The URL can be used to link to this page

Home My WebLink About01-0088 FX .. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (21~) ~1i1_7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY, MT. LAUREL, NJ 08054 TERM Plaintiff NO. 0 I -8(5 Cloll v. CUMBERLAND COUNTY KIM D. KLOSE 6605 CARLISLE PIKE, MECHANICSBURG, P A 17055 Defendant(s) C'TVTT. ACTTON - LAW COMPT.A TNT TN MORTr.cAr.cR FORRCT ,OSTTRR NOTTCR **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing 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 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, P A 17013 (717) 249-3166 Loan #: 7983026 11- I, ~ -~ ,- " J. Plaintiff is: CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY, MT. LAUREL, NJ 08054 2. The name(s) and last known addressees) of the Defendant(s) are: KIM D. KLOSE 6605 CARLISLE PIKE, MECHANlCSBURG, P A 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/21/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1477, Page 911. 4. The premises subj ect to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 1<-1 ~ - ~"", .- , 6. The following amounts are due on the mortgage: Principal Balance Interest 2/1/00 through 1/1/01 (per Diem $14.97) Attorney's Fees Cumulative Late Charges 8/21/98 to 1/1/01 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $76,690.46 5,029.92 3,834.00 251.52 55lLO.Q $86,355.90 0.00 148.2.i $ 74R ), $87,104.15 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. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $87,104.15, together with interest from 1/1/01 at the rate of$14.97 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. 11- ~~ ~}-~ I~/ Fr:mk- F~ilp.nn~n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ <--""') ,"-, '" ~- ALL THAT CERTAIN lot of ground with improvements erected thereon situate in the Village of Hogestown. Silver Spring Township, Cumberland County, PennsYlvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which is thenortbwestern corner of the lot herein described where the same comers with property now or late of Paul Rhoads and the southern edge of the right-of-way of the Carlisle Pike, also known as U. S. Route II: thence North 69 degrees 30 minutes East, along the southern edge of the said right-of-way, a distance offorty (40) feet to a point; thenee South 20 degrees 30 minutes East, along property now or formerly of Harry Mixcll. a distance of one hundred fifty (l SO) feet to a point; thence South 69 degrees 30 minutes West, along the northern edge of a fifteen (15) foot paved alley, a distance of forty (40) feet to a point; thence North 20 degrees 30 minutes West. along property now or fonnerly of Paul Rhoads, a distance of one hundred fifty (ISO) feet to a point; the place ofBEGINNlNG. BEING Lot No. 39 on Plan of Hogestown and as described in accordance with the survey of Genit J. Betz, Registered Surveyor, dated June I, 1972. BEING the same premises which Gary M. Neights and Emma B. Neights, husband and wife, by their deed dated August 28,1987, and recorded in the Office of the R.ecorder of Deeds in and for Cumberland County in Peed Book "X", Volume 32, Page 454, granted and conveyed untO Paul E. Gerhard and Pearl C. Gerhard, husband and wife, Grantors herein. HAVING THEREON ERECTED a dwelling house known and numbered 6605 Carlisle Pike, Mecbanicsburg, Pennsylvania 17055. ,~. 1"1 J I " ~ ~ , . "" " . ~ VERIFICATION MARK HINKLE hereby states that he is V.P. ofCENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correctto the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. J4.llt.L/ r DATE: Itl//J9/00 , ~I- ,,, '_J - iiIl i ~0 :=. 7'~ 8, s::... ~ ~ -t ~ r;;;:- '~""" .'" .." ~,< IlQI!IIlIII!!' ~ -~~_. "I ~,-, <~ v, ,. ,-~--. -.,-,"'- --. -- -- " (~ ce -0 t7 ~ e.g- . ~ (\J .., ::s: ~ c:.... o c -<, ""DDI ~~r ~~. ~~F~ Pc: '7 :::; -< 611~ c -;-,. ~ -,""- .r;-' -:;J r;-;'l .:..,.., \D ~s )(.f =<~ ~1mM ~-"""~('f!!H~t~",",'~~ 1M1i,1lI:"ZjIi'."lil'!<'-l'.,,_, -, Hi'lJjijiiliM1 .. ~ ~ ,",~,""...lig 1!iI!~'t"i SHERIFF'S RETURN - REGULAR CASE NO: 2001-00088 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS KLOSE KIM D CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KLOSE KIM D the DEFENDANT , at 0017:12 HOURS, on the 17th day of January ,2001 at 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 by handing to KIM KLOSE 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 18.00 5.58 .00 10.00 .00 33.58 S~iZ~~t R. Thomas Kline 01/18/2001 FEDERMAN & PHELAN Sworn and Subscribed to before me this J. '-I 'C day of ~.u '''j ::l..-<n1 ( A.D. C};,I.L- a. ~ di~/ # Prothonotary' BY'~:4?~~ Deputy S iff -~W'<I ""'1 [-'I -,;" () ." ~ -~. FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION 6000 ATRIUM WAY MT. LAUREL, NJ 08054 Plaintiff Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION vs. : NO. 01-88 KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 Defendant(s) 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 KIM D. KLOSE, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: , i As set forth in Complaint Interest 1/1/01 to 2/21/01 TOTAL $87,104.15 778.44 $87,882.59 i , ,-1 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 Rule 237.1, copy attached. ~k ~~~ FEDERMAN, ESQUIRE Attorney for Plaintiff D~GES ARE HEREBY ASSESSED AS INDICATED. k~ 4 DATE: J..-J.3 (0) ~. 1tII~ PRO OTHY ~ "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEfVED A DISCHARGE IN BANKRUPTCY AND THiS DEBT WAS Nor 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. .. - , 1"1" -'I- 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 CENDANT MORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY KIM D. KLOSE NO. 01 - 8 8 Defendant(s) TO: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 FILE COpy DATE OF NOTICE: FEBRUARY 7. 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, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ;~~~ '-, '-1""1 I" - " - FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103.1814 (215) 563-7000 ,,,,,' ,~~ Attorney for Plaintiff CENDANT MORTGAGE CORPORATION Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas vs. : CIVIL DIVISION KIM D. KLOSE Defendant(s) : NO. 01-88 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: '"'''' ..-,., (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant KIM D. KLOSE is over 18 years of age and resides at 6605 CARLISLE PIKE, MECHANICSBURG, P A 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~E~1I;AfM-- Attorney for Plaintiff ."'.. I. I ". ~ 'I ~,.~, , (Rule of Civil Procedure No. 236 - Revised) CENDANT MORTGAGE CORPORATION Plaintiff : CUMBERLAND COUNTY -. : Court of Common Pleas vs. : CIVIL DIVISION KIM D. KLOSE Defendant(s) : NO. 01-88 Notice is given that a Judgment in the above captioned matter has been entered against you on FEBRUARY ,).3 ,2001. By~J ~EPUTI / .~" If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 "TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND 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. ,* ._,,, !Ii4 .. ",=,=",-".,," _""'_~_T ,~- -~_.~ ~x~ ,,/" 'b ~ ?t:, ~ ~ ~ ~ r;:> (<. '......:... c. <><,) ~ -- =<0 - '. .. .,,-.-..... .. c(' ~ v ~, ~~"~,,~'" - ~ ~ d 9--, , ~ '-.)J ~ (') c <' \]i-~ ~~~"j Z(' v~ ;." "~ ~: -- ~2 -7 =2 ". " ~':'l:I)j!1f~FW'3li1~h'.,"Prt_'l';~"!1f1~l'i1_~__,...., ",,_. ...- 1IIiII,' liT ,,-) -; ) -...., ;'Tl ~--:G ['0 t~,) Cj- ~..,.-, N ,.J tS \Lf ,?mli_~~j?: i PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION Plaintiff, v. No. 01-88 CIVIL KIM D. KLOSE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $87,882.59 $ 6,777.05 and Costs Interest from 2/21/01 to 6/5/02 (per diem -14.45) TOTAL $ 94,659.64 ~~:T~ FRANK FEDERMAN, ESQUIRE One Peun Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. ,,' ~ ~r"fl ,,-- .. >.=o_r~., ~_'"-" __",.~~.,"_r C) r 2- f'C" Yo, ~ ~ :.<<. .-'-. '= ~... G ~ ~ ~ -ot~:! ',00 ')::) <Q. "- ~i; rurn 't ~ :.0 t..., z::0 fk :-...... . c.-.. h ozt;:". ,~ . , (P. ,', 8 ~ D 0 & < . =<.> 'lo r:'C :;,."^' C' c- o ~ ~ '- ~ ""C' -- Iltl z.-l i9 }: I I C> :-:;='L) 6 I I YC: " Z lI) lV ~ -U :.;:, \.0 $,; \) [) :: , ... F -...} - ~ ... ~ ~ ... ~ - ... , ..... ... "- , V~ ... - ... , ~..z:- -niTH [II ""rm1 - ,. .1""'1, ~"~~ .'"' _ ~~. . ~ ~ w"""""!' ,,', i"'" ~~'!"'_~~-'^ "", .,...,,"-'l",-:j;[-'c.,~,,"m~7><""'~""f'~>:"ii<1~j~'"It'l~~!l!'~'''' -,~~~""'''''~-~,~'? r "~mPJ:!I~~': DESCRIPTION ALL THAT CERTAIN lot of ground with improvements erected thereon situate in the Village of Hugestown, Silver Spring Township, Cumberland Couney, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which is the Northwestern comer of the lot herein described where the same comers with property now or late of Paul Rhoads and the Southern edge of the right-of-way of the Carlisle Pike, also known as U.S. Route 11; thence North 69 degrees 30 minutes East, along the Suuthern edge of the said right-of-way, a distance of forty (40) feet to a point; thence South 20 degrees 30 minutes East, along property now or formerly of Harry Mixell, a distance of one hundred fifty (150) feet to a point: thence South 69 degrees 30 minutes West, along the ;.tonhern edge of a fifteen (15) foot paved alley, a disrance of forty '(40) feet to a point; thence Nonh 20 degrees 30 minmes West; along property now or fOrIIi.erly of Paul Rhoads, a distance of one hundred tifty (150) feet to a point; the place of BEGINNI?\iG. BEIl'iG Lot Nu. 39 on Plan of HogestDwn and as described in accordance with the survey of Gc:rrit J. Berz, Rc:gistered Surveyor, dated June 1. 1972. HA VING THEREON ERECTED a dwelling house known and numbered 6605 Carlisle: Pike. Mc:chanicsburg, Pennsylvania 17055. BEING Tax Parcel # 38-18-1332-039. RECORD OWl'iER TITLE TO SAID PREMISES IS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard, husband and wife dated 8/21/98, recorded 8/24/98, in Deed Book 184, page 61. ,,~ , .--. " ,~~ .W~" FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION KIM D. KLOSE NO. 01-88 CIVIL 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: (X) an FHA mortgage () non-owner occupied () vacant () 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. ~~~ FRANK FEDE AN, ESQUIRE Attorney for Plaintiff . ~" ,--,., H~I - e!l'l .", ''< CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIM D. KLOSE CIVIL DIVISION Defendant(s). NO. 01-88 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .6605 CARLISLE PIKE. MECHANICSBURG. PA 17055. I. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address caunot be reasonably ascertained, please indicate) KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 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 caunot be reasonably ascertained, please indicate) None. '~ . _. .-. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address caunot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address caunot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address caunot 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 caunot be reasonably ascertained, please indicate) Tenant/Occupant 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 19, 2002 DATE ~~:;ju~ FRAJ{KFEDE~AN,ESQU]RE Attorney for Plaintiff . :,,,l'li!fil~ II I' I --" CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-88 CIVIL KIM D. KLOSE Defendant(s). February 19, 2002 TO: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 "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. 6605 CARLISLE PIKE. MECHANICSBURG, PA 17055. is scheduled to be sold at the Sheriff's Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 87.882.59 obtained by CENDANT MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ";"'''''~.';''.' '<~i:fi,;~ ',,"'i_i '1 "' _~ ,~~ , I-I ,,, ~ I~~ " ,,"' ~~__I YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. 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 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 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 LmERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 1:_H__ ^ _ " ,~. " "".. DESCRIPTION ALL THAT CERTAIN lot of ground with improvements erected thereon situate in ehe Village of Hugesrown. Silver Spring Township, Cumberland Counp}, Pennsylvania, more particularly bounded and described as follows. to wit: BEGI='iNING at a point which is the Northwestern comer of the lot herein describ<:d where the same corners with property now or late of Paul Rhoads and the Southern edge of the right-of-way of the Carlisle: Pike, also known as U.S. Route 11; thence North 69 degrees 30 minutes EJst, along the Southern edge of the said right-of-way, a distance of forty (40) feet to a point: tb~,".c_ :c <.leh ::U degrees 30 minutes East, along property now or formerly of Harry Mixell, a distance or one hundred flti:y (ljO) feet to a point; thence South 69 degrees 30 minutes West. along the Northern edge of a fifteen (lj) foot paved alley, a distance of forry--(40) feet to a point: thenc:: ='iorrh 20 degre::s 30 minutes \Vest, along property now or formerly or Paul Rhoads. a dist:l.llce of one hundred tifty (ljO) feet to a point: the place of BEGI='iNI='iG. BEING Lot :-';0, 39 on Plan of Hogesrown and as described in accordance with the surve:; or Gerrie J. Berz. Registered Surveyor, dated June 1, 1972. H.-\ VING THEREON ERECTED a dwelling house known and numbered 660j Car~isle: Pik:: - . Mechanicsburg. Pennsylvania 170jj, BEING Tax Parcel /I 38-18-1332-039. RECORD mV~"ER TITLE TO SAID PRE"IISES IS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard, husband and wife dated 8/21/98, recorded 8/24/98. in Deed Book 184, page 61. '51..:!, . "~ 1'1 I.,' ~ "' " -., , ,,",. ~, -..,.,.,~""'~ ~. ~'.' o {',) Q c. :2;. ""OCf; ~P" Z';S ';2',..." (jJ"-,~, ;.(...:.-- ~C."__' 7?,:Q. /-~, " 7(~"::. ~ ~:.. :J'. ...,-yl' ':i~ \ SA --j _\ ~;:~ --.h.. -' ,..-, ";": - ,0 ,- ..~OKnl!!.. _~ ~,*"w,;1!t)lm,"!l.'''''''''J'('H;r,J1~ml'''~~~~ljr,~~!m'lll!'!'f~f.f:r';!ln~j ., ..., /~ Steven K. Eisenberg, Esquire Steven K. Eisenberg, Law Offices Attorney Numbers 75736 530 W. Street Road, Suite 200 Warminster, Pennsylvania 18974 Attorneys for Cendant Mortgage Corporation (215) 675-4211 Polk, Scheer & Prober P.O. Box 4365 Woodland Hills, California 91365 In The United States Bankruptcy Co For The Middle District of Pennsylva LED HARRISBURG PA loRe: JAM - 1 ?W:::'2 Chaptell' 13 Clerk, U.S. Bankruptcy Court (;rfifL. Kim D. Klose Kathy J. Klose DEJ3TOR(s) BANKRUPTCY NO. 01-03224 Order f,~r Relief from the Automatic Stay Pursuant to 11 U.S.C. ~362 in Favor of Cendant Mortgage Corporation HEARING DATE: AND NOW, this 1M day of 'Q;nuttr j 200.2- , this matter having been brought before the Court by Steven K. Eisenberg, Esquire, attorneys fOJr secured creditor, Cendant Mortgage Corporation ("Cendant"), by Motion for Relief from, and to Vacate, the Automatic Stay (the "Motion"), , and it appearing that said Motion having been regularly served upon all parties concerned, and after [opportunity' for a hearing] [hearing], and for good cause shown and upon consideration of said Motion, it is hereby ORDERED that Judgment by Default be entered in favor ofCendant Mortgage Corporation and against Debtor(s), Kim D. Klose and Kathy J. Klose, for failing to respond to Cendant's Motion for Relief from the Automatic Stay; and it is further, ;'~i'llrr'f r"",,,M . , 0_,""'.__ , Docket for Case: "+ GetCaseNoO + II (" + DktTypeExpand(m.gsDktType) + ") Page 1 of2 -'" Bankruptcy Docket Report 1 01-03224 (Harrisburg) KLOSE, KIM D and KLOSE, KATHY J Docket items entered between 0110111931 and 02/28/2002 Filing No. Docket Entry View Date document 06/05/01 1 VOLUNTARY PETITION under Chapter 13 & Mailing Matrix [EOD 06/06/01] Doc #1 PDF (2 [CR] pages) 06/06/0 I 2 NOTICE of intent to dismiss case unless missing documents are filed: due by None 06/21/01 Re: Item # 1. [Compliedl [EOD 06/06/0Il [CRl 06/22/01 3 CORRESPONDENCE to Attorney allowing until June 29, 2001 to file missing None documeuts. Re: Item # 2. [BOD 06/22/01l [CA] 06/29/01 4 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. Doc #4 PDF [EOD 07/03/01l [CR] (23 pages) 07/16/01 5 CERTIFICATE of Mailing of Notice of341 Meeting. Objections to the plan are due None 15 days after meeting held. [EOD 07/16/01] [CA] 08/16/01 6 341 meeting held. [EOD 08/16/0Il [CA] None 09/04/01 7 ORDER Cornrrming Plan Re: Item # 4. [EOD 09/04/01] [DR] None 09/07/01 8 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on None 10/11/01 at 02:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 [EOD 09/07/01l [JC] 10/16/01 9 STIPULATION by PARTIES. Re: Item # 8. [EOD 10/16/01] [CG] None APPROVED by the court. [EOD 10/16/01] [CGl 11/30/01 10 MOTION for relief from stay Re: Cendant Mortgage Corporation (Fee paid, Receipt None #576580, $75.00) [Disposedl [EOD 11/30/0Il [KZ] CERTIFICATE OF NON-CONCURRENCE [EOD 1I/30/01l [KZl , 11/30/0 I 11 ORDER that answers aredue on 12/20/01 Re: Item # 10. [EOD 11/30/01] [KZl None 12/06/01 12 CERTIFICATE of service Re: Item # 11. [EOD 12/06/01] [CRl None 01/07/02 13 MOTION for defaultjudgmentRe: Item # 10. [Disposedl [BOD 01/07/02] [CRl None 01/07/02 14 ORDER granting defaultjudgmentRe: Item # 13. [EOD 01/07/02] [CRl Doc #14 PDF ORDER granting relief from stay Re: Item # 10. [EOD 01/07/02] [CR] (3 pages) rnntea: : lU:)):Ul5 I PACER Service Center [ I Transaction Receipt [ I 02/28/200210:55:08 [ IP ACER Login: IIfp0039 IIClient Code: I [Description: IIDocket IICase Number: 1112001-03224 [ I II II II I http://pacer.parnb.uscourts.gov/cgi-binlfoxweb.exe/npacer/nPacer?ExecThis=docket&puid=O 10 2/28/02 !'""~...,,"" .-, 1""'1 ( ... ., -"f , Docket for Case: "+ GetCaseNoO + II (" + DktTypeExpand(m.gsDktType) + ") Page 2 of2 .' IIBilIable Pages: II 112 IICost: 110.14 ~Need help? Try the PACER User's Guide ~acer Service Center http://pacer.pamb. uscourts.gov/cgi-bin/foxweb.exe/npacer/nPacer?ExecThis=docket&puid=O 1 0 2/28/02 ,~ , J'PG- . .... .- AFFIDAVIT OF SERVICE . CUMBERLAND COUNTY PLAINTIFF CENDANT MORTGAGE CORPORATION No. 01-88 CIVIL DEFENDANT(S) KIM D. KLOSE ACCT. #7983026 SERVE KIM D; KLOSE AT 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 SERVED Served and made known to J<-\ "'^ 0 I K [0 5 ~ . Defendant, on the /0 fl day of }J1~(.1. "" . 2002,. at 7: ~"I ,0'c1ock~.m.,at rgr,,05"' ~-\)tt -R\:.~ I 0Jle.I..~,,""""c....~.lt.') . Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. ';/--- Adult family member with whom Defendant(s) reside(s). Relationship is 'S 0 IV Adult in charge ofDefendant(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. vJClVi J. )(\t> se Other: Description: Age----l-8- HeightL Weight~ Race~Sex~ Other j \...,.Se.'5 I, Cld~ U->c 'to L, C..~~ ~'li competent adult, being duly sworn accordin to law, depose and state that I personally handed a true and correct copy of the N.;tlce of Sheriffs ill e ~~!At_ herein, iss d in the captioned case on the date ,and at the address indicated above. ElIZABETH M. Jo.'"1A~lSS0N, NoIIIy PubIIo Greene Wip., Ff~iikli~ County Sworn to and subscribed My Commission Ellpiroo Dee. 19, 2005 befor~ rpe this ~day of~1r. ,200~ ---.... '- /) Notary:~ "h\. ~h~BY: CJ- ' PLEAa ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE D . NOT SERVED On the day of .200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 -;~~'""""""'1-~-' . .-""" r~-'I .. I ~ \ -.. ;''''''',~- 1~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: CENDANT MORTGAGE CORPORATION ) ) CIVIL ACTION vs. KIM D. KLOSE CIVIL DIVISION NO. 01-88 CIVIL ) ) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for CENDANT MORTGAGE CORPORATION hereby verify that on 2/28/02 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 2/28/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: April 18. 2002 ~:~~R~~~QUlRE Attorney for Plaintiff . . I ~<I"" I - c I' , , r .' ~i ~q, c~ '" o .\~\ 1'- @ii ~l-'tm\' ~ ___ h-i ? \ ~D:i-'I- ~" ~ .I' ,'\,.."'" :. .. ." -,-.:_.:, ...... " p,- "".. ~__I:-i . v ... ~ 8 ~ 0;;-= -c E- .~ :::I sa~ ~ Pfj~.2 z ~ ~ ;:J]1;! ~~dl~ ::c:~ M ~CI)..go ~~@~ ~5~~ u ~ of 2~:E ~d;~~ Out-cO ~J::"""":-= ~O\O--" -~ 't:l ... ;~~ ., '" = 8.a '" ~"C~ z<t:O ~~.,.~,,,,.t'" '~""~ . - '" - o r--- - ~ :.: " . u " o ~ ~ ..--l ~ I ! <>:: a:I g; ~ ~ ~ ~ ... ~ :r: tIJ ~ ?; ~ z 1) a:I ~ ~ t3 ><" z ~ ~ ~ u 8 '" ~ ~ ~~ ~" oj i;; ~ ..--l a:I > Ul ~ ~ ~ u Z u C> ffi lr1 [/) lJ..t g z ... \0 o 0 b ~ j ~ gj ~ ~ ~ t; 0 ~ ~ o u . .. ~ o . ". t " "' g ~ ~ ~ :5 . . E . z ... ~ ~ ~ .. ~ U <Zl ~ ~ " .S ..... ..--l -- ~~.I I I I I I I I . .., '" . ' _ 09~g909 , !=Sftl"= HWW", '\lei'', .~ .m!SOd"s'; ,;.~,.l. : ~lo,aco .3<~J: ... ..' -......",', ,) ,," -.,eo..i .30"'1 _. _ "'_ :::.=::::1 r I , , - <81:: !'I ~ 'E. a 1 t'~~ z.6' g'a o~~~ .~ g ~.g ~ ~".;:; ~ -g~:Bg "E.!!l @Q E g"@ ~ 'R ~ E .; E ~;-:: g ~.~ ~ ~ f-<.2 '" ::: ] ~ i'~ "0 a LQ.il i!! 0 i:l 0. Il.I tl 0 0 ;;;.... <u,s '~~:g'~ ~ ~ ~= ::: <.> P.:\l .,g.g..c:-~ ~ r; ~ 'g ~::;s-o"O ~ l:l'~ ~ @ a 5'~ .g Uj.E ~ "'.... ><.. E~E~ .g3J:l8~ ~ E-!;''O~-~' 5Eg~~ "0 ::l e.:!l 0 i!! g !3.1!~ "9"0 <.>.0 0 o".1! g~;g ; ~ t a.2 ._ 0 0.03 <I.> o.ag'-';:l ~~o~~~ ~g~.g.8 a '0 ;::'6 N ._ l:: 0 ::I 0\ E.g.~.S~ ~~:.::~a ~ ;g ~ ~ ~ ~ ~_~~Bl~ 1!...:ggg .....;S"'~~ I on o - r--- - -< '" c:f e3 a:I ~ on on o r--- - '" c 'S 'g .:! ~ o ! " ~ .: .~ ~~ "-,, ~~ c.Ul ~ <t: B u o ~ ~ ~ " . .~lE "0 'ou: " c 11" ~~ z ~ r~ >-.:! ~ M Q 12 '" ..... " -1l 0 ~ on \0 ~&' ..... 00 ." '" 0 - -fj~ - N - - '" :': C'~ - ~ z--' I a 8 o . .....0: " ~~ , N '" " rill II , 71bO 3901 9844 70418828 , TO: KIM'D. KLOSE . 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 SENDER: JPG - K.~ REFERENCE: KLOSE - 7983026 PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE R(!tum Receipt Fee Restricted Delivery Total Postage & Fees .... 2.10 , 1.50 .00 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail '" ... - ~~, ,," 'h.~.<'> "....._;~~.~'''''' it ~, ~~, ~"- - "0.-' ~.'< _~,~ .WJ = , f (J CO () C r'v -n <' ".P!'o -r) " me' ~ rn ,,: -;-0 ::':. --. --' cT; Z N , - C.\ " U , .::.<- ",,"- (~) I~ " .,~- -- -C' --.-, ~ ~-- -n ;~ C (~ c:: .. " ..~. rn C" ~~ :;.!: :=> ,- --I ::0 -< .~ -< 1:5 \L-q o.'l"""" :Ol"""~~~F""ffi:W-"""1""?!h',--w"'r"m."""\>"'1"'T'\\'il!;'lll1ltIiMW-"iWWi!~!!!~!'l~'lfffl~IiWf,lft1\'I~~!~j ~ . SALE DATE: JUNE 6. 2001 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CENDANT MORTGAGE CORPORATION No.: 01-88 vs. KIM D. KLOSE AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.c.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 6605 CARLISLE PIKE. MECHANICSBURG. PA 17055. As required by Pa. R.C.P. 3l29.2(a) Notice of Sale has been given in the mauner required by Pa. R.C.P. 3l29.2(c) on each ofthe persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy ofthe Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ~~~ At orney for Plaintiff May 3,2001 ~ - ;. .' ,-I"""I ~~ < . , . CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIM D. KLOSE CIVIL DIVISION Defendant(s). NO. 01-88 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPOR.~TION, 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 6605 CARLISLE PIKE, MECHANICSBURG. PA 17055. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NALvIE LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: . NANlE LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NANlE LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has, any record interest in the property and whose interest may be affected by the sale: NANlE LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NANlE LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) Tenant/Occupant 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 26,2001 DATE 4~/2:{d~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ;;J;". 'I -. < 'f'"?'1 II DATE: 02/26/01 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) KIM D. KLOSE PROPERTY: 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on JUNE 6. 2001, at 10:00 a.m. in Cumberland County Courthouse. South Hanover Street. Carlisle, P A. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH ,~ ~. "M .- "'I" , . <::> <::> "" " - .- N Z~Q < ,- ...l"a, ~~~ ::===-< ~...~ ~':i IV .... ~ = = ~U:a ~=.s- = ... ""0 "' ~ OIl Qo:= ~~..c ......~ 't .. -= ... ;~] ,," ... 8 -6 <Zl " -=... Z < Q -.'. . I I T T I I I v t.:=::::::: c::~~ ,. ~ 'i::"""' or ........."'. l.::a....... ~ .. '?- i. ."",,- r- ~ ~~ ,()-;s:.\- j~ U.S.POSTAGf I~ ~'1, ::r MAR 5'01 - v.. ,l" ;~ . PHI -. )> ... I~ ~ I'" 1:\.--- : - ~ :: 0 .7 5 ~ i; ):: .,0. PBMElfi'l .,. lb J".p~ ~ 606836J :. lS .,~ l".-~ . ~ ,I ~\ . {~ :ji .. '" ~~ 'NI'l V 0 ~ - t- <"l - - -< u 0 p., t- - ~ -< ~ ~ 'J .~ '" - '" '" .~ 0 --g ::r:: t- - U '" -< ~ t- O) '0 p., ~ N d' ~ >< <Zl 0 [::1 a; 0:1 > 0 0:1 ~ p., CIl 0)' 8 ::r:: ... ~ ..<:: ~ 1:: Q) ::r; 0 ~ '" z 0 u ... '> ~ <"l 0 '0 u ::E - 'Ei 01 ;:. ~ ~ 0) 0 ~ ~ v <= :> E . 0 1:- p., u fr " ::J "CI v . CI .. . <= .:- ~ '" CIl " " ~ v '" ~ - .~ ~ ~ -<: ... 0) E- o .0 _ "- u > &~ IE a >. 0 U :> '" . u a 0 '" ... .. 0 '" 0 0) I ;; '0 p., ~ '0 '" . . <= ... v ~ 0 0 ~ ~ @ .~ ..<:: Oi . v ~ i:< v u ~ 0.. Q) '" ~E :> 0) ~. i:::O . " ~ :;: ~ - ~ " ~ o . '" 0 .~ l:: E:i~ '" -<: ~ ~ 0 ,Q- '" a ~ E . ~ @ 0) 0'" 0 a a z ~ v 5 '. E 0 0 ~ -sB . f-< CI U o v Z ....'" " v '!) ,Q E 0 z . " v v :g '" 0 -< v '" ~ '" ~,Q 0", ~E o . 0'- - N <"l '<t '" '0 t- oo 0\ 0 - N <"l '<t '" z-;;; v - - - - - - "is ~ 0 ;.:J o.~ ...... ,~ ',1 . " >,.' ~~ t"~ "....4l..M1I!11i1\'.IL .J .,>..,-."-- h> __ ','_ .~'''d~" "'''''''''-~'''''_;'_;.-~~ ,_""" o ~ ""tJi~~ f:1!ri:.' ~"-:f'; < i~~ ~i~_: ~l_i ~E/ -"c.:: ~~ ~ ..- ......'''''-....IIl'llll Q r", , .~ ~._i:" ;;";"., --< ! -7 ::! -- - ',.::.: -- -);--1 , .: ~:) g\~' );1 :"6 "'<,' ';::' t.n ,~ ="J.~ ~Wmtl1~1.T~"'Nj;.W"^-",.-)~"''',,,-Cit;,''v~,,:!><'~.,..'''''''''"!C.;rm'''"<[f.*~,',,.,1'"'i~_'~"m, _";W'~-.'~_<;Fll0li;,~!!fli/{(~~ ~~ Cendant Mortgage Corporation VS Kim D. Klose In The Court of Common Pleas of Cumberland County, Pennsylvania No. 2001-88 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library County Levy Postpone Sale Surcharge Certified mail Mileage Law Journal Patriot News Share of Bills 30.00 16.18 15.00 l5.00 .50 l.00 l5.00 20.00 20.00 1.39 11.16 3 l6.55 225.60 25.09 $ 712.47 Sworn and subscribed to before me This .2 9 today of c;Lu 2001, AD. ~L f1n,Jd;'.,,~ rothonotary ~"'"""""',.,..", , -II .' paid by attorney 06-07-01 ~~~ R. Thomas Kline, Sheriff BY ~~C/~ Deputy Sheriff 100 . CIe.. 3.}.<;3S ~ //3'7/? . , ., ~~""'~- ".7_ .,. ^ f 1!, ,..,. . "- . CENDANT MORTGAGE CORPORATION '"I CUMBERLAND COUNTY Plaintiff, v. KIM D. KLOSE Defendant(s). COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-88 AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK. FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 6605 CARLISLE PIKE, MECHANICSBURG. PA 17055. NAME 1. Name and address ofOwner(s) orreputed Owner(s): KIM D. KLOSE LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 NAME 2. Name and address ofDefendant(s) in the judgment: Same as above LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME None (, , I~ 1 , 1 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 1'"'1 ,~" ~~ ... ... 4. Name and address of the last recorded holder of every mortgage of record: .' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) " None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person 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 caunot be reasonably ascertained, please so indicate.) Tenant/Occupant 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 26,2001 DATE d~/2(d~ FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff .:TI1fj,.__ ' , ~-. '.d. _" "~ _r' ! CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-88 KIM D. KLOSE Defendant(s). February 26,2001 TO: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE 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 6605 CARLISLE PIKE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5. 2001 Sheriffs Sale. 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: I. 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. ,,1_1~~ i 'I ~I,-_ ,_ ..., You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. 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 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 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 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 ([0) 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 ATTOR.NEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 :',~~"'" ~I .,., ," ,r" .. . 'co DESCRIPTION ALL THAT CERTAIN lot of ground with improvements erected thereon situate in the Village of Hogestown, Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which is the Northwestern corner of the lot herein described where the same corners with property now or late of Paul Rhoads and the Southern edge of the right-of-way of the Carlisle Pike, also known as U.S. Route ll; thence North 69 degrees 30 minutes East, along the Southern edge of the said right-of-way, a distance of forty (40) feet to a point; thence South 20 degrees 30 minutes East, along property now or formerly of Harry Mixell, a distance of one hundred fifty (150) feet to a point; thence South 69 degrees 30 minutes West, along the Northern edge of a fifteen (15) foot paved alley, a distance of forty (40) feet to a point; thence North 20 degrees 30 minutes West, along property now or formerly of Paul Rhoads, a distance of one hundred fifty (150) feet to a point; the place of BEGINNING. BEING Lot No. 39 on Plan of Hogesrown and as described in accordance with the survev of Gerrit J. Betz. Registered Surveyor, dated June 1, 1 972. HA VING THEREON ERECTED a dwelling house known and numbered 6605 Carlisle Pike - . Mechanicsburg, Peunsylvania 17055. BEING Tax Parcel # 38-18-1332-039. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard, husband and wife dated 8/21/98, recorded 8/24/98, in Deed Book 184, page 61. " "';;,,~!j,. ~'"~ ,,' '.-' ~'I 'I~- .! >~,",,_, ,',. '''''_'.>. ,', ,. ".~ ~~__='~'9 _ m ;:"'Ir~,,~" c. \1/ N\f,~ 1,\ S N /Bd -I~ (' ',II"" :..~, ; -:::. j j '_r -, V /01 He! 05 E 9 II'H A,.Ulllf;:j ,Q NV"'.:(i i'lilli IJliWIS ]lfll 30 :/liIiJJIi :-;mI_ ~~~~~,T ~ ~ ,,~ .M.. ',,"""M".' W', ,,,,,,,~,,,,,,,~,,,'''~'',,,,,,,,,,,, ""~lfl6i1ifn i "If . c' ~;~'P'=''1'''''''1'''-%"~';'F''-''h!.;'I~~\'iI~~~_llIQ'm, ffil", ','. ,~J~'JW! .-. .,. ... -~ . 'WFUT,QFEXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) Non-88 CIVIL~ TERM ,:'CI}'IL~CTION - LAW - TO THE SHERIFF OF Cumberland COUNTY: To satisty the debt, interest and costs due rpnr'l,mt- M()rt-gr>gP r()rrc>ri'lt-i ()n PLAINTIFF(S) trom Kim D. Klose 6605 Carlisle Pike. Mechanicsburo. Pa. 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell 6605 Carlisle Pike. Mechanicsburg. Pa. 17055 -,_ '~-. :<,-, ,'i! ':'-' ''-':' , (2) You are also directed to attacn the property of the defendant(s) not levied upon in the possession of r GARNISHEE(S) as follows: and to notffy the garnishee(s) that: (a),a(1 attachment has been issued; (b) the garnishlle(s)illl,are ,\l(1joined from paying any debt to or for the account of the defendant(s) and from delivering any property of the!di1fendiint(sj or otherwise disposing thereof; (3) If property of the defendant(s)notlevied upon an subject to att-aeAfI'I6AH&feIlFl8.inthe'pOssession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as agarnishee and is enjoined as above stated. Amount Due $ 117. 1111? Sq From 2(21(01 - 6(6(01 (per diem-$14.44) Interesr 1. 5Hi. 2Q L.L. $0.50 Due Prothy 1 .00 Other Costs My's Comm My Paid Plaintiff Paid % lOS.SR Date: March 6. 2001 Curtis R. Long Prothonotary, Civil Division by: ~r-'-' 0, ~ REQUESTING PARTY: Deputy Name Frrmk Ffrl<ennan. ERdUire Suite 1400 Address: OnoPBnn Ccmtor at ~Hl:mr\;)an ~tation pp:iJ~n~lrh;~. P;:'l 1Q1('11 Attorney for: P 1 i'l; n t-i ff Telephone: 215-563-7000 Supreme Court ID No. 12248 "~!1"~ - ,"'''!''l'!~ , " 1'1 11' ; -. ~= ~ -,." - "', '~ "- ... .. REAL ESTATE SALE No. 10 <&~~\~\\ .in 11 a..uA.. 'i'J ole D I the sheriff levied upon the detenocli, . interest in the real property situated in ~.-J~ 7D~ Cumberland County, Pa., knov,c-'nd numbered as: u(PfJ5 C~ PJu... fi/~ and more fwoed on Exhibit "A" filed wit" this writ and by this reference incorporated herein. Date: r1o..M:.A.~ JOol By: ~~ C1~ ~~ Vllf,nl),.SNH3d -~}"l C' \ .'\'If'r1~ .., 0 ~ ,," \, IQ. ~ld os E 9 lIII l1Kilt~>.\ ,u~..m) :I:l11l31lS 31111 JO 3:J1:lJO fS ~ i ,'~ ~,..,....,~ I!!\I~._ l ~_,' _"'."_~'."!""1"'!I!.~~'!!}""f1t'-'lF'_','r'J':);"i,,?;,'!!<'~I>='.j.,<liMilJfllt~~J!!~itl!!.~_$':ffi,.o "',.-r'_r-,1ljJ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-88 KIM D. KLOSE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $87.882.59 ,j Interest from 2/21/01 - 6/6/01 $1.516.20 and Costs (per diem - $14.44) $89,398.79 TOTAL . ~~~ ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. {,.(,oa (l.CtrttS{L Pc'kL. /y\ t C--kM'l'(l:5 ~ c.--v-5t Aq.- U nvoo :1l; ..,. _ j - ~ , ~,~, _,a " =.-- ~'"' '-',. "'C_' .-. - ,-, ~ """' ~ -, ~-< -," '~_,"._W___C-d~-"~C__"""n_" .". "- ..- "'II' . Iio.;$ z z on o~ 0 0 on <::> 00> .... .... r-- ~~ ~ Eo< .... ;;;> < ""'00 U ~~ .,j ~z 0 ~~ <l) Zz ~ ~ s:~ 1: ~ ::l <l) Q O~ ~ .- Ul 0 '" 1:1 ~~;;;> ~~ 00 Iio. Q <l) ~ ~ ~ U 0 0<3 '&1 m"",Q:l .n - ~ O~ ~ " ~ 00000 0 ~ Eo< .. ....U 0 [J .; ;:~ .... 0 UZ <8 ~~z N Iio.;;;> < ;;. i::l Ul g [J ~ ~ >. . < Il 00 ~ <l) QU= Eo<U ~ ~~ a ~ <l) ~ 01:: 0 ~onU ~ Eo< ~Q ~ ~ ~<::>~ <l) ;;;>~ Iio. Q ~~ .... ~~ <l) 8~ Eo< ~, '-' ~ .... 0; ~~ ~ U Ul =Q:l Q ~ .;,; ~ ~ ~~ <l) ~ Z - .- ~ ~ "" ....U U __~~~~Illfilli~~W~!!li""",~/!'\"I~m'''''?'-t!J;-''''''''''''''''''"'''I''':~;''-fI;~i'i'c'.'F!!''''-''?~fffil!r''''!(~&1-~jIlffiJn~~~(-1~~~~il'!r;;__mijf.''"' ~ . . DESCRIPTION ALL THAT CERTAIN lot of ground with improvements erected thereon situate in the Village of Hogestown, Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which is the Northwestern comer of the lot herein described where the same comers with property now or late of Paul Rhoads and the Southern edge of the right-of-way of the Carlisle Pike, also known as U.S. Route 11; thence North 69 degrees 30 minutes East, along the Southern edge of the said right-of-way, a distance of forty (40) feet to a point; thence South 20 degrees 30 minutes East, along property now or formerly of Harry Mixell, a distance of one hundred fifty (150) feet to a point; thence South 69 degrees 30 minutes West, along the Northern edge of a fifteen (15) foot paved alley, a distance of forty (40) feet to a point; thence North 20 degrees 30 minutes West, along property now or formerly of Paul Rhoads, a distance of one hundred fifty (150) feet to a point; the place of BEGINNING. BEING Lot No. 39 on Plan of Hogestown and as described in accordance with the survey of Gerrit J. Betz, Registered Surveyor, dated June 1, 1972. HA VING THEREON ERECTED a dwelling house known and numbered 6605 Carlisle Pike, Mechanicsburg, Pennsylvania 17055. BEING Tax Parcel # 38-18-1332-039. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard, husband and wife dated 8/21/98, recorded 8/24/98, in Deed Book 184, page 61. .'lY~ ,.'. 'l' . ~-,= w, ,_, "~~'~ -~, ~ ~ (") ,~", ~ ~ c - " r-- ~ -- rL> ..' - fI'i:" ..,\.~ t: \' 10 :%--.- , 7--': 0; G.\ ~. CJf cr', ~ ... ---- l "~ r:::\:. ""<\ <: - ',' .- :;.J c>-> t: G !'-i U,) '""- - ~ ~ I..N . \ 1- ~ 'a 'c1 8: .~ ~ a t-'>l,~"_ ~'........... _ ~!JlIl!mr!._~_~~~!lJiII~~;;<li1",j'-____\i",'1rWT''";''';;'''''f.,".,,,,,;,'''T''",w"'wl-~"""r""'E'ffi']'i"~t'''_'';''O,'''T.''''I-'''~"1':~l~~ ... . '" CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIM D. KLOSE CIVIL DIVISION Defendant(s). NO. 01-88 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 6605 CARLISLE PIKE, MECHANICSBURG, PA 17055. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) Same as above 3. Name and 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 so indicate.) None "'':0. - ,,' " ~_~ _ > ,,~c II 'I 1-' ~ _.,!II!8l! , .~ 4. Name and address of the last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address caunot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person 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 caunot be reasonably ascertained, please so indicate.) Tenant/Occupant 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 26,2001 DATE 4~4:UI~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ?""H""''''''''''1~''_' - ~"""4"'1 .'1 --~ '. .' '-e_>t'_', '~,k - "" ~ ~'.o,' ,,_ ,_ _r,-,-.__,"'_"_'~ _,=~ _~"_<_~~,_> ", ""'-,,-'~.>, .~, ,< C) ~ ~fi~' (.f1}_- -<....:.... r;:::c:- ';:";,:(' ;:,"C <~ --, -<: . - ~. "O,"_~' ' '1 ,., ,.' \ CJ , C', ", ~, ~0 i\__L~l<ftI!!!il".,,,,,".....~!!!III'I/ili~~',,,,,,,,,, , ~~~!lIl'iIl~!i'Wi'Wi_ii'l;~~""""'~~I,,,,,;'''''~''1';%'"''''''j~ '-;"'Hj:""'~__~"-"I'_"'i~'tjI1~"1P""'O];"""~i''1'1''''''''.;''-'!W""JIj~,*i!!'l~~ FEDE~andPHELAN By: FRANK FEDE~ Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION KIM D. KLOSE NO. 01-88 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: (X) an FHA mortgage () non-owner occupied () vacant () 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. /1':?i~P^- FRANK J?EDERMAN, ESQUIRE Attorney for Plaintiff "_""~ '1""1 .., '! 7 ~ .,..,.- ~- ~ ~. . ~~ '-'~'. 'lW11I~"~~_lt~_ ~ " ~ ~'e., . ",." - .-~ '>~'~-'-~;""''''''-'- - " -~. '--~~-'~~~- C) ~ [;CJ~~" . (Jj=:' C:, e: ~~ t~~ ~, " =< -, v_, '.~ ,'I~ ., , r, ---; ~!Il!'IJl!II!IllIlIlIlJf!~~"~'l!!f;'-!'I~V'7""~N'. -,~-', ",-",~,~--"",;r;'"';'"'t"""1l'Wj!~w""m'W-",,:p""F1'!!Ol:~~~'~';~!~ ," CENDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-88 KIM D. KLOSE Defendant(s). February 26,2001 TO: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS 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 6605 CARLISLE PIKE, MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriffs Sale on JUNE 6, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the September 5.2001 Sheriffs Sale. 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: I. 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. '"T ~ . ,,-, '-1'.1 __. ',' ~- , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have Qf stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe 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 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 ',k !~ ," 11-- "I' . , DESCRIPTION ALL THAT CERTAIN lot of ground with improvements erected thereon situate in the Village of Hogestown, Silver Spring Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point which is the Northwestern comer of the lot herein described where the same comers with properry now or late of Paul Rhoads and the Southern edge of the right-of-way of the Carlisle Pike, also known as U.S. Route 11; thence North 69 degrees 30 minutes East, along the Southern edge of the said right-of-way, a distance of forry (40) feet to a point; thence South 20 degrees 30 minutes East, along property now or formerly of Harry Mixell, a distance of one hundred fifty (ISO) feet to a point; thence South 69 degrees 30 minutes West, along the Northern edge of a fifteen (IS) foot paved alley, a distance of forty (40) feet to a point; thence North 20 degrees 30 minutes West, along properry now or formerly of Paul Rhoads, a distance of one hundred tifty (ISO) feet to a point; the place of BEGINNING. BEING Lot No. 39 on Plan of Hogestown and as described in accordance with the survey of Gerrit J. Betz, Registered Surveyor, dated June I, 1972. HA VING THEREON ERECTED a dwelling house known and numbered 6605 Carlisle Pike - . Mechanicsburg, Pennsylvania 17055. BEING Tax Parcel # 38-18-1332-039. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard, husband and wife dated 8/21/98, recorded 8/24/98, in Deed Book 184, page 61. Wi'!' ~ "'j 1,1 '1- - , AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY No.01-88 DEFENDANT(S) KIM D. KLOSE SERVE AT 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 Type of Action - Notice of Sheriffs Sale Sale Date: JUNE 6, 2001 SERVED Vi IN'\ P t (/\05e Served and made known to f\ ,f' at /0: It) , o'clock -a.m., at G (p 0 ~ C -o-tZhsl ~ , Defendant, on the lo J.k day of ~U( l, jO(k~ / .M~c.~'d-r-Jic..,., Iolflt.-j I ,200_, , Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served. Adult family member with whom Defendant(s) residers). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) residers). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: I , Description: Age.!it2. Height S J Weight /5'6 Race ~ Sex MOther C\ott-e.f,)c.~ t, C<W-+f <;1tt, I, 'r , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. swo.rn to and suiJ,s~~ibed ~Y-- beror ethis~day ~ i of '200L~ Notary: LJ. By: 0' NOT SERVED Moved Unknown 2.eJ, ~~~~" ~ubli2'cloc _.m., Defendant NOT FOUND because: Chambersburg Boro. Franklin County O~Expjres Aug. 5. 2002{ ac nt em ar, ennsy vania ASSOCiation at No aries On the . day of Other; Swom to and subscribed before me this __ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - J.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, P A 19103 (215) 563-7000 "~I ':";~l ''T - "' "1-1 I., - <.' " ~j;:lI'l 'T?'1'FIYVP'!'tII!IfiOl''III " ~~~~!~iiH~_~"'- " =, H, n"~_> ",'~ ~ " (') 0 C ~. - -0 O-~: '::;':11. mn: :~::r r~ 2""- ?:C': "j] ~~ ~~~ IJ:) '. r::C: ::::.1 :i>C-' u , .....;.. ,~-) :i::! ~d :;~::: C' )>C '* 1-) rn Z r:- ~ =< 51 'D -< ~ "" "",,"~~8ifil~~'-~'""'~~<"~""~---;""~-"Y .-,J'~'; ':',--l;!\"'1',ii,,'\l'lf<l'r:m1!}1i1ir.i!'l!i1i1WNl<j'li'fI!J'tt'1!j;;-it_"f~,~m1'!!llfiIfWll'11'>""""'~""1'I!1"l!I// ..-- STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ______________________________________________________________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sherifrs Deed in which ________________ Cendant Mtg Corp . -------------------------------------------------___________________________________ ~ thegr.lntee the same having been sold to said grantee on the ______:_:~_____________________________________ day of , ____________________-!~~~________________ A. D., r _~:__, under and by virtue of a writ______________ Execution . 7th ______________________________n_________ __ _____ ISSued on the _____________ ___ ______ __ ____ __ _______ March day of __________________________ A. D., Civil ------------------------------...-- ----- ---------- ---- --- -- ------- ----_____________ Term, : 02 -----, out of the Court of Cornman Pleas of said County'as of 2001 ,. . BB Cendant Mtg Corp Number ______________, at the suit of n_____________________________________________________________ Kim D ]Kl,gse ----------------------------------- against_ -- - ---- -_ _____ ____________________ __ __ __ ____ _______ is 252 1B19 duly recorded in Sheriffs Deed Book No. ____________, Page ____________. IN TESTIMONY WHEIlEOF, 1 have hereunto set rnYird ~d seal of said office this _r2t._~___ day of ~ft----~-- ------- .? .@~ ---- -~ ----- ---- - - Reco llooonIer 01 III , Cendant Mortgage Corporation VS Kim D. Klose In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-88 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2002 at 5:33 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: Kim D. Klose, by making known unto Julie Klose, adult daughter of defendant, at 6605 Carlisle Pike, Mechanicsburg, Cumberland County, Peunsylvania, 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 11:25 o'clock AM., 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 Kim D. Klose located at 6605 Carlisle Pike, Mechanicsburg, 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 mauner: The Sheriff mailed a notice of the pendency of the aC,tion to one of the within named defendants to wit: Kim D. Klose, by regular mail to her last known address of 6605 Carlisle Pike, Mechanicsburg, P A 17055. This letter was mailed under the date of April 04,2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5, 2002 at 10:00 o'clock A.Moo He sold the same for the sum of $1.00 to Attorney Frank Federman for Cendant Mortgage Corporation. It being the highest bid and best price received for the same, Cendant Mortgage Corporation of 6000 Atrium Way, Mt. Laurel, NJ 08054, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $745.59, it being costs. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy $30.00 14.62 15.00 15.00 30.00 10.00 1.00 12.42 1.85 15.00 )l"__~"f' "II ~ ~ Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 20.00 307.25 193.75 25.20 25.00 29.50 $745.59 paid by attorney 06/20/2002 Sworn and subscribed to before me So Answers: This lib.- dayOfC)t., r~...-t:. ~ ~ . R. Thomas Kline, sle~ 2002, AD. ~. () "hull,. "~ ro onotary '~ ~:l~puty -'rh'''''''!t.., , , II - ~ 3o./YfJ~~ }.rJD l' rue.. 3'703 7 ~. ;:l1ls6' ~ -.. .,- .' . t CENDANT MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS KIM D. KLOSE CIVIL DMSION Defendant(s). NO. 01-88 CIVIL AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney,FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .6605 CARLISLE PIKE, MECHANICSBURG. PA 17055. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address caunot be reasonably ascertained, please indicate) KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 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 caunot be reasonably ascertained, please indicate) None. :"'~f I-I 'I -~ .', ... 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address caunotbe reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address caunot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address caunot be reasonably ascertained, please indicate) Tenant/Occupant 6605 CARLISLE PIKE MECHANICSBURG, P A 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 19. 2002 DATE ~~:;iu~ FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff I,,-~ I ..- f"""1 ." . ~ , ~ .~ ''''~'-'~ CVNDANT MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No, 01-88 CIVIL KIM D. KLOSE Defendant(s). February 19, 2002 TO: KIM D. KLOSE 6605 CARLISLE PIKE MECHANICSBURG, PA 17055 "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. 6605 CARLISLE PIKE. MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriff's Sale on JUNE 5,2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 87,882.59 obtained by CENDANT MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . ,,,,,,-, 'I "~","~\-~'-'- ~--,,- ".', ~-'-- "-_=,"'I"l'I_ ~~-\-_''''"l ~. - ,~: ~-," '-'I.'"'' ". .. Y_',""._,- -'~' .". ~,,,. - WRIT OF, EnCUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-88 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORPORATION, Plaintiff (s) From KIM D. KLOSE, 6605 CARLISLE PIKE, MECHANICSBURG, P A 17055 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) thegarnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $87,882.59 L.L. Interest FROM 2/21/01 TO 6/5/02 (PERDIEM-14.45) $6,777.05 AND COSTS Arty's Corom % Due Prothy $1.00 Arty Paid $830.55 Other Costs Plaintiff Paid Date: MARCH 7, 2002 CURTIS R. LONG Prothonotary, Civil Division ~tv>. D f?_ ~r~~<~. r:~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SillTE 1400 PHILADLEPIllA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ,,_""1_~ I II - ~ ~~~? .~ I i I r I I---._~~ ~~ .-, REAL ESTATE SALE No.3Co On March 11, 2002 the sherifflevied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, P A, known and numbered as 6605 Carlisle Pike, Mechanicsburg and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. ~ ~ ~ @.e.l ~J Date: March 11, 2002 By: JocftrS~ Real Estate Deputy vi ~J\.f i\ l!. (:; H H3d . " ZO, ~!1 Gi] 01 II HVW A1N0~J ' . .GrinO ~:JIH3HS 3;,.,jO 3~U:JO "~, "~"~~" ~,,.Ill,~Pl'i ~~1",",,~"...,}!'III!!'il1li''!I'-~'''f__ _ ,-_~ "': ~~~~~~",*~#i1""~;t-"d"!""(""'H'-_" ---........ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 ComTfibITWealth 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 The Sundav Patriot-NBws 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(sL 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 personai knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #36 ~..~................................................. . . 17th d 2002 A.D. RE,i\L ESTATE SALE No. 36 Writ No. 2001.BB ~___ Civil Term C~ndant Mortgage Corp. vs Kim D. Klose __ ~jty: Frank Federman DESCRll'TION ;\ll .THAT- CERTAIN lot of groupd wit.l1 ~~~,~t~l~p~:~ow~s~~: -_.CjIJltberland, ':ounty, Pennsylvania, more ,iii:l.ypp}!ncJe? ~q d.es~rib:ed as follows, to _ . I -INNING at a point which is, the P#hwe~lem corner of the lot herein described -- ere the same corners witb property now or late ' FOr Paul Rhoads and the Southern edge of the -tight-.of-.way.of the .Carlisle Pike. all>O known as l1:S. Route.ll; thence North 69 degrees 30 mmutes East, along the Southern edge of the said _.right'of.way,, distance of forty (40) feet to , Publisher's Receipt for Advertising Cost point; thence South 20 degrees 30 minutes East alongpropertynoworformer1yofHarryMixe]!,~ G., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general - distance of one bundred fifty 0.50) feet to a point; Ige receipt of the aforesaid notice and publication costs and certifies that the same have - thence South. 69 degrees 30 mmutes West, along ~tl!e Northern edge of a fifteen (15) foot -paved alley, a distapce of forty (40) feet to a point; thence. North 20 degrecs 30 minutes West, aiong '" property no.,,/ or formerly of Paul Rhoads, a - dist.anceofone hundred fifty (150) feet to a point. the place of BEGINNING, . BEING Lot No. 39 on Plan of Hogestown and as described in accordance with the survcy of Gerri! J, Betz, Reg~J.~d,sun'eyor, dated June 1, 1972, RAVING THEREON erected a dwelling house known and numbered 6605 Carlisle Pike Mecbanicsburg,Pennsy1vania 17055. ' BElNGTax Pared #38.18-1332.039. TITLE TO SAID premises'is vested in Kim D, Klose by Deed from Paul E. Gerbard and Pearl C. Gerhard, husband and wife, dated 8121/98, rccorcfed 8f'..4/98, in Oeoo Book 184, page 0[. ._ Notarial Seal Terry L. Russ~n. Nolary Public Harrisburg, Dauphin County My CommissIon Expires June 6. 2002 Member, Pennsytvanla ASSOCiation of Notaries y commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFACE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 192.00 1.75 193.75 By.................................................................... _AI. 1il1l'l\UIE _ NO. 38 Writ No. 2001-88 Civil Cendant Mortgage Corporation vs. Kim D. Klose Atty.: Frank Federman DESCRIPTION ALL TIIAT CERTAIN lot of ground with, improvements erected thereon situate in the Village of Hogestown, SllverSpringTownsrup,Cumberrnnd County, Pennsylvania, more partic- ularly bounded and described as follows, to wit: BEGINNING at a point wruch Is the Northwestern corner of the lot herein described where the same corriers with property now or late of Paul Rhoads and the Southern edge of the right-of-way of the Car- lisle Pike, also known as U.S. Route 11: thence North 69 degrees 30 minutes East. along the Southern edge of the said right-of-way, a dis- tance of forty (40) feet to a point; thence South 20 degrees 30 min- utes East, along property now or formerly of Harry M:ixell, a distance of one hundred fifty (150) feet to a point: thence South 69 degrees 30 minutes West, along the northern edge of a fIfteen (15) foot paved al. tey. a distance of forty (40) feet to a point; thence North 20 degrees 30 minutes West. along property now or formerly of Paul Rhoads. a dis- tance or one hundred fIfty (150) feet to a point; the place of BEGINNING. BEING Lot No. 39 on ptan of Hogestown and as described in ac- cordance with the survey of Gerrit J. Betz, Registered Surveyor. -dated June I, 1972. HAVING THEREON EREC1ED a dwelling house known and num- bered 6605 Carlisle Pike. Mechan- icsburg, Pennsylvania 17055. BEING Tax Parcel #38.18-1332. 039. RECORD OWNER TITLE TO SAID PREMISES tS VESTED IN Kim D. Klose by Deed from Paul E. Gerhard and Pearl C. Gerhard. husband and wife dated 8/21/98, recorded 8/24/98. In Deed Book 184. page 61. l;~., >, '., ..' , . '--~ 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, Esqnire, 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, Vtz: APRIL 26, MAY 3, 10, 2002 Mfiant 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. . r-/t/)/Pl R.6ger M. Morgenthal, Editor - \ SWORN TO AND SUBSCRIBED before me this 10 dayof MAY. 2002 II