGATION Affiant is the principle of CONFIDENTIAL INVESTIGATIONS which performs investigative services and states that he has made a good faith investigation by performing each of the stated searches, I verify. under penalty of perjury, that the foregoing is true and correct, to the best of my knowledge, I understand that false statements herein are made subject to the penalties relating to unsworn falsification to authorities, Affiant: t~ SW..::Jnd subscribed befo~e me this '2- q , day of ;W~~ or Pt:"J~j)WLVi\1~,i, i...,(;l:::.f-.t:, cD lfNEST1G.t,T(?I, Enc J, Ke-rUm0f County of'Monroe License No, lOB EXpli'0fi: ()4!O'U;~OOi Phone', 5'!O~9n2-242b Seal r- -!Iii: I ".,!.:~IMi., _- p-"..Jmoet pr."'i~l'''''''''' " , ' 1;.tj1""'1 ~""'Iitj h~tiatlon at Nofarie8 8&( b V ~ UNITED STATES ~I POsTi1LSE/lV1CE REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS Please furnish this agency with the new address, if available, for the following individual or verify whether or not the address given below is one at which mail for this individual is currently being delivered, If the following address is a post office box. please furnish the street address as recorded on the boxholder's application form: 1'"""-,.,.,......,-,......,",....,.,',',...,_..,...,',-',.,.,',',.,-,'-, ..,-,..,....,-, ,"",",..."....,.,',-" ........,-" ,,".,.__..,-'--~ I,_~ame: I~,~H~RD~~~~~~BA~ LO~G__,..__,_,____"",.,..,_.. l Addres~~029 LOCUST ST, HARRISBURG, PA 17109- : , __,_".,_...,_,_,.,.~,.,~.,.,~~__._"i,.;.,.~...;.;..:;;;..,...~.._...;,.~..~.~,..:.:....:.:, -- - - .____.__1 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. POSTMASTER PO BOX 9998 HARRISBURG PA 17109 REQUESTER: CONFIOENTIAL INVESTIGATIONS investigations & Legal Support $elvices 455 Linden St, Allentown, PA 18102 RR3, Box 2025 ,Effort, PA 18330,1901 Toll Free: 1,800,969-4827 The following information is provided in accordance with 39 CFR 265,6(d)(6)(ii), There is no fee for providing boxholder information, The fee for providing change of address information is waived in accordance with 39 CFR 265,6(d)(1) and (2) and correspond~ng Administrative Support Manu,fjl 352,44a and b,___~__"_,, f1' CapacitY- of r~quester (e%)p;ocess ~~rv~"r~ att~rney, "['PROCESS SERVER' ,,------ -------'-'.'1 party representing himself): ..-----.-....,i--......... , _I' 2, Statute or regulation that empowers me to serve I Pennsylvania Rules of Court. Service of Original Process and process (not required when requester is an attorney or Other Legal Papers. Rule 400. Relates to service within the, , a party acting pro se - except a corporation acting pro I Commonwealth and prescnbe the person who may make service, I i"~::::'::;\~.,"O fu"'""'ti~. --1 CO,O-- --- j f-~;;::o::~~:~:::~:::i~nTRTOF CO.MO' ~~:'F;'~) - 16, The capacity in which this individual is to be served i Il!IDEFENDANT OWITNESS OOTHER I 'I_'o'."'_",,\:':'~ def:nd~~~r witness):_,______.___..,_."_,L,_,,...,___, _,_J 7, Date of this ::,':uest:"...._,_,_..".."..,._"_,..,, I 08/28/01 ,__" WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR Af'N PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE , .fEE ,F.oR CH,lINGE,OEf\.QDBEssJJIIEORMATIO,N OHIQ:LMQRE..THAi'l 5.. YEARS,.DEl.8OTH.(TlTLE,18.U..S_G..SECT!ON,,1QO,1), ___' , I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation, "~fI:~~'\ ~~',"C;'~,','""""",,~;;;~,,_,., 2f- 'l . #<IHR",iL-P. ~'{,"""'''' " /f/l _ ,"""'.', \~ " 455 Linden Street I AUG, 3 r iOil1 J-.__ Signature Address \ --.. / ~~ Meqan Krotz Allentown, PA 18102 /~l'?1!i.""'~l' Printed Name City, State, Zip Code NEW ADDRESS ORBOXHOl.[)ER'SS1'R,EETA[)~DRESS ~ail is 'delivered to address given. o No change of address order on file, o Not known at address given, o Moved, left no forwarding address, o No such address, Name: Street Address: City, State, Zip: iI"';"'~~; ~~_I~Mf~"lilllllll- "~~~'ilM~>'!~.J",iw.'_''h~=<~i'~'',i',b~':M!MI;~_~!lW.ili'W~ 4U~",~",'f""""~""''"'_''''~ ~lI," __. "_~__ ~,~^II "_<~ _,,,,_~,,_~, ~_ , ~,. ~liIIIIii ,,'~,"'''''''"__''- _ ",~I"~_ ",' ,'_~ ,""" ,>'. ,"V, ,I", .. ~"-~'" ~,', ~ ,~~,., , ~, ,..- (') C (J C <--'" ~r ri{ f[: U':> ~'1 _..:- 1_, -u "2] ...:;....:::1:,; ,- Q~: ,-.,-, UJ ~~~~ u I g::C.1 JO> (;J -'~~ ~2 -q -\.' - C'5 ,-f,c5 PC' CD C) rn Z ''; =< f'" ~ -< . _0 c ~ ] '" , .. ~ " Beneficial Consumer Discount Company D/b/a Beneficial Mortgage Co. of Pennsylvania VS In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8426 Civil Term Richard p, Long a/k/a Richard B. Long and Barbara A. Long R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon Haller. Sheriff's Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Out of County Dauphin County Law Journal Patriot News 30.00 30.00 15.00 .50 1.00 25.66 11.05 15.00 15.00 1.72 16.40 20.00 9.00 29.25 335.15 281.64 $ 836.37 paid by attorney 10-10-01 Sworn and subscribed to before me So An~ P"Af' ?"12'c>';' -~,,~.... This /,} f!:; day of (l)eT;.J. . , _ R. Thomas Kline, Sheriff 2001, A.D. Yr. () k, i;;. ) .d!ftr q j. '): .~ ) BY Ou....c! ~ tIVU. Prothonotary Real Estate Deputy "0 n:' '-~ ~', ''''"'''''=->--. 'I\.. c)lL.:3'\').. 11td &,v-I I l-u... ~'"I , ~,J' -~; - .", - ,"";.. , ~ _ '2;. '! . " '/ BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO, OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's'Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M, LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 335 NINTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG "' - -," '~,::-;:::\~:' : ;:\---~~, '{iiN'<:,', ,"-' ,- < ! , , ,I < ,~, ,~,. "",-,,,;;], ':-,,-) '< ',- ,--, ,_;., ,_;;,..-.,';'i.i~ . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1, You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2, After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This " ,,--' n,"_ -'d _"_ ~ I ' - ,_ ;,.,.,-:,_ ,,'C ~,_. '-iL:;',,,,,,,-",,,_ ,"'-;~, '~. . , - petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ."'~'~ I ,~' _J . j c, ._<_ ,~ ; ,I " ' , ~-. . .. - ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland, Cumberland, County, pennsylvania, being bounded and described according to a survey made by Ronald S. Raffensperger, R.S., dated February 29, 1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, 50 feet wide, at ,the dividing line between Houses 335 and 337 Ninth Street; said point being measured 145.0 feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North 47 , degrees 00 minutes West, 100 feet to an iron pin on the Southeasterly side of an alley, 10 feet wide; thence along said alley, North 43 degrees 00 minutes East 22.50 feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; ,thence along said di- viding line South, 47 degrees 00 minutes East, 100.0 feet to a point on the said side of Ninth Street; tl1ence along said Ninth Street South 43 degrees 00 minutes West 22.5 feet to a point, the place of BEGINNING. BEING the Eastern 13.5 feet of Lot No. 36 and the Western 9 feet of Lot No. 35 on the plan of Seven Maples No.1, as recorded in the Cumberland county Recorder's Office in plan Book 1, Page 94. HAVING THERERON ERECTED a dwelling house known and numbered as 335 Ninth Street. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated August 30, 1985 and recorded September 3, 1985 in Deed Book L-31, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long, TO BE SOLD AS THE PROPERTY OF RICHARD P. LONG (A/KIA RICHARD B. LONG) AND BARBARA A. LONG ON CUMBERLAND COUNTY JUDGMENT NO. 2000 8426. PARCEL: 26-24-0811-218 """""'" ~ ~.. ~ i -j '"'~~~ ~ '" ,~'''' ,- , .-~ ~'. '" li""""~', WRIT OF EXEC!JTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 00 R47h CIVIL Jtll TERM CIVIL ACTION - LAW TO THE SHERIFF OF. Cumberland , . , Cb0NTY To satisfy the debt, interesl and costs due Beneficial Consumer Discount Ccmpanv Beneficial Mortgage Co. of Pennsylvania from Richard P. Long A/K/A Richard B. Long and Barbara A. Lonq 335, Ninth street. New Cumberland. Pa. 17070 D/B/A PLAINTIFF(S) DEFENDANT(S) '(1) You are directed to levy upon the property of the defendant(s) and to sell Levy 'upon and sell the property described in the attached description known as 335, Ninth Street. New Cumberland. Pa. 17070 ,:,:-p.-' (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as tollows: and to not~y the garnisnee(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 in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated Amount Due Interest at Interest Atty's Comm Atty Paid Plaintift Paid $ 97.083.48 $34 . 84 per diem 8,€iQ5.48 to sale date L.L, $0.50 Due Prothy 1 nO Late Charges at $53.96 per month to Other Costs 5177 7? Escrow Deficit $2,000.00 sale date % $?hh 7') Date: June 12. 2001 Curtis R. Lonq Prothonotary, Civil Division by C};L. 0 ~ I Deputy REOUESTING PARTY Name 1,eon P. Haller Address: 1719 North Front Street Harrisburg, Pa. 17102 Attorney for: Pl a;nT; ff Telephone: (717) 234-4178 Supreme Court 10 No, 15700 n:w In Test";~~~Y FROM ReCORD and the seal of BOt, I hare unto set my hand Th#a /,; ~ da~jd ~rli6le, Pa. t )'lL 0 ~ - ~11~~/ Prothonotarf i~~i@.,t;;iil.1'Ii,~6<~-"".i:":''''~';''''';''-#,'''''\-i!t-p,j~I0dIli'.E0J:,$,;~,'''''';#J'~;;ctk,,,,,,c;"-,/"\,,,,'C'~'''';':,i,0''';,\-'~''"'"--",;!in'llicl!~1~i'~_~lh'l\1i"'~-!i~lililil!lllltt~w~~ . ' ~..... REAL E~TATE SALE NO.4 \ e,i :fuN.. 1'5. ~OO\ thr "'P""" 'evier 'J~OIi tht jetp,,"~.. ' Interest in the real pro()er1v .. N.luJ wvY\~,,~rc(t l"'!lbered as: 335 f'y~ S\-.- Cumberland County f ?;;" f\fu.J CjN\~~nd mom , " ' -1 fllI1! exhibit "A" flied !ti~'f', this writ and by this mfemnoo ,1';j!~~rated herein. Oat8~..:ru tU.. is I d,CO I By~ SvU,th ~uty .svwu ~ VIr,{V i\ l) S 'I N 3d :~ --; ,~ ! ...~. 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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 The Patriot,News and The Sundav Patriot,News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot,News and The Sunday Patriot-News were 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 and 31 st day(s) of July and the 7th day(s} of August 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", Notarial S"I S ALE #41 Tarry l. Russell, Notary P I~ HanlsbUlll, Dauphin My Comntission Expires June 6, TARY PUBLIC Mamber, PennsylVania ASsooialion 0/ NolIri.' My commission expires June 6, 2002 , I CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUR1HOUSE 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 $ 280.14 1.50 281.64 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........,........................................................... "y., REAL ESTATE SM.E NO. 41 Wrtt No, 2000,8426 Civil Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co, of Pennsylvania vs, Richard p, Long a/k/a Richard B. Long and Barbara A Long Arty,: Leon p, Haller ALL 1HAT CERTAIN piece or par- cel of land. situate In the Borough of New Cumberland, Cumberland County, Pennsylvania, being bound, ed and described according to a sur- vey made by Ronald S, Raffensper, ger. RS.. dated February 29, 1980. as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, 50 feet wide, at the dividing line between Houses 335 and 337 Ninth Street; said point being measured 145,0 feet to Oak Alley: thence along the dividing line between 335 and 337 Ninth Street; North 47 degrees 00 minutes West, 100 feet to an iron pin on the Southeasterly side of an alley. 10 feet wide; thence along said alley, ,North 43 degrees 00 minutes East 22.50 feet to an iron. pin at the dividing line between Houses 333 and 335 Ninth Street: thence along said dMding line South 47 degrees 00 minutes East. 100.0 feet to a point on the said side of Ninth Street; thence along said Ninth Street South 43 degrees 00 minutes West 22.5 feet to a point, the place of BEGIN- NING. BEING the Eastern 13,5 feet of Lot No. 36 and the Western 9 feet of Lot No. 35 on the Plan of Seven Maples No, 1. as recorded In the Cum, berland County Recorder's Office in Plan Book 1. Page 94, HAVING THEREON ERECTED a dwelling house known and num- bered as 335 Ninth Street. BEING'THE SAME PREMISES WHICH Kevin B, McCartin et al by deed dated August 30. 1985 and recorded September 3, 1985 in Deed Book L-31. Page 705 granted and conveyed unto Richard p, Long and Barbara A Long. TO BE SOW AS THE PROPER, 1Y OF RiCHARD p, WNG (A/K/A RiCHARD B. WNG) AND BARBARA A WNG ON CUMBERLANDCOUN, 1Y JUDGMENT NO. 2000 8426, PARCEL: 26,24,0811,218. <'~- ~ ~' ~, C", ;~ ' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 20, 27, AUGUST 3, 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. RO~Editor ~ SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 " NOTARIAl LOIS E. SNYDER, ~ PublIc QdMilorQ, ClIIIbeIlalld CotInIy , My ComIIllllan ExpiII8Ma1l:h ~ 2005 "" , ""'C' ,""'"' ""- ~. ~ ~~~ ~ , -;; L , ] - '~- '~ "~~__ ~ J ~~' ~IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2000 8426 BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO, OF PENNSYLVANIA, PLAINTIFF TOTAL AMOUNT OF JUDGMENT $ 97,083.48 Interest at $34.84 per diem to sale date $ 18,116.80 Late charges at $53.96 per month to sale date $ 809.40 Escrow Deficit $ 2,000.00 TOTAL $118,009.68* VS, RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS *SALE DATE: WEDS.,JUNE 5, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the oned case. Date: March 12, 2002 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. Haller PA I.D. #15700 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 335 NINTH STREET, NEW CUMBERLAND, PA 17070. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY M;~_~l!f.~i*11S~:>''';;:':i",'iftill'JX'''!\:f1liliJ''''IM'H,\>iil~<l''''~,;f,'",~n;''',!!n,,'d;.',,"",l,",""'~" "- ]v ~ ~ y ~-". (:J It.rt ~ --.J ~ t ~ . o () f} --- ~ ~ Ut '-..' ~ , ~,J ';;J,"t~fu{'i:Wil''iilli8l''ffiJ " -l;~ ~-ofrtr-~ gg~~~ I j ~ ::- ~ ...... .:; ~ -... "'" ,~,Jl=_ ~_~, _~,~, l1iili. "!' ~_ r. , ~ ......~o(q" ~r-~~ ~ 8 ~ Q I I () ~ ~ r f! ~ ~.~ LJ =~ -..ltIIi-.liiltfd;''ii""''''- ~ 51~BhiI~ol.i!N_ <::) 0,.'>0 c: s: -oO".'! rnrr~ Z:L &;~~. :::;,c" ,<:,L J:-....,~-; ~Z(~) 5>e: :z; "., -<. ."A ~~ ~-.J II I' I " C' "",1 :3: S; ~---j -'1 ;'''ir_:, -c"'I" 'i;~9 , .-' (~; w -0 -~,~ 0.~~ 5::; -< :-......... (,Il I if~.-~ r 1I.iLlI'" - l _ ~l ~ " ._" I 1 < ,~ ~e . ALL THAT CERTAIN piece or parcel ofland, situate in the Borol,lgh ot:New Cumberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made by Ronald S. Raffensperger, R.S., dated February 29,1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, fifty (50) feet wide, at the dividing line between Houses 335 and 337 Ninth Street; said point being measured one hundred forty-five (145.00) feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North forty-seven (47) degrees zero (00) minutes West, one hundred (100) feet to an iron pin on the Southeasterly side of an alley, ten (10) feet wide; thence along said alley, North forty-three (43) degrees zero (00) minutes East twenty-two and fifty hundredths (22.50) feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; thence along said dividing line South forty-seven (47) degrees zero (00) minutes East, one hundred (100.00) feet to a point on the said side of Ninth Street; thence along said Ninth Street South forty-three (43) degrees zero (00) minutes West twenty-two and five tenths (22.5) feet to a point, the place of BEGINNING. j HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 335 NINTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated 8/30/85 and recorded 9/3/85 in Deed Book L-31, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long. TO BE, SOLD AS THE PROPERTY OF RICHARD P. LO~G A/K/A RICHARD B. AND BARBARA A. LONG ON JUDGMENT NO. 2000 8426. "i1i; ,'I, -< : LONG PARCEL: 26-24-0811-216 , , ' ,-~". , , I, . " _ ""J ,_ ~ , ~ "'__t. ',!_i_ '-'""^"'"'; BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO, OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 335 NINTH STREET, NEW CUMBERLAND, PA 17070: 1. Name and address of the Owner(s) or Reputed Owner(s) Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4, Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Beneficial Mortgage Company 4910 Carlisle Pike Suite 104 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN ,'I ~~.~ , 'y - J-. " ,-'-, .~~'~'-, 6, interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7, Name and address of Plaintiff has knowledge who has may be affected by the sale: TENANTS IF ANY.,. Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 every other person of whom the any interest in the property which (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. DATE: March 12, 2002 Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 i!fi~'f:i!;~Ili>Ul~~~l<i!F;ti"l.IiiH~!;!jM..~.Ml:'~"-~~""'''''~'"'.t__'''''',L''i'~'""":i'_"'~'_'~ll"Oir:ot~!lmfi!'.~~'~' ItllrOO ,,.,. ,>~,--,,~ .- ',~ ~"'-- ~'" ~"'''~' ~,," ,_. ,~~"'- ","'"~, _ ,~,L", -, ,,~,,~,'_, ~ ,_ '" , ~~.~='~"~l~'-' ,~ 0 <=> , "~~ C f-,,) ::;: 3: "'U en ~;~ m!Tl ::xl Z:'D ;?::c ~~{ G.) <C.' ---0 ):>c: z('--} )>r- --- Z 1':> ~ ()"j , ':' . nP"'"~ ~ '-'"""...._'~ ~ _.. J , . ~ -". b, ~ ~ L' - , '~"'~IIi$lllllifl$l~f>>-'_" , BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 5, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner(s Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 - THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be $,old . "". - ,())~ , " " r is: 335 NINTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME (S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD P. LONGA/K/A ,RICHARD B. LONG AND BARBARA A. LONG ,;:".;. --,"~, ~.-..- - _J _.... L ~ ~,~l ~J,~lt'l&J~, A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and ,to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TLME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away, A lawyer can advi(le you more specifically, of these rights. If you wish to exerc~se your rights, YOU~' MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249~3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 .'; ,'i~\,~ .1(1. , 1'.- ,'; THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the withi]l C01,mty to set aside the sale for a grossly inadequate price, or for other proper cause. This l;V.>>ll,~" ~= '.~" -~ petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. ,-,- ~' l ,--," 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on ,the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execut~onis attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 , : f>, ':,) J(II, J '(, , ' ;""''"~--~- .. ALL THAT CERTAIN piece or parcel ofland, situate inthe Borough of,New Cumberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made byRonald S. Raffensperger, R.S., dated February 29,1980, as follows, to wit: , BEGINNING at an iron pin on the Northwesterly side of Ninth Street, fifty (50) feet wide, at the dividing line between Houses 335 and 337 Ninth Street; said point being measured one hundred forty-five (145.00) feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North forty-seven (47) degrees zero (00) minutes West, one hundred (100) feet to an iron pin on the Southeasterly side of an alley, ten (10) feet wide; thence along said alley, North forty-three (43) degrees zero (00) minutes East twenty-two and fifty hundredths (2250) feet to ann-on pin at the dividing line between Houses 333 imd 335 Ninth Street; thence along said dividing line South forty-seven (47) degrees zerO (00) minutes East, one hundred (100.00) feet to a point on the said side of Ninth Street; thence along said Ninth Street South forty-three (43) degrees zero (00) minutes West twenty-two and five tenths (225) feet to a point, the place of BEGINNING. ^~:/ HAVING THEREON ,ERECTED A DWELLING HOUSE KNOWN AS 335 NINTH STREET, NEW CUMBERLAND, PENNSYLVANIA, 17070. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated 8/30/85 and recorded 9/3/85 in Deed BookL-31, Page 705 granted and, 'conveyed unto Richard P . Long and Barba},a, A . Long. TO BE SOLD AS THE PROPERTY OF RICHARD P .tOl\lG A/K/A RICHARD B. LONG AND BARBARAA. LONG ON JUDGMENT NO. 2000 a:~,*6. , ~1~~1 " (, PARCEL: 26-24-0811~216 ' ';;" l.' .' ".' ~'~lillllili~\fw' 1~~lWt-mll~lli!il\$it1*;5r)'A;Mi:rilsl>'!it'-o1:~i!J~~W(f,r~,*,l<0>"i0:,*,;;'''-'"',"'''d ,",~,""~""",,_;iOi;;k'-:&,M~"';'" b:li:;;.:"~~"; ~"' II ="L~_" 1'\",," "~,'__,,~, ,,,'~~~ I~ W""''''~_' ~, - ;r Jx\ Ii '! 0 0 , , C f'-..J- -0-"1 S :;!:. "un; 1~-"" r;l r-~ ; ::;.::1 Z::C ZS, C,,J ~=-~ ~c:': c-::) -0 " ; >,-, - , ;! ~9 ' , 'on , , ~- ~:~ ~ C,) ::-:) (Jl -< - -~ , BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS ",,- j, "- _i! ,-I i '" '. ~" '". IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 4- -)1--(/.:2. ,a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129,1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A, Long 335 Ninth Street New Cumberland, PA 17070 Beneficial Mortgage Company 4910 Carlisle pike Suite 104 Mechanicsburg, PA 17055 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 i'~:W"' '^ ."',~ '. b.J ~- t. _,~ l_i - ,.J,',,, '-''''-:im" ,,' J JOHN W, PURCELL HOWARD B. KRUG LEON p, HALLER JOHN W, PURCELL JR BRIAN J. TYLER JILL M, WINEKA LAW OFFICES PURCELL, KRUG AND HAlLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102,2392 TELEPHONE (717) 234,4178 FORECLOSURE DEPT, FAX (717) 234,1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533.3836 NOTICE TO: Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 Beneficial Mortgage Company 4910 Carlisle Pike Suite 104 Mechanicsburg, PA 17055 Domestic Relations Office , ,,~umberland County Courthouse Hanover & High Streets Carlisle, PA 17013 .'~':('-{f,~-)',;".<." NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to pennsylvania Rule of Civil Procedure 3129.1 attached )).ereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, if any, said Sheriff's Sale. against the said u have an eing otified of By: Leon P. Haller PA I.D.1S700 Attorney for Plaintiff "g~ , " " 'q ~w ~, ' ~A!illfllili! . .A , BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B, LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 5, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land" (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 335 NINTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG ,__Lo ." ." -~. ~ ~ ..""'"t,i A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE; Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you, 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or"for other proper cause. This e=-:....'->=l. ~ r _, -.,--d:'''_' -~,;, _ "c'.-' "~" ~,;., petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~~~.--" ~ ~ "" - 1- , J '"'_~ ......~ . ,.' ALL THAT CERTAIN piece or parcel ofland, situate in the Borough of,New Cumberland, Cumberland County, Pennsylvania, being bounded and described according to a survey made byRonald S. Raffensperger, R.S., dated February 29,1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, fifty (50) feet wide, at the dividing line between Houses 335 and 337 Ninth Street; said point being measured one hundred forty-five (145.00) feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North forty-seven (47) degrees zero (00) minutes West, one hundred (100) feet to an iron pin on the Southeasterly side of an alley, ten (10) feet wide; thence along said alley, North forty-three (43) degrees zero (00) minutes East twenty-two and fifty hundredths (22.50) feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; thence along said dividing line South forty-seven (47) degrees zero (00) minutes East, one hundred (100.00) feet to a point on the said side of Ninth Street; thence along said Ninth Street South forty-three (43) degrees zero (00) minutes West twenty-two and five tenths (22.5) feet to a point, the place of BEGINNING. ,,/ HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AS 335 NINTH STREET, NEW CUMBERLAND, PENNSYLVANIA 17070. BEING THE SAME PREMISES WHICH Kevin B. McCartin et al by deed dated 8/30/85 and recorded 9/3/85 inDeed Book L-31, Page 705 granted and conveyed unto Richard P. Long and Barbara A. Long. TO BE SOLD AS THE PROPERTY OF RICHARD P. LONG A/K/A RICHARD B. LONG , ~. AND BARBARA A, LONG ON JUDGMENT NO. 2000 8;.l-~6. PARCEL: 26-24-0811~216 'I'll ,'I, ,':: , , , , :i.~.L.~~"",," ~ I ,",'" '~ - .-, ~~-- -ft~':"- . Re: BENEFICIAL MOTGAGE COMPANY/LONG, Richard p, & Barbara A, Cumberland County -sale- 06/05/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: RICHARD P LONG NKlA RICHARD B LONG 335 NINTH STREET NEW CUMBERLAND PA 17070 U. S. POSTAL SERVIGE CERTIFICATE OF MAIL]NG (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: '" BARBARA A LONG 335 NINTH STREET NEW CUMBERLAND PA 17070 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: BENEFICIAL MORTGAGE COMPANY 4910 CARLISLE PIKE SUITE 104 MECHANICSBURG PA 17055 ~"-' ,-I ~; '"' .. ~, . U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: . One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HANOVER & HIGH STREETS CARLISLE PA 17013 ~~i!i!,:;j!I;Ii;j~~g,g,"'_]@"\!'i"~mi-il'_f;g,6i11eio<<K\'~,~;~~Cl;"'t.;"):li",,"'":;';,;"oJl'U--;:;"":-~"'-{;;-'N"'''''''''fThili&~1IiM-IIit'-''';'~tlf \' ~-""""~--,"",, , " -,,' .,~"-"_,, ,,,~,,_~. "_,,,-_" _,~~~ ,... _I . ",",r_"" 0'" ,~< ,'~, ,'''. =~, - ""-' ~~i!I!1Il~~" ,~..,,~ .~ --~~< "" () ~;, i/ (.0 _~:-. -< ". ,.,.., ." ~-,- ( i-:;; :s:f," <: -, -< ~--, ~" , ~ , . ~, !.~:' _2: ---~ ~:", , {\) CD j -, 'i.;! ",,:()' cjrn :i:! :n ,'"" .'LJ '-.} ~jZ;, McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA V. RICHARD P. LONG AfKJA RICHARD B. LONG : AND BARBARA A. LONG COURT OF COMMON PLEAS CUMBERLAND COUNTY NUMBER 00-8426 CIVIL ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as co-counsel on behalf of Plaintiff, Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania, in the above-captioned matter. (~~trrtw TERRENCE J. MCC BE,'ESQUIRE oJ , , ~"""~~~~:m~j~.~li1 ~- ~-~_~liihi!l~f<w~~:~~~~i8ldblRi&. ~" ,,~ _"~~v~,_.. ,",_I' ~~-,=~- il- ~,~, ~,,' jf'(' ~ ~''''', o N ::\l: ~ g ~, ~CQ ~g:) ZC~ <.n -.;" 2,;;,; n ,.-v ~Q ~O J"C ~ - ," (".:l -0 :% o -n C"-1 -,-..1'1 ;-'i'r: 'om ",0 (')h ~-r, QB z.:rn g ~ - t.:? '" <1' , , i'" _' "-,->,-,-; '"",,~ J:i.' , BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PE~SYLVANIA PLAINTIFF VS. RICHARD P. LONGA/K/A RICHARD B.LONGAND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 2000 8426 " ,IN MORTGAGE FORECLOSURE MAY 1 2002 PROTHONOTARY'S OFFICE CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 RE: BENEFI,CIAL CONSUMER DISCOUNT COMPANY, ET AL VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG CUMBERLAND COUNTY; CCP; NUMBER 2000 8426 ACTION IN MORTGAGE FORECLOSURE PREMISES: 335 NINTH STREET, NEW CUMBERLAND, PA 17070 Dear Sir/Madame: Enclosed please find the original and one copy of Affidavit of Service relative to the above-captioned matter. Kindly file the original of record with the Court and return to my attention the time- stamped copy in the stamped, self-addressed envelope which is provided. Please advise promptly if there are any problems in this regard. Thank YOU for your assistance in this matter. Sincerely, ATTORNEY FOR THE PLAINTIFF /nh Enclosure cc: Office of the Sheriff/Real Estate Division -"" -" ~ ,~ " ' . ; ';'"_'~-o'" '''''' ". ,- ~ ~1S;;.l&!J:i~1..[: r BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONGA/K/A RICHARD B. LONG AND BARBARA A.' LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 " ,IN MORTGAGE FORECLOSURE AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the lOth DAY OF MAY, 2002, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A" . Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." , SWORN TO AND SUBSCRIBED BEFORE ME THIS lOth DAY OF MAY, 2002. '" -~, ;,1 "I . ~ " 'wj~i , r BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 " IN MORTGAGE FORECLOSURE AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 335 NINTH-STREET, NEW CUMBERLAND, PA 17070: 1, Name and address of the Owner(s) or ReputedOwner(s): Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. LOng, 335 Ninth Street New Cumberland, PA 17070 . j 2. Name and address of Defehd,mt (s) in the Judgment, if different from that listed in (1) above: SAME' ,3. Name and address of every judgment credi1ror whose judgment appears of record on the real property ,to be sold: :; ~:'. '~';;~- .'. 4. Name and address of last recorded h6fd.er of, every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : ,Beneficial Mortgage Company 4910 Carlisle pike Suite 104 Mechanicsburg, PA 17055 5, Name and address of every other person who has any record lien on the property: UNKNOWN T "",,I,A ,'" EXHlB\, '" ~~-,- _ l-,~ ",-,,--- . ,~ -": . . 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of ,plaintiff has knowledge who has may be affected by the sale: Domestic Relations Office Cumberland County courthouse Hanover & High Streets Carlis1e,PA 17013 every other person of whom the any interest in the property which Commonwealth of Pa Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 Tenant(s) 335 Ninth Street New Cumberland, PA 17070 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my Personal knowledge, information and belief. I understand that false 'statements herein are m~de subject ,to the penalties of 18, PA C. S. S.::;ction 4904 relating to unsworn falsification to authorities. Leon P. Hal~r PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisb~rg, PA 17102 (~). 7) 234~4178 "-f,. DATE:, ~~ \C\ 8~~~ :;.~\ ."~:~"q, " .'\ ! T "A" "'EXHlBl, r'\ -0 .(;J ~ o 3 '" co ... .:" )> ~ ~ ~ ill. '" o o o ,-I', ..... 'j ->. w'z. (J1' ~ <5"m~ ~zl' ~ c g>~1 ' , g.g, , " " ~ . CJ ,H .0 ~[ [if .3 :;[ gg, -" ~~., . . " o ~ ~ .~ " ~ o o 3 " 'C . ii' 3 ;- . tT Q, '< " o ~ ~. 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N ->. if [ I , 'bl ft :5""" Ie. ~C./ I :> '" <>: G Z c 3 ,cr ~ Z m 3 . m ~ -U _ 1e :!;~~ ~O~ mcnc::~ !:Og-:i!~m ~m"'~<il "'N;;o )> ~OOtDZ )>~e;:=O ",00 ~ ;tizO o m(i)Z -0 !!1 ~ :< '" p ~ ~ DODDO 9 I p (;> 0 6: P'!i'g~! ~" '~f ~ ~ ~!r~ l ... (/ ::>:i: =::r 3 o O~ i : T ,~I g ~ I~ 1? [! I 0000 ~ I - I I rg ~ I f!}'I "''I ~ -..1 ~'... ~ E'~, 8 1910l ~/j,:~!UU I~I rr; ~IHJ I 01 [QG' I g f I I (/)1 r5151 g i "'! I ! M4~ I ~ ~~~ ~~~ ~ (jj~f'S::g~ X 19,~Q,&Q~!!2 1~~~a.l:3 ~i:O J:t~~ QI 'C (}:J: .~:::l.s 1is :r: gg ~ ~ ~ cO@: I CD Gl,g j tion ,-:> Il[! ~<! ..' ,- , .~ ~. I~\i , (l"'1 Og:, jCc.l ~l -"01 :Co! "",1 1;0 1"11001 19:Ij I I~~! I I"~I I j<<> i EXHIBIT "B" ;:ii:/ 5@! ~l :'::::-~":.""":"-:;"~'. ;iW~iI_W1ftrll;?!;,.::i!"",m",,-",':l~:,gJ.i<jaf-'" ~i"Chf"~""Eii-~_'"ill!!aLjf;.~~L.-' " "-~" ~,~ ~, -'-''''Co,''''0o -",<~H_;;~<,'.4ili~iJIiI_.MJW~--~."~'''":~~'~''W~tilW~~~iiII~ h_""'_.!!I~.......""",," w, '~ 0 a 0 c- ''0 $: -q ,-, r::U :1: =-:':,~ no r'i'; J:::.. "7 ;;'1:;: --< " ~ 7 1'0 r- 0'1 >" _';rn Co ;_':."C? J-:';': C ~ :::.... :=.;<-? ~'-' :2:: CI ::1: ,'j :-0 5.:; ;;2 5 C) () en 2~ :;;: --I "'> -.:c C) :1:1 -< I"~ ' " ,> I, ~~ -- ,~ ~' , McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 ~hilade1phia, PA 19109 (215) 790-1010 Attorney for Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONGA/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 ., IN MORTGAGE FORECLOSURE FINIAL AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 24th day of APRIL 2002 and on the loth day of MAY, 2002, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." ~ SWORN TO AND SUBSCRIBED BEFORE ME THIS 27TH DAY OF AUGUST, 2002. 1;f;uk~ if, ift;t~ NOTARY PUBLIC '."''''''' ' " " -.'~.., ..,'-..'.".1 ," l\iU rJ,kli,t SE.At ' '. ":CIIELLt ')(, llCIJ\CIK, Nota!)! Pubho ' ~i;y' oj Philad~ph.ia, Phila, ColJnty "', lAii nmlsSlOlll:Xmres Ma!'!)h 28, 20()~ I ____._ _,,_':__,'_'..c,,-.'""'''''-_~' , d'l.,,' ~~~ .~. -~..~ '., ~" '. ",-_,I 'e ..""~ . McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff ,BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS AMENDED AFFIDAVIT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 2000 8426 0, IN MORTGAGE FORECLOSURE PURSUANT TO RULE 3129 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as'of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 335 NINTH -STREET, NEW CUMBERLAND, PA 17070: ' 1, Name and address of the Owner(s) orReputedOwner(s): Richard P. Long a/k/a Richard B. Long 335 Ninth Street New Cumberland, PA 17070 Barbara ,A. Long 335 Ninth Street New Cumberland, PA 17070 j ....; , :< 2. Name and address of, Defendi3,nt (s) in the Judgment, if different from that listed in (1) above: SAME' 3. Name and address of every judgment credit-or whose judgment appears of record on the real property ,to be sold: 'e , ".. , " ~~~:~- . ,~I-.., .. 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : , , , , , , Beneficial Mortgage Company 4910 Carlisle Pike Suite i04 Mechanicsburg "PA 17055 5 . Name and address of every other person who has any record lien on the property: . ' UNKNOWN , 'B' \1 <up\' EXH\ - "" , '" " ,L, _ . b' ".t ~_ ,~" ''''<Lit 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN ? .. Name and address of every other person of whom the 'Plaintiff has knowledge who has any, interest in the property which may be affected by the sale: Domestic Relations 'Office Cumberland County courthouse Hanover & High Streets 'Carlisle" PA 17013 Commonwealth'of Pa Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 Tenant(s) 335 Ninth Street New Cumberland, PA 17070 (In the preceding information, where ,addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the, best of my p~rsonal knowledge, information'and belief. I understand that false 'statements herein are mc(de subject "to the' penalties of 18' PA C. S. S-~ction 4904 'relating, to unsworn fals'ification to authorities. JJ~ DATE EXHIBIT uP:.' , . , ' '"', . ,> '0" _,- .,',,~ ~ .' -L '~-) Re: BENEFICIAL MOTGAGE COMPANY/LONG, Richard P. & Barbara A. Cumberland County -sale- 06/05/02 u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: RICHARD P LONG NK/A RICHARD B LONG 335 NINTH STREET NEW CUMBERLAND PA 17070 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: BARBARA A LONG 335 NINTH STREET NEW CUMBERLAND PA 17070 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: EXHIBIT "B" BENEFICIAL MORTGAGE COMPANY 4910 CARLISLE PIKE SUITE 104 MECHANICSBURG PA 170S5 - ,';;'" 1 , '"~ .~ .. ' ,'-i- U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS OFFICE CUMBERLAND COUNTY COURTHOUSE HANOVER & HIGH STREETS CARLISLE PA 17013 EXHIBIT "B" ,-,.j. i.Il8iIi"""-'~'~ ~~ ,. '; 0;' ..-. '" co '" 1 ... tftt i7 '" IV [~I\f' W \ N i.... 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' _~~~.OF aii~g~i U>i;3.Iil"~~ Ill.~.l"i ~;::~3~ , U>~.. ~c:: II) at~3. ~~.. ~~<1 i1iQ'i/il3';>~ :Q~: ~ [~~ \!:(~~~<\l."2.."U ~o.~~~g~ . iie:<D-<lIlr:::f a~Q''g~~ ~.al!lQ I [()iO'6"~ I . ... .-> -00 .-> 00 ...oN ~ -oJ 0) tion I ~ fi II EXHIBIT uB" I~ !l ~ Z " ~ ~ z . 3 . . o ~ ... ~ ~ :rl'>~ s; ~"""'~ \:) 0 mcnc: r-C-'Zm "::;:1:-;;0 ~mooOlil "'N"'Z~ - co... :::!!""~c:~ -00;:::- ...... (AOO ~ ;tizo o mG>:?: '0 -l ~ :< '" f> 00000 9 . 5'(!,oo~ ~ A: "" -6 !!!. 0;:1 "t Q. i CiI ~ Os; "0 i a. =~ lit Ql (I) :s::~ g, : ~3. 3 z 3 ~ III t 11t g ~ g '" :i ,!l . o '" " o ,. '" '" . . U> DODD cn;:o;:o;:o .g~~8 fll3""a ~;oflll 41.410. 00.0.0 o. . :::1"0 = ~- < :3 Q' ~ 8<~ s- ::II I $" ff .!\ lii'd'.fl ~~~ ~ i,. arn.: ~!! x I ~ g,i SI,!~& g: I J~~~st= ~ ICba. t:r_a III 'lJ OJ: 2::r.s-~ :r =rm fn.Cl.. ~ (tI lIlal""" . a; <D~I I"''', ;nSl! I~[l !!.<! ~~ 1 "'~ <::Jl ~~! <D~I =o:il Oml o~, o~l ~ "0 mo "'" mo I,,", 1m:!: , ''';>3 1:0 , i~~ jQl '" '" ;.,- l....~ij, . . s ~ :.:."..:>.:-~...~-.,~,-:. :-. Jil~WMtWI<!'Jt-4d,fu,"",Ii'd"i-f",,,d;,;"';'~"',".ffi;,,,,""""""""~!ol'_d'-"h\o,,,"-,""";" '~.~", 'n_'"'o"'d,&o"-",,;i!,,,ci>~ik:~_i'ft"'~-''''"''~l~=>~'~-~ ~~',i.~_-"" " A.dIlliJ1iii!Ii8Ji'll........... 'I ,I I il () Cl 0 C 1'0 " <"" (/) -oC''' '-4 md-: l"'1 ~~~ Z:::-.) " zy , ~g8 ~:-} G,) C,)<:, r:::o ~C) " ::t 2j :x () .,~,J >2 ->(") r:y C5rn Z ,,-,-\ -l 1] -< .-J -< ,,=-'_ "'u~__",~,='".. ," . _ ,,~"" " ",,_~- ,,~_"______', _~_ "~-,,<>,\,,,(,j _, ~4"'" 'h'"'-' ',c_"" "1.-,_,,, fe", ._,___ '._' ~"~ ~" ~," "_,-;_1""",",_.. ".. " ~"","~", ,^, ,,~,,-- ~ "~ J I ,; , , JiilIlI.J>&. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Beneficial Cons Disc Co d/b/a Beneficial Mtg Co ofPa is the grantee the same having been sold to said grantee on the 4th day of Sept A,D., 2002, under and by virtue of a writ Execution issued on the 13th day of March, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2000 Number 8426, at the suit of Beneficial Cons Disc co d/b/a Beneficial Mtg Co ofPa against Richard P Long aka Richard B & Barbara A is duly recorded in Sheriffs Deed Book No. 253, Page 3677. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this Plfo day of .J1Jo.% , A.D. 2002 . I ~IJ~ (3, ~~" J~Jj~ I R~corder of Deeds ~eo::-~"==C;:'~ ~" L " ;_,1 ~. "~'.';i . . Beneficial Consumer Discount Company D/b/a Beneficial Mortgage Co. of Pennsylvania VS Richard P. Long aIkIa Richard B. Long And Barbara A. Long In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8426 Civil Term Valerie Weary, Deputy Sheriff, who being du1y sworn according to law, states that on March 28, 2002 at 10:30 o'clock AM, EST, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Richard P. Long aIkIa Richard B. Long, by making known unto Richard Long personally, at 700 Lisbum Road, Apt. #5, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Harold Weary, Deputy Sheriff, who being du1y sworn according to law, states that on April 2, 2002 at 12:35 o'clock PM, EST, he served a true copy of the within Real Estate Writ, Notice and'Description, in the above entitled action, upon the within named defendant, to wit: Barbara A. Long, by making known unto Barbara A. Long personally, at 601 3rd Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2002 at 2:27 o'clock P.M., E.S.T., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard P. Long aIkIa Richard B. Long and Barbara A. Long located at 335 Ninth Street, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Richard P. Long aIkIa Richard B. Long, by regular mail to his last known address of 335 Ninth Street, New Cumberland, P A 17070. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attorney Terrence McCabe for Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co. of Pennsylvania. It being the highest bid and the best price received for the same Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co, of Pennsylvania of P.O. Box 8621, Elmhurst, IL 60126, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of $877.22, it being costs. ~y 3b,1J11 ,(}7 I, tJt. ~l'2~J- ~. /3iJ'iO'J ~"....... ~ Shedfr s Costs: Docketing Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed ..i"1 ~~ ..Jiilltuli?' $30.00 17.20 15.00 15.00 30.00 10,00 .50 1.00 33.81 1.81 15.00 30.00 20.00 325.85 251.35 25.20 25.00 30.50 $ 877.22 paid by attorney 9/20/02 Sworn and subscribed to before me This q l{? day of ().~ 2002,A.D.~ a~.~' rothonotary ~/ ~ :c _,~:: rY~-7~~' ~ R. Thomas Kline, Slieriff ByJocL-j ~ Real Estate Deputy -~-~ .-,~I '. _"~~_r_ '-~ " BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD p, LONG A/K/A RICHARD B, LONG AND BARBARA A. LONG, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 335 NI:trrH _STREET, NEW CUMBERLAND, PA 17070: 1, Name and address of the Owner(s) or Reputed Owner(s) Richard p, Long a/k/a Richard B, Long 335 Ninth Street New Cumberland, PA 17070 Barbara A. Long 335 Ninth Street New Cumberland, PA 17070 2, Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name Clnd address of every judgment creditor whose judgment appears of record on the real property to be sold: of . ,: ',~ ", 4. Name Clnd address of last record: '~:, {~' ~ ' '~, recorded 1:l~J,.der of every mortgage ,\1 PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Beneficial Mortgage Company 4910 Carlisle Pike Suite 104 Mechanicsburg, ,PA 17055 5, Name and address of every other person who has any record lien on the property: UNKNOWN -j:!~ 0" .L .. ~~_. h___~'.....o- -~' "","'L~j",,,~,,,, 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief, I understand that fals~ statements herein are made subject to the penal ties of 18 PA C. S. Section 4904 relating to unsworn falsification to authorities. ~" Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: March 12, 2002 ; ~'. ~ ,\ .J ,~I,_ ; , "~, ,> _',~.'--~- I~ ~. .' 1 L..._~ , ' ~~=~~-" ..~-, __~""";'_""'""1' # BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO. OF PENNSYLVANIA PLAINTIFF VS. RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG, DEFENDANTS IN THE, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 8426 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO pgNNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, JUNE 5, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner~ ,s Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 J THE PROPgRTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be 'Sold -:'-'-1\ ,,(Ii , " ~~ is: 335 NINTH STREET NEW CUMBERLAND CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2000 8426 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RICHARD P. LONG A/K/A RICHARD B. LONG AND BARBARA A. LONG J.jQI;-"~ -, . ~" '.~__ u _"~ -____~~..~,,~"""'_~'~"M'"""_' ., A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE T~E AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away, A lawyer can advi~e you more specifically. of these rights. If you wish to exercise your rights, YOU..! MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 , " , THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you.' 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the withil1 County to set aside the sale for a grossly inadequate price or for other proper cause. This ",,,,,"b~,,,,,~.~'> ~~ ~-~ <L~""""",,~ - -, b."".~-""""",*,,*,I"'a_"""""'-~~-~ ' ''''';;'''-'''''IN!>1;!,*,'i, ., petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3, A petition or petitions raising the legal issues or rights mentioned in the ,preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execut:i,onis attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ,- :-..', \;<~" , ',' ,'i 'f ALL THAT CERTAIN piece or parcel ofland, situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, being bounded and describedaccording to a survey made byRonald S. Raffensperger, RS., dated February 29,1980, as follows, to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, fifty (50) feet wide, at the dividing line between Houses 335 and 337 Ninth Street; said point being measured one hundred forty-five (145.00) feet to Oak Alley; thence along the dividing line between 335 and 337 Ninth Street; North forty-seven (47) degrees zero (00) minutes West, one hundred (l00) feet to an iron pin on the Southeasterly side of an alley, ten (10) feet wide; thence along said alley, North forty-three (43) degrees zero (00) minutes East twenty-two and fifty hundredths (22.50) feet to an iron pin at the dividing line between Houses 333 and 335 Ninth Street; thence along said dividing line South forty-seven (47) degrees zero (00) minutes East, one hundred (100.00) feet to a point on the said side of Ninth Street; thence along said Ninth Street South forty-three (43) degrees zero (00) minutes West twenty-two and five tenths (22.5) feet to a point, the place of , BEGINNING. -~j, HAVING THEREON ,ERECTED A DWELLING HOUSE KNOWN AS 335 NINTH STREET, NEW CUMBERLAND, PENNS,YLVANIA' 17070. BEING THE SAME PREMISES WHICH Kevin B. Mccartin et al by deed dated 8/30/85 and recorded 9/3/85 inDeed BookL-31, Page 705 granted and convexed unto Richard P. Long and Barba~a A. Long. ' TO BE SOLD AS THE PROPERTY OF RICHARD P . tONG A/K/A RICHARD , AND BARBARA A. LONG ON JUDGMENT NO: ,2000S(~;~6. , "~;!1,;:i:, , ,. 'I" B. LONG PARCEL: 26-24,-0811-216 , , L' , ~~ ~ ~~.._" ....."'lfiarl .,_~m;,.lOfu_l WRIT OF EXECUTION ami/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 00-8426 Civil CIVIL ACTION - LAW TO THE SIIERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA PLANTlFF(S) From RICIlARD P. LONG AlK/A RICIlARD B. LONG AND BARBARA A. LONG (I) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION OF PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due$97,083.48 L.L. Interest AT $34.84 PER DIEM TO SALE DATE $18,116.80 Atty's Conun % Due Prothy $1.00 Atty Paid $1115.12 Other Costs LATE CHARGES AT $53.96 PER MONTH TO SALE DATE $809.40 ESCROW DEFICIT $2,000.00 Plaintiff Paid Date: MARCH 13, 2002 CURTIS R. LONG Prothonotary, Civil Division By: ~;MA- ~ ~jw f1f REQUESTING PARTY: Name LEON P. HALLER, ESQ. Address: 1719 N. FRONT ST. HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ill No, 15700 !ii' ':0;" ~-,~;J,~"d''''ifIW!1#!ij~i!?iiijjj~-liiO!:il;;:-~~!El!\!\'!~I1\f$.'''''~fDj",cf\-t)1''i'A~fu:<l:!!!~lii~~...j~b1;li>Mi:'~~**~~.lf~!l~l'",,"-1!~_jOliJill,*ti~' ,. liJ '~--"' ~ r-:ww- ~ Real Estate Sale #48 On March 14, 2002 the sherifflevied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA known and numbered as 353 Ninth Street, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 14, 2002 By: J{)~l~ Real Estate Deputy t8 CUi} CUi} 11;::::I Gi) IiVil t:.~ ':'1"---' ,".::..... (.Z.:J ~~ - I "",,- \\l.l.h:"':J ,~--;:~( -<<I:;: ~, l[;; (:Q' ~).. , N -~ - " cO ,.- L_r) \.,1-- . {i,; --"- tb!_,~--~ -' - ;;c: ~?--.:t ---- w I~~' :Ei 0- 4"..4>. Q, ",""C -- '-"-'<, .. __ ~ J ~< ,,_ .,_ L_,.J,<__~_ __ ~>. ~~, b '-"'-, -. ."~,i~,',,,,< REAL ESTATE SALE NO. 4S Writ No, 2000,8426 Civil Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Co, of Pennsylvania vs, Richard p, Long. a/k/ a Richard B, Long and Barbara A Long Atty,: Leon P. Haller ALL THAT CERTAIN piece or par, cel of land, situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, being bound- ed and described according to a survey made by Ronald S. Raffens- perger. R.S.. dated February 29. 1980. as follows. to wit: BEGINNING at an iron pin on the Northwesterly side of Ninth Street, fIfty (50) feet wide. at the dividing line between Houses 335 and 337 Ninth'Street; said point being meas- ured one hundred forly,fIve (145,00) feet to Oak. Alley; thence along the dividing line between 335 and 337 Ninth Street: North farly' seven (47) degrees zero (00) minutes West. one hundred (100) feet to an iron pin on the Southeasterly side of an alley, ten (10) feet wide; thence along said alley, North farly, three (43) degrees zero (00) minutes East twenty-two and llfty hundredths (22,50) feet to an iron pin at the dividing line be- tween Houses 333 and 335 Ninth Street; thence along said dividing line South forty~ seven (47) degrees zero (00) minutes East, one hundred (100.00) feet to a point on the said side of Ninth Street; thence along said Ninth Street South forty-three (43) degrees zero (00) minutes West twenty,two and fIve tenths [22.5) feet to a poip,t, the place of BEGIN- NING, HAVING TIlEREON ERECTED A DWELLING HOUSE KNOWN AS 335 NINTH STREET. NEW CUM, BERLAND. PENNSYLVANIA 17070, BEING TIlE SAME PREMISES WIflCH Kevin B. McCartin et a1 by deed dated 8/30/85 and recorded 9/3/85 in Deed Book 1.-31. Page 705 granted and conveyed unto Richard p, Long and Barbara A Long, TO BE SOLD AS TIlE PROPER, 1Y OF RICHARD p, WNG, A/K/A RICHARD B. WNG AND BARBARA A WNG ON JUDGMENT NO, 2000 8426. PARCEL: 26,24,0811,216. II ~ ~ ,~~'" . , .d-I , _i ~' ~, ~ 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. Morgentha1, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, VIZ: APRIL 26, MAY 3,10,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 10 day of MAY. 2002 -L. NOTARw.: SEAL. LOIS E. SNYDER. Nolary Public CaI1isIe 80m. Cumberland County, My CommI88Ion Expires Marl:h 5, 2005 REAL ESTATE'SALE No. 48 Writ No.2OIlO-S42li . Civil Term . 'Beneficial COnsumer Dlscouilfeo, dlbla BeneflclalMortgage Co. at Pennsylvania . "" Richard P. Long aIkIa Richard B. Long 6arbara A. ~ng . .. Ally: leon Po Haller . DESCRlPTIDN , ALL THA.T CERTAIN pi~e or parcel of land, , '~itnate ..i~, the Bprough jjf NeW Cumberland, , Ci.1rUhedind County. Pennsylvania, being bounded 3JlP described'accoirlmg to a survey IIl3de by Ronald : $, Raffensperger, itS" -d~ted February 29, t980, as 'follow~.towjt: :' BEGINNIKG at an irori phI' on the Northwesterly side of Ninth Street, fUtY (SO) feet wide, al the , dividing line hetv,een Houses 335 and 337 N'mth ",Street; '!l\1ld pQint being J11easured olle.hundred forty- flve (l45;oo) , teet to Oak Al1ey; thence along the , dividrng line between 335 and 33.7 Ninth Street; North rorty-scven (47) degrees zero (CO) minutes : West, one hundred (lO{JI feet to an iron nin on the ~~~,eil.sterly side of an alley, ten (10) .~~ wide; thenc.~"along said alley, North forty-tliite"'tilJ) :""g,~~,~[l) \,Ql)l minutes East twetlty-two'":~~ r,1f.\y- ":~ri:ri:~'l)~'~5l)rI:'iit lti.?':p:,i[W1:,mll at the divjqing '...ifile":,:tict\\ie:eii ',:aQu,~:es: xn, :irid" 3$" Niiiih SM ;,)hell,~,~9ni ,s,a!d ,'diyidin'g rm~ 'Sw1!i fQ(iY" ~veD "::(~7fd~grees"'!-cirO (Ix)) trlirt~leS East. ~ ~i!ild'red ,(lOIIOO) feet td 'if'point-ou"ihe satd ~ide:of Ninth Street; thence along ~aid Ninth Street South forty- tlu:'ee{43)degrees7.ero(~)rninutesWestlwenty" tv.u and five tenths (22.S) fee-~ to a point, the place of BEGTh'NING.' HAVING THEREON erec~d a dwelling house known a.s 335 Ninth Slre.;-"~ New Cumherland, Penmyh'ania1707G. ,BEING THE ~ame prcmise~ which Kevin B. McCartin et al by Ileed dated 8130/85 and recorded 9D/85 in Deed ~ook L.lL Page 705 gmnted and : c,onveyed Ul~O Richard P. Long and Barbara A. ,Long. : TQ::BE SOLD as the property of Richard P. Long AlKJA Richard B. Long arid "Barbara A. l.Qng 011 Judgment No. 2000 8426. PARCEL:26-24-081 1-216. ....~ . . I-.J~ ,,' . '"' ~t~ill:f!1~_ .... -. 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 Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and~ 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 23rd and 30th day(s} of April 2002 and the 7th day(s} of May 2002. 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 ollice for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #48 ~...~............................................ . '1thdo 002A.. Notarial Saal Torty L. RUSIflI, Notary Public HarrIsburg, Dauphin County My Commission Expires June 6 2002 . Member Pann""lva . A .' commission expires June 6, 2002 , -, nl8 SSOOiaUon Of Notaries CUMBERlAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 f 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 $ 249.60 1.75 251.35 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....................................................................