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HomeMy WebLinkAbout01-1303 FX ,-,'''-' .~-~ ~ ~. ~~..~_,i .~ , CHARLOTTE K. HUMMEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 63657 GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff, vs. Suzanne M.. Thomas aka Suzanne Thomas 97 RichneckRoad, Newport News, VA 23608, Defendant -. ,~ -" =~..lllli'<:o1l\;,l, Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 0 (-- /3c.3 ClJ~C;-~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you by the court withont further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede conlinuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. U sted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. V AYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PA 17013 717-249-3166 800-990-9108 -. ~...,,~._~~ "~ I., "" , ~, ~, , ,~-",!" CHARLOTTE K. HUMMEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 63657 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff, COURT OF COMMON PLEAS Cumberland COUNTY vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608, Defendant Case No: 0/- /3D3 CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. plaintiff is GMAC Mortgage Corporation, a corporation organized and existing under state law, with offices for the conduct of business at 500 Enterprise Road, Horsham, PA 19044- 0963. 2. Defendant, Suzanne M. Thomas aka Suzanne Thomas is the mortgagor and real owner of premises 217 South Sixteenth Street, Camp Hill, PA 17011, hereinafter described, whose last known address is the same as in the caption above. 3. plaintiff brings this action in mortgage foreclQsure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by ''''.1'"--''''' -~-, . ,~~ J~ _.~, ;I-~ _ ~ . ~" lUiI0lllM,1I!1!-'_"''''''.\<'.''"",__ the above named defendant, mortgagor and real owner to GMAC Mortgage Corporation on November 13, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Record Book 1499, page 216 secured on premises 217 South Sixteenth Street, Camp Hill, PA 17011 a true and correct description of which is attached hereto as Exhibit 1. 4. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 5. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, for the month of October 1, 2000 and each month thereafter, up to and including the present time. 6. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: principal Balance Interest from 9/1/00 to 3/6/01 At $19.30 per diem Late charges for 2/01 $104,339.30 $ 3,609.10 ,,~,--- ,. . "'"=,~ , _~...."". J ~~ ~- " ~, ~, ,gJ.'",wM,z.-;;""",-, At $34.51 per month Accrued Escrow deficit to 1/24/01 Monthly escrow deposits for 2/1/01 To 3/1/01 at $210.45 per month corporate Advances Monthly Inspections from 10/01/00 To 3/01/01 at $15.00 per month Attorney's. Fee Title Information Certificate photostats and Postage Notarizations $ 34.51 $ 182.70 $ 420.90 $ 7.25 $ 90.00 $5,200.00 $ 350.00 $ 45.00 $ 10.00 TOTAL $114,288.76 9. plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for $114,288.76, plus per diem interest at $19.30 from 3/9/01 to the date of judgment plus monthly late charges of $34.51 from 3/15/01 to the date of judgment plus monthly escrow deposits of $210.45 from 4/1//01 to the date of judgment plus monthly inspection costs of $15.00 from 4/1/01 to the date of judgment and foreclosure and sale of the mortgaged premises p~costs thereon ~!;!lul(~ Charlotte K. Hummel Attorney for the Plaintiff .il"." ~>'. "l~ "'~ ~ -. ~ -, l~iiI '~~'~''''''""I_,.,,,,, VERIFICATION I verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. ~ Tina yers Title~~~ ?~ " By: Dated: . ~&.to J , . Conestoga Trtle Insurance Company EXHIBIT ~ Commitment Number. 1998100756. SCHEDULE C PROPERTY DESCRIPTION .':~ . . -, ~ ~: The land referred to in this Commitment is described as follows: ALL that certain tract of land situated in the Borough of Camp Hill. County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point two hundred forty (240) feet South of the Southeast comer of Second and Sixteenth (fonnerly Jackson) Streets: thence Eastwardly along the South line of Lot No. 51, one hundred fifty (150) feet to a point in a went)' (20) feet wide alley; thence Southwardly along the West side of said alley Forty (40) feet to a point; thence West-Nardly along the Northern line of Lot No. 63, one hundred fifty (i50) feet. to a point in Sixteenth Street; thence Northwardly along the East side of said Sixteenth Street forty (40) feet to the place of BEGINNING. It being Lot No. 62 on the Pan of Lots known as Greater Harrisburg, Estate of Jackson Free, recorded in the Recorder's Office at CarHsle, Pennsylvania, in Plan BOok 1, Page 20. BEING the same premises which Paul R. Eichelberger and Lettie Eichetber~r, his wife, by their deed dated November 1954, and alxlut to be recorded in the Recorder of Deeds Office In and for Cumberland County, Pennsylvania, granted and conveyed. . '.~t>:r~ ~O"~i:s.. ~',"rl\ ..':iJ"...,-;.~'~~i;<'J~.'" "":~~1'~'::'~~!~";~\ ,o;v-~7'-':,o; ,...,. ,.:.~;-l,\t2'51~;...t.,:::~',;: ,,': .;~, 04::;;: '~1f1'" ~~..;t :~ i't ,.~..I ;--.. ..~.<. ,.) , ~...~ "I\"i-'.~:"''''' , ,''':' "'~" '..:...~.. w';:'~'O" '. f'..\fi " .-- !1.~~.' , , c.-. .....~\.~-\U,~'!...;-~. ". -;{.....~'-d."~:;:r.~~ .'$-", ....-;-.... ~~.'.....K. "',', ..: ~. "":'.~~~,,!'\ .~.(jj'.~~~...- 'It'jr-.#f, Sta,e of Pet'll'lSY{\Iania } COt.:r:~'t of Cumberland 86 ::X~'"dd;t'c;hi Off~ice for the recording of Deeds ~.\'I . -" "r~rn Iland County Pa. l:~".", 8uok.J::L1 or.~Pag'e~ \'I":-~mYhanda~S'aalotOffjceof _ C"rllsle, PA this \:I day of .t\, ,( ) t!:J ~l9_ ..~~ew- ~~ Al.TAComClli\ment Sc:heduleC (,99a1007W'2) .BooK!499PAGl; 222 '" " ,~... - . ,'.; J ,~ , ~=-~, GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE DATE: December 18, 2000 Servicing EXHIBIT ~ -- AND ACCELERATE LOoMAc Mortgage CERTIFIED MAIL NO. Z TO: SUZANNE M. THOMAS 97 RICHNECK RD NEWPORT NEWS, VA 23608 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 164381204 217 S SIXTEENTH STREET CAMP HILL, PA 17011-5535 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the October 1, 2000 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 2 payments @ $900.56 $1,801.12 1 payments @ $921.05 $921.05 Accrued late charges...... .............. ...........$69.02 NSF Check Fees....................... . . . . . . . . . . . . . . . $0.00 All other fees accrued to date.................... .$12.00 . Less available suspense credits ......... .........$188.66 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,614.53 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's cheek, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) ~. ~ -j~~ "' ,,~ ~ - <"" 'tn, December 18, 2000 Page 2 164381204 off the debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. Remember you are also responsible for keeping all real estate taxes current. We may also sue you personally for the unpaid balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately one-hundred and fifty (150) days from the date of this letter. A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-850-4622. The payment must be in cash, cashier's check, certified check or money order and made payable to us at the address previously stated. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. NOTICE - This is an attempt to collect a debt and any information obtained will be used for that purpose. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL TIlE PROPERTY TO OBTAIN MONEY TO PAY OFF TIlE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER TIlE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME TIlE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTIIER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES TIlE RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. DMS5-BRCHPAC (Page 2 of 2) - "'=.L....~ ~...J ~~ _"' "Ni. _ , " "~~ i-E_ .. GMAC Mortgage Corporation P.O. Box 85071 San Diego, CA 92186"5071 3451 Hammond Ave P.O. Box 780 Wa\e~oo, IA 50704.0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: December 18, 2000 Servicing CERTIFIED MAIL NO. Z TO: SUZANNE M. THOMAS 217 S SIXTEENTH STREET CAMP HILL, PA 17011-5535 LOGAN.BAii.E.... . . ..,.#"'t .. ~ Mortgage RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 164381204 217 S SIXTEENTH STREET CAMP HILL, PA 17011-5535 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours). As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the October I, 2000 and SUbsequent monthly payments as listed, and/or for other reasons as indicated below:' 2 payments @ $900.56 $1,801.12 1 payments @ $921.05 $921.05 Accrued late charges...................... . . . . . . . . . $69.02 NSF Check Fees................................ . . . . . . $0.00 All other fees accrued to date................ .....$12.00 , Less available suspense credits ... ....... .... ....$188.66 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,614.53 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) ~- ,. .. , . \ ~4 ~I i__..", ''''''' . December 18, 2000 Page 2 164381204 off the debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. Remember you are also responsible for keeping all real estate taxes current. We may also sue you personally for the unpaid balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure. sale (and perform any other requirements under the mortgage). It is. estimated that the earliest date that such a Sheriff's sale could be held would be approximately one-hundred and fifty (150) days from the date of this letter. A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-850-4622. The payment must be in cash, cashier's check, certified check or money order and made payable to us at the address previously stated. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. NOTICE - This is an attempt to collect a debt and any information obtained will be used for that purpose. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. DMS5-BRCHPAC (Page 2 of 2) ,~~~'I"'''~ ~~ .ujjQ[,-..>j,"~~ii~~';ill,.;!li;f;;gr"illl~"'lllilii~~'1<Jil~~~''Il~Wlli~;''d",;:,,_1i,ii'',1\<il,*"-'-"'llr,",. ~- "~~~ ~ ~fiilIi~"""''''- (:) ~ <f yt h " " (j C\ " t~ e ~,'~_.",=,,~_~< _~ -" , .~.~,- ~, ,. w. 6 v). ~ ~ J \ ~Y.J t'f. ~ .,-, .~,', ," -, -"~-'-. I'~~"~I <- '"~""'IiiIlW 0' (;:) c s: ~~ zc we "<5 ~ ~.~ '>2 z ~ J' " ~ :;II: J>o ;:0 I -..l .-, :T:-,jj n-;p --.r]!n l.~ \-"--< ::-.;0' el{'} j!:p ()r"') L?n 8 ~1'> ~ -0 :x o ::::> (.:> .. L' I ~ ~ ,-'~^, -." ...", J." _,,;= , " SHERIFF'S RETURN - REGULAR CASE NO: 2001-01303 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS THOMAS SUZANNE M ET AL DEP WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TERRE TENANTS the DEFENDANT , at 1536:00 HOURS, on the 8th day of March , 2001 at 217 SOUTH 16TH STREET CAMP HILL, PA 17011 by handing to MARNA HARTZELL CURRENT TENNANT 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 So Answers: 18.00 8.68 .00 10.00 .00 36.68 ~~~-t:~ R. Thomas Kline 03/12/2001 MARTHA E VON ROSENSTEIL Sworn a~d Subscribed to before me this -< ~ 'E-. day of ~ LIY, :40 ( A.D. Ck<.jl ~# Prothonotary' ~~ By: . y Sherif .,;"", ~ ,- ~"~ .J,. CHARLOTTE K. HUMMEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 63657 GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff, vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road, Newport News, VA 23608, Defendant - ~ '=~~_1E"-~" Att'orney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: Of - JJQJ LL~L '1~ CIVIL ACTION - MORTGAGE FORECLOSURE < THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrila 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante 'i requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE, CARLISLE, PA 17013 717-249-3166 'I'B8.... 800-990-9108 ... i nuc COpy FROM RECORD IItImony w!isr9iJf, I oors 11lllllll8t my ItaiW .. 1M Mi of Mid Coort at Carlisle, PI.. ~~ da~ M~ ~.. ~ .~ P. . ~~~~ 7 ..., .....".~ "~ CHARLOTTE K. HUMMEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 63657 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 plaintiff, COURT OF COMMON PLEAS Cumberland COUNTY vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608, Defendant Case No: CIVIL ACTION - .MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is GMAC Mortgage Corporation, a corporation organized and existing under state law, with offices for the conduct of business at 500 Enterprise Road, Horsham, PA 19044- 0963. 2. Defendant, Suzanne M. Thomas aka Suzanne Thomas is the mortgagor and real owner of premises 217 South Sixteenth Street, camp Hill, PA 17011, hereinafter described, whose last known address is the same as in the caption above. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by """"'--''', < ;~.~ j~,,~- ~ 1 "" - the above named defendant, mortgagor and real owner to GMAC Mortgage Corporation on November 13, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Record Book 1499, page 216 secured on premises 217 South Sixteenth Street, Camp Hill, PA 17011 a true and correct description of which is attached hereto as Exhibit 1. 4. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 5. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, for the month of October 1, 2000 and each month thereafter, up to and including the present time. 6. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 9/1/00 to 3/6/01 At $19.30 per diem Late charges for 2/01 $104,339.30 $ 3,609.10 -~~--"-- < ;,"',"',....lJ' < , ~; ~~ .- ,. " ~~ -- ~~~~-~-.~ ~ . '_~~~_:i At $34.51 per month Accrued Escrow deficit to 1/24/01 Monthly escrow deposits for 2/1/01 To 3/1/01 at $210.45 .per month Corporate Advances Monthly Inspections from 10/01/00 To 3/01/01 at $15.00 per month Attorney's Fee Title Information Certificate Photostats and Postage Notarizations $ 34.51 $ 182.70 $ 420.90 $ 7.25 $ 90.00 $5,200.00 $ 350.00 $ 45.00 $ 10.00 TOTAL $114,288.76 9. Plaintiff sent to defendants, mortgagors and real ownerS a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of < 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for $114,288.76, plus per diem intere.st at $19.30 from 3/9/01 to the date of judgment plus monthly late charges of $34.51 from 3/15/01 to the date of judgment plus monthly escrow deposits of $210.45 from 4/1//01 to the date of judgment plus monthly inspection costs of $15.00 from 4/1/01 to the date of judgment and foreclosure and sale of the mortgaged premises Pl~~CO.sts thereon~ " ..// 1 (//~ ._,..;: U4(tAf~~I\.~ /V/Ctf Charlotte K. Hummel Attorney for the Plaintiff -""""",,,-~ '.... ~ ~J ~< ,- .-- VERIFICATION I verify that the statements made in the foregoing Complaint in Mortgage foreclosure are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. By: '- k ~\;\, {j'vfJ Tina yers Title~u~M'tV\-0 ~fucJwk Dated: ~~lwld J h..~.,,;_ , Conestoga Title Insurance Company EXHIBIT .:e: Commitment Number: 1998100750. SCHEDULE C PROPERTY DESCRIPTION .:..- The land referred to in th\s Commitment is described as follows: All that certain tracf of land situated in the 8o(Qw;h of Camp Hiil, County of Cumberland af\d State of Pennsylvania, bounded and described as follcws: BEGINNING at a point two hundred forty (240) feet South of the Southeast comer of Second and Sixteenth (formeny Jackson) Streets; thence Eastwardly along the South line of Lot No. 61, one hundred /ifty (150) feet to :;I point in a twenty (20) feet wide alley; thence Southwardly along Ihe West sjde of said alley Forty (40) feet 10 a point; thence Westwardly along the Northern line of Lot No. 63, one hundred fifty (150) feet to a point in Sixteenth Street thence Northwardly along the East side of said Sixteenth Street fort)' (40) feet to the place of BEGiNNJNG. It being lot No. 62 on the Pan of lots known as Greater Harrisburg, Estate of Jackson Free. recorded in the Recorders Office at Carlisle, Pennsylvania, in Plan SOak 1, Page 20. BEING lhe same premises which Paul R. Eichelberger and Lettie Eichelberger, his wife, by their deed dated November 1~54. and about to De recorded In the Recorder of Deeds Office in and for Cumberland County, Pennsylvania, granted and conveyed. ,.;......_~~~I. ,,-~ij~1t~s _.-."t,1\ t ~ ~ :..t,~>;'."r.4~.~;.t . ,....v~'!-~~~$.~llt~.. ";~:;,\ !J"~ ~~~'~:."::;' ~. ~ "~, '_" t>/lr~;.:,~' , ,-~ ~ ;:\\r.! ,-..,~~~,,~,. ,~~_ i ~.. ~i';;~-''''J\~~~7.. ~':tl{.~:~ J ......~\('\;~n..,..."1,7'....- .;"'" . \:...-. ,~~.\;;;..,,~f"".,~ ". /~~~:~~~~~1~~~' ,\t'Jr..;t,.fi Sti:;3 of pennSYlVania} CCcii":~Y (If CU'''Oer!and 86 .~~c.C?,:0:~';,.,i~' to! office for the recording of Deeds ''''Nr.~~'~'' ler ~}lJ1J,9flr!and County, Pa. :;:.... ~ _ ..ook J::I.1':(Vo!. ~ Page JiJi ,..",:.~~;:, my hand a?f s?aJ of QWceof . . Ci:r!rs.a,PA!his \) dayof-4lLL..19 fJ .'.>'?A.-'< """~r' .'.vC'~.-7J' ~ r C' ALTA Commitment Schedule C (199810075S112) eooK1499 PAGt 222 ~ ~-,.""~'"" ~. J". "~ ~~L.. , -" ...~""'" -~ ~~=~ . ,.~ '~-~<lOl~;M" GMAC Mortgage Corporation P.O. Box 8507f . San Diego, CA 92186.5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704.0780 NOTICE OF INTENTION TO FORECLOSE DATE: December 18, 2000 Servicing EXH:S!T tC .--- AND ACCELERATE LOoMAc Mortgage CERTIFIED MAIL NO. Z TO: SUZANNE M. THOMAS 97 RICHNECK RD NEWPORT NEWS, VA 23608 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 164381204 217 S SIXTEENTH STREET CAMP HILL, PA 17011.5535 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the October 1, 2000 and subsequent monthly payments as listed, and/or for other reasons as indicated below: * < 2 payments @ $900.56 $1,801.12 1 payments @ $921.05 $921.05 Accrued late charges.... ......... ... ... ....... ... ..$69.02 NSF Check Fees.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date..................... $12.00 * Less available suspense credits ... .... ..... ..... .$188.66 The total amount now required to cure this default, or in other words, get caught up in your payments. as of the date of this letter is................... . . . . . . . . . . . . . . . . . $2,614.53 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780, Waterloo, IA 50704.0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) ~,I",~ ,~ I..' ~..-~_ ~~~~. -. ..~ " - ~~~" - December 18, 2000 Page 2 164381204 off the debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. Remember you are also responsible for keeping all real estate taxes current. We may also sue you personally for the unpaid balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately one-hundred and fifty (150) days from the date of this letter. A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800.850-4622. The payment must be in cash, cashier's check, certified check or money order and made payable to us at the address previously stated. ~ You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. NOTICE - This is an attempt to collect a debt and any information obtained will be used for that purpose. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. DMS5-BRCHPAC (Page 2 of 2) -"~"~~" " L... ....J~ "'"~''''' .Jh , .~ GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: December 18, 2000 Servicing LOoMAc Mortgage CERTIFIED MAIL NO. Z TO: SUZANNE M. THOMAS 217 S SIXTEENTH STREET CAMP HILL, PA 17011-5535 RE : MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 164381204 217 S SIXTEENTH STREET CAMP HILL, PA 17011-5535 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the October 1, 2000 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' ~ 2 payments @ $900.56 $1,801.12 1 payments @ $921.05 $921.05 Accrued late charges. .......... ......... ........ ...$69.02 NSF Check Fees....................................... $0.00 All other fees accrued to date...... . . . . . . . . . . . . . . . $12.00 , Less available suspense credits ..... ....... ......$188.66 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,614.53 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made ei,her by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) ~ _c ",--,,- "-'<'lli1l "~ ......~~ - December 18, 2000 Page 2 164381204 . off the debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you Owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, -you will not be required to pay attorney I s fees. Remember you are also responsible for keeping all real estate taxes current. We may also sue you personally for the unpaid balance and all other sums due bnder the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately one-hundred and fifty (150) days from the date of this letter. A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-850-4622. The payment must be in cash, cashier's check, certified check or money order and made payable to Us at the address previously stated. You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. NOTICE - This is an attempt to collect a debt and any information obtained will be used for that purpose. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. DMS5-BRCHPAC (Page 2 of 2) ;. ,- ""'-""""""""" < &_;h' 'w <:::::;;.-, ;:;:::.-.-' ig~~~'~ r~:!~~J ,?,::C,) \,':..:::/,;:~ .., ,., _<_~,~,'V,,,~ --..,r -",' ~~'-IlfM.J!i!'-~'"'"'a~ '..ili<ii!'.,..1I"......"'''''",il!!I . ~,I i~",,!f;\~~~, \f/~,t)~ 7/ SNNJd .:-f J ,,< l~lUvO 10, !t} La /1 L /lUll ).lNOul', 01."..~,,:, " , , :/i/{(pJ./c-"" ;;~l!~_ ::'~'JahnD - v ~n_~ ~,~ :.N)f::);jd --~ ^- 0_______1___ -., . ~ 1 1 -4lllb.1 raU:>.~ J ~ 0" ~ , -,~~~--~"~ ~" <, , ,~ = . ,~' ~~'=,-~, , '" .. . I. Martha E. Von Rosenstiel, P.C. Charlotte K. Hummel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 63657 Attorney for plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Defendant COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01-1303 civil Term CERTIFICATION OF SERVICE CHARLOTTE K. HUMMEL, Esquire, hereby certifies that she is the attorney for the plaintiff here, and that service of the Civil Action in Mortgage Foreclosure in the above matter on the defendants pursuant to Pa R.C.P. Section 403 and Pa. R.C.P. Section 404 by certified mail April 21, 2001. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: April 25, 2001 ~~)~~ C arlotteK. Hummel Attorney for Plaintiff yy u .' " , . Complete items 1, 2. and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can retum the card to you. . Attach this card to'the back of the mailpiece, or on the frcn~ if space permits. 1. Article Addressed to: SUZANNE M. THOMAS AKA SUZANNE THOMAS PO BOX 22411 NEWPORT NEWS, VA. 23609 T , >, j , .. \ o Agent k o Addressee \ DYes i DNa j 1 { ( 3. ~rvica Type ;c-.l Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise- D Insured Mail 0 C.O.D. ieted Delivery? (Extra Fee) Yes 2. MIele Number (Copy from service label) 7(Jqq ,-=<,tfl1O OCOr 02\'13 <:) "tf,J)(() PS Form 3811, Jufy 1999 Domestic Return Receipt 7J :2 08- C Ktt- 102595.oo.M.0952 :~~~#;>.'H'(':;"'''b,,,,"~h,,,,"f~~'''-;;;rJ-'&t~L''~''''',lil:!'=''';I'fk-i':''''i''~''l::'ilf,Mj"",<WiiM~~~itM~~~-~ -~--~"'~ ,=""",,,,,,---~ "_<""~,'" ~,~~'c, ~_..~_ ..=c.n,_ _~~"_",.<"__",',",,O"''''"'''' .L. -?.,-~,'~ _~ ,~" ~ ~ l~lIlitt'i' .~ C') S;; _:S: ";':CO 9[l'.'~ :i:e 01 '.' fJiS ~o :sO c:: ~ w c.;, ... ~ , o C' _/ "q h ::0 -;v r", "-J :--::1 ',- ,; i- '_, tn .~~j ~~; '::') -ri >0 r::5n; ~ :0 -< CJ -'" -. I'v " ~~ lli ;<;'~~ ~' ~~. . ",-Itt!r.~w~, Martha E. Von Rosenstiel, P.c. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, P A 17011 Defendants No: 01-1303 Civil Term PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $116,921 ,44 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: 500 Enterprise Road Horsham, P A 19044-0963 Defendants: P.O. Box 22411 Newport News, VA 23609 /! / . /. 'i!i~~~~d.i1ill;i,,,..,,,jL;di;h-,,,'-'!fi,-,,;:r~,'W,~iii:;:--,,lnii:'il=tM;W"'<olil;!;';I'i..;]'db;;;;,rt."'f~'I*""l'.;,",.i_'~,;;,,!;jili~<r"".fu.,"o.i,,@...~'''''' ~"," .~ l , ",'<',,_,~' w,',,, ,,~~'" ,<.,."",",~" "__~H .~::" - 1d~~~;ll~~~"""'" I-l-~ 'I 0 0 0 C "'1'1 ~ ~ -0 OJ C t11fj" Z :0 Z:T' ,- zr i~~ (j) )> c...) -<2: ;<CJ " )> .-, :J::: ,~~,-.{ z" ~' C) ~(-, r:y (jrn Pc z w g =< CO -< J , .~ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, P A 17011 Defendants No: 01-1303 Civil Term ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 03/09/01 to 06/13/01 at $19.30 per diem Additional late charges from 03/15/01 to 05/15/01 at $34.51 per month Additional escrow deposit 04/10/01 to 06/01/01 at $210.45 per month Additional monthly inspections from 04/01/01 to 06/01/01 at $15.00 per month $114,288.76 $ 1,852.80 $ 103.53 $ 631.35 $ 45.00 Totalassesslllent M . on Rosenstiel Attorney for Plaintiff ------ AND NOW, to wit, this I?J day of J ~ ,2001, damages are assessed as above. (l4A~ P r~ _..~ Pro Prothy . . 't . , "~r"'l!I:iWlimw','! -~~~ ~ n '0 , ~o:;~, ' '''''"ffiL6MM~j,,---- Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney I.D.# 52634 Attomey for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, PA 17011 Defendant No: 01-1303 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, being duly sworn according to law deposes and says that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; That Suzanne M. Thomas aka Suzanne Thomas is over 21 years of age and mailing address is P.O. Box 22411, Newport News, VA 23609. Sworn to and Subscribed Before me this June 11, 2001. /~t4/~ / Notary Public lOOl 'Ol _~r s9J!dx3 UO!SS!WW03 ^l^l A\un039JeMel90 '.OJOa 9uMopsuel O!lQnd AJ8ION 'llnl:H 30G lV3S lVll:Ilf lON ,. 'V'i ., ~~ J___,~ .____ ~'~jI): . . Martha E. Von Rosenstiel, P.c. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 No: 01-1303 Civil Term r'( Defendants CERTIFICATION OF SERVICE MARTHA E. YON ROSENSTlEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on May 15,2001, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.8. Section 4904 relating to unsworn falsification to authorities. arth n osenstiel, Esquire i Attorney for Plaintiff DATED: June 12,2001 / !'W< J_, " Martha E. Von Rosenstiel, P.C. Charlotte K. Hummel, Esq. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff vs. Suzanne M. Thpmas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Defendant - Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY , Case No: 01-1303 Civil Term TO: Suzanne M. Thomas aka Suzanne Thomas 217 S. Sixteenth Street Camp Hill, PA. 17011-553 Date of Notice: May 15, 2001 , IMPORTANT NOTICE ,.~~, () If'l../ 0'-- SIc YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT 1iJ'A'1i!l)1i! vnn _ t"!1lN' r.:.1i!"I" T .1i!t:a.L., RRL'P_u. u.s. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: MARTHA E. VON ROSENSTlEl, P.C. I Ii 5. LAN5Elfl'vVN[ AVf.. P. O. BOX 457 lANSDOWNE, PA 190501. I . ~ . One piece of ordinary mall addressed to: \ \" ~.~t:~/ SUZANNE M. THOMAS AKA SUZANN~-T .....""-~~ 217 SOUTH SIXTEENTH STREET CAMP HILL, PA. 17011 PS Form 3817. Mar. 1989 ;;W~ .. ,..\ t ! .... \ r ,,,\.{ < ~~.>- .' ~p~~"_! 1.",1 t II . I'.'~':l S. lol." '-oJ ~ i ! J VI lti;j fll I .! . It It....... 'It........ .. :SOCIATION /Ji,({ - , ~'~t~" ,,,,"~, I~_ c.d _ _ 1 " ,~..~- .-1 . . . Martha E. Von Rosenstiel, P.C. Charlotte K. Hummel" Esq. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney 1.0.# 52634 GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Defendant - , ~"~"~t~'B"~ _'M& 6~U~ sf Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01-1303 Civil Term TO: Suzanne M. Thomas aka Suzanne Thomas P.O. Box 22411 Newport News, VA 23609 Date of Notice: May 15, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT - - -- -- --. -...""....... .....'" ...nT.T.nwING OFFICE TO FIND OUT u.s. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND'INTERNATlONAL MAIL DOES NOT PROVIDE FOR ' , Received From: 1 16 S. LANSDOWNE AVE. P. O. BOX 457 LANtiUUWNt:, I'A 19U:l0 ,,\:.;.\ .... ~ ;..... '= , ~ ~ ~-- ..'~, ;,,' -,'........ ,~,~, I,' ,-- < 16 One piece of ordinary mail addressed to: SUZANNE M. THOMAS AKA PO BOX 22411 , NEWPOrtT NEWS, VA. 23609 PS Form 3817, Mar. 1989 ;:{:.20~ :OCIATION rn ~ Cl m , ^" f i. ; 'eo. \ ~ ,"...... (.,Cj ....., . 1 8'll.J1f.~-,.j --'i~'"'' III . I,~~ . I ~ Ii!. '-J I'" Ul [1:...11. I. HI t!d h ~ ..... fl................ " iil~~I<C.~'~--' -'<~~.",."..." -~.~ '~~ i&%,"'iii;~ihl~I~!i~3."i,;,:""<,~;;,~,'''k~;!Ab.~;';''''"''-'-''-'_"j;;'f''''''''!i,,,'!~"';"'i~';""E'!"",:i1'!;Pl'''''~;'''':'''''~'',Mii''.i$i;~~~''''illllalb'l:hU:UWIlf ~ '~>=<i'i&mJll i ~lL---~OCrlJJJl dHlr U ~ ,~, ~~. !\~ ~ -- :.:i.:~... 'j i l, . '\ i i (" A l!'~ i~ Ir- i Ii ) I~' j~ :t. ~ ..../ "\,. { ,.,~ ,~ _~ ,~,~_,_.,_ """",..'.. "_^' "0 ~,,' "--, ,~,'~ , '. ~ @~ iJv -. .l) ~ ........ t:;J 0J ~ t' ~ : ~ ,', ,,~ - ~ \ '" ......... '-^'(j.. ~ r!: Ch' ~ J r o C '0>- -otJs rnr7"l Z::D zc- SJ~r: GC7 ~ )>0 Z;o ';PC z :;! c::> ~ r . .' o -n L- c:: ~'.: .,....! GO , -n illp :~JQ :.3~~), :~~~ ';:;:; :!Q :< -0 ::~~: ~ :..'> (P PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND GMAC Mortgage Corporation v. Suzanne M. Thomas aka Suzanne Thomas . 'ii;-' NO. 01-1303 Civil Term Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 06/13/01 to SALE DATE At $19.30 per diem (Costs to be added) Martha E. Von Rosenstiel Attorney for Plaintiff $116,921.44 $ $ Y~~_~d.~i'D"1'~i',;)~~,*-'bl"ii"i~'f'8!;l!,-1i~""l1~:'biJ,j'f{fb-O'L"".'4'j.-_':-l.,!;f ,~:tt.'''''_:l....,~'''''-81:'_'''!'l.B1i<f&iij\.U~lWlilffiil<lliliill!l!UlliiliS.iOililll~ mli'lr'.I!l!il<l~!!i~lI. k'j'_ ,,_" ,,0__ ~ ,,=w.~,~,. _",.' ,...."'-"""'_"...-,.",,'q_,_~. _",,,., _ ~__". ''''',," .'"_, _, ",<, ___~ ,. ., I ~>, ,~, ~ > ", ~Jllll~'Il1t,. '''~--- . > IJi:i!I:' ~~...~ ""'-=t'; . 0 0 0 C -n -~ '- ;:". -0 OJ c::: -n mrT, Z r:;::; Z:::C' ,')-rn ZC;::: W :--"-::19 ~~-~ <() !<: C} :;2 ~:8 ;t>~ ZU _.'-.b .c""O ~-o ry orn ~c ~ z 0) ::<l <.0 ~ t;R l!lf''''''''~" '-~'. ~",J " ., ,. "11'~- "-~':;-, DESCRIPTION ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point two hundred forty (240) feet South of the Southeast corner of Second and Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one hundred fifty (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the West side of said alley forty (40) feet to a point; thence Westwardly along the Northern line of Lot No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East side of said Sixteenth Street forty (40) feet to a place of beginning. It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free, recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20. Tax Parcel #01-22-0826-062 " ,- ~I ~ ~ J "' ~-~ ~, ,~ >. - --"..,i;\'l!1L .. WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) PRC.P. 3180 to 3183 and Rule 3257 GMAC Mortgage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 01-1303 No. Term, 20___ E.D. Term, 20-_ _ A.D. Suzanne M. Thomas, aka Susanne Thomas WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYL VANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 217 S. Sixteenth Street Camp Hill, PA 17011 Amount Due $116,288.76 Interest from 06/14/01 to SALE DATE@$19.30perdiem Attorney's fees Total $ $ $ $ Costs as endorsed. Daten Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy '-i~>li>i~!,i,;.f.,r,r:'-",hol\;~i'r," ~,Ib..-,_, .,,:.eh'h~'_^,,',<j'-;;:J'..:d.,; ':';;:;"~_f,'~A",_,,,~,j,,,,, ~~.,,__"',-, ",'~'-'r<_,j,.:;;b";""Y;i';'k'&'''l:i;li;Y",,''~b:@!liiI..i1iI~~~~~m'''~!I'R~~~~.1:liiiliJl[[~' ~'t'r'i-G. o "" <') 0 <') - , - 0 0 ci :z z q d ~ ~ :If D- o "" ~ 0..,; "'- ..,;~ ~> .-:1'-" ~;>-o C/) 5~ ;;Sr:e ;;S ;>-0- Of- uS ~O OU f-< ~ o o u ~ ~ ~ i:: o .~ t;l .... o e- O u <l) bIJ c:<l bIJ t:: o ~ U ~ d - " ;> tfl" ~ c:<l S S 0 0..>:: E5~ <l) ~ g <l) CIl ga N c:<l ;:l~ ell <:o::l z""' 00) _ il f-< '" ::;J..'a u u ~ ~ :x: 0 ~~ 0) ~bl) o '" bl) f-<t:: - 0 ~::E ;s--- i)\--' t=~-' \ ~ ~ .,,~ ~ --- ~ ~ ''''-~' ,~..._.,,"~-~~ - ^.~",.^"'~ - en t;; o U "0 ~ o .... ~ 0) 0) ~ bb ""0 ~ ...; u ..; '" r/l ~ ~ ~ -\:::--?:--. G"' 0"1 ~ " '" 'i3 <::>('I \j '^ 0' n. 0- '" >il - .~ g tl~O :1 0) Of) w ;> 0 "'~O' ~O)...... i::~~~ OO~'" >~ d)"'~ ~ 5 ~ ~ '" .-:I 0 '" ~rn]S ,<:,,,,"co ~.,......;~'-' .~ .~ .~ ~ c .~ m ~ ~ ~ o ~ >, w c ~ o ~ ~ '" ~. .... <l) <l) tl ell ~ <l) <l) ~ .~ ell ell r-- ...... N '" ...... w ...... p o ~ r-- ~ ......, " <e:"' ~ ~ ^ 8 - ffi ~ '"' S'~ <:o::l ~ U1: " m m " ~ 'd 'd '" () <::> Ci c .." :::... 5- ';".1 ~ -OeD fil[T; Z [-7': ;J2 :Z:::I:,; zc "'1-'l1 Cf) L:" W -:-';\.,j -<~:-~ --: f~"':) r:c., ""0 ., ;i'"=o :-1,':': -':'::-'-1 2(5 I~;:;C) >c N Ejln 2 -1 :..J ;to> =<! :IJ .0 -< Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, PA 17011 Defendants No: 01-1303 Civil Term CERTIFICATION 1 hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a. result of a Complaint in Assumpsit ex) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: ( a) Service of the notice on defendants (b) Expiration of30 days since service ofthe Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. Dated: June 11,2001 I further agree to indemnify and hold harmless the Sheriff for any false statements give ~';l:l-,h Martha E. Von Rosenstiel, P .C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, P A 17011 Defendants No: 01-1303 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 217 South Sixteenth Street, Camp Hill, P A 17011. L Name and address of owners(s) or reputed owner(s) Suzanne M. Thomas aka Suzanne Thomas P.O. Box 22411 Newport News, VA 23609 2. Name and address of defendant(s) in the judgment: Suzanne M. Thomas aka Suzanne Thomas P.O. Box 22411 Newport News, VA 23609 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Westgate Garden Assoc. 1149 Columbus Ave. Lemoyrte, P A 17043 "~ -LTI~~~,"", 4. Name and address of the last recorded holder of every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 Inheritance Tax Bureau Harrisburg, PA 17105 U.S. Inheritance Tax Bureau Washington, DC 20530 f Commonwealth Dept. of Revenue Inheritance Tax Division 1400 Spring Garden Street Philadelphia, PA 19130 Internal Revenue Service Federal Estate Tax, Chief Examiner's Div. Grp. 18120 P.O. Box 2040 Philadelphia, PA 19105 Register of Wills of Cumberland One Courthouse Square Carlisle, P A 17013 ~~~ . o'~"" -' ., "', - ~~~~ '~~t*i\@1_~_ I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ ,-I ... ~ ^, "-- '~ " --- < '1f,~; MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSbOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660 FAX(6l0)623-2745 June 11,2001 TO: Westgate Garden Assoc. 1149 Columbus Ave. Lemoyne,PA 17043 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 20111 Court Term and Number: Court of Common Pleas of Cumberland County, Dockeffl 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / ~;"-- MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(6 1 0)623-2745 June 11, 2001 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners ofthe aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ,. ~.^,~}:,: MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61 0)623-2660 FAX(61O)623-2745 June 11,2001 TO: Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A i 7011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ~ " "' ~_, - ~,~ I . " I, <. ~. _ 1 ~~,--; MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660 FAX(6l0)623-2745 June 11,2001 TO: Inheritance Tax Bureau Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ~,,-- MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660 FAX(6l0)623-2745 June 11,2001 TO: U.s. Inheritance Tax Bureau Washington, DC 20530 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. . This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the fIrst mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date ofthe filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, i ~ // ,/ Martha OR R-cS\,.tl1i:tL~d // ,. . ~ -,-- -l . ~-^" ........"l'I~$" MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660 FAX(6l0)623-2745 June] 1,2001 TO: Commonwealth Dept. of Revenue Inheritance Tax Division 1400 Spring Garden Street Philadelphia, PA 19130 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ~ - M ~ _ ~ ~~ _ l "~^ .~ L!L:MiiI!~j,'~iliii6j~," MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX( 610)623-2745 June 11,2001 TO: Internal Revenue Service Federal Estate Tax, Chief Examiner's Div. Grp. 18120 P.O. Box 2040 Philadelphia, PA 19105 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, PA 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Dockeffl 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage; which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, I . - .. -~" . , . ~ .l=",__ iliJ'- '-~e MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(61O)623-2745 June 11,2001 TO: Register of Wills of Cumberland One Courthouse Square Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the fIrst mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, "-"'. ~" I""""'.......,..'J-= ~ .. _ L ,"-."" . .........~ - JiI.r-_'lll ,',.,,;;, - .. Martha E. Von Rosenstiel, P. C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill,PA 17011 Defendant No: 01-1303 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Your house and/or real estate at 217 South Sixteenth Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on September 5,2001 at 10:00 a.m. to enforce the court judgment of $116,921.44 obtained by GMAC Mortgage Corporation against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT TIDS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to GMAC Mortgage Corporation the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "iij~ L___~,". , ~ '~^""""-~'""''-'';'~- y You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value ofthe property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717240-6200 ~""'"' l' T 1110 " ...... -.~"I. ~~ . _-1-,. .lItrl~A--:~ y CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (I) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 "' ~. . "' .J . Il:ill!l!ii> . WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) p.R.e.p. 3180 to 3183 and Rule 3257 GMAC Mortgage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA vs. No. 01-1303 No. Term, 20_ _ _ E.D. Term, 20-_ _ AD. Suzanne M. Thomas, aka Susanne Thomas WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 217 S. Sixteenth Street Camp Hill, PA 17011 Amount Due $116,288.76 Interest from 06/14/01 to SALE DATE@$19.30perdiem Attorney's fees Total $ $ $ $ Costs as endorsed. Dater! Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy 6"'Tiwi&~'ji-lliI:ili!lli1Mili"i~!i2' ;1'>'-- "'JW<;";,',"-"L.o"ii:iil~~,l.t;c.i"d;;"""'''''-''',i;'''b,,''. 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DESCRIPTION ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point two hundred forty (240) feet South of the. Southeast corner of Second and Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one hundred fifty (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the West side of said alley forty (40) feet to a point; thence Westwardly along the Northern line of Lot No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East side of said Sixteenth Street forty (40) feet to a place of beginning. It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free, recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20. Tax Parcel #01-22-0826-062 :. I ~""bdl!t.tr<1'M~'~-"_h.,c<'" """"-"",-,~,;/-!:"~i,,"",~N~~,<'Bi,",jM,';,'':;~'~;'',/'_,,~;e--.;'o''1""~~;,;;,"""'''",,.~j-''~'A--''\li')'-B.r-;;;,~g~''Hid'l1:iial!ili~"M~~~IlI~'' -'"<i':lf.!1~~ , 0 0 0 C -n s:: '- .-1 -C(J:) S -1_ mp\ "":- ':~~~ ..,.~' ~.;-' Z~. w (j)" i_--'S(1-. -'<> .J s;:.C) --v t~ t,~ "];::C" :1~, ~g r:Y z ~) ~ ~ ,0 =< ~ ~ HL j~U11!iIl![ Hf!(!!!~~_~~~ ~JL.., ~,_c" '<~~ _ __M,~__~~ = 0, '" .1, .1. ,~"""_......"".~" " - M'-. JS.i:hU;~i;t';::,,_ \ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham PA 19044-0963 COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. No: 01-1303 Civil Term Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Defendants PRAECIPE TO SUBSTITUTE ATTORNEY TO THE PROTHONOTARY: Kindly withdraw my appearance as attorney for the plaintiff in the above captioned action. ~fJ(~ Charlotte K. Hunnnel, Esq. TO THE PROTHONOTARY: Kindly enter my appearance as attorney for Martha E. Von Rosenstiel Dated: June 11,2001 '-:;W!ih~J,),j,""1i!l,jdJ.io:"..L ,;-j,0~~~_,~_~";y;J!,->-!ili.\t&\\W'-">i:,,,,,,'_"di.,,,,!;'!C,")1~~,,:rA"",~ii>!~\E~~__~~- "'i -.'lll!i:--j P"llNj~ ,~'", ;;L~,~~._- ,~IJl _ ~""_ s~'" "-'_"-'.',*~"_" ,0 ,_, ,~".,"''''''''''' !l'.""'f"Z",;""~_=_,,O.'.''''''''''''A'_~'~'_~.",,""',,' ~,,^,J ~ ~_ lti.~ 1llj'niJ\'r~ ~itilU1fJl~]'r1--q-~'~I~li lJ-1!iff t () C) 0 C -~ 1'1 ""Dee C- .-I t:prn c:: ~ "I' ~ ,. :"D zt- ::-r.:~~; W_L> w iS7 C (~~'1 (~) ;<' " )>() ,~~'1i 5;0 _.. C ~ 25~~ :?: '"" :::-i -< :'6 -< 0:> -< , ~"..~ - ,~- ~~~- ,-~ ~~ ~ . ~Il"~-l ~, 11 !Mf:;iO~ #8202 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, P A 17011 Defendants No: 01-1303 Civil Term AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYL VANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Westgate Garden Assoc. 1149 Columbus Ave. Lemoyne, PA 17043 2. Name and address of the last recorded holder of every mortgage of record: NONE 3. Name and address of every other person who has any record lien on the property: NONE 4. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: - "." -,' ,,"'~..-~~ "~rOt '~-!i~''''';''"',~^ Family Court/Domestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 Inheritance Tax Bureau Harrisburg, PA 17105 U.S. Inheritance Tax Bureau Washington, DC 20530 Commonwealth Dept. of Revenue Inheritance Tax Division 1400 Spring Garden Street Philadelphia, PA 19130 Internal Revenue Service Federal Estate Tax, Chief Examiner's Div. Grp. 18120 P.O. 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'2. if !:E a> . m' "'" .~ _J ~"'~3~~ ~ :0 cn.-_i3':i\ .(1) ,'\~.,o: ~~/$i ~,m./~~'1 ,;,,111:\ ~ I\!~ III h~ ""-(;1" Q" ~" ~i ;0 .. !!l ~ ." " " ;: II' " o (j) g m ......,. ._.."'......... >1-" '" .". h C-, . Complete items 1, 2, and 3. Also.,g'.....~letl! item 4 if Resttfcted Delivery is desired. r.i Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: D. Is d iv address different from item 11 If YES. enter delivery address below: SUZANNE M. THOMAS aka St'ZANNE THOMAS 651 SOUTH ANN STREET LANCASTER, PA. 17602 3. Service Type , ACerlified Mail 0, ~ [) 'Registered - - 0 Insured Mail [] Express Mail [] Return Receipt for Merchandise OC.O.O. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Copy from service label) 1 06>C \ U,iO' 006 G-- PS Form 3811.July 1999 , , ~ o :S~(); _Co'16~ D~m~~iC~R~t~r'nRecerPt'::' '1$20 ~5?10259.5'~~ tr I::l f'- -lI I::l -lI LJ1 I::l Postage S Certified Fee $2.10 ru I::l I::l I::l Retum Receipt Fee $1 <0 (Endol'$El'!lentRequJred) .oJ ResI.~9rl Delivery Fee $0.00 (EfldorsementRequired) ;:2 Total Postage & FeN -lI r-'I I::l I::l I::l f'- PS Form 3800. May 2000 See Reverse for Instructions ""-'!ll!li~':mm!~i.>1tKli~mli,;e4l;;t.:"';;;;;-lci-'hiLes:;;,H'~",,,'I"IJiiit'''''f'.*-,,'hl:r.-'-'.0,0-""",,,,,,,,_;,1'0.. "'f--'i<'l!''''j('''t".-,itl<;;*"",~MiiJii4~':''~'''';ill;ll!;,,<j:~' ~~ - _'",,,,,; ~!dJ1>>t1~j)iJ! ~IF! I __,~"",=,JJb""." lUl,:JiI.~, "",""_"',<~~," ,-~"~"'"D-~'~",'"W,,,,"',,"""~'''''''''''_.r4'_,',,'~'"' ~_,],~. __ ~.c , ~ = _ ,~. :It..>lMlIIii'~ ~ _,c,,,,,, """"~"''''"-,-,--~. -;"t, I 0 0 0 C -n :;;:: (/) .-; -0 CD rr1 ~iF lT1rT! -0 Z:[) ZC =";2P~ (fJd.-:::' w .-../ ~-.. ~?- 96 _CJ -0 .._\'1" "- . )> (-. :3l: '5-~'1 Z' ~o ~g qm ~ r=- ~ en -< ~ ~,;_~,~. _~~ ~~ .~J ;.;"'" I ~. . ........~~~~~dBi\'. GMAC Mortgage Corporation VS Suzanne M. Thomas a/k/a Suzanne Thomas In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1303 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Martha E. Von RosensteiL Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 20.00 15.00 .50 1.00 25.66 19.50 15.00 15.00 9.58 12.41 20.00 223.55 225.60 $632.80 paid by attorney Sworn and subscribed to before me ?J};?~Jt:~~ . R Thomas Kline, Sheriff '"--' n This ? day of AV"4W 4. ~ 200l,A.D.0r . () It.,p". J/~ Prothonotary BY~()~~ R al Est e Deputy p-U Ut 3'f'r!ifi 1lv.1/ 1 S'f ( ""'<t- - """,".oJ l~~ - - , -1/" ,;L " , , . ~ .. ~ ~ """""'">~~~"",",-"~'k"'<I'..' ~ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstie1 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610623-2660 Attorney l.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill, PA 17011 Defendants No: 01-1303 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYL V AN1A: SS COUNTY OF DELA WARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 217 South Sixteenth Street, Camp Hill, P A 17011. 1. Name and address of owners(s) or reputed owner(s) Suzanne M. Thomas aka Suzanne Thomas P.O. Box 22411 Newport News, VA 23609 2. Name and address of defendant(s) in the judgment: Suzanne M. Thomas aka Suzanne Thomas P.O. Box 22411 Newport News, VA 23609 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Westgate Garden Assoc. 1149 Columbus Ave. Lemoyne, P A 17043 ~..~ "~ . .J, ~"I,~_".,,,,,,,-,,~ -"\">\H->ro~ii<i<>'",,--; , . ~ 4. Name and address of the last recorded lio1der tif every mortgage of record: NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address .of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept of Public Welfare Box 2675 Harrisburg, PA 17105 Inheritance Tax Bureau Harrisburg, P A 17105 U.s. Inheritance Tax Bureau Washington, DC 20530 Commonwealth Dept of Revenue Inheritance Tax Division 1400 Spring Garden Street Philadelphia, PA 19130 Internal Revenue Service Federal Estate Tax, Chief Examiner's Div. Grp. 18120 P.O. Box 2040 Philadelphia, PA 19105 Register of Wills of Cumberland One Courthouse Square Carlisle, P A 17013 ~ . I _ I _ ~ "-, L '~~~'~~",i""',\~*,'-'" I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. c.s. Section 4904 relating to unsworn falsification to authorities. , ~O' C " - ~~ , '~'I-iIlll1\j!ll.,"d~~;.;:"-";.j",,,,,c MARTHA E. VdN iWSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660. FAX(6l0)623-2745 June 11,2001 TO: Westgate Garden Assoc. 1149 Columbus Ave. Lemoyne, P A 17043 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. . This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / "'~~-J.. ~ ~...'. ~. . .,~ ~ .--- ,~ -L~ ""'o~~ . ~ ~1<lm;;;M_f.>l~~"'"",,,,.h'" : MARTHA K VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, P A 19050 PHONE( 610)623-2660 FAX(6l0)623-2745 June 11,2001 TO: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ~1 _.~. I .J' .-J 1'I<"""~..'"ill':,, ; MARTHA E. VON ROSENSTIEL, P.c. ATTORi"fEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDO\VNE, P A 19050 PHONE(6l0)623-2660 FAX(61 0)623-2745 June 11,2001 TO: Dept of Public Welfare Box 2675 Harrisburg, P A 171 05 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Dockeffl 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, PA ] 701] will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. . This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 7] 7 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, e ll';\it;''''' .l_J -1- __, ~ ." ~ ~_L. ,-- ~~~',,";'_'''hl~-''',_' ; MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6l0)623-2660 FAX(610)623-2745 June 11,2001 TO: Inheritance Tax Bureau Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, PA 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 170 II will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a .lien on the property secondary to the first mortgage, which is being foreclosed: This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / ~ _. L I. " ~ .', ~...h"''''F,,,",,1 MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDO\VNE, PA 19050 PHONE(6l0)623-2660 FAX(61O)623-2745 June 11,2001 TO: U.S. Inheritance Tax Bureau Washington, DC 20530 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, M.ihi~ ""=0<//--- /. I -. " ,- .J~' ~ - ~, ~...i,~ ~~~~~~." '''2l',,,,,,,,:,,,,~,,,,_, ; MARTHA E;. VON ROSENSTIEL, P.c. ATtORNEY At LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6 1 0)623-2660 FAX(6l 0)623-2745 June n, 2001 TO: Commonwealth Dept of Revenue Inheritance Tax Division 1400 Spring Garden Street Philadelphia, PA 19130 RE: NOTICE OF SALE OF REAL lIROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,92~.44 Date of Judgment: June 13\ 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 0~-1303 Civil Term Plaintiff: GMAC Mortgage COJ1poration Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, P A 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and, reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, . / artha~ "" ReseRotie{ ,-'=. '~''"'= ~,. -, , __ I ~ '"~ 't<J.~....~ ..~r"",''''.::."':,_,'''~. . MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDO\VNE, PA 19050 PHONE( 610)623-2660 FAX(6l 0)623-2745 June 11,2001 TO: Internal Revenue Service Federal Estate Tax, Chief Examiner's Div. Grp. 18120 P.O. Box 2040 Philadelphia, PA 19105 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on September 5,2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, __ 1 _" J ~ " ~"""~~"," ,""..!""..<>"~," Ii MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, P A 19050 PHONE(6l0)623-2660 FAX(6l0)623-2745 June 11,2001 TO: Register of Wills of Cumberland One Courthouse Square Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 217 South Sixteenth Street Camp Hill, P A 17011 Amount of Judgment: $116,921.44 Date of Judgment: June 13,2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-1303 Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Suzanne M. Thomas aka Suzanne Thomas Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 217 South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners ofthe aforementioned property are Suzanne M. Thomas aka Suzanne Thomas. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. . You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, .",,~.- , __"",;>1,#, >. ',,: Martha E. Van Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney l.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Harsham, PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Suzanne M. Thomas aka Suzanne Thomas 217 South Sixteenth Street Camp Hill,P A 17011 Defendant No: 01-1303 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Suzanne M. Thomas aka Suzanne Thomas 97 Richneck Road Newport News, VA 23608 Your house andlorreal estate at 217 South Sixteenth Street, Camp Hill, P A 17011 is scheduled to be sold at Sheriff's Sale on September 5, 2001 at 10:00 a.m. to enforce the court judgment of$116,921.44 obtained by GMAC Mortgage Corporation against you. NOTICE OF OWNERS RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to GMAC Mortgage Corporation the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. - ; I __d_ --I ,,- - -Le ~-"~I>!~' You may contact an attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717240-6200 '''';~~'''' .. J~~ '~~ - '-r";;_~"",,,,=,,,_ CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 717 240-6391 ~ .. ..l '. , "--'_"'n--~.' WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.c.P. 3180 to 3183 and Rule 3257 GMAC Mortgage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. No. Ol-1303 Term, 20 _ _ _ E.D. Term,20- _ AD. No. Suzanne M. Thomas, aka Susanne Thomas WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 217 S. Sixteenth Street Camp Hill, P A 17011 Amount Due $ 116,288.76 Interest from 06/14/01 to SALE DATE @ $19.30 per diem Attorney's fees Total $ $ $ $ Costs as endorsed. Datrrl Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy .~" , . - " """".~"'"- . . DESCRIPTION ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point two hundred forty (240) feet South of the Southeast corner of Second and Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one hundred fifty (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the West side of said alley forty (40) feet to a point; thence Westwardly along the Northern line of Lot No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East side of said Sixteenth Street forty (40) feet to a place of beginning. It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free, recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20. Tax Parcel #01-22-0826-062 """""" '"~ . ~ _ -l_ " -, - ,-I , - , ""~'ii""'" ,. -';".,' . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 01-1303 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: GMAC Mortgage Corporation To satisfy the debt, interest and costs due PLAINTIFF(S) from Suzanne M. Thomas aka Suzanne Thomas, 217 South 16th St., Camp Hill PA 17011. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at 217 South 16th St., Camp HIll PA 17011. (See attached legal description.) (2) You are also directed to attach the property ophe defendant(s) not levied upon in the possession of :\ii.' Ii I, I: Ii Ii I: " ii I' " 11 Ii " I: GARNISHEE(S) as follows: and to not~y the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to not~y him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $116 , 921. 44 6/13/01 - 9/5/01 @ $19.30/diem Interest L.L. $.50 Due Prothy $1.00 Atty's Comm Atty Paid Plaintiff Paid % Other Costs $108.68 Date: ,),,,,,,,,1 13, 2001 eurtis R. Long ~.rJh:Z; Deputy REOUESTING PARTY: Martha E. Von Rosenstiel, Esq. 16 S. Lansdowne Avenue Name Address: Lansdowne PA 19050 Attorney for: Telephone: (610) Supreme Court ID No. Plaintiff 623-2660 52634 ,'-';J,",',,', '~"~.mIlil\iiilii~~~iliO!i~li&Ml'WA_'it'''-'E'''''""~lj"][,!,,,,'''''ji,*''l0;;,..jM;:dUr~",c,M,d.~,i;~'~';"'--~"'.I,>.."'=" '"'.............,-'<._...~''' ._" - -, - . ' - ' """""'__....."., .......""""'~1<lliri !llIlIlil!~Gili!r~--- '-~--,' . REAL ESTATE SALE No. 5'1 CntJU VVL I q I ')..00 I the sheriff levied upon the oe.renoarn, interest in the real property situated in (jor{j1~ tJ f ~ €tV- Cumberland County, Pa., known 'ind numbered as: /J.{7 S. /& 1h Sf. ~ {ioJ1t(' +f,flJ and more tUli~ described on Exhibit "Ail filed with this writ and by this reference incorporated herein. Oa1es..:JUru.. 19 f JODI By: 9~ S~ D4JuftrShJAi6D ._, ('\\~nd 'Q \ H'\! If>., .\.r ~!:,-/r" , -<'" ~ - . \ U. \\~ \)~ t \'\ ::\' , ) ,'~t\I\ Hl\i'C" ~\;~j\)>3;)\HO H\\\~\lS c ' ",~~~"-"'"~ ..~~" -~ "-~ ~.-_.~"~~.,--~-"- ,.~ '1jl (~.t CVlJ CVlJ c::::::3 G:e> CiVil ft "~I l .'. 'I, ._--'"._" 1','_ - "" . '~~ ' REAL ESTATE 8ALB NO. 57 Writ No. 2001-1303 Clv:ll GMAC Mortgage Corporation vs. Suzanne M. Thomas aka Suzanne Thomas Atty.: Martha E. Von Rosenstiel DESCRIPTION ALL 11fAT CERTAIN tract of land. situate in the Borough of Camp Hill. County of Cumberland. and Com- monwealth of Pennsylvania, more wrticularly bounded and described as follows. to Wit: BEGINNING at a point two hun- dred forty (240) feet South of the Southeast corner of Second and Six- teenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one hun- dred fifty (I50) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the West side of said alley forty (4OJ feet to a polnt; thence Westwardly along the North- ern line of Lot No. 63 one hundred fifIy (150) feet to a point in Slxteenth Street; thence Northwardly along the East side of said Sixteenth Street forty (40) feet to a place of begin- ning. It being Lot No. 62 on the Plan of Lots known as Greater Harris- burg. Estate of Jackson Free, re- corded in the Recorder's Office at Carlisle. Pennsylvania. in Plan Book 1. Page 20. Tax Parcel #01-22-0826-062. -'" 'b""_~~;.t ,_.C~ _~ ,. .:." ^ , ~,- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough <;>fCarlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the officiallegal 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 pnnted 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, VlZ: 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 M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 , NOt LOIS E,,' SNYDE~ NllIc CarII8Ie Bolo, CUll 'CoIrIlY- ,My ConIm'lIian ElcpIi8s MIn:h 5.2IIlI5 ... ;,;=<'--=-~_O~_'--_ -_ -- - ',-:--- ::-:-"~- - ~ _ ~-REA( ESTATE SALE NO. 57 ~., _ nWritNo.2001-1303 "'" ~*';;__ "tlvWTeini'- ~. -~ -, GriA~~ort'gage - 'r ~ration' . ~- '--~ -~""" - "~y{ _mas -mas~' a E. V'orlRosensteil 'DESCRIPTION ~~_..1' =-AU: T.HAt CERTAIN tract of h~nd, iituate - ,~:oili:tf.;tBorough' ,of Camp Hill, County of ~CU_m~dand, and Commonwealth of ~]5{:i1nsylv,mia. more' particularly bound~d ~l'iffu,,_ des~riblXl a'i follows. to wit: IiWlliNlNG ~t ,a pointtwo hundred fort)' ;:~-:m) feet South of th~ Southc-ast corner of ~_::..'tiOOIi'd and 'Sixteenth (form~r1y Jacl<.son) dS1Q..~:-thcncc Eastwardly along the Soulh ~~1inc bfLot No.-61. one hundred fifty ~r~O)feet to a point ,in 3.-twenty ('20) k...1 ~c_alky: -them:e 'Southwardly along the ~t' sj_o~ of said alley lOrty-HOl ft.":! to a ~~(: ihcn~e _.- We~twarOiy along the ~fiem line of Lot No. 63 one hundred ~(r50) -feet' to a point in Sixtct'nth ~~t; th,enCc_NonhwardI9 along the Ea~ ~.A-Q:f.-}Uld Sixteenth Street forty (40) feet :J~ R!ae~-olB~ghliling. - . - --nrne'ing Lor No. 62 on .the Plan of Lot~ .J;uQwn a't Greater Harrisburg. E5tatc of ~laCli_wn__Erl~._ reconkd in 1.he Recorder's o-ffi~_ _~t Carlhk, P(;llnsylvania, in Plan U'&ik \. Page 20. }~~ f reel #O1.22-0826-06'l. , . ^ ""' THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS .. Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} 55 James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of IbJ! Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid: that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 24th 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 vlrtue 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 Mis71aneous Book "M", V;I~:~I~::~~:' .....................................~........................... COpy . t is 21st of A SALE#S7 I, ~,~~~ ", Notarial Seal ~ Torry L. Russoll, Notary Horrlsburg, Dauphin County My Commission Explras Juno 6, T ARY PUBLIC Member, Pennsylvania Association 01 NoIaliWly commission expires June 6, 2002 t 2001 A.D. CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 224.10 1.50 225.60 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.................................................................... " " 'J,..", , , , ,1', ,~'~i?^__,"'lJ1X}'!'i'<t'i~~.......,,, ,.t ~ ~:!1ffll