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HomeMy WebLinkAbout00-08797 " --, -~, . .-.,.', l!!.1iR#. 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 Household Realtv Com is the grantee the same having been sold to said grantee on the 2nd day of April A.D., 2003, under and by virtue of a writ Execution issued on the 10th day of October, A.D., 2002, out ofthe Court of Common Pleas of said County as of Civil Term, 2000 Number 8797, at the suit of Manufactures & Traders Tr Co against Robert Landis aka Robert Lerov & Darlene Landis aka Darlene Joann is duly recorded in Sheriff's Deed Book No. 257, Page 896. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ;l,;,l.. day of ~ ~ , A.D. 2003 A,~~ . Recorder of Deeds __alOIII(I, CllInIledInlI"CIMI. M -.<: 0'111 r-1Elfl1ht1lll....UOiIIIIII.......... o;P,u/ 36JY" I':SO C/t.. 'IOSq'l Pv /3?0''j) '2" ,j7~ -~=~-~ . . . .'.- ,--~ ~ - ~'};o;7_ Manufacturers and Traders Trust Company VS Robert Landis a/k/a Robert Leroy Landis And Darlene Landis a/k/a Darlene Joann Landis In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-8797 Civil Term Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on October 30, 2002 at 9:08 o'clock AM, 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: :Robert Landis, by making known unto Robert Landis personally, at 15 Hill St., Mt. Holly Springs, 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 duly sworn according to law, states that on October 30, 2002 at 9:08 o'clock AM, 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: Darlene Landis, by making known unto Robert Landis, husband of defendant, at 15 Hill St., Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2003 at 3:45 o'clock P.M., he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert Landis a/k/a Robert Leroy Landis and Darlene Landis a/k/a Darlene Joann Landis located at 15 Hill St., Mt. Holly Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Robert Landis a/k/a Robert Leroy Landis by regular mail to his last known address of 15 Hill Street, Mt. Holly Springs, P A 17065. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Darlene Landis a/k/a Darlene Joann Landis by regular mail to her last known address of 15 Hill Street, Mt. Holly Springs, P A 17065. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on April 2, 2003 at 10:00 o'clock A.M. He sold the same for the sum of$96,100.00 to Attorney Terrence J. McCabe for Household Realty Corporation. It being the highest bid and best price received for the same, Household Realty Corporation of P.O. Box 8604, Elmhurst, IL 60126, being the buyer in this execution, paid to Sheriff R:Thomas K1ine the sum of $98,222.00. '"-'-~. . - ~- . .iIi'"~< ,<<o~ Sheriff's Costs: Docketing Poundage Posting Bills 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 - ~ Mb~~__. __ , $30.00 1922.00 15.00 15.00 30.00 10.00 .50 1.00 8.28 8.84 15.00 30.00 20.00 246.80 244.54 25.21 25.00 40.00 $2687.17 Sworn and subscribed to before me so~: lP ~ ~ ~". :.r<: ~ This~dayof ?~ ~ .' R. Thomas Klme, Shenff 2003, A.D. . ~LQ')'hd!',:~ ~ ro honotary BY Real Estate ~uty - --~. .I._,~-- --..c.. 11~~ ~""l!.:. ~ ".~ .~ - ~-. "01 , - ~ - . - '""""f'~'~f:.0J-_ft'" , , , MANUFACTVRERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS NO. 00-8797 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following infonnation concerning the real property located at .15 HILL STREET. MOUNT HOLLY SPRING. P A 17065 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT LANDIS, A!KI A ROBERT LEROY LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 DARLENE LANDIS, AlK/A DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 2. Name and address of Defendant(s) in the judgment: \ Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ,do'" ~'!i'1-11 ~ . I~~ "__--= - -,.. "'~"""~'ilI11,,,,~i!!b"' -' 4-. Name and address of last recorded holder of every .mortgage Of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) AMERICAN GENERAL FINANCE INC. 6 S. HANOVER STREET CARLISLE, P A 17013 HOUSEHOLD REALTY CORPORATION 25 GATEWAY DRIVE, GATEWAY SQUARE, STE 107 MECHANICSBURG, P A 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF MOUNT HOLLY SPRINGS MOUNT HOLLY SPRINGS, P A 17065 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 15 HILL STREET MOUNT HOLLY SPRING, P A 17065 \ Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl!:! Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. f\ 0<,,"" 9, 21m -h ),~"L"() "', DATE F FEDE , ESQUIRE Attorney for Plaintiff -~ , '-,2'~J- o,I " - ...1 -J ~~ ' "-~.-' ~.~ "~ W'l'iliiId..mfF"" ,. , MANUFACTURERS AND TRADERS TRUST COMPANY " CUMBERLAND COUNTY Plaintiff, No, 00-8797 v. ROBERT LANDIS, A/KJA ROBERT LEROY LANDIS DARLENE LANDIS, A/KJA DARLENE JOANN LANDIS Defendant(s). October 8, 2002 TO: ROBERT LANDIS, A!KIA ROBERT LEROY LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 DARLENE LANDIS, A!KIA DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRING, P A 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ,15 HILL STREET. MOUNT HOLLY SPRING. PA 17065. is scheduled to be sold at the Sheriff's Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $78.583.60 obtained by MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ E"6!:,~~ ':~ , ,-" L'"~J~~ - "". ~"I-J ~ """,,--"-" . "'I'i"~IM .....,........;-~ ' "" "~~i!i~~-1".,i,r, " . YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within 30 days ofthe sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ,,~"" -,,~"~ , ,;,JI~.1 , '" '" .'W. '.~~I , . ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mt. Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Hill Street, at the comer of lands formerly of L.M. Austraw now of Samuel Garonzik; thence along lands of the same South 23 degrees 45 minutes East 679 feet, more or less, to stones at comer of lands now or formerly of J.W. Craighead; thence along lands now or formerly of J.W. Craighead, South 50 degrees 55 minutes West 151 feet, more or less, to stones at comer of lands of J.W. Craighead and Clair Yeingst; thence along lands of Clair Yeingst, North 21 degrees 15 minutes West 730 feet, more or less, to a point on Hill Street; thence along Hill Street, North 72 degrees East, 111.3 feet, more or less, to the place of Beginning. Having thereon erected a two story dwelling house and garage. Containing 2 Acres and 12 perches, more or less. Being known as No. 15 Hill Street, Mt. Holly Springs, Pennsylvania. TAX PARCEL #23-32~2336-3515 TITLE TO SAID PREMISES IS VESTED IN Robert Leroy Landis and Darlene 10300 Landis, his wife by Deed from Roy M. Bly and Grane E. BIy, his wife, dated 11/30/65, recorded 12/18/65, in Deed Book 21-V, Page 505. ~,~ ~,~ -' ~ " ~j, I -~ L,_ ~. ,-'- WRIT OF EXECUTION' and/or ATTACHMENT , COMMONWEALTH OF PENNSYL V AN1..A) COUNTY OF CUMBERLAND) NO 00-8797 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisry the debt, interest and costs due MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff (s) From ROBERT LANJJIS, AlK/A ROBERT LEROY LANDIS, DARLENE LANDIS, AlK/A DARLENE JOANN LANDIS, 15 HILL STREET, MOUNT HOLLY SPRINGS, P A 17065 (1) You are directed to levy upou the property of the defendant (s)aud to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notiry 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 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 otherthan 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 $78,583.60 L.L. $.50 Interest FROM 7/31/01 TO 3/5/03 (pER DIEM - $12.92) - $7,532.36 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $119.72 Other Costs Plaintiff Paid Date: OCTOBER 10, 2002 CURTIS R. LONG (Seal) Proth~ ~ lh': D~,.~2. ~r Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 "",-'" o';"_-id"';,'H"'~;"-o_~"-,,,_,,,'.'~,,,_i"'__"~;;""m&~,,;$:!:MiliITh'",".J-~_-<li{"';4%c-j""d,",,,~.."~~1l!?"~"'~""f,M - ~iI;l~~,.. ..,~ ~ '. jr! Ii !1 i I ~: , i Real Estate Sale # 16 On October 29, 2002 the sherifflevied upon the defendant's interest in the real property situated in Mount Holly Springs Borough, Cumberland County, P A known and numbered as 15 Hill Street, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: Jcx:JhJ ~ Re~l gstate Deputy ~ "'~ '^' -~ ~~v ~-- ':',,! -, If'" (", 111:10 '." , ii' ,'\.11 .:J.jn;:~:r; , - ,,::;,~:/() I.,,~ " ~" . I; - ,,' ' .,' ., ,t, REAL ESTATE SALE NO. 16 Writ No. 2000-8797 Civil Manufacturers and Traders Trust Company v.. Robert Landis, a/k/a Robert Leroy Landis and Darlene Landis, a/kj a Darlene Joann Landis Atty.: Frank Federman ALL TIIAT CERTAIN piece or par- cel of land situate in the Borough of Mt. Holly Springs, Cumberland Coun- ty. Pennsyivania. bounded and de. scribed as follows: BEGINNING at a point on Hilt Street, at the corner of lands for- merly of L. M. Austraw now of Sam- uel Garonzik: thence along lands of the same South 23 degrees 45 min- utes East 679 feet. more or less, to stones at corner of lands now or formerly of J. W. Craighead; thence along lands now or formerly of J. W.Crffigh~d.~ufu50d~~55 minutes West 151 feet. more or less. to stones at corner of lands of J. W. Craighead and Clair Yeingst; thence along lands of C\alr Yeingst, Norfu 21 degrees 15 minutes West 730 feet. more or less, to a point on Hill Street; thence along Hill street, Norfu 72 degrees East. 11 \.3 feet. more or less. to the place of Begin- ning. Having thereon erected a two story dwelling house and garage. Containing 2 Acres and 12 perches. more or less. Being known as No. 15 Hili Street, Mt. Holly Spring.. Pennsylvania. TAX PARCEL #23-32-2336-3515. TtTLE TO SAID PREMISES IS VESTED IN Robert Leroy Landis and Darlene Joarm Landis. his wife by Deed from Roy M. Bly and Grane E. Bty, his wife, dated 11/30/65. recorded 12/18/65. in Deed Book 21-V, Page 505. ~~"' - , ~ ,I l__ . i~<t~"'L'c , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, v!z: JANUARY 31, FEBRUARY 7,14,2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe 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 14 day of FEBRUARY. 2003 NOT. IftI. LOIS E. SNYDER, t.&;!;;iy PublIc CailWle IiIcro, Ctil11J}ill;llflll County My~ Expires MaIch 5, 2005 _'--4 ~ ~~ ~' J 111 ~"""''''''-' . . ~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller 01 The Patriot News Co., a corporation organized and existing under the laws 01 the Commonwealth 01 Pennsyivania, with its principal office and place 01 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 generai 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 28th day(s) of January and the 4th and 11th day(s) of February 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character 01 publication are true; and That he has personal knowledge 01 the facts aloresaid and is duly authorized and empowered to verify this statement on behall 01 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 01 Deeds in and lor said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #16 worn mt~S ib bef re Teny L. Russell, Notaly P ',c City Of Hanisburg, Dauphin county My Commission EXpires June 6, 2006 Member. PennsyiVanla Association Of Notaria. My commission expires June 6, 2006 CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY 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 $ 242.79 1.75 244.54 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 01 the aforesaid notice and publication costs and certilies that the same have been duly paid. By.................................................................... E-lOALCSTATE-SALENO:-16--- . ,>-f 'Wrlrjlio,~~IiQ.:s797 . ~. ,~~~~~gM~~~~J~ T(aders ' - Trust Company vs Robert Landis aIkIa ",. . . C Robert Leroy landis and ~. . Darlene umdls a1k1a _ ~_O_ad~ne J~n ~ndls ~Atty. : Frank Federman .~ =:--__~Qe.$Ci"il'PTION' , _ ~HAt.CER;rA1Kpi,ece or parcel of land_ ~ma~n_uL~13_orougJi of Mt. HoUy Springs. ~t.umb.etland County, Pennsylvanla. bounded and ~-:-:'Ue:scribed as foUows: ~EGINNlNi3 at a pohrt on Hill Street, at the ~cr af.laods f9rgJ_Cr[~'-of LM. Austraw now of o::Wan1ue1 Garowll.;1lience along lands. of the l>arl\t J.ooTh 23 degrees 45 minutes East 679 feet, more :=7or tess, to stqnes at _~mer of Jands now or :::"Tormerly of J.W. Craighead; thence along lands rJI~(ir_former1y of I.V{. Craighead, South-50 ~tegrees 55 minutes West 151 feet, more or less. ~-stones at conier oflan9s of J.W. Craighead and ~J.!.-tJ1W~\<,~lan~so.fClajr~ei.ngst, r ,~{iitli"2'1 aegrees 15 mlOutes West 730 feet, more _ ~or less, to a point on Hill Street; th~nce along Hill ~treet,North 72 degrees East. II 1.3 feet, morc or ~ess, -to the p[al:e_.of~EGINNING. HAVING - JhereolLcrected a two-story dwelling house and _ :garage. Containing 2 Acres and t2 percnes, more --"or less.Being known WI_oNo. I5 HilI Street, 11t. ~!fSprings, Pennsyl"mia. !rAXVARCEL 123.32-2336.35 IS. - TO ~AJQ ~SJ;S IS VES.11'9 IN_ .,m ~iL~,p~!~e!Je lQ?!ll! I,~a!ldis, . I ml\iiYl,qIY..!.adj)(a!),E. - \W6i,!C<O<ds4 !2118165,. !][__~~~~0~_______~_ ~",,---]r!l -- - - , '"'~ . lioI_'-~~ _'ii:,<~T " , SCHEDULE OF DISTRIBUTION SALE NO. 16 Date Filed: May 2, 2003 Writ No. 2000-8797 Civil Term Manufacturers and Traders Trust Company VS Robert Landis alk/a Robert Leroy Landis and Darlene Landis aIkIa Darlene Joann Landis 15 Hill Street Mt. Holly Springs, P A 17065 Sale Date: Buyer: Bid Price: April 2, 2003 Household Realty Corporation $96,100.00 Real Debt: Interest: Attorney Costs: $78,583.60 7,755.56 119.72 Total: $86,458.88 DISTRIBUTION: Receipts: Cash on account (10/29/02): Cash on account (04/02/03): Cash on account (04/17/03): $1,500.00 10,930.00 87,292.00 Total Receipts: $99,722.00 -,"", " -. ~ - _" . J - -~ Disbursements: To Sheriffs Costs: To Legal Search: To Attorney Frank Federman Cumberland County Tax Claim Bureau To Mount Holly Springs Borough To Manufacturers & Traders Trust Company To American General Finance, Inc. To Household Realty Corporation Total Disbursements: Balance for distribution: So Answers: ?<~#~ , , Sheriff $ 2,687.17 200.00 1,500.00 4,508.36 333.88 86,458.88 3,791.22 242.49 ($99,722.00) 0.00 ~ . ;l\t 1" 2::c.J , (~~ ,...~"- > " "_L .~ ~ -'L "f-.rl'iailit;:~-" TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 16 Held Wednesday, March 12, 2003 Date: April 18, 2003 TAXES: Receipts for all taxes for the years 2000 to 2002 inclusive. Taxes for the current year 2003. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to . dated 2003, and recorded 2003, in Cumberland County Deed Book , Page RECITAL: Being the same premises which Roy M. Bly and Grace E. Bly, his wife, by deed dated November 30, 1965 and recorded December 18" 1965 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book "V," Volume 21, Page 505, granted and conveyed to Robert Leroy Landis and Darlene Joann Landis, his wife. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Under and subject to rights in the roadbed of Hill Street 6. Mortgage in the amount of $81 ,500.00 given by Robert Leroy Landis and Darlene Joann Landis to First Union Horne Equity Corporation. recorded December 10, 1993 in Mortgage Book 1184 Page 626. Assigned to Manufacturers and Traders Trust Company by instrument recorded June 30,1994 in Miscellaneous Record Book 477, Page 109. Further assigned to Credit Based Asset Services, LLC by instrument recorded in Miscellaneous Record Book 695, Page 3984. """" '. - '" " d J;lt:;l'lij;XlI~:~;i,;, Complaint in mortgage foreclosure filed by Manufacturers and Traders Trust Company as Plaintiff against Robert Landis, also known as Robert Leroy Landis, and Darlene Landis, also known as Darlene Joann Landis as Defendants in the Office of the Prothonotary of Cumberland County to file no. 2000-8797. Judgment in the amount of $78,583.60 entered July 31, 2001. 7. Mortgage in the amount of $10,000.00 given by Robert Landis and Darlene Landis to American General Finance, Inc. dated July 21,1994 and recorded August 2,1994 in Mortgage Book 1226, Page 381. 8. Mortgage in the amount of $25 ,000 .00 given by Robert Landis and Darlene Landis to Household Realty Corporation, dated July 22, 1996 recorded July 30, 1996 in Mortgage Book 1333, Page 801. 9. Mortgage in the amount of $11,395.00 given by Robert Landis and Darlene Landis to Household Realty Corp., dated march 11,1999 recorded March 15,1999 in Mortgage Book 1526, Page 336. 10. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $4,508.36 as ofthe date ofthis report. 11. Municipal lien filed by the Borough of Mount Holly Springs as Plaintiff against Robert L. Landis and Darlene J. Landis as Defendants in the Office of the Prothonotary of Cumberland County on September 4, 1998 to file No. 1998-5160. 12. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff's sale. 9. Real estate taxes accruing on and after July 1,2003 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be . d or b nding nntil countersigned by an authorized signato . ,1-' , 1-. '~ .'-" tloo.. REAL ESTATE SALE NO. 16 Writ No. 2000.8797 Civ1l Manufacturers and Traders Trust Company vs. Robert Landis, alkla Robert Leroy Landis and Darlene Landis. alkl a Darlene Joann Landis Atty.: Frank Federman ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Mt HoUy Springs. Cumberland Coun- ty, Pennsylvania. bounded and de- scribed as follows; BEGINNING at a point on Hill Street. at the comer of lands for- merly of L. M. Austraw now of Sam- uel GaroDZik: thence along lands of the same South 23 degrees 45 mln- utes East 679 feet, more or less. to stones at comer of lands now or formerly of J.W. Craighead; thence along lands now or fonnerly of J. W. Craighead. South 50 degrees 55 minutes West 151 feet, more or less. to stones at comer of lands of J.W. Craighead and Clair Yelngst: thence along lands of Clair Yeingst. North 21 degrees 15 minutes 'West 730 feet. more or less. to a point on Hill Street; thence along Hill Street. North 72 degrees East. 111.3 feet. more or less. to the place of Begin~ ning. Having thereon erected a two story dwelling house and garage. Containing 2 Acres and 12 perches. more or less. Being mown as No. 15 Hill Street. Mt. Holly Springs. Pennsylvania. '~. TAX PARCEL #23-32-2336-3515. TITLE TO SAID PREMISES IS VESTED IN Robert Leroy Landis and Darlene Joann Landis. his wife by Deed from Roy M. BIy and Grane E. Bly. his wife. dated 11/30/65. recorded 12/18/65. in Deed Book 21-V. Page 505. ;Ill ' ~-~-~ ~, : ''" . I ~" --. -'-';, .. ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff, v. No. 00-8797 ROBERT LANDIS, A/KIA ROBERT LEROY LANDIS DARLENE LANDIS, A/KIA DARLENE JOANN LANDIS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $78,583.60 Interest from 7/31/01 to 3/5/03 (per diem -$12.92) $7,532.36 and Costs TOTAL $86,128.88 '~UIRE One Penn Center at Suburban Station 1617 JohnF. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. . . .<~. !'Y'!ji~, ~ Llli.liW1Nill!!iliiti"""I'I!,",_~1- ;Iffi " '!fc~~!ii.~"~,-~_,,.~.ll ~ r ~ ~ ~ + .",~" -~,~~ ~ CD ..., CD >t:J ~ CD ..., '" ~ '< 0"' CD '" CD ~ p.. _ (J ~'i w ~ (;\ -0 ~ Uv (>& _,_ .r"~" "",.;",,,,.,. ~ El' CD '" ~ .... Ul := ... t"' t"' CIl .., ~ t"'l .:-3 ~ o (j ~ := o t"' ~ CIl ~ ; -9 ~ .... ~ c:I'I Ul ~, ,~ I~~ ,j>(,ih!?", . .._~....,..h,_dml_r~ '-,.~~ '-- !v......;.,,'~riimmlt1l!ll:~1 ,~';iI@:">!,,~~~~;';l,_. "~. - , 'Tj _. ~ ~ ("'l ... ,...,"ll ~t"'l !Cl ~~ ~~ Sl "" ~ 0 ="'l = t"'l ~~ ("'l t:: "" ... o z ;f4.~ c, () C C f-f) ":.. ~g t"'lt"'l ~::l t"'t"' ~~ ... ... CIlCll ~~ ~~ ~~ ~::l t"'lt"' ""'t"'l ~~ z~ t"'~ ~... ...CIl CIl < '" ~ ~ t:: "'l ",,> ~~ CIlt:: ""[;:l 8~ ~~ <"" ~ t"'l ~ ("'l... t::z ~"" =:= ~~ ~g ~::l ("'lo o"'l t::("'l ~o ~i t"'lo Zz Z"ll CIlt"' t$t"'l <> ~~ >"'l 2 :?: -of,: CPt+'; I.. 1<l.:"""c.' .1. ...... VJ '-:2'-'-:r" ~ ...0 ~ D' - "1 G'> . D ~ D ~8 . ~~'. o () 0 C' 1-J i2 I I I I ~~? : : ~ : ~ ~ ~ ~ -0 ..::! 1-J I ~ .'" -"~~-~ --'~ "~.~~!: , .. ") :-:-0 .-'. -:_~- --n ;1;.:;:;::: o .~i~\ ~~ ~'-;' 0 ~... "--In ~? ':2\ ~ .....J o !'.:; o c-, ....... '" c".dlo"""",,~LolI ~ ~...._- ~ -~ lil'''F''"'"~'-"''''''"' ~~ - ~" ~I . .1 ~, - ^li~ ~~_i':!,', r 1 . ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mt. Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Hill Street, at the comer of lands formerly of L.M. Austraw now of Samuel Garonzik; thence along lands of the same South 23 degrees 45 minutes East 679 feet, more or less, to stones at comer of lands now or formerly of J.W. Craighead; thence along lands now or formerly of J.W. Craighead, South 50 degrees 55 minutes West 151 feet, more or less, to stones at comer of lands of l.W. Craighead and Clair Yeingst; thence along lands of Clair Yeingst, North 21 degrees 15 minutes West 730 feet, more or less, to a point on Hill Street; thence along Hill Street, North 72 degrees East, 111.3 feet, more or less, to the place of Beginning. Having thereon erected a two story dwelling house and garage. Containing 2 Acres and 12 perches, more or less. Being known as No. 15 Hill Street, Mt. Holly Springs, Pennsylvania. TAX PARCEL #23-32~2336-3515 TITLE TO SAID PREMISES IS VESTED IN Robert Leroy Landis and Darlene Joann Landis, his wife by Deed from Roy M. Bly and Grane E. Bly, his wife, dated 11/30/65, recorded 12/18/65, in Deed Book 21-V, Page 505. " ~.~="";..- ~....~-...... ~ . , ..ll.L.i J ~~ j^'"""~' ~ 'c' , FEDER]dANandPHELAN,LLP By: FRANK FEDER]dAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBLVD., SIDTE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION ROBERT LANDIS, AlK/A ROBERT LEROY LANDIS DARLENE LANDIS, AlK/A DARLENE JOANN LANDIS NO. 00-8797 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above- captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. t gI\AA~~AA^rOk^ RANK FE RMAN, ESQUIRE Attorney for Plaintiff ~~JOmf~!iIi!!l]i!;,i1f~"~'Jj'c~;iiJ:t,rfj~IIk~1tiIW1;m~;ip~i......;i;"iN:;;j-I"":-&;1H"'.lJt,,'~,~-I;:'~'f'-~~';~~1B&.t~IIiJ-1tilfj_<' .~~ --'-,-,-"",~- ,~ --- .".,~~J"N >_,,_,,~~ ~ L , -".- ~- ~. ,U,,"J - I" - ... ~~.':":' '. --;-""~ ~-c'-=--""'-Jlti---- (") C '7 -OrB [T1 [1"' z::-c; :ZC ~~~ r:: \....--- ';oz"?c:< _~-Cl >c :z :z ~.~'-~h c::> N => " --l o "n o --I ,-h ~~:.~ (,1:11 ___)11 ;~~~ ~~rn 55 '-< -0 ~ ...J . .,~~.".,J;;.-...~~~'-~-~"," " ., , , 11' ,U: ,... . MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT LANDIS, A!KIA ROBERT LEROY LANDIS DARLENE LANDIS, A!KIA DARLENE JOANN LANDIS NO. 00-8797 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .15 HILL STREET. MOUNT HOLLY SPRING. PA 17065 . 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT LANDIS, AIKI A ROBERT LEROY LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 DARJLENE LANDIS, A1K1A DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None -\>i.d".<,~~__ ~ ~~ ..;..1 L. ,.. ___1_ ~. ,~ III " y-- ~ 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) AMERICAN GENERAL FINANCE INC. 6 S. HANOVER STREET CARLISLE, P A 17013 HOUSEHOLD REALTY CORPORATION 25 GATEWAY DRIVE, GATEWAY SQUARE, STE 107 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BOROUGH OF MOUNT HOLLY SPRINGS MOUNT HOLLY SPRINGS, P A 17065 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 reMi"" to =w= fiilirifioilion to ",",oritiw. ~ October 9. 2002 ~ .\.. .A/\I\ () \;\., DATE F FEDE ,ESQUffiE Attorney for Plaintiff j.;~'~?M~,:1f1!,j,lillt,%,M;S~':l' '""d'!hti';;"~t;;~ilroli~~j;f!tll~j"'&fili';''''""'':'i'''-''' ,~,'.c",i,o"'i',,;, -!'''''''-';''''''jIO;;,*_$r~~~' ~ ,~,~ _I~ ,M _ .~~~.J, '~I!lkiI1l~~,jJ'&:t'IY"'~- -"- 'Ii___ _. "1 . 'I~ , 4. -~ 0 0 0 C N """ Tj "TJ lX' a :,? D.]r-r: n ..c......::t, -l ;'(i~ zc ;3~ ~,,;',', <::) ",' <C) '" ,c~.{ - --.,.; ~{~~ ~~)o S'? ;~" nl -c ~ :z: ::<! ....J -< ._c IT ~~ ~-","",-Il~ ",,~, """""~"__ .~ "",,' '"" ,~ .~l ... ~. I ..... ; l '-~~.&,.- , MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, No. 00-8797 v. ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS Defendant(s). October 8, 2002 TO: ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS 15 HILL STREET MOUNT HOLLY SPRING, PA 17065 DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRING, P A 17065 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at .15 HILL STREET. MOUNT HOLLY SPRING. PA 17065. is scheduled to be sold at the Sheriffs Sale on 3/5/03 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $78.583.60 obtained by MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: . 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) -JCfl!lIj;t~...._", ~~ ~,'- '". , llIWit -~ - l ~". ......-.i" , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as ifthe sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ;&&' e.~~ ~~~ ,-> l~ '-""'<f,~~"':t!~f. , ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mt. Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Hill Street, at the comer of lands formerly of L.M. Austraw now of Samuel Garonzik; thence along lands of the same South 23 degrees 45 minutes East 679 feet, more or less, to stones at comer of lands now or formerly of J.W. Craighead; thence along lands now or formerly of J.W. Craighead, South 50 degrees 55 minutes West 151 feet, more or less, to stones at comer of lands of J.W. Craighead and Clair Yeingst; thence along lands of Clair Yeingst, North 21 degrees 15 minutes West 730 feet, more or less, to a point on Hill Street; thence along Hill Street, North 72 degrees East, 111.3 feet, more or less, to the place of Beginning. Having thereon erected a two story dwelling house and garage. Containing 2 Acres and 12 perches, more or less. Being known as No. 15 Hill Street, Mt. Holly Springs, Pennsylvania. TAX PARCEL #23-32~2336-3515 TITLE TO SAID PREMISES IS VESTED IN Robert Leroy Landis and Darlene JoannLandis, his wife by Deed from Roy M. B1y and Grane E. B1y, his wife, dated 11/30/65, recorded 12/18/65, in Deed Book 21-V, Page 505. ,iiL~~)!i,~~1ii.ii~"")~ ;',~,,"<,'-;'.!.",r, I;~"",;;~,~~':;!':""'!.~c"*_",~b'T:t'H:,,"',ii"-'~":i' ,,,,-,",t,,il ,-".,,;:,;:,,1/ ,-~,~~~];I~~i"~'~ c ~ ..........~iiQml~.ft:'lI1o.;,"~ ..,., ,,,U, "" J ~"_~,,~, ". ,~ "J~ "~ _~ ~." - ~~ ~ H (") c:: < -otD l"1'1r1'" Z:I. -7:-'- Cf:' ).... -<,,: ~~'~'";. .::::':?-< >~ ~ - o N o ("") -l ,~, ~i , o -n ,=> ..~ ;-1~ ::D . , -rlrn ,0,0 ~';~6 '2:w -.~ "<0 ;'=-.)1"11 :='\ 'D- ~ -'0 -~..,. ~? _-J " ;::iIillli~ <OK...... ~, _ -~- ~ ~ " ~ ~ J ~ > ~ '~~ .L~uj ,~.". ~ -~~ ...' - UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA IN RE: Robert L. Landis a/k/a Robert Landis Darlene J. Landis a1k/a Darlene Landis Debtors : CHAPTER 13 : BANKRUPTCY NO.01-00326 RJW ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this 1 s<;jay of ~ ,2002, upon Motion of Fairbanks Capital Corporation (Movant), and after notic; of d;;-(ault and the filing of a Certification of Default, it is ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided by 11 U.S.C. 362 is modified with respect to premises, 15 Hill Street, Mount Holly Springs, Pa 17065, as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED AND DECREED THAT: Rule 4001 (a)(3) is not applicable and Fairbanks Capital Corporation may immediately enforce ~/nt this order granting Relief from the Automatic Stay. (P" d. ~ L... . Bankruptcy Judge 'l.~ cc: Judith T. Romano, Esquire Autherine B. Smith, Esquire Jay B. Jones, Esquire Jerome B. Blank, Esquire Peter J. Mulcahy, Esquire Suite 1400/0ne Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 r--~'..~~.~?"~~.~~!~'~:~'-i .~ Charles J. Dehart, III, Esquire (Trustee) P.O. Box 410 , Hummelstown, Pa 17036 ..:~U6 - I 2002 ...- --- --. ~ "0:-:-- --.-- _h___.~_ -. 1._.-.. ~'''''' .... Robert L. O'Brien, Esquire 17 West South Street Carlisle, Pa 17013 ---- ~ --...:. --- Robert L. Landis and Darlene J. Landis 15 H ill Street Mount Holly Springs, Pa 17065 ~ . ~ ~~ - . - .1 I~ ~ .",.: WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-8797 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MANUFACTURERS AND TRADERS TRUST COMPANY,Plaintiff(s) From ROBERT LANDIS, AfK/A ROBERT LEROY LANDIS, DARLENE LANDIS, AfK/A DARLENE JOANN LANDIS, 15 HILL STREET, MOUNT HOLLY SPRINGS, P A 17065 (1) You are directed to levy upon the property of the defendant (o)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied npon 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 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 hirnlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $78,583.60 L.L. $.50 Interest FROM 7/31/01 TO 3/5/03 (pER DIEM - $12.92) - $7,532.36 AND COSTS Ally's Cornrn % Due Prothy $1.00 Ally Paid $119.72 Other Costs Plaintiff Paid Date: OCTOBER 10, 2002 CURTIS R. LONG (Seal) Proth~ p ~ ~y: fJ/k 17 ~. ~y~ r- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHlLADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 I. 'j_~-'-'-'C ~~ ~~"~~'fl '"~ ~_~ ,;,1- - -~'. ,l -~- J:J'_' , FEDERMAN AND PHELAN, L.L.P. BY:' FRANK FEDERMAN, ESQUIRE ATTORNEY J.D. NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MANUFACTURERS AND TRADERS TRUST COMPANY ATTORNEY FOR PLAINTIFF v. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO: 00-8797 ROBERT LANDIS AIKIA ROBERT LEROY LANDIS DARLENE LANDIS AIKI A DARLENE JOANN LANDIS PRAECIPE TO MARK JUDGMENT TO USE OF PLAINTIFF TO THE PROTHONOTARY: Please mark the judgment in the amount of $78,583.60 in the above captioned matter to the use of CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC, 335 MADISON AVENUE, NEW Y NY 10017. DATE: April L 2003 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of CREDIT BASED ASSET SERVICING AND SECURITIZATION, LLC, 335 MADISON AVENUE, NEW YORK, NY 10017. ; DATE: April L 2003 ~!!t!lg;-W~;~I.:1i!,1l4iilil~~l*,,;'.;c;t0,*~H'ii.h~,,!;,ll~di"'H,~'~~'!ii.\r .-' ~~_,. N. ""C~ ,~", ". "~ n"~' ~,~,,~ __H.'~~,_.~^ __~" ,,"__.~ ~,.J, <~ - ~ ...o"~"~'-'-'~"d~'" ,;", l~ ., . l1' 0 <:;;) ~1;:" c- ~ S; w '11 ~~ ~ ~ :--Ocb "'" [Iln- -0 ,':kj11 j) <::7'; :::v <r-' (0.:;:'- I ~ ;$" ~, ~'~.!!i; -<.~:- /~Z9 "- \' :;::::c' ,~@ ~ ~(" v " " ... ::--.; r-< :Jl: j... ...... f",\ ;:be: - ---. -<;, e :2: """ ~ ::< ,;;, ':-1 "'- eJ'i 5-.1 -< --" ~ W~ .~...... - li'LUIl -'. - -~,'. -'~~-, lJI..f- f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: MANUFACTURERS AND TRADERS TRUST COMPANY ) CIVIL ACTION ) vs. ROBERT LANDIS, AlKfA ROBERT LEROY LANDIS ) DARLENE LANDIS, AlKfA DARLENE JOANN LANDIS ) CIVIL DIVISION NO. 00-8797 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MANUFACTURERS AND TRADERS TRUST COMPANY hereby verify that on 10/9/02 & 12/6/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 10/9/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: February 3. 2003 ~~ ~NK FEDERMA ,ESQUIRE Attorney for Plaintiff - I ~ ~.iI l!f if ~ ~ o ~ i:' g s: il ~~g.~;l og........ CD {;;~a@!1; ~(lIS5lg. ~ ~ ~& ~ p.. ~.a. g.; ~ ~ g, ~ g' ..... _.::;:;;, 0 ~~goi' [~b!g ~._::;..8o _. ..."<: 'tl e.'" g.'d ~ ~~ 5l~ g 5",€!. og:02-~ ~.!" ~ 8 _. Ei 0 < '" ii::l ~t:'Ig=e ~~~gg: 6'i~a a ~.trj g. tt9.g.g ~ 5SI.\~ @ ........::s p..g.~~ 3 ::l ;::., fj; ~E!.c..g. . ~ g:l ~"d " .. :a~ iiil a ~.O"al!9:- g.na~ -8g8@. ~.~~ ~ E.] l! '" ~'g; g'~ ~ ~ S' CD ::l ::: ~ ~ g ~ fJ ~. W(l8@ CD s....:;! O::l '" _. a ~~~ (D<'l>- ::j . _. '" . ::to i,;l ::::;_. ~~8~ ~B'g~ g::"'''' !>> r:; <;;.~.~ [ ~ Q' :9.01 ~g, . z [I ~a. if ~ H n . 0 -~ 0" Slo' g H ~I _L... 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R R =l'lo:t:lj"t:lA C .!;I:S 'J i~,!! 9~eO F::l~ "'> ='ii' O~ ~U~~~~ a~iC)~~;3 o:q~... 01= ~:> ~~ ......""'" ,::= Kg:;; ~g 51- VI l:""i '~J go ~;g ! ~~ ~ '" Co ;S g <: ; ~ ~ > ~ 6.t-~I'Os)....... ,:)O:i .,,<^ !:j ~P,' :;.,,--- 8........... z- ~~ -=' ~ AfNEY sOW€S $ 01.800 . 0004300377 DEC 06 2002 MAILED FROM ZIP CODE 1 9 1.0 3 / 't . 7160 3'lO1 9844 0124 1563 .1 TO: i i I I. , ! l I j I i ! f DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS 15 HliL STREET MOUNT HOLLY SPRING, P A 17065 _~~fr~ l TEA;;l SENDER: REFERENCE: PS Form 3800 June 2000 RETIJRN Postage RECEIPT Certified Fee SERVICE Retum Receipt Fee Restricted Deliva US Postal Service i 'j i I , I No Insurance Coverage Provided i 00 Not Use for Intematlonal MaU ,~;',~._~~':..~' ._-~--,-,:~-,-'~-~~~~"_-,-.C-~-:-'---_..' ~ ~.":.-:--,-,~--~~::,-,~..-~:::-~,-~"~.~:~~-,.:;::.,c.~ Receipt for Certified Mail 7160 3901 9844 0124 1556 TO: ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS 15 HILL STREET MOUMT HOLLY SPRING, PA 17065 r:;;: .' I SENDER: ~~.~~~~I TEAM 3 REFERENCE: . PS Form 3800 June 2000 I RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 Not Usa fur International Mail :K1J' ~ 0.00 o '~liM.~ffi1.~I~,"",;f,;;';1.-':-J;M,,,,.;t",-Uo&8!&;M'~'f.l'!F~,\{",>Jl'O!o.&'O..-i<;;N:,P-l~1-Ir,!''MYH"""'~i';;i.IiMi~lli!llidt@j~llIll'mirtH~~-lli'::- ~"~ iIii~liI1_:J"'" '"' "" , . ~ "~'---!I . 0 0 0 C W ,1 s: ...,., '-! ul"T! nlrTl rr1 -j." ~r-r:~i CO , fir t~)-.- a 'IF? -<";;:' r-- Ci () ~ " " t--, ~ :?0 z ... ,~ >-8 '::' ~) rtl ~ c--l -,. en S:> -< .~; 1 :OS".,;, ,"~' =_."" .~, ,. ""_ , ~ ., .'.' .". ,'"__",,," ,1,,,, <.. _ ,'.-,,' ~ _^"~""~ ~. ~__h ,"~, -~,,-, "" -i:~~~"-.C:lOlH-l""II","'-' - ~-.." ..... "'~~'i.. AFFIDAVIT OF SERVICE " , 'PLAINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY .' CUMBERLAND COUNTY KMD No. 00-8797 DEFENDANT(S) ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS ACCT. #2008193597 Type of Action - Notice of Sheriff's Sale SERVE DARLENE LANDIS, AlKJA DARLENE JOANN LANDIS AT 15 HILL STREET MOUNT HOLLY SPRING,PA 17065 Sale Date: 3/5/03 SERVED ~ . Served and made known to Tn \(:l i\Q l Grrt', S . Defendant, on the Jo day Of,~ nll.ptuJo:i'2oo~ atJ:Ollo.o'c1ocke,m.,at \6 ~\\ &-") llOL.4'\.-\- ~r-,\\\r ~i~"P . Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. )< Adu1tfami1y member with whom Defendant(s) reside(s). Relationship is~ ) - J)(iaJf\.J , Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s).; Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant( s)' s company, Other: Description: Age~ , "<(11' HeIght ......LL1 Weight.L21 Race LC) SexA Other Sworn to and sub~bed before e this ~ day of ;). 200.;!,. Notary: tla ~ PI.EASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. I, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the N tice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. SBlJeJCN.IO UO!ler.x>ssv B!Ui!'/lI^SllLl~ '.taq 900G 'S;;: Ainr S9J!d><3 UCISS!lU lIIuno::> puIlllllQwll:) 'OlO9 a "!Illlld MIlaN 'Jadwnr 'r I1l9S I 8ION ""'iT NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant r 151 Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of . 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - J.D. No. 12248 ;.-"""~' - , ~. ~1~l;~"_Iil~~L",l,JJ_"~ iljWl,JUL;;W .~~,-'!,', AFFIDAVIT OF SERVICE . (PI:AINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY KMD No. 00-8797 DEFENDANT(S) ROBERT LANDIS, A/KIA ROBERT LEROY LANDIS DARLENE LANDIS, A/KIA DARLENE JOANN LANDIS ACCT. #2008193597 Type of Action - Notice of Sherifrs Sale SERVE ROBERT LANDIS, A/KIA ROBERT LEROY LANDIS AT 15lllLL STREET MOUNT HOLLY SPRING, PA 17065 Sale Date: 3/5/03 SERVED servedandmadelmownto~ll!oO{\- '\ RfY\i S ,Defendant'Onthe-19~ daYOf,~O~200~ at ');<19. o'clock?m., at_~t6 \-t..\ \ ~~. f'l'o. IAO)-+- \-\(',\ kl ~n""'ll ,Commonwealth .J "J ' of Pennsylvania, in the manner described below: Defendant personally served. =AAdult family member with whom Defendant(s) reside(s). Relationship is R (V\. - ';?, f ; ~ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant( s) reside( s).. Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age~ Height:21i .. Weight.m RacellSex ~ o~er I, \k. \l~1 \" ("'""Yd' I ~~ competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the ~~i Sheriff's Sale in the manner as set forth herem, Issued m the caphoned case on the date and at the address indicated above. S9Jl"lON JO \lO!PlPOSSV e~ 'JllQ S d b .b d oore 're.linr SElJ!dx9 UO! . . worn to an su scn e lI\unOO puepElQUlllO 'OJ08 before ,me this ~ day 0IIQlld M!loN 'Jadwnr T . of /iffl//... .200;?,. I'l8S (IlJl8lON Notary~d.<l-9~ By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On th~ __ day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: 2nd Attempt: / / Time: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 )~~~lliMI.ti1J!1J,eiL_'-'W~""H~Lo"~;Y,"*olV-1ii~*~~""WJj'!'~;"""'''i:' ',"ir _..l'N~", ;'foi,S, ;;'';:_~~~,';t4\''~Y;;,..@-,;jjtMi~~,I!\ki:;i"HffiIiW~~~llifM-!!i'!:'1/ii"aN@g,;lt:lSiliil<<€l1Mt"l'~' .~ - ,-.,.' o ~ -o6~ rnfT' '7-, ..,-__ ._J. t55~-^ -< ~~~ r;:c,,; "" 40 ~>~ ::z ~ ...,~, ,~) f.~ (.,) "1 ["1'1 ;:0 o -n Cl y -0 i ~~_j :-"'):.::D 'c::-'-C'J qfll "> :n -< w 01 ~, ~ FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MANUFACTURERS AND TRADERS TRUST COMPANY 3815 SOUTHWEST TEMPLE SALT LAKE CITY, UT 84115 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO. 00-8797 CIVIL TERM ROBERT LANDIS, AIKIA ROBERT LEROY LANDIS DARLENE LANDIS, AIKIA DARLENE JOANN LANDIS 15 HILL STREET MOUNT BOLLY SPRINGS, PA 17065 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem. in favor of the Plaintiff and against ROBERT LANDIS. AIKIA ROBERT LEROY LANDIS and DARLENE LANDIS. AIKIA DARLENE JOANN LANDIS, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 12/13/00 TO 7/30/01 $74,713.50 $3.870.10 TOTAL $78,583.60 p I hereby certify that (I) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) notice has been given in accordance with Rille 237.1, copy attached. ff/)/YJ~ i!11.L//M- FRANK FEDE , ESQUIRE Attorney for Plaintiff ........ DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE:...July .:H, .;Levf (t/J-/;;:;.-J ~. PRO PRO "THIS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. I; ~.j SHERIFF'S RETURN - REGULAR . CASE NO: 2000-08797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS LANDIS ROBERT ET AL WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE LANDIS ROBERT A/KIA ROBERT LEROY LANDIS was served upon the DEFENDANT , at 0015:00 HOURS, on the 29th day of December, 2000 at 15 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 by handing to DARLENE LANDIS (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.72 .00 10.00 .00 31.72 So Answers: ~~r#'~~(' R. Thomas Kline 01/02/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this day of ( Deputy She A.D. Prothonotary 4'0. - ~. ' I.' c , "---,~,,.;- 'l. SHERIFF'S RETURN - REGULAR CASE NO: 2000-08797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS LANDIS ROBERT ET AL WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LANDIS DARLENE A/K/A DARLENE JOANN LANDIS the DEFENDANT , at 0015:00 HOURS, on the 29th day of December, 2000 at 15 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 by handing to DARLENE LANDIS (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~-4!~~ R. Thomas Kline 01/02/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: \ Deputy Sherif me this day of A.D. Prothonotary :o1-~ . ~"'~~.u"'~.... ~~~ ~ ' ,",'J j- I '. ' ......:-fJi . FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff CIVIL DIVISION CUMBERLAND COUNTY vs. NO. 00-8797 ROBERT LANDIS, A/K/A ROBERT LEROY LANDIS DARLENE LANDIS, A/K/A DARLENE JOANN LANDIS f""" ~ [' ,~ (T>', "'');0, ,j -, "" "__ i., ,-, " ,-,~, J!f , L L ts ~,.H"~ Y Defendant(s) TO: ROBERT LANDIS, A/K/A ROBERT LEROY LANDIS 15 HILL STREET MOUNT HOLLY SPRINGS,PA 17065 DATE OF NOTICE: JULY 17.2001 THIS FIRM IS A DEBT COLL,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOS~. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 .< Frank Federman, Esquire Attorney for Plaintiff .1 , .~ 1IoJlidO<Io'''''''~';- ~liIOli<I~.... - '. "J~ ,,;oj I ~.' , ,'" --"~'1 FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 one Penn Center Plaza at Suburban Station, Suite 1400 philadelphia, PA 19103-1799 (215) 563 -7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS MANUFACTURERS AND TRADERS TRUST COMPANY CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO.00-8797 ROBERT LANDIS, A/K/A ROBERT LEROY LANDIS DARLENE LANDIS, A/K/A DARLENE JOANN LANDIS FilE COpy Defendant TO: DARLENE LANDIS, A/K/A DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRINGS,PA 17065 DATE OF NOTICE: JULY 17.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~ Frank Federman,Esquire Attorney for Plaintiff , '" ~"' - - . FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MANUFACTURERS AND TRADERS TRUST COMPANY Attorney for Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-8797 CIVIL TERM ROBERT LANDIS, A!KIA ROBERT LEROY LANDIS DARLENE LANDIS, A!KIA DARLENE JOANN LANDIS Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of1940, as amended (b) that defendant ROBERT LANDIS, A!KIA ROBERT LEROY LANDIS is over 18 years of age and resides at 15 HILL STREET, MOUNT HOLLY SPRINGS, PA 17065. (c) that defendant DARLENE LANDIS, A!KIA DARLENE JOANN LANDIS is over 18 years of age and resides at 15 HILL STREET, MOUNT HOLLY SPRINGS, PA 17065. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1rM~ 0dU111$V FRANK FEDERMAN Attomey for Plaintiff ,;,'- ~- , ~," - " ~ L ^ "'<iffi.,; (Rule of Civil Procedure No. 236 - Revised) MANUFACTURERS AND TRADERS TRUST COMPANY : CUMBERLAND COUNTY : Court of Commou Pleas Plaintiff : CIVIL DIVISION vs. : NO. 00-8797 CIVIL TERM ROBERT LANDIS, A!KIA ROBERT LEROY LANDIS DARLENE LANDIS, A!KIA DARLENE JOANN LANDIS Notice i:!,ven that a Judgment in the above captioned matter has been entered against you on JULY .'itlt6. ~Ool. . By ~a~ p .27'fDAAf.!TIEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TIllS F1RM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** '^~[i~~"-,,'*t,~6iej:r.t~AA~~~;iijjIj;fdX#,,,"--"".1">"',,~~~'~"'~"-'~"'""i!:o.>A'ii\0!~,'{ji<i,~i'!i~-;_~111-- '.^.~ilj~W~dN-"~'M'''':- " ". -.~, ,,-,,,, , ~ -l<l -- ~ ~ ~ ....0 ~ -- B -- -, ~ ~CJ r ~ ..... -- ~ r r -..l:: -I" ~ ~ .. ~ en ~_., ... ~t -'. ("..:' f' r-> ~ , to \ \ \ ..1. -~,=". . < ." , - " - ,~." ~. ~ ~ ,. ~=" ~~"" t; FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400 One Penn Center Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff MANUFACTURERS AND TRADERS TRUST COMPANY COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 00-8797 ROBERT LANDIS DARLENE LANDIS DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. liU~ l~~.. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: July 26, 2001 f~ ".i;~' '" I~ 1 ~ '''''''''","_~f,' 12/27/00 WED 14:45 FAX 2155637588 FIlDERMAJi & PHELAN III 006 ROBERT LANDIS #2008193597 VERIFICA nON <2:K)(1\)XlO. YY'en:1DzU hereby states that helshe is -fore.GIO"'ztLre '3peV CtXI~t of f'al (PQnk$ Capi+cJ Cor p. mortgage servicing agent for Plaintiff in this maller, that he/she is authorized tg take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of histher knowledge, infonnation and belief. The undel~igned understands that rbi. statement is made subject to the penalties of 18 Pa. e.s. Sec. 4904. relaling to lUlSwOrn falsification to authorities. '-, " ""., , DATE: fl- d-0 -01 1I ',- l.'_' ,.".J ~. ....",<. '=",",," c.-: ; ) ~ _'J!IlI$,i't"'IRtIlII!l~"l:!!'iig!l!W1Plll " _~ ~.,~..~..,. ,'11J~ ~ ~ "'. , .-~ : lJAR 0 9 ZOOl , l,l~I~'~'~~A'}j...s;""-""j'JY*wnm,,'>:!,II';i'!~''!-l$!1l'!''!t',!~J:!j,,j!lQW~''''J','1;~'~~""1S':"",.,a:",,,,_,,;,,, _,~~ :od2Jlliiil ,- ~~ ...;:" I, -'-'~- '" ,~-,', ' ,lie SHERIFF'S RETURN- REGULAR CASE NO: 2000-08797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS LANDIS ROBERT ET AL WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LANDIS ROBERT A/K/A ROBERT LEROY LANDIS the DEFENDANT , at 0015:00 HOURS, on the 29th day of December, 2000 at 15 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 by handing to DARLENE LANDIS (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.72 .00 10.00 .00 31.72 So Answers: f!""~-.,~~t R. Thomas Kline 01/02/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: ( Deputy She me this 3,w1...., day of ~ ~f AD C~ ~ .~, rothonotary ,.itiJ~ ~ " - ~. ~' I~ ,[, ,-~,', ~ ," "~-'l;:; SHERIFF'S RETURN - REGULAR , CASE NO: 2000-08797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS LANDIS ROBERT ET AL WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LANDIS DARLENE A/K/A DARLENE JOANN LANDIS the DEFENDANT , at 0015:00 HOURS, on the 29th day of December, 2000 at 15 HILL STREET MOUNT HOLLY SPRINGS, PA 17065 by handing to DARLENE LANDIS (WIFE) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~.~~t:~! R. Thomas Kline 01/02/2001 FEDERMAN & PHELAN Sworn and subscribed to before By: me this 3>1AC day of ~ ~I A.D. (l1M.- D 'yw,POL..) V!Af:: ,-, I forothonotary I' r - J -~-' ~~~- ~1Il~ ..""""~,~ =~. _lL.. , .' . "-"- ~ -, " ~0 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION MANUFACTURERS AND TRADERS TRUST COMPANY 3815 SOUTHWEST TEMPLE SALT LAKE CITY, UT 84115 Plaintiff TERM NO.6D-?'I9r (?,Q'<l~ CUMBERLAND COUNTY v. ROBERT LANDIS, AlKJA ROBERT LEROY LANDIS DARLENE LANDIS, NKJA DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRINGS, P A 17065 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE >'.'.',. "TillS FIRM IS A DEBT COLLECTOR ATTEMPTiNG TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BEDSED FOR THAT"~SE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEIlT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD.NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFOIWE!\!JENT OF A LIEN AGAINST PROPERTY. .. You have been sued in Court. If you wishiddefend against the claims set forth in the following pages; you must take action within twenty(:20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief .d requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE. SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: 2008J.93?97 ,,," . ""'" ~~ ~~- "', - '-.--'<~:~ 1. Plaintiff is: MANUFACTURERS AND TRADERS TRUST COMPANY 3815 SOUTHWEST TEMPLE SALT LAKE CITY, UT 84115 2. The name(s) and last lmown addressees) of the Defendant(s) are: ROBERT LANDIS, NKJA ROBERT LEROY LANDIS DARLENE LANDIS, NKJA DARLENE JOANN LANDIS 15 HILL STREET MOUNT HOLLY SPRINGS, P A 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/8/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FIRST UNION HOME EQUITY CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1184, Page 626. By Assignment of Mortgage Recorded 6/30/94 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book NO.4 77, Page 109. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 9/13/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. l' ". ~ J, 'c'l, '. '-~ ~, ~, ~ - ;S;~, 6. The following amounts are due on the mortgage: Principal Balance Interest 8/13/00 through 12/13/00 (Per Diem $16.90) Attorney's Fees Cumulative Late Charges 12/8/93 to 12/13/00 Cost of Suit and Title Search Subtotal $68,239.33 2,078.70 3,411.00 0.00 550.00 $74,279.03 Escrow Credit Deficit Subtotal 0.00 434.47 $ 434.47 TOTAL $74,713.50 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. 91680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $74,713.50, together with interest from 12/13/00 at the rate of$16.90 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~~::r~ / s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "~' "'" ~~ -~. ": ,. ."~); ALL. that certa.i~ piee;e or pa':cel of lancl situate in the Borough of Mt. HOll~ Springs, CUn:'b~.rl...nd County, Pennsylvania., bounded and described as tollows: . ., ... B.EGINNINO at a: p~int on Hill Street. at the. Corner of lands formerly of L. M. ~Au.traw now of Samuel GaroDlllik; thence along lands of the same South 2.3 d.sr.... <4.5 minute. :&:ast 67~ feet, more Or le.., to .tones at corner c4 lands liow Or tor...erl)" ~t J._ W. Craighea.d; thenee along Landa now or . torrnerly.ot:s. W. Craigh.ead, South 5Q clegree.. 5S minutes West 151 Leet, . moreor les., to ston.. ai: cOrner of laneSa ot:s. tIf. Craighead a.nd Clair Yeinga thence al'(;ng lancls of Clair Yeingat, North a1 d.grees 15 n:linute. West 730 feCI more or lesa, to a point. on HiU Street; thence alona Hill Str.et, No..th 7l. clegree. East, 111.3 feet, moro or less, to the place of Beginning. Having thereon erected a two stor.y dw.lling house and garage. Containing Z Acres an 12 perch;"..., <nOre or Ie"..; .Being kno":'n as NO. 15 Hi:U Street, Mt. Holly Springs. Pennsylvania.~: ;. BXING th~ .am';:p~en:oise. which George W. Mayhugh and Elsie M. Mayhugh;~hi. wite, by deed dated Decel:Qber 2.9, 1943, duly.re<=orded ill. De..d Book la "T" 89, granted and conveyed to WilliarD H. Harman and Grace E. Harman, his wiLe. The ..aid WiUiam H. Harznan cUeci .Ap~ 3, 1953, u..... vesting tiU';::in hi. ..iiiclow;' Ci-ae. E.' R.u'man by .urvivorahip. The aaiei Gaoace E. Haaoz:tlan 'has since i":ie z.-m.arried with Roy M. Bly, a.nci is n_ mO.D a. Orace E~ .:Sly, who tog.theao. with.her hual:>a.nci are the.partie. ~ the fir.t part. , . .--, ....-; I~= j , , "_Jo ~ 'U"'~'~"" VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this maner, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 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