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Home My WebLink About01-0543 FX ~, , , , HOMESIDE LENDING, INC Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW ROBYN M. NOLEN Defendant ACTION OF MORTGAGE FORECLOSURE ll.t,O;.5LI.3 ~ I~ TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVlCE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l7013 717-249-3166 A VISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON EST A DEMANDA Y A VlSO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VlSTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN EST A DEMANDA. RECUERDE: SI USTED NO REP.oNDE A ESTA DEMANDA, SE PUEDE PROSEGUlR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVlSIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVlCIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVlCE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 '"" "". '0 ^" ." ~ HOMESIDE LENDING, INC, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. ROBYN M. NOLEN, CNIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity ofthe aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. lfthe Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification ofthe said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff .N'"j L, ., '" < , -,- I'K:';J - HOMESIDE LENDING, INC, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CNIL ACTION - LAW ROBYN M. NOLEN, Defendant ACTION OF MORTGAGE FORECLOSURE no Of- 5LJ3 ~ l<---- COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, HOMESIDE LENDING, INC., is a Corporation, with an address of 8120 NATIONS WAY, BUILDING 100, JACKSONVILLE, FLORIDA 32256. 2. Defendant, ROBYN M. NOLEN, is an adult individual, whose last known address is 848 BRIAN DRNE, ENOLA, PENNSYLVANIA 17025. 3. On or about, March 27, 1997 the said Defendant executed and delivered a Mortgage Note in the sum of $59,850.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Nate, in order to secure payment ofthe same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office ofthe within County and Commonwealth in Mortgage Book 1372, Page 525 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and was recorded in the aforesaid County in Book 557, Page 855 on September 22,1997. The Said Mortgage and Assignment are incorporated herein by reference. 5. The land subject to the Mortgage is: 848 BRIAN DRNE, ENOLA, PENNSYLVANIA 17025 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. ""_ J " .. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on August 1,2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $57,627.13 Interest at $13.61 per day From 07/01/2000 To 02/01/2001 (based on contract rate of8.625%) $2,926.15 Accumulated Late Charges $566.01 Late Charges at $22.64 Per month for 7 months $158.48 Escrow Deficit $83.28 Attorney's Fee at 5% of Principal Balance $2,881.36 $64,242.41 **Together with interest at the per diem rate noted above after February 1, 2001 and other charges and costs to date of Sheriff s Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgement has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II ofthe National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. ~ L "'_ t.'_ 1, )''-' '. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.625% ($13.61 per diem), together with other charges and costs including escrow advances incidental thereto to the date 0 ff s Sale and for foreclosure and sale of the property within described. eEL , G & HALLER Leon Per, Esquire Attorney for Plaintiff LD. # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) I.~ - "~- -. Exhibi1 .. 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'li , . :.j ~ > " ), ';'., . .~ ..n .)i(", '. ,'''l. , ,I', ':.1, '" ';~i~l ~ ,..[ ..:j. '.:~~ ;,; ;~t.: ~: r.~'i (;"1 ,,",; W." .}\1;, I'~' ~...: 'J'~ , I , ~ . .::~~~,i~ .',m;;, ~,~ ~. a.,:'.;.....:.. ., .J't;;,. _, I ~ " .;; ,_ "j.J :" < ~ .. .-' ,d ,- " ,',~ _ . ' "DEC-22-21211210 1218:1215 PURCELL,KRUG,HALLER , . 717 234 1206 P.i2l7/07 . .~! I I COMPANY NAME: IDIJESIIE IENJIN;, ll\C. VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that faIse statements herein are made subject to the penalties of 18 Pa. c.s. Section 4904 relating to unsworn falsification to authorities. Dated J!\l\U\RY 25, 2001 -~ I J - "f. Title TOTAL P.12I7 ~~~ I , - " ~ ",,",,0 r~'ll ""'~-, SHERIFF'S RETURN - REGULAR CASE NO: 2001-00543 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOMEISDE LENDING INC VS NOLEN ROBYN M 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 NOLEN ROBYN M the DEFENDANT , at 0019:34 HOURS, on the 8th day of February, 2001 at 848 BRIAN DRIVE ENOLA, PA 17025 by handing to ROBYN M. NOLEN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 SO?~~~ R. Thomas Kline ! me this ME day of 02/09/2001 PURCE~~: KR~~~ C? Sworn and Subscribed to before f~ ,~ ~.yr Pr t~onotary , ,. -" - " " " -, ',-,,', ""'_ ~_,> ,_ _, _-.,-0' , ",' '-~'~j , '"' . ,""1 j '\ HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant ROBYN M. NOLEN for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $13.61 from 7/1/00 to 2/1/01) Accumulated late charges Late charges ($22.64 per month to 2/01) Escrow Deficit 5% Attorney's Commission $57,627.13 $ 2,926.15 TOTAL $ 566.01 $ 158.48 $ 83.28 $ 2.881.36 $64,242.41** / ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, By Leon P. Hal er #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\NOlEN.P \. .,. t i ~ ~~ ~ ~ , ~ I ! I :i 1i" ~ , ~ :(<1 ,;1 j i ~ ,- FilED-OFFICE .0'''' l' ". P""'-' '('WOTM'Y j'- ,1-'[' ,,'~-\U I r~\.,-~ .il It\f1 01 JUN I 2 Mill: n 7 CUMBEHLhNU COUNTY PENNSYLv'<\NIA ;.W;,"-k~_~' .~ " " .. , ", ~--"-"~tk ~ ~. , HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on MARCH 1, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller FA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 , j - . ~,- ~ .. , .'"r,~~~:.-; CC ;j '. . . .~ HOMESIDE LENDING, INe. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL Y ANIA YS. : NO. 01-543 CIVIL ROBYN M. NOLEN Defendant : CIVIL ACTION LAW : IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: March 1, 2001 TO: ROBYN M. NOLEN 848 BRIAN DRIVE ENOLA, P A 17025 TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOu. UNLESS YOU ACT WITIlIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TillS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 717-249-3166 ~:nlCEL~~ LEON P. HALLER, Attorney for Plaintiff LD. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 ~'-> . {Jr1. ~ Q'1.W , . FILED--{)FF1CE A- 1'1'- c"_A-', cO' 'OlARY U,.,. ",;- . ,'L,,; ill"'!', ;'H . , ;!,-.! ,,,..'._,,,- . . 01 JUlU 2 An II: 06 CUMBf:hAi'JD COUNTY PENNSYLVANIA ~~ ~ c, . . * ~ ~ . , " I .~ .i1i . . I I I I m I ~ Ck. 3 S~OL3 ~ )/:2 '121 - ~ -, - ...~ "'. . " .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 543 HOMESIDE LENDING, INC., PLAINTIFF TOTAL AMOUNT OF JUDGMENT $64,242.41 ~ Interest at $13.61 per diem to sale date $ 2,926.15 Late charges at $22.64 per month to sale date $ 135.84 Escrow Deficit $ 2,000.00 TOTAL $69,304.40* VS. ROBYN M. NOLEN, DEFENDANT *SALE DATE: WEDS, ,SEPT. 5, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the ioned case. Date: June 11, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon P. PA WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: captioned described ENOLA, PA Date: I ~ . . -.. i::!_F[}'{)f~F1CE OF T;<"~ r'-"T!.iCil''.!OT,,\!-lY n I JI)'J I" ""., I.. 21 U ,t i' ,j f'n ". . CUMBERL/\iJU COUNTY PENNSYLVM~[A I I i j ,~ ~ :~ :1 1; ~ i !I i1i ~ , . :'~ "~ m ! 'm ;~ ~;; j I I ~ , .' I 't- ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan ref~rred to below as Westwood Village Condominium located in East Pennsbor~ Township, Cumberland County, Commonwealth of ~ennsylvania, which has heretofore been submitted to the provIsions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, P.L. 196, by the recor?ing in the Office of the Recorder of Deeds of,Cumberland County, Pennsylvania, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Misc. Book ~13, Page 283, and amended by a certain First Amendment to Declaration Creating and Establishing Westwood Village Condominium dated May,28, 19?6, and recorded on June 22, 1976, in Misc. Book 222, Page 729, and a certain Secon? Amendment to Declaration Creating and Establishing Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Misc. Book 223,.pa~e 343, and a certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9, 1978, and recorded on .June 23, 1978, in Misc. Book 236, Page 225, and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Mi sc. Book 236, Page 250, and a certa i n Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9, 1979 and :ecorded on January 23, 1979, in Mise. Book 240, Page 884, and a certain Sixth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated March 1, 1979, and recorded March 12 1979 in Misc. Book 241, Page B36, and a Code of Regulations of Westwood' Village Condominium dated January 29, 1975, and recorded on January 29, 1975, In MISC. Book 213, Page 328, and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28, 1976, and recorded on June 22, 1976, in Misc. Book 222, Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Plan Book 28, Page 72, and amended by a certain Second Amendment to Oeclaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23, 1978, in Plan Book 33., Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condominium dated January 9, 1979, and recorded January 23, 1979, in Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3, being designated on said Declaration Plan of Westwood Village Condominium as Unit Nq..8414_Su.itp 110,- ,Ll0-T?iI~!!__~loCk #5, ~ui!dinq #7, known as848Bri.an'~Drjve,. Suite 110, Enola, Cumberland CoiIfft-y,-Pennsylvania, as more tully descrTI5e(( in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto, TOGETHER with a proportionate undivided interest in the Common Elements (as defined in such Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRI~ DRIVE, ENOLA, PA. 17025. BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 I . ..p L c..k.- j I!> C'I) G.:G::\ 9.oT! YO: sZJ 3'7.:lo SI../IC. ;}:;,""t:> '/01,30 /,trD ~ , $1) "I-.. ~ '\'" I , ~ J j , . " . I ~ , ~ I 1 ~ 3::;'0/3 I~I/;;ld~/ ~-, - .' .. ^' I ~" k_ - . ,,-'..,~. ,,,,t- . < " ~~ Iilif. , ... .I HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following captioned are hereby notified that judgment has been entered matter: on ~ '. 1:2, agains you in ~ I the the above- $64,242.41 and for the sale and foreclosure of your property located at: 848 BRIAN DRIVE, ENOLA, PA 17025 Dated: qJAL /).., 20-0; ~'h-rnj K ~~~~ PROTHON T Y Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Robyn M. Nolen 848 Brian Drive Enola, PA 17025 K:\MKF\DOCS\CUMBERlA\NOlEN.N ,w~~ .=_ ."', , " " <' ;-~--, , "il!i.",.b': , < HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant ROBYN M, NOLEN for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $13.61 from 7/1/00 to 2/1/01) Accumulated late charges Late charges ($22.64 per month to 2/01) Escrow Deficit 5% Attorney's Commission $57,627.13 $ 2,926.15 $ 566,01 $ 158.48 $ 83.28 $ 2,881.36 TOTAL $64,242.41** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. By , '~-"J PURCELL, KRUG Leon P. Hal er #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\NOLEN.P ~ , f:- HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 848 BRIAN DRIVE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) Robyn M. Nolen 848 Brian Drive Enola, PA 17025 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the .~- ~ - " ~ , _, J ~ 0' A'tf ~ sale: UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn 'oleifieafion fa aUfhorifie,_ ~ Leon P. Haller A I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 11, 2001 , Fi~ED-O~} iGE OF '1" ',,!()-:-L-:'\lClTA8Y 01 JUrJ I 2 AH II: I ! CUM!:3EHLAr'D COUNTY PENNSYLVMlIA . i ~ ~ ~ ~ '" , 11 I I I ~ 1 i I t:J~ I, j " ,. --> . . HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 848 BRIAN DRIVE ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 543 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: ROBYN M. NOLEN I j, ,~ " ~~'1'i'_'; A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. 1 f you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This "-~~ " I, , "......"", }~~~ , petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~-- . ' . _~e_. .d.~~"""';'._- . ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan referred to below as Westwood Village Condominium located in East Pennsbor~ Township. Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3; 1963, P.L. 196, by the recor?ing in the Office of the Recorder of Deeds of Cumberland County, PennsylvanIa, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29. 1975. and recorded on January 29. 1975, in Misc. Book ~13, Page 283, and amended by a certain First Amendment to Declaration Creating and Establishing Westwood Village Condominium dated May 28, 1976, and recorded on June 22 1976 in Misc. Book 222. Page 729, and a certaIn Second Amendment to Declaration c~eating and Establishing Westwood Village Condominium dated July 21, 1976, and recorded on July 26.1976, in Misc. Book 223,.Page 343, and a certain Third Amendment to Declaration Creating and EstablIShIng Westwood Village Condominium dated June 9, 1978, and recorded on June 23, 1978, in Misc. Book 236. Page 225. and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, .in Misc. Book 236, Page 250, and a certain Fifth Amendment to Oeclaration Creating and Establishing Westwood Village Condominium dated January 9, 1979 and recorded on January 23, 1979, in Misc. Book 240, Page 884, and a certain Sixth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated March 1. 1979, and recorded March 12 1979 1.n Misc. Book 241, Page 836, and a Code of Regulations of Westwood' Vill~ge Condominium dated January 29. 1975. and recorded on January 29, 1975, In MISC. Book 213, Page 328, and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28, 1976, and recorded on June 22, 1976, in Misc. Book 222. Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on July 26. 1976, in Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Oeclaration Plan of Westwood Village Condominium dated January 9. 1979. and recorded January 23, 1979, in Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12. 1979, in Plan Book 35, Page 3, being designated on said Declaration Plan of Westwood Village Condominium as Unit Nq.1J48.....Su.itp l1G.r- ,~!.9- T2A,..in Block #5-,.JllJj_~<<!illiL!t?, known .as 848 Brian'.Drive. ~uite 110. Enola, Cum1lerl and County .l'ennsyl vani a, as moretully>oesCff6eo in such Dee laration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the Same appears of record as set forth above, including any amendments thereto, TOGETHER with a proportionate undivided interest in the Common Elements (as defined in such Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRI~ DRIVE, ENOLA, PA. 17025. BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 , I :!~ \0D-C;?:"iCE (''- ."" 'fc\I:'-I',BY . _-I,.,) J o I JUN I 2 {,M II: I 2 CUM8diU\ND COUNTY PENNSYLVI'.NIA , ~ ~ ! , ff: ~1 '1'1 F1 ~ ~ . j ~ ~ ~ , , \ Homeside Lending, Inc. VS Robyn M. Nolen Ie .' . ' - ,~. ,. ,- t~'"-""<-T!f:i, In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-543 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon Haller. Sheriff's Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30.00 20.00 15.00 .50 1.00 25.66 22.10 15.00 15.00 .97 25.77 618.80 524.40 $1314.20 paid by attorney 10-03-01 s~orn ~ subscribed to before me 7~ ....-'C: 4~ This JOlv dayofg~ f"'-' Jl R. Thomas Kline, Sheriff 200l,A.u,- I'/''' {2 7u,/l../,~. ByqOcU.tJru-fj, Prothonotary Real Estate Deputy '"' /.~6 CL 3'1/19 ~. //7 ~.59 ~'1...\' " -~ - ~ - ~'~ ~~,-""-: , "4. ~ . < . , HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA f VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TOP.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 848 BRIAN DRIVE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s) Robyn M. Nolen 848 Brian Drive Enola, PA 17025 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the ~I~.~. ., t. :, f , sale: UNKNOWN 7 . Name and address of Plaintiff has knowledge who has may be affected by the sale: TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 ,', :..-~~ ~""'"""""".h every other person of whom the any interest in the property which (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falaificefion fo aufhoriflea. ~~ Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: June 11, 2001 oM" ~- I -~ ~~- ...J.... ,~"",- -~ ~~-_...,,-- ,,., . , HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, SEPTEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 848 BRIAN DRIVE ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 543 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: ROBYN M. NOLEN ~'",,~,I , ~~~...... ' -- ^:M;"",,-- . l A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale fn accordance with this schedule will, in fact, be made unless someone obj ects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY, IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This '''''''I~r , 1 =-"-, "-, . petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ;~"._' ~ ,~" ~--". - "~~ "~ , . , -L....J._~ 1t.L -~-, , . ALL THAT CERTAIN unit in the property known. named and identified in the Declaration Plan referred to below as Westwood Village Condominium located in East PennsbQr~ Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3; 1963, P.L. 196. by the recor~ing in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration Creating and Establ ishing Westwood Vi llage Condominium d.ated January 29. 1975. and recorded on January 29. 1975, in Misc. Book ~13, Page 283, and amended by a certain First Amendment to DeGlaratlOn Creating and Establishing Westwood Village Condominium dated May 28, 1976, and recorded on June 22. 1976. in Misc. Book 222, Page 729, and a certain Second Amendment to Declaration Creating and Establishing Westwood Village Condominium dated July 21,1976, and recorded on July 26,1976, in Misc. Book 223, Page 343, and a certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 9, 1978, and recorded on June 23. 1978. in Misc. Book 236. Page 225, and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Misc. Book 236. Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9. 1979 and recorded on January 23, 1979, in Misc. Book 240. Page 884. and a certain Sixth Amendment to Declaration Creating and Establishing Westwood Vi llage Condominium dated March 1, 1979. and recorded March 12 . 1979 in Misc. Book 241, Page 836, and a Code of Regulations of westwood' Village Condominium dated January 29. 1975, and recorded on January 29, 1975, In MiSC. Book 213, Page 328. and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28, 1976, and recorded on June 22, 1976, in Misc. Book 222, Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 15. and amended by a certain First Amendment to Oeclaration Plan of Westwood Village Condominium dated July 21, 1976. and recorded on July 26, 1976, in Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23. 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condominium dated January 9, 1979, and recorded January 23, 1979, In Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979. and recorded March 12, 1979, in Plan Book 35, Page 3, being designated on said Declaration Plan of Westwood Village Condominium as Unit No.J;J48..,_5Ilitf' 110,..._ J10-TZJh_--.if!_Block #5, Buildillil #7, knownas 848 Brian-Drive, Sllite 110, Enola, Cllmoerland COUm:y,l'enns-yTvania;-a-s moretlltlyaesc-r:Jteif in such Oeclaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above. including any amendments thereto. TOGETHER with a proportionate undivided interest in the Common Elements (as defined in sllch Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRIAN DRIVE, ENOLA, PA. 17025. BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto RobynM. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 "-.1 ~ , WRIT OF EXECUTIOtO and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-543 CIVILl% TERM CIVIL ACTION - LAW ,-,\ ~ TO THE SHERIFF OF Cumberland To satisfy the debt, interest and costs due COUNTY: Hnmf'Ride Lending. Inc. PLAINTIFF(S) from Robyn M. Nolen 848 Brian Drive, Enola, Fa. 17025 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Levy liDOn and sell the property described in the attached description known as 848 Brian Drive, Eno1a. Fa. 17025 (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 notWy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due . Interest at Interest Atty's Comm Atty Paid Plaintiff Paid 5 64.242.41 $13.61 per diem 2,920.15 L.L. 50.50 to sale date % Due Prothy Late charges Other Costs 1 nn at $22.64 n'l.R4 per month to sale date 109.30 Escrow Deficit $2,000.00 Date: 6/13/01 Curtis R. Long Prothonotary, Civil Division by Chu- Q.~ Deputy REQUESTING PARTY: Name T.prm P IjAll Pro ESQ. Address: 1719 North Front Street l-T;:n-ric::hllr~ Pr=l 1710? Attorney for: Pl Ai nti ff Telephone: (717) 714 -4 17R Supreme Court 10 No. 15700 jJ' -.' ~ ~'lhJI:ii.~iiil~~~!li;im~u:~\lill;I.'I'iii!~_'-"'" ~-,.,'.~~- .' ...'-, "~"._r~"- ~&.L~ ", "~ _." 0 _" ""' - ~ ".j .' REAL ESTATE SALE No. (00 Of! Ju I'1...Q. i 9, ~CD ( the sheriff levied upon the Oel't11 ,,~o . Merest in the real property situated in ~a.5J- P.V/l/llS hov 0 flJ]i.?..:.. Cumberland County, Pa., knOWililld numbered as: Zt.{f !SrlaV1 0 r. 610 L a...- and more fully -),"scnhed on Exhibit "A" filed wit~ this writ and by this reference incorporated herein. ~. . '"late: J UN. lq, :JIJ(J( By: 91l~ s~-lh . De{JUfit. Jhu-, Ff VINV t\1,V2NICld .--,~, !~' -- -, 1! f;\ \0. H~ so 6 pI Mllf UIW(.c ,'" ',',';"/1:> ~~t\!3HS "JH L .iU j;ldjO j' I €3 ~il CViJ c::::::a Gi> INU Il .____.-,__:_ .__ c____________~ ," .. REAL EstAtE SALENb,iid. ...JiitNO, 2001-$43 , ,Civil T~riTt Hoffleside l~nding, Joe. ,;s' Robyn M. Nolen Atty: leon P. Haller DE$C'lJPTlON ALL THAT CLRTA1N unit in th~ Pf<1pt;l1:Y kn,o\\'n~ f,all"icd and lckntified in thl.'; ~diiratiol1 Plan, rctl.-'/'1cd to below ;!~ Wc,~twO\ld Vil1:lg<, OmdQ\11inlurn i()C~lcd in Ea~t Pcnnsl1<.)n) T()wllshlp. Cumix'rl~nd 'Cviinl). C4'lmmOnWt"lllh of ~nn...yh:a'nia, ,: wl1idi 'has hcf't.:lOfore b<,~n ~i"'ornilloo to tht:. .: f-i-;i;\:r,\1ii!\~:~" O.(,',~~e..--t.i'~,it" f!,O,P~~1Y :A~-:;,nt , fii~i!~~~~~~i~il :::,~:~:~t8.9Ijshitlg ,)Vestwood Vil!d~::" ::-~-pndominiurn Jatt'd January 29, 1975. arid "-rec~micd 011 Januarv 29, 1975, in Mi~. ~ ZB, Page :i3. und amended by a certain First AmerJ:ment t(1 ~:ll';l!ioiT ('.te-aling and F..stablishin:g Wcstwood'ViU.l~e CQndominium rilted May ~. - j976,__ ~d recoro.cd on June 22, 1<;176. in Ml~c. Book tn. Page 7'29, ,md' a .:eNai'n '&'",-xrnd Amendment to D<'..:laration Crcatino and fSlabli~hing W~S:twood Villa(>c Coodominiurn dated, July 21. 1976, u~u ~)('dt;:d on July .%..197tl. in Misc. ~ 223. Pa~ 343. 'and Ii Ct.'1i:tin Third Amendment to Dedaration C.reation and 'Ef':;.tabli:.hing 'Westwood, VilJage ('j)fldominium dated Ju~' 9,' 1978, and recorded on June 23, 1978, in Misc. Book '2~'6. Pa*,e 225, <m-d a certain Fourth ~71dmen', 10 DecJarntJrm Crlfuliilg imo E:nJbli.::;~ing We~twood Vill;3.gc CondommlUm dated June 13.. 19713.' -and T<<O'rded on June: 23.,1978, in Mbc.' Bnu{.._ i 2.36_ - Poage 2:50. imd a _ certain Fifth !:,A,ltlC'whncnt to Dedara~i(m Creating .md ,Est3bli~hing, ...we~twoQd_ Village C.Q!1oominium dated .Jan~ry q, 1979 ::ind ~ded Qfl January 2.1, ) 979, in Mi,~c. Blil)\.;, :uQ, Page &S4, and a ccn3in Sixth ~a:nend~~n'. to Oef:-laratlon Creating ':.In',,) b,tab[ndllng W~~twood Village : Cimdomillium dated March 1, 1979, <1M rt.,,<;-orded March 11. 1979 in Misc. Book , 2-H. Page 836. and a Code or.r~egulatjoi\s of "V&st'V.'ood Village,,' CQni.l()minium dated J;-Htua.ty 29, 197.5, and recordt.>d on January , 29,1975, in Misc. Book :!l3, Pag", 328, and amended by. a cel14in firSt Amcndi1Tent to , C(j~e. of Regu]ati{ln~ of, Westwood Vill<\ge "d.)'ild()mini~m UatC\"1 May 28. 1976 ilnti .- reoor-dcd on June 22, IQ76, in Mi!>C. Book 222. J:'3g.: 737, :and Declaration Han of ! Wesl:woOO Vil!~e C.orn:tom;ni~m oo!ca , January. 29. 1975;,J,mu recorded' on Januarv 29, 1975 in Plan Book 26. Page 15. tl1~ amended by 3. 'cel1ait1' HrM Amendment ~o ~cclar~'!~, Plan of We.,twoocl Vjjbpc (lJtidt)JlllmUm daicd July 1~. t976. and r~.con1oo on July :6, 1976, in Plan Book '2l:t. Page' n. -and amended 6y ii' certilin 'Second ~~~-,-_______~;___~~'__~___L _ ~,; :e;.~llumenr-- -tO~~ uc:c]::irntiOfi----,PI:ifl~-~.rjr. r .,W~;i,~wood Village: Cond6rr1inium dated June "',I(<-t97's,' and reco~ed on June 23. 978. in "'~3ri 'B0(1].,' }3,. Pa,gc,28. and' aillcndcd by, a I;t.-rt:l.lri- "Third Amendment to 'f)e(;laration Plan of WestW1.lo([ Villag~ Condommium dated January 9,' HlJ9, and:record{:d JaJ)uary 23. 1979, in Plan ,Book. '3,4. Page 100. and amended by a ,certain, Vci,ur,ih A.r!lcndment t"O DeClaration Plan of ",..We'stw(iod Village, Condominium dated, March J. 1979, .lod :i ,~iordt'J y;,.lary I ~ 1919, in Plan Book 35. , 'Pa~ .l, ,being: ,:dc,<>ign,ated (In S<.11Q ,Qttlarallon 'Plan of. Westwood VHI;ige ',: Crm&imlnium as Unit No.8..J8, Suile 1,10. , Ll.O-T2A. ill Block #5. Buildm~ #7, kn~:n :::in '}J4-K Brian DrIve, SUite 110,' E-nd\a:, , '(",umlXrlanJ Count~. Penns.y.{vania, as m~ :,ftiUv described in such l)cdaration Pla~"a:nd ; ': rkcl$lhOn Creating 'and Estab\1~~~pg 'Wt.<Stwo...'X1 Village Condominium,':iES :'r,he ,s-a.rric -appears of record 3.... set forth <ibtl\'C. " ,tiidoding 'any amendment::> therelO. " toGETHER with a prowrti'onate undi'..::i~ed -lilt'ereM in the (\lmW('ir! Ele~'lIls ",'fJ.'> ,dt';tl~J ill, such,', Dcdaration) of S~en }liJ:ri~r;:'d Se\'ir'Uteen: thou:.andths p-c"rt:~nt (.,il7~,), " '" ^ ,~OWN' AS, &is Brian 'Drive, En~ra.;, p~ f7Q2S~: , ',' , , : aBtNG:rUE S:A..\.1E prcmi:;"cs which David 'R Wrh:iht 'and 'C::in:jlvn ,G. Wright by'- 9~U 'cbtl.:d'3127f97 mid ::eC.9rd,->d in ~~ Book' i5.s..jJ:lgc i'S:l.) grauie,j' and coiweyeJ."untt) Robvl\ M. Nolen. ' , -10 ~E SOLD as the {lropcrtior. R,obyn M, , 'Nolerl on' Q.mlbcr(:l.nd County JUligmem ,No..2i)()! $.tt . " " . ASSESSMWT: 09,12-2991-001 {< (J >78-1M, . ..- ,~ ,~ .. "- .., -.... THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principai 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 ~ Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot,News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since: That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 24th and 31st day(s) of July and the 7th day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in 7ellaneous Book "M", v;I~:L11~:~~:~' ..................................0......................... COpy SALE#60 Notarial Seal / Terry L. Aussell, NOlary Public Ie: Harrisburg. Dauphin County My Commission Expires June 6. 2002 Member, PennsylVania Association ot Notari.. OTARY PUBLIC' My commission expires June 8, 2002 . CUMBERLAND COUNlY SHERIFFS OFFICE CUMBERlAND COUNlY 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 $ 522.90 1.50 524.40 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have , been duly paid. By.................................................................... " ~- REAL ESTATE SALE NO. 60 Writ No. 2001-543 Civil Homeside Lending. Inc. vs. Robyn M. Nolen Atty.: Leon P. Haller ALL TIfAT CERTAIN unit In the property known. named and identi- fied In the Declaration Plan. referred to below as Westwood Village Con- dominium located in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submit- ted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3. 1963. P.L. 196. by the recording in the Office of the Re- corder of Deeds of Cumberland County. Pennsylvania. of a Decla- ration Creating and Establishing Westwood Village Condominium dated January 29. 1975, and re- corded on January 29. 1975, in Misc. Book 213. Page 283. and amended by a certaln Firsi Amend- ment to Peclaration Creating and Establishing Westwood Village Con- dominium dated May 28. 1976. and recorded on June 22, 1976. in Misc. Book 222, Page 729. and a certaln Second .t\1:nyndment,.tP .~clar~!l~n C;:';a!b;g and EstabUshin!iWestwood Village Condominium dated July 21. 1976. and recorded on July 26. 1976. in Misc. Book 223. Page 343. and a certaln Third Amendment to Decla- ration Creating and Establishing Westwood Village Condominium dated June 9. i978. and recorded on June 23. 1978. in Misc. Book 236. Page 225. and a certaln Fourth Amendment to Declaration Creating . and Establishing Westwood V~e . Coodomlnlum dated June 13. 1978. and recorded on June 23. 1978. in ~, Book 236. Page 250. and a cer- tain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated Janu- arY 9. 1979 and recorded on Janu- ary 23. i979. in Misc. Book 240. Page 884. and a certaln Sixth Amend- ment to Declaration Creating and Establishing Westwood Village Con- dominium dated March 1. 1979. and recorded March 12. 1979 in Misc. Book 241, Page 836. and a Code of ! Regulattons of Westwood Village Condominium dated January 29. I 1975. and recorded on Janumy 29. 1975. in Mise, BOOk 213., Page 328.' ,,,- , ~. and amended by a certain First Amendment to Code of Regulations of Westwood Village CondOminium dated May 28. 1976. and recorded on June 22.- 1976. in Misc. Book 222. Page 737. and Declaration Plan of Westwood Village Condominium dated January 29. 1975. and re- corded on January 29. 1975 in Plan Book 26. Page 15. and amended by a certaln First Amendment to Dec- laratton Plan of Westwood Village Condominium dated July 21, 1976. and recorded on July 26. 1976. In Plan Book 28. Page 72. ""d amend- ed by a Certatri Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16. 1978. and recorded on June 23, 1978. in Plan Book 33. Page 28. and amended by a certaln Third Amend- ment to Declaration Plan of West- wood Village Condominium dated January 9. 1979, and recorded January 23. 1979. in Plan Book 34. Page 100, and amended by a cer- tain Fourtb Amendment to Declara- tion Plan of Westwood Village Con- d~dIlIiOclnlif....ch 1. HW9. and ~. __~!t J!J!,7~. In Plan Book 3.5. Pat!!: 3, being designated on said Declaration Plan of Weste wood Village Condominium as Unit No, 848. Suite 110, LlO-T2A. in Block.#5. Building n. known as 848 Brian Drive. Suite llO. EnoJa. Cumberland COllllty. Pennsylvania. as more fully described in such Dec- laration Plan and Declaration Cre- ating and Establisbing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto. TOGE1HER with a proportionate un- divided interest in the Conimon El- ements (as defined in such Decla- ration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRIAN DRIVE. ENOLA. PA 17025. BEING TIlE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOW AS TIlE PROPER- 1Y OF ROBYN M. NOLEN ON CUM- BERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-00 i ^ U 7848-5. ._~I~ , .,'. ,-I,';' ., ...", PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. MorgenthaI, Esquire, Editor ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, aeposes 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 publieation attached hereto is . C exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. {~ Roger Nf. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 Not . NO'l'ADL'sEAL LOIS e, SNYDER, NoIlIly NlIIc.. CIrllaIe 8010, Curnbertanil ColI1Iy My COlllilllllDII ElipiIIs MlIdl S. 2005 -. ,. ~ " , ~_d"'_ ,~ ie, , .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 543 HOMESIDE LENDING, INC., PLAINTIFF TOTAL AMOUNT OF JUDGMENT $64,242.41 / Interest at $13.61 per diem to sale date $ 5,389.56 Late charges at $22.64 per month to sale date $ 249.04 Escrow Deficit $ 2.000.00 TOTAL $71,878.01* VS. ROBYN M. NOLEN, DEFENDANT *SALE DATE: WEDS.,MARCH 6, 2002 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: November 29, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: captioned described ENOLA, PA To satisfy the judgment, interest and costs in the above case, you are directed to levy upon and sell the property in the attached description known as 848 BRIAN DRIVE, 17025. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY ,. l- J , , ~ ~. , -,""",', "i: } c.' '... ! , ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan referred to below as Westwood Village Condominium located in East Pennsbor~ Township, Cumberland County. Commonwealth of Pennsylvania, which has heretofore been submitted to the proviSions of the Unit Property Act of pennsy I van i a . Act of July 3. 1963. P. L. 196, by the record i ng in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania. of a Declaration Creating and Establishing Westwood Village Condominium dated January 29. 1975, and recorded on January 29, 1975. in Misc. Book ?13, Page 283, and amended by a certain First Amendment to Declaration Creating and Establishing Westwood Village Condominium dated May 28, 1976, and recorded on June 22 1976 in Misc. Book 222, Page 729, and a certain Second Amendment to Declaration C;eating and Establishing Westwood Village Condominium dated July 21, 1976. and recorded on July 26, 1976, in Misc. Book 223',Page 343, and a certain Third Amendment to Declaration Creating and Estabilshlng Westwood Village Condominium dated June 9, t978, and recorded on June 23, 1978. in Misc. Book 236, Page 225, and a certain Fourth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated June 13, 1978. and recorded on June 23, 1978, in Mise, Book 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood village Condominium dated January 9, 1979 and recorded on January 23. 1979, in Misc. Book 240, Page 884, and a certain Sixth Amendment to Declaration Creating and Establ ishing Westwood Village Condominium dated March 1. 1979. and recorded March 12 t979 in Misc. Book 241, Page 836. and a Code of Regulations of Westwood' Village Condominium dated January 29. 1975, and recorded on January 29. 1975, In MISC. Book 213, Page 328, and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28. 1976, and recorded on June 22, 1976. in Misc. Book 222. Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, 1975, and recorded on January 29. 1975 in Plan Book 26, Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976. and recorded on July 26. 1976, in Plan Book 28. Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23. 1978, in Plan Book 33. Page 28, and amended by a certain Third Amendment to Oeclaration Plan of Westwood Village Condominium dated January 9, 1979. and recorded January 23, 1979, in Plan Book 34. Page 100, and amended by a certain Fourth Amendment to Oeclaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35. Page 3, being designated on said Declaration Plan of Westwood Village Condominium as Unit No. 64l,L_Sllitp 110-,- ,pO-~slk~lock #5, !J.llJ~ding #7. know~as H48.Brlao'-Orive,SuHe11O, Enola, CUffil)erland CoUJft-y,--Pennsylvania, asmoretuHy--oescrTI\edin such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above, inclUding any amendments thereto, TOGETHER with a, proportionate undivided interest in the Common EI~ments (as defined in such Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRI~ DRIVE, ENOLA, PA. 17025. BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 -~~...- ;,~- ~,.....-- n ~. "' .", , I,;: t,' 'C\Ct.,.,., o'{ ~ I ..-'~ I ,~\IL ,:~HU1A\"\ cr ",," ,', D1J, 2: k9 0\ GEe - J I I, - - . ". i' "/\U\-.)'('{ CUiv'i8t.riU,",l; ;-'iA ' PEl\\NSYLVf\N, ~ l irj~ W 37,30 q. ( Ie: t3 ( 4- J-O I~~ o-V \ ~3 ~ ~/ ----- Co ; i I i 'j ~ ~ , I I I !it ~<- 42-33 Cf (j] K. Ii q 3(., f (b-J ~ L I .. .' t HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 848 BRIAN DRIVE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): Robyn M. Nolen 848 Brian Drive Enola, PA 17025 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the ",-:""~~' "~ . " I I ~ ~" " '''-' ;0>.;, <, sale: UNKNOWN 7 . Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale, TENANTS IF ANY... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating unsworn falsification to authorities. Leon P. Haller #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 29, 2001 . . . . ." r iLCD ,-C;:F1CE OF !;\ iHcr.:rJTi',RY nl O\="C -'" pu 2: 4Q ~, ~ '_' .J J II .", CU"~~-I.' "QU'CTY hJ:tjtd....i-\i\U (.; . I~J PENNSYLVl\N\A I . I ~ t I I ~ j!!il" L ~. ~' , , ',-, , -- ,. ,~.. w, , f HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, MARCH 6, 2002 TIME: 10:00 o'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 848 BRIAN DRIVE ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO, 2001 543 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: ROBYN M. NOLEN ~ I I ,~ , ^" J '~". , f A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale recei ved and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU, IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ~-"' .j,'.-, ., ,c , I petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court7" A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 -,~,-~ ." - ~ -~ ." ~ .,.','; , . ALL THAT CERTAIN unit in the propertyknowni named and identified in the Declaration Plan referred to below as Westwood Village Condominium located in East pennsbor~ Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, P.L. 196, by the recor?ing in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Misc. Book ?13, Page 2B3, and amended by a certain First Amendment to Declaration Creating and Establishing Westwood Village Condominium dated May 2B, 1976, and recorded on June 22, 1976, in Mi sc, Book 222, Page 729, and a certa 10 Second Amendment to Declaration Creating and Establ~shing Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, in Misc. Book 223, Page 343, and a certain Third Amendment to Declaration Creating and Establishing Westwood Vi II age Condominium dated June 9, 1978, and recorded on June 23, 1978, ~n Misc. Book 236, Page 225, and a certain Fourth Amendment to DeclaratIon CreatlOg and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Misc. 800k 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Hestwood Village Condominium dated January 9, 1979 and recorded on January 23, 1979, in Misc. Book 240, Page 884, and.a. certain Sixth Amendment to Declaration Creating and Establ ishing Westwood Village Condominium dated March 1, 1979, and recorded March 12 1979 in Mise, Book 241, Page 836, and a Code of Regulations of Hestwood' Village Condominium dated January 29, 1975, and recorded on January 29, 1975, In MISC. Book 213, Page 328, and amended by a certain First Amendment to Code of Regulations of Hestwood Village Condominium dated May 28, 1976, and recorded on June 22, 1976, in Misc. Book 222, Page 737, and Declaration Plan of Hestwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26, Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976, In Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwo?d Village Condominium dated January 9, 1979, and recorded January 23, 1979, In Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3, being designated on said Oeclaration Plan of Westwood Village Condominium as Unit NO..l34a._Sui1.e-UOr- ,LlO- !~,-jJL~lock #"?2-BuHdinq #7 ,kn9w~asl34eBr~~n'-orTvii.?ui:te 110, Enola, Cumberland County;-pennsylvania, asmore;.'tullrilescrtl5et( in such Declaration Plan and Declaration Creating and EstabliShing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto, TOGETHER with a proportionate undivided interest in the, Common Elements (as defined in such Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 B~I~ DRIVE, ENOLA, PA. 17025. BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 , ...~=~ '~"~~iililill~;:,w;;~~ii.:lJI~:i4i- ~~ ~,~ !iii~MA~!iI.Hfi>jOjj~%;~~'';''-';'-~'- . "IiJi6ilillj~ -.J' ." =~ '~---' ~ . 0 C) , , ~t " 0 -0 C') f '1 1'1 l'j' ~ C"") f' ~ 7 :~tj Z I r,.', (f) 2'.: G) '.-:' -(",:.- c:; ~~ -', '1, -D " __"1-, ~2C) ~, C) \",1 Z ::...-:! ~ .,.. :iJ \0 -< . ',~IUlI.'""= ~ I l: ,,_ OH ," ,l'~", ' .. f HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE RETURN OF SERVICE I hereby certify that I h~ve deposited in the u.s. Mails at Harrisburg, Pennsyl vania on / -I tJ -tJ 2. ,a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Robyn M. Nolen 848 Brian Drive Enola, PA 17025 Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By PURCELL, KRUG & HAL R Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 )f~-J ,~ I, , _" ~I ."' .. . JOHN W. PURCELL HOWARD 8. KRUG LEON p, HALLER JOHN W, PURCELL JR, BRlAN J. TYLER JILL M. WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Robyn M. Nolen 848 Brian Drive Enola, PA 170.25 Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. By: nst the said have an notified of YOU ARE FURTHER 'NOTIFIED that the lien real estate will be divested by the sale opportunity to protect your interest, if said Sheriff's Sale. Leon P. Haller PA .D.15700 Attorney for Plaintiff u~t.t<!O('.'." - __ l ,I." ,~ '~ '~ '\11I,. '; ~ , HOMESIDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, MARCH 6, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 848 BRIAN DRIVE ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 543 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: ROBYN M. NOLEN ,.,~= "~" J. <J ^ ~ L I, ".,1' ~,,'. ......."" A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days. after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This _~~.._o~ ,~ "'iI>-,_ petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 M,~I ~"~ < " -~ " ALL THAT CERTAIN unit in the property known, named and identified in the Declaration Plan, referred to below as Westwood Village Condominium locat~d in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvama, which has heretofore been submitted to the provisions of the Unit Property Act of pennsylvania, Act of July 3, 1963, P.L. 196, by the recording in the Office of the Recorder of Deeds of Cumberland County, pennsylvania, of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Mi~c. Book 213, Page 283, and amended by a certain First Amendment to DeclaratIon CreatIng and Establishing Westwood Village Condominium dated May 28, 1976, and recorded on June 22 1976 in Misc. Book 222, Page 729, and a certaIn Second Amendment to Dee larai.ion C~eati ngand Establ i,shing Westwood Vi llage Condominium dated July 21, 1976, and recorded on July 26, 1976, in Misc. 800k 223,.page 343, and a certain Third Amendment to Declaration Creating and EstablIshIng Westwood Village Condominium dated June 9, 1978, and recorded on June 23, 1978, in Misc. Book 236. Page 225. and a certain Fourth Amendment to Declaration Creating and EstabliShing Westwood Village Condominium dated June 13, 1978, and recorded on June 23. 1978, in Misc. Cook 236, Page 250, and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated January 9. 1979 ~nd recorded on January 23, 1979, in Misc. Book 240, Page 884, and a certaIn Sixth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated March 1, 1979, and recorded March 12 1979 in Misc. Book 241, Page 836, and a Code of Regulations of westwood' VIllage Condominium dated January 29, 1975, and recorded on January 29, 1975, In MIsc. Book 213. Page 328, and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28, 1976. and recorded on June 22, 1976, in Misc. 800k 222, Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, t975, and recorded on January 29, 1975 in Plan Book 26, Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976. in Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23, 1978, in Plan Cook 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwo?d Village Condominium dated January 9. 1979, and recorded January 23, 1979. In Plan Book 34, Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3, being designated on said Declaration Plan of Westwood Village Condominium as Unit NO..1HB.,,_SlIitp 110..- t10- T?I\,~l'L!llock #~-,_J!J_gdinqJ2,knownas!;l48~rian-otive,Suite 110, Enola, Cumoerland County-;"l'ennsylvania, as more-tul1ycc1leSCr'fl}e(( in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above, including any amendments thereto, TOGETHER with a proportionate undivided interest in the Common Elements (as defined in such Declaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRIAN DRIVE, ENOLA, PA. 17025. " BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5 '''~,-~ ',.1, , , " ~-" --- Homeside v. Nolen Cumberland Sales 3/6/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Robyn M. Nolen 848 Brian Drive Enola, PA 1702.5 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Forin J877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING compliance with Postal Service Form 3877) (In Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: / '~"::',~::i:;b\~ c; j~\\ -;. \ 'i ;~~ $,) ~o ~\J\l~ <1;'/ -' ,]'.; US?'<>,/ p()_C!t-~- '"'__...._.__-""" ---=:::::-J ~ or-~$'~~ .. __---=.;::;7 ~ ~rs.,p;:::=:;:-F-=1;~-:' ~~e(j~/ J' I~', u.~.?U~\P<D\. \~ (!J".N\ G'CZ1bry' ~';~...."J~\:o U J S ::\~ ~..- ~~.;.. \. \ ,,,--" L- -------' , '--1'J-/ ~7b)SD5 .- One piece of ordinary mail addressed Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 to: ,,'~ J ~~~ - ~ , 1,,- . '~ ,~ , ' "J~,..J.~ , 'L,--"> "' ,t.,f , -' \ U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service For.m 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 -."" ','J "t..'di&.lIi~ ~ ~',~'" '-"""''"'~" ~~ ~~~-,' ,~, ~ ~ 0 , , ~.. ," ~~. ,- ~.l!lmlia.~,-~~_~li~~ "~", ~~, .~ ~, '<' ~~,' ~~ "r ~, 0 <:) ,~ d C r...,) '"'7! ~ -.., --- -ocr' m " mnl O::l r'-"~" Z:c- r....J- -, Cel ZC:: C) '.,r ~Z '~,,~:~~ !<O ~;:: )>0 -- 0,;0 z .' ~s.)rp _(i 9? PC 'c:j ~ '''"' 'P "D '< ill - i';,- . , .. -".,- ,I!o -". ,'~ , " STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler ~ --------------------------------______________________________________________Ilecorderof Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which nnn______n__ H~eside Lending Inc _ __ __ _ __ __ ___ ___ __ ___ __ ___ _'. ____ ___ __ ___ __ ___ ___ ___ __ _____ _____ _____ _____________ _ __ is the grantee the same having been sold to said grantee on the _n__~_:~_________________________n__n_____n day of March _____nn__________nn___n__n_nn___ A. D., I!J~:?QQ~n' under and by virtue of a writn_____n_____ execution . 3rd ___ ___ _nn __ _ __ _____ __ _ __ ___ __ u __________ _____ ISSued on the _ n n___u___ _n n_ n_ __ __ __ __ ____ ___ Decell\ber = . day of ___________n___n__n_n_ A. D., mo200-l-, out of the Court of Cornman Pleas of Said County as of civil = ________ ________ __ ___ _____ ___ _.. ______ _ n________ ________ n__ ____________ n n _____ Term, __ _20m 543 Ho~eside Lending Inc Number __________u__, at the suit of __U__n_____________________n__n______________________nn__ . Robyn M Nolen IS' ___________________________________aganost____________________________________________________ duly recorded in Sheriff's Deed Book No. ___~~~__n__' Page __~!_2_~_____. IN TESTIMONY WHEIlEOF, I have hereunto -tr set my hand and seal of said office this Pl_L_______ day "Q.. U~,t:'r4_=-~. ,_"""""",-",, ,..1.. ;.a"."",,,,,,,,,,. - . '. .' -" .~~ <"-"'ili~"",~.,.",.,,~!tMi~~n~r "'~'''''c.IO_''' ",,""..""""... .,<;"15, " ,~:', ;:.. :'c.:;'l'il~ ~,~ ~ ,;W'~...., ,jV,dI""M~" ", ~^. , ,""" "'.""~" ~,~I_. "'~ .~~ >~~~ ~< ~ --, ,~- '. '" m"~ h_ " .' ~~" .....c, '" ~ ~-.,""""_. ~' ~ ,- ~ ~ "<- .!- Homeside Lending, Inc. VS Robyn M. Nolen In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-543 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Robyn M. Nolen, but was unable to locate her in his bailiwick. He therefore depntized the Sheriff of Dauphin County, Pennsylvania to serve the within Real Estate Writ, Notice and Description according to law. DAUPHIN COUNTY RETURN: AND NOW: January 23,2002 at 10:35 A.M. serVed the within Notice of Sheriff s Sale of Real Estate upon Robyn Nolen by personally handing to T~poper Richelle Berran At POE, one true attested copy of the original Notice of$heriffs is!lie of Real Estate and making known to her the contents thereof at POE: PAState PC1I\pe, Troop H, Rt. 39 & 22, Harrisburg, PA 17110. So Answers: J.R. Lotwick, Sheriff of Dauphin County, Pennsylvania. Roben L. Fink, Sf., Deputy Sheriff, who being duly sworn according to law, states that oh~anuary 09, 2002 at 5:15 o'clock P.M., E.S.T., he posted a true copy of the within Real iBstate Writ, Notice, Poster and Description, in the above entitled action, upon the pf0I1erty of Robyn M. Nolen located at 848 Brian Drive, Enola, Pennsylvania, according to ~aw. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Robyn M. Nolen, by regular mail to her last known address of 3304 Spring Street, Apt. #A, Harrisburg, PA 17109. This letter was mailed under the date of January 23,2002 and returned to the Sheriffs Office on January 24,2002 as "Moved, Left No Address, Unable To Forward, Return To Sender." 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 March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of$1.00 to Attorney Leon P. Haller for Homeside Lending, Inc. It being highest bid and best price received for the same Homeside Lending, Inc. of8120 Nations Way, Building 100, Jacksonville, FL 32256, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of$1388.65, it being costs. Sheriff's Costs: Docketing 30.00 Poundage 27.23 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 ,""" ",,",,_.,>~,,-,...." ~ ~~ Out of County Dauphin County Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed , '. "'~ l_1 9.00 29.25 1.00 10.35 .82 15.00 20.00 618.80 481.50 24.20 25.00 26.50 $1388.65 paid 3/18/02 Sworn and subscribed to before me ~SlP r~,,",-;-~~ This ~ day of ~J Q '../ R. Thomas Klme, Shenff 2002, A.D. J(' 0 '71t-1J,.__, ~ J' rI" (' -+t r honotary BY /J~ ...JrYiL-.lli Real Estate Deputy "~ - -,~,' . . ,~ ~. ^"j ~r 30,iF C~ I-~ tL 3s'l 'I'; {~j;l3(,(, 'f I, ! " . .," HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 848 BRIAN DRIVE, ENOLA, PA 17025: 1. Name and address of the Owner(s) or Reputed Owner(s): Robyn M. Nolen 848 Brian Drive Enola, PA 17025 2. Name and daddress of Defendant (s) in the c Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: Westwood Village Condominium Homeowners Association 650 Westwood Drive Enola, PA 17025 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the . ",,' J:i.';, ,~".' ,dj I ~j '.'rr\" , , sale: UNKNOWN 7 . Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY... Domestic Relations Office . Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I underst~nd that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating/}el unsworn falsification to authorities. '~r~~' // 0~ ~----------/ .~/' I Leon P. Haller N\....I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 29, 2001 ,,,,v~..b. , , ~ ~,; , . HOMES IDE LENDING, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2001 543 ROBYN M. NOLEN, DEFENDANT IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, MARCH 6, 2002 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 848 BRIAN DRIVE ENOLA CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 543 THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property is: ROBYN M. NOLEN ,,1'kf_" .J' '.' , . .". ~ A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have ~egal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This ~~ ~~~ '" ,'I' _ ;" " ~~"." d"~i; petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas. of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~"~ ,'I .' , ALL THAT CERTAIN unit in the property known, named and identified. in the Declaration Plan referred to below as Westwood Village Condominium located in EastPennsbor~ Township, Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963. P.L. 196, by the recor~ing in the Office of the Recorder of Deeds of Cumberland County, PennsylvanIa. of a Declaration Creating and Establishing Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975, in Mi~c. Book ~13, Page 283, and amended by a certain First Amendment to DeclaratIon CreatIng and Establishing Westwood Village Condominium dated May 28, 1976. and recorded on June 22 1976 in Mi sc. Book 222. Page 729. and a certal n Second Amendment to Declaration c~eatingand Establi.shing westwood Village Condominium dated July 21, 1976, and recorded on July 26, 1976. in Misc. Book 223,.page 343, and a certain Third Amendment to Declaration Creating and EstablIshIng Westwood Village Condominium dated June 9, 1978, and recorded on June 23, 1978, ~n Misc. Book 236, Page 225. and a certain Fourth Amendment to Declaration CreatIng and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978, in Misc. Book 236. Page 250. and a certain Fifth Amendment to Declaration Creating and Establishing Westwood Vi llage Condominium dated January 9, 1979 and recorded on January 23. 1979. in Misc. Book 240, Page 884, and.a certain Sixth Amendment to Declaration Creating and Establishing Westwood Village Condominium dated March t, 1979, and recorded March 12 1979 in Misc. Book 241. Page 836, and a Code of Regulations of Westwood' Village Condominium da~ed January 29, 1975, and recorded on January 29, 1975, In MISC. Book 213, Page 328, and amended by a certain First Amendment to Code of Regulations of Westwood Village Condominium dated May 28, 1976, and recorded on June 22, 1976, in Misc. Book 222, Page 737, and Declaration Plan of Westwood Village Condominium dated January 29, 1975, and recorded on January 29, 1975 in Plan Book 26. Page 15, and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21, 1976, and recorded on Ju I y 26, 1976. in P I an Book 28. Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and recorded on June 23, 1978, in Plan Book 33, Page 28, and amended by a certain Third Amendment to Declaration Plan of Westwood Village Condominium dated January 9, 1979, and recorded January 23, 1979, in Plan Book 34. Page 100, and amended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1, 1979, and recorded March 12, 1979, in Plan Book 35, Page 3. being designated on said Declaration Plan of Westwood Village Condominium as Unit Nq..64a.__Sul1e-.UD..- -!, 10- T?fI-> in Block 115. Bui Iding 117,. known. as848Br;ian,:~DrIve.Suite 110, Enola, Cumberland CourltY;--PennsyTvania, asmore:tUI1Y'desi:~ in such Declaration Plan and Declaration Creating and Establishing Westwood Village Condominium, as the same appears of record as set forth above. including any amendments thereto, TOGETHER with a proportionate undivided interest in the Common Elements (as defined in such Oeclaration) of Seven Hundred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRIAN DRIVE, ENOLA, PA. 17025. c_ BEING THE SAME PREMISES WHICH David R. Wright and Carolyn G. Wright by deed dated 3/27/97 and recorded in Deed Book 155 Page 150 granted and conveyed unto Robyn M. Nolen. TO BE SOLD AS THE PROPERTY OF ROBYN M. NOLEN ON CUMBERLAND COUNTY JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 AU 7848-5 _iir'v~ ~~, - ~j j, -~ ~,' - ..d:it:IJK~~tl WRIT OF EXEC,UTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 01-543 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY To satisfy the debt, interesf and costs due __,__,_,fI.omeside Lending, Inc. PLAINTIFF(S) Irom_Robyn M. Nolen, 848 Brian Drive, Enola PA 17025. DEFENDANT(S) (1) You are directed to levy upon the property 01 the defendant(s) and to sell Real estate located _at R4R Rrinhn Dr.. Enola PA 17025. (See attached 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 notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) iSfare enjoined from payingi!DY debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise dispo'gJ(1g thereof: ' (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $64,242.41 Interest @ $13.61/diem to 3/6)02 $5,389.56 LL Due Prothy $1. 00 Ally's Comm Arty Paid Plaintiff Paid % $1436.00 Other Costs Escrow Deficit Late charge @ $22.64/mo to bol~ JaL~ 3/6/02 $2,000.00 $249.04 Date: December 3, 2001 CURTIS R. LONG by _ Deputy REQUESTING PARTY Name Leon P. Haller, Esq. 1719 N Front St Address: Attorney for: Harrisburg PA 17102 Plaintiff Telephone: ( 717 ) Supreme Court 10 No. 234 4178 15700 ~ ~ = ~ ~J " ~ , ~'"h"';"k"'''''['1''''_,"~~k'1<~~t<i\~~lmRII!.!i!II'<@;:!.a.~ib.lb~~!'lIl'iM].J. . . REAL ESTATE SALE No. L\4 On December 12,2001, the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A, known and numbered as 848 Brian Drive, Eno1a, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12,2001 By: <1b~ SC~ Real Estate Deputy ),.S,~'t\1c\ \"i\\>.Ioq t'-.\.. .". .'" ", 'II \\ r~ \ ':. 'r': ~ '~ ~t.t, \\ 'j~ \\). ~~, ;'d;Y/ll\~\) ,,~ ;, - ,n 3:\\;} .~"II"" -\;Ii ~v .. .,.,,\lS :l :\:\\,,~ ^~" .,~~"~,,,,~,I~..,..^,~,~, - f' w. "" ;;.u 1-1 ./ REAiL ESIJ'A'l'E SALE NO. 49 r , and Establishing WestwOod VJnage Condonililium dated March 1. 1979. and recorded March 12. 1979 in Misc. Book 241. Page 836. and a Code of Regulations of Westwood Village Condominium dated Janu- ary 29. 1975. and recorded on Jan- t.uaiy 29. 1975. in Misc. Book 213, Page 328. and amended by a cer- tain First Amendment to Code of Regulations of Westwood Village Condonililium dated May 28. 1976. and recorded on June 22. 1976. in Misc. Book 222, Page 737, and Declaration Plan of Westwood Vil- lage Condominium dated January 29, 1975. and recorded on Janu- ary 29, 1975 in Plan Book 26. Page 15. and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated .:1uly 21. 1976. and recorded on July 26. 1976. in Plan Book 28. Page 72. and amended by a cert_ Second Amendment to Declaration Plan of Westwood Village Condo- minium dated Jnne 16. 1978. and recorded on Jnne 23. 1978. in Plan Book 33. Page 28. and amended by a certain 11Urd Amendment to Dec- laration Plan of Westwood Village Condominium dated January 9. 1979. and recorded January 23. 1979. In Plan Book 34, Page 100. and aIhended by a certain Fourth Amendment to Declaration Plan of Westwood Village Condominium dated March 1. 1979. and recorded March 12. 1979. in Plan Book 35. Page 3. being designated on said Declaration Plan of Westwood Village Condominium as Unit No. 848. Suite 110. LIO-T2A, in Block #5. Build- ing #7. known as 848 Brian Drive. Suite no, Enola, Ctunberland Coun- ty, Pennsylvania. as more fully de- scribed in such Declaration Plan and Declaration Creating and Es- tablls11ing Westwood Village Condo- minium. as the same appears of rec- ord as set forth above. including any amendments thereto, TOGETHER with a proportionate nndivided in- terest in the Common Elements (as defined in such Declaration} of Sev- en Hnndred Seventeen thousandths Percent (.717%). KNOWN AS 848 BRIAN DRIVE. ENOLA. PA 17025. BEING THE SAME PREMISES WIDCH David R. Wright and Caro- lyn G. Wright by deed dated 3/27/ 97 and recorded in Deed Book 155 Page i50 granted and conveyed unto Robyn M. Nolen. TO BE SOW AS TIfE PROPER- 1Y OF'ROBYN M. NOLEN ON CUM- BERLAND COUN1Y JUDGMENT NO. 2001 543. ASSESSMENT: 09-12-2992-001 A U 7848-5. Writ No. 2001-543 Civil Homeside Lending. Inc. vs, Robyn M. Nolen Atty.: Leon P. Haller ALl, TIfAT CERTAIN unit in the property lmown. named and identi- fied in the Declaration Plan. referred to below as Westwood Village Con- dOIlJinium located in East Pennsboro Township. Cumberland County. Commonwealth of Pennsylvania. which has heretofore been submit- ted to the provisions of the Unit Property Act of Pennsylvania. Act of <July 3. 1963. P.L. 196. by the recording in the Office of the Re- corder of Deeds of Cumberland County. Pennsylvania, of a Decla- ration Creating and Establishing We~tw<?od Village Condominium dated January 29. 1975, and re- con:led on Januroy 29, 1975. in Misc. Book 213. Page 283. and amended , by a' c~rtain First Amendment to I ])e(;lar.i-tlon Creating and Establish- I ing Westwood Village CondOminium I dated. May 28. 1976. and recorded on June 22. 1976, in Misc. Book 222.; Page 729. and a ce~ Sec- ond,iAmendment to Declaration Cre- ating and Establishing Westwood Village Condonililium dated Juiy 21. 1976. and recorded on July 26. 1976. .in Misc. Book 223. Page 343. and a certain Third Amendment to Declaration Creating and Establish- ing Westwood Village CondOminium dated unne 9. 1978. and recorded on June 23. 1978, in Misc. Book 236. Page 225. and a ce~ Fourth Amendment to Declaration Creating and Establishing Westwood Village Condonililium dated June 13, 1978. and recorded on Jnne 23. 1978, in Misc. Book 236. Page 250, and a certain Fifth Amendment to Decla- ration Creating and Establishing Westwood Village Condominium dated January 9. 1979 and recorded on J"!'uary 23. 1979. in Misc. Book 240. Page 8B4. and a certain Sixth Amen<lment to Declaration Creating - ._~-,~~ "~ ~ ~' - ~i " - .',,, ~ <~- , PROOF OF PUBLICATION OF NOnCE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : R!)ger M, Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2,1952, and desiguatedby 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 25, FEBRUARY 1, 8,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing staten nts as to timf' p1'lce and character of publication are true. I Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 NOTARIAL SEN. PublIC LOIS e, SNYDE~ CoUnlY Mv== Expim MardI 5. 2005 REALESrATESALE No:49 Writ No. 2001-543 Civil Te.m Homeslde Lending, Ine. vs Robyn M. Nolen , . Atty: Leon P. Haller , DESCRll'l10N I 'ALL THAT CERTAIN unit in the property ,known, named and identified in the 'Declaration Plan,. rd'crred to below -as- Westwood Village Condominium located in East Pennsbara Township. Cumberland County, Commonwealth of Pennsylvania, which has heretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, P.L 196, by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania., Qf a Declaration Creating and Establishing , Westwood Village Condominium .-dated Janum} 29,1975, and recorded on JanualY 29. 19.75, In MIse, Book 213, Page 283, and amended by a certain First Amendment to , Declaration Creating arid Estabflshing West. wood Village Condominium dated May 28, t976, and recorded on June 22, 1976, in Mise, , :Heiok 222" Page 729, and a certain Second "Amendment to Declaration Creating and Establishing WestwOOd Village Condominium : dated July 21,1916, and recorded on July 26, : 1976~ in Misc. Book 223, Page 343, and a certain Third Amendment to Declaration : Creating and Establishing Westwood Village ,Condominium dated June 9, 1978. and F,recorded on JUTP 23, 1978, in ML~~. Bo~l<~~ r.:-'::,~. ~,~~35I..'.'~n..~.(.~erW!1 ,Fo,Ur!f).,,,Aro~,!l:~I':'~~"'!O i:::,,;m~cllID1tigQ..".,.~'9~ating' .and EstatiI$~tng '::':',::Westwood Yll~~" ,Condqtpmiu~" $~' iilne H::':::J3,;, :-1978~,.an9 ,rcCoroe'd' :00" June'13, fn~;, "lil t::::::J~1iSC. Book :n:6, page 250~ and a ceruifn'Ftf'th i:' "Amendment to Declaration Creatilig and i ,Establishing Westwood V1l1age Condominium ,dated January 9, 1979 and recorded OD January 23, 1979 in Misc. Book 240, Page 884, and a certain Sixth Amendrneut to Declaration Creating and Establishing Westwood Vlllage COndominium dated March 1. 1979, and recorded March 12, 1979 in Misc. Book 241, Page ,83,6, and a Code, of "Regulations of Westwood VilJage'CciridoininiUrit dated January , 39.,1975, and recorded on Jan11alY 29. 1'975, in :' Misc. Book 213, .Page 328. and amended by a certain First Amendment to Code of Regulations of Westwood Village CQ11dominiurn dated May 28,1976. and nx:opjed on June 22. 1976, in Misc. Book 222, Page 737, and Declaration Plan of West~ wood Village Condominium dated January 29, 1975, and recorded on January 29., 1975 in Plan Book '26, Page 15, and amended by a certain F'tr5{ Amendment 10, Declaration Plan of Westwood Village Condominium dated July 21,)976, and : recorded on J1'\.o-) 2-6, 1976, in Pl311 Book 28. i Page 72, ano,..mended by a certain Second ~ Amendment to Declaration Plan of Westwood : Village Condominiiim dated June 16, 1978. and recorded on June 23. 1978, 10 Plan Book 33, . Page 28, and amended by a certain Third , Amendment 'to Declaration Plan of Westwood : Village Contlominium dated January 9,1979. l...,a~d.Je.cpp:\ed Janu~~J[li.__i!i ~~~~_ '..34; Page 'loo,'and ameiidecrRY a cetfum Founn , 'Amendment to Dedaration,Plan ofWest~ wood "Village condonllhium dated MarCh 1 1979 and ;,,:::~~~!ded ~arch r~ 1979, in Plan.' Book 35, Page 3. bemg desI.gllated on said Declaration Plan of WC5lwood Village Con. domiruuffi as ,,::Ynit N? .848, Suite 110, LlO.T2A, in' Block ,,,lis, BUIldmg 1f7, known as 848 Brian Drive ."Suite...,1l0" Enola, ,Cumberland County: ,P,~,I1J1~ylvania, as 11lOre fully de5cnbed in such " Declar:ati?n Plan and Declaration Creating and Estabhshmg Westwood Village Cpndominiom, , .as the same appears of record as set forth ,ab?ve, ,l.r!~ludil g any amendments thereto, ,W,qETHER wtlli a proportionate undivided :,interestin the Common Elements (as defined in -:' ~uch Declaration) !Jf Seven Hundri:d Se~'enteen thousandths Percent (.717%). ,'~OWN' AS 848 Brian Drive, Enola, PA 17025. "BEIN(:r the same premises' which David R. "Wrlglj.frinii Carolyn G. Wrigh't by deed dated 31 ' ',,,271J7 a,",d recorded in Deed Book 155,Page 150 , granted and conveyed unto Robyn M. Nolen. TO B8 SOLD as the propeny of Robyn M. ,N~len on Cumberland ,County Judgment No, .1001543. 'ASSESSMENT: 'D9-12~2992-00t a ti 7848-5. , .'''-'''.' .", ,,~' ~._" I. "v.::...,.Cj._' ,*," ; " I" - . ". ~~',,; THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Ass!. 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 Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true: and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. ' PUBLICATION COPY S ALE #49 Notarial Seal Terry L. Russ,n, Notary Public Harrisburg, Dauphin County My Commission Expires June 6, 2002 TARY PUBLIC Member, Pennsylvania Association of Notaries My commission expires June 6, 2002 CUMBERlAND COUNlY SHERIFFS OFFICE CUMBERlAND COUNlY COURTHOUSE CARLISLE, PAc 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 $ 480.00 1.50 481.50 ! Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By....................................................................