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Home My WebLink About01-1422 FX ., "-', . ";';,jJ',' 0'_', ,'L'~"G."",,~< ,; "">'~i;; '-, "~'"S> ""'-'""~""".r';"'" 'V" ;', "" ~' . _' '~i! ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY BANK OF PENNSYLVANIA, CIVIL DIVISION NO. 6{- I'I).~ ~ Plaintiff, COMPLAINT IN MORTGAGE FORECLOSURE vs. LINDA L. EDEN, single Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 .. ,.'- '-". " '~, ,,";', ~,'L ,'. _ "", _. -- '., ,,\ .;;, ' __ , ~(, ;'; ,.-- , -~~...."""~,:;'. CQMPLAINT IN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 " - , ~ ,.-'''''' -, "O.~~ -,' .;;, "".--::~ ,,,~__..,, ;'>;' KlIm'~'l'} 7!.eo/./</.:zL ~ I~ COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: I. The Plaintiff is a corporation duly authorized to conduct business within the laws of the Commonwealth of Pennsylvania, having a principal place of business located at 4401 Market Street, Camp Hill, PA 17011. 2. The Defendant(s) is/are individuals with a last known mailing address of 21 Givler Avenue, Enola, PA 17025. The property address is 21 Givler Avenue, Enola, PA 17025 and is the subject of this action. 3. On the 6th day of November, 1998, in consideration ofa loan of Sixty-One Thousand, Seven Hundred Three and Noll 00 ($61,703.00) Dollars made by National City Bank of Pennsylvania, a P A corporation, to Defendant(s), the said Defendant(s) executed and delivered to National City Bank of Pemlsylvania, a P A corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s) and National City Bank of Pennsylvania, as mortgagee, which mortgage was recorded on the 9th day of November, 1998, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1496, page 179. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. 4. The premises secured by the mortgage are: (See Exhibit "An attached hereto.) .... ~ "~,, ' ,';A -'I' 0 ;',' '" ',,: ,;.,:,;'--~ '0 ,'- ,,-",,,, ~ ,__' -",. "''-~O:','-- ,",,' '0 ,': J"~~;, 5. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attorney's fees." 6. Since January 18, 2000, the mortgage has been in default by reason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to foreclose. The appropriate time period has elapsed since the Notice ofIntention to Foreclose has been served upon the mortgagor(s). 8. The amount due on said mortgage is itemized on the attached schedule. 9. Plaintiff does hereby release the personal representative, heir and/or devisee of the mortgagor(s) from liability for the debt secured by the mortgage. , , ~ - ^''''~'' .,- ",-,--, """".""""'""'~""_"'---,>_";',"~,,"""',,C"~~~''''~',*q'',,,, "',","" r "'':./'''i: WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 114 7( 6), Plaintiff demands judgment for the amount due of Seventy-Seven Thousand, Five Hundred Sixty-Three and 76/1 00 Dollars ($77,563.76) with interest and costs. Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. BYC~?~ Louis P. Vitti, Esquire Attorney for Plaintiff - ~o '" ~ ."'~ "w_~ -<<"--="'~""~'''ll,.'''.' ,,_'~" ._" ~~ Eden, Linda L. SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance 61,641.66 Interest 11.0000% from 12/18/99 through 03/31/2001 (Plus $18.5769 per day after 03/31/2001 ) 8,712.58 Late charges through 03/06/2001 o months @ 29.43 Accumulated beforehand (plUs $29.43 on the 17th day of each month after 0.00 794 61 794.61 03/06/2001 ) Attorney's fee 3,082.08 Escrow deficit 3,332.83 (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriff's sale) BALANCE DUE 77,563.76 - -" "I ~..l. .~ rJli~~,~\ll!",'; ....._-..;.~.,,,.:-'-"'-'"'-..:f~-~-..~-----".~,--,---,~ . ~r . -3\Li9SC r : ~ ; .'1:_'.' i.,I.:I) ;':L\,,';r: '1'.', '91 NO .Ii! Pt'l 3 IS TAX PAIleZL . ~1:11 n"1I!!ft I: ~ II I . XNlS ft. .31~ clay of ~t::"?"ba4'!~,_, in 'the 1"..1: ortc. ~hDuCland n1ne hUlLCll:e4 and ninety.sia '1"7). ,S..".... IIB'ZRD !lDU'S M. LLOrD, A widow, elf Inela, CUIiAe.rluc!! county, Penn.ylvanLa. ha~ein'~~4~ Q~.ncor, P.~y of ChB Pl~at part, "UD.. LlaCA L. IUIN. I sinCl. ~OlIIan, at' EnolA, CUllbal:lal\4 count.y. Pe""aylval'lia, h.....in..C''t..... I)r.,,1:oo, Part:y 0' "'. ';.0"'"4 Pa.&"~. ,II I. WITH%SI~X, ta..~ 1n con.id.~.t:lon of the ... of Ono and OO/,J,DO COllu.. ($.l.oal, Ln hand paid, th. nCloipt: vb_eot .a.. be~ acknowl~d9.4, the ..id Grantor do.. he~by 9~.n~ and (:QnVIl)' to 1:h:. sa.i.d. ~I."Ant.... "a.:- hd.t'W. succ...an, i!lft4 AIiS1gnc: AU. THAT CZR:A%N' p~.~ N" pa:rcel oj!' land. eJ.cuata In Eu't. Pe1'lftsl:loZ'o 'tOWSJ\lp. CWD.be.t'1and CDWrt.y, 'e:tJllylvan1o, l31Q"nd.d _n4 desc:r-.iJ:Mad ~ accord_nee with .. aUlNar and plan tMl'.ot. ot" March 2', ,ltU, preplred by ROy M. I. aen]D1n, Re11atar.4 En9ift..~, .. !ollowa, BEGINHIHC! at . point on the h..1:&m line of Giv18;O Av.nve, ..1d pa1n~ a.i.nq 91 'au .1n . $c'Utharly d1rBct.t.on t~ 'WCANS.lm COZ'ftIlZ' ot 'the i.n~.r:a.c:r;J.oZl of GiVler A,vanua' and. ChUZ'Cb. Street, 8a14 po~n. ~c1n. an tne d1vi~1nq line between LOea MOt., 13 and l2 on th. here!nat'ter nen~lon.d plan oi 14"0; tbeno. alonq Mid d1v1d.1ng U.n. Horth l' dOfiree. !a.~ 190 I:..t: to . paint iCtI\ the "..'tem line Qt an 411.y; thence alonq tbe we.tarn line at ..1d alley SouT.h 1~ d.,r... Ba.e 81 t..1: 'to . po1ncr ~hen~a South " 4eqreea W.oC 15a f..t ca . point on ~hll Ba8'ta~ 11ft. ~~ C1vlct ~v.nu., ~h."c. o.lor'lq- tho Ea.tun lina ot Glvlar AV8nqe Koren 11 deq~ees Y~at. !S hat. t= ;a 5=Qinc ,t:Q ,h.=: :t aEOIl<NZNO. t.O:l 167 "".11:15 EXHIBIT 'A' Bood496 PAGE .181 --> '",>,'.,-" "',"',,"" < --,~,' --- 'fO""", ",~' ,""' ~',' " ~, mt~j VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. L-~W Louis P. Vitti Dated: March 6, 2001 tlJM~~~~~~n iii.J1~"''-~;;;'''9i:~~-~lJii\:Ml'> "u- . ~ ""',, ,~ ~~" -'~, ~:0 ..>u ~ ~ t:0 " , ,~ (') ,",'J () -~ c- ."\ ~ ~'-. ~ N ~l s:: -.::,t: -~ -up:::. "':.. :Q \:) "" ~, IT! r ~ ~ ;;';;.:J ~. 2:1.' ~:)t? .. , C>(1 c:::: 7; ~ "-'" ~ ~~~ N '.::~9 ~ '-->J r:"'-'1 -0 ,- fl <:-- __-"}""'1'1 -......j ?O :Jt Or (''') b'Ci Zen ~' ~ C:J 0' PC: ~ ~~ z G ~ ~ C..> '< , \ u.. ~ f-~ ~^ _>,~"""',,e,,p,o, ^ ..,~- ,~ '. ~ b,~~ ,~.. :"~....,;,~ ,,'., _ ~ ,',' ",I ~"''"'''(4ilt~'" SHERIFF'S RETURN - REGULAR CASE NO: 2001-01422 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY BANK OF PA VS EDEN LINDA L JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon EDEN LINDA L the DEFENDANT , at 0014:37 HOURS, on the 28th day of March 2001 at 21 GIVLER AVE ENOLA, PA 17025 by handing to LINDA EDEN a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: ~fiI??4~~ R. Thomas Kline 03/29/2001 LOUIS P. VITTI, ESQ. Sworn and Subscribed to before By: ~ ~~;;S) /" ,..oeput eriff ,,,'" , {/. me this IL /1- day of Cf,.-p kv I A.D. ~. 0 ~J~ r thonotary ," , !,O,,' [I _~ '_', _ ,- f " ,"""o,<,i,. -' ~,,_ _~hJ". -;.. '.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NATIONAL CITY BANK OF PENNSYL VANIA, CIVIL DIVISION NO. 01-1422 CIVIL Plaintiff, PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- MILITARY SERVICE vs. LINDA L. EDEN, single, Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.c. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 ~.. '; , 0,.' _" . " " ,'" _,..;: ~' ". __', .'~--- 1, ,-'" ^,---' -.,".-," -"00;;;" "'r." ,- j~~"i'~ <..i ':;;';''':''''''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO: PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of $89,638.74, in favor of the National City Bank of Pennsylvania, Plaintiff in the above-captioned action, against the Defendants, Linda L. Eden and assess Plaintiffs damages as follows andior as calculated in the Complaint: Unpaid Principal Balance Interest from 12/18/99-01/10/03 (Plus $18.5769 per day after 01/10/03) $61,641.66 20,787.56 Late charges (Plus $29.43 per month from 03/06/01-06/11/03 $794.61) 794.61 Attorney's fee 3,082.08 Escrow Deficit (Plus any additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) 3.332.83 Total Amount Due $89.638.7~ The real estate, which is the subject matter of the Complaint, is situate in East Pennsboro Twp, Cumberland Cty & Cmwlth ofPA. HET a dwg k/a 21 Givler Avenue, Enola, PA 17025. Parcel No. 09-13-1000-036. Louis P. Vitti, Esquire Attorney for the Plaintiff ~ ,~' ,'.- ". .'--.,>1 ._ ". "~ ~':iI~!t~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA 1. EDEN, single, Defendant. CERTIFICATION OF MAILING I, Louis P. Vitti, do hereby certifY that a Notice ofIntention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on December 30, 2002, giving ten (10) day notice that judgment would be entered should no action be taken. LOUIS P. VITTI & ASSOCIATES, P.e. BY: ~@d6t Attorney for Plaintiff SWORN to and subscribed before me this 10th day of January, 2003. NOTARIAL SEAL LOIS A. E1/ANGEUSTA, NOTARY PUBUC . CI1Y OF PI1T$BURGH, H.LEGHEIIY COUNlY "",COMMISSION EllPIRES OC1lJBER 17, 2005 . , ,_ k ~, ' ~" -",,'< ~ "'"""",,,--<4IIffi","'': IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA 1. EDEN, single, Defendant. IMPORTANT NOTICE TO: Linda 1. Eden 21 Givler Avenue Enola, P A 17025 Date of Notice: December 30,2002 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSON ALL Y 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 (1 0) DAYS FROM THE DATE OF THIS NOTICE, A mDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 LOUIS.If.JTTI & /,~""~""" / ' BY: / Lbui.. . itti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, P A 15219 ~~. ** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** ,;:, ~ ~ , I. -.",1"",,..,_,,,,,, AFFIDAVIT OF NON-MILITARY STATUS TO THE BEST OF MY KNOWLEDGE AND BELIEF, Linda L Eden IS NOT NOW, NOR HAS BEEN IN THE LAST 90 DAYS, A PERSON IN THE MILITARY SERVICE OF THE UNITED STATES AS THAT TERM IS DEFINED IN THE SOLDIERS AND SAILORS CIVIL RELIEF ACT OF 1940. ALSO, TO THE BEST OF MY KNOWLEDGE AND BELIEF, THE AFORE SAID PERSON(S) OWN(S) THE REAL ESTATE AT: 21 Givler Ave Enola, PA 17025 MORTGAGE LOAN 8000008725 HELD OR SERVICED BY NATIONAL CITY HOME LOAN SERVICES. STATE OF PENNSYLVANIA, CITY/COUNTY OF ALLEGHENY I, , A NOTARY PUBLIC IN AND FOR THE JURISDICTION AFORESAID DO HEREBY CERTIFY THAT Taryn L. McCreary OF THE FORECLOSURE DEPARTMENT OF NATIONAL CITY HOME LOAN SERVICES, WHOSE NAME AS SUCH SIGNED TO THE FOREGOING INSTRUMENT HAS ACKNOWLEDGED THE SAME BEFORE ME. GIVEN UNDER MY HAND THIS DAY, January 07, 2003. /&y {O~~ MY COMMISSION EXPIRES: Notarial Seal Gail A. Walter. NotaIy Public Clly Of PittsbUrgh, Allegheny County My Commission ExpIres Apr. 2. 2006 Member. Pennsyty"-lnfa Association OfNolaries FC130/TM1 1$ :lo~~,t""ifflk"!""':iIc~""~,*,1<~_~'~'do2l""4<\"'bW--"i.-i:t0ti,,A\4J;',li..j-'E~~f.J,"";\ilt':'1'J>~~ illilli(~ 'lI.",__" ,~,,~_ .=~.- ~~.~ ,",.' ~'~"'~''''~"''"'' ^.,."~ , 1El~" """~~ t ~ (") 0 9, t~ c:: w :--0 ~ "- -." ;:gro :::- i~;9~ 8 1'11 z: z::o zs;, N ~'? N ~O F ~ i;j ~-7 -::>u ~. f! ~(~1 " :-.r-r, 6J ...0 :l" ::Jl:: ,--..:!J & ZO ~(") ~ ~ ~g W om Z ~ W ;;i ~~ ~ ~ 'D ~ ,a:- , ~.' .~ -.~~ -~i I I I Ii , Ii ,. !I ;1 ,I !! -", ,. -k,'..'''' _': .._,;. ",,,..-,/';" " ,",~,_ : _"',' '" ",'0'",,,,,; ~ M!; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY BANK OF PENNSYL VANIA, CIVIL DIVISION NO. 01-1422 CIVIL Plaintiff, PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS vs. Code MORTGAGE FORECLOSURE LINDA L. EDEN, single, Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA LD. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh,PA 15219 (412) 281-1725 ... . . ". .'" liiuOio;. Iil,,'i;t~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $89,638.74 Interest 01111/03-06/11/03 2.823.68 Total $92.462.4l The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate in: East Pennsboro Twp, Cumberland Cty & Cmwlth ofPA. HET a dwg k1a 21 Givler Avenue, Enola, PA 17025. Parcel No. 09-13-1000-036. ~68~ ~L 'PV"E . oms . Ittl, sqmre Attorney for Plaintiff ~""=.".""'~.... .~~- "~ , - " ,~,. .~""' .- ~," "'"'"",-""I~"~""'"I.,,,t1l<w'U . c.,.. "~ IN, THE COUp,:r OF COMM:lN pLEAs OF CUMBERfAND COUNl"{, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Confessed Judgment National City Bank of Pennsylvania, other vs. File C\b. 01~1422 Civil A=unt Due $89,638.74 Interest 2.823.68 Atty's Ccmn Costs Linda L. Eden, 'IO THE PRCl'IHON:ll'ARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail insta..llIrent sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate or:i.ginal proceeding bled pursuant to Act 7 of 1966 as ' arreoded; and for real property purSlia,Q,t to Act 6 of 19;4 as amended. Issue writ of execution in the 'above ma,tt;er to th!'= Sheriff of Cumberland COUIlty, for debt, interest and costs'u~t) the fallowing described property of the defendant(s) See attached legal description. PRAE:l::IPt :FPR ATrAClMNl', EXECIJI'IOO Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs. as above, directing attachment against the above-nared garnishee( s) for the following property (if real estate, supply six copies of the description; supply four' copies of lengthy personalty list) and all other property of the defendant ( s) in the possession, custody or control of the said garnishee(s). ( Indicate) Index this wri t agains t the garnishee( s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. .ca ~ _'.. r--- . DATE: January 10, 2003 Signature: /' 4~ ~" P=int Name: Louis P. Vitti Mdress: 916 Fifth Avenue Pittsburgh, PA 15219 Acto~ey Ear: Plaintiff :~12::hor.e : (412) 281-1725 ,<";''';'H''''-0l>1%J@;-"kliiiOi 1.,j"" ,'. ','jj",~-m\;0",,"'~,""~~""',M '~~.,'1li,'~i;l~ ili:ItJ:)l.'IH:,,^D"-___ jjj~~b t: P. .=r ~) ~ 7ft~ (bC;:;~ ~~ ~~J l~ '-J t' W l :-fq,~ . . d & r-~ r- ",.L~A --' liWliri~lliilll -~. '-~ ~"ili;l~-u''iI';Iil Iii ~ ..f:. . lJ-> () ~ -'.pO ~ ~ ~ ~g~~8 I , 1~:cJ ~~~[F ~ ~: ~8t ~ .----.c.... w""'- tilh':-,::"j "'j f:i I, :l! :', i:: L I' ,. ;1 I:! ili I' n l'! (') 0 0 S;;; W -"~f s:: '-- ,~, .~ ;:Fjm ):lo f+'j:O fT1 ;Z " f- Z:x: N ...-.rr; t5~. N :09 ."" ~~~~ ....... ~t~: ~ ":i:n ~() :J:: ~,() ;';:0 ':.d orn c:: s: z w :;! :J:1 'D -< i: Ii 1'1 I' ! II ,I 'I \1 :1 Ii I I' I ;i Ii II I I I I , ,I I I c , ~ , "'~~t\ilil,,_~i~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO, 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. LEGAL DESCRIPTION ALL that certj\in piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania,' bounded and described in accordance with a survey and plan thereof, dated March 25, 1966, prepared by Roy M. M. Benjamin, Registered Engineer, as follows: BEGINNING; at a point on the Eastern line of Givler Avenue, said point being 99 feet in a Southerly direction from Southeastern corner of the intersection of Givler Avenue and Church Street, said point being on the dividing line between Lots Nos. 13 and 12 on the hereinafter mentioned plan oflots; thence along said dividing line North 79 degrees East 150 feet to a point on the Western line of an alley; thence along the Western line of said alley South II degrees East 85 feet to a point; thence South 79 degrees West 150 feet to a point on the Eastern line of Givler Avenue; thence along the Eastern line of Givler Avenue North II degrees West 85 feet to a point the place of beginning, HAVING erected thereon a dwelling known as 21 Givler Avenue, Enola, PA 17025. PARCEL NO. 09-13-1000-036. BEING the same premises which Edith M. Lloyd, a widow, by deed dated 10/31/1997 and recorded on 11/18/1997 in the Cumberland COUllty, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 167, page IllS, granted and conveyed UlltO Linda L. Eden, a single woman, , ;^~^"-..I.',, ~_ ,'" _.; ,- ,-A'" <",o~_ ,,' ,._' ,,C''. '.,X:',., ," "'-" d~--s:<i . ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the Defendants'last known address is 21 Givler Avenue, Enola,PA 17025. ~~ Louis P. Vitti, Esquire SWORN TO and subscribed before me this 10th day of January, 2003. NOTARIAL SEAl LOIS A. EVANGEUsTA, NOTARY PUBLIC CITY OF PI1TSBlJRGH,ALlEGHENY CooNn' MYCOMMISSIONElCPJRES OCTOBER 17, 2005 p . . ~~r..iD__]~ ---_.]it;J(a.~m~~;M-..' ,~~ "~, . ""'. -x ,.-r''- ,---',,""--,' ..'.;;:~~~;;:;,;~\' I";":,<\,_,,,,,l~ j{)Y.,,,. -.j",'.(:i fi'0t{;{;iMf~\n~ l-w;j . .,-~,"--~"'~~ ---_.~"., ,-.-,") .\",,-,; ,...,,'.......',.'" ''" ~ Cl 0 W -n s.. '- 'J'::D -un) ,.,.. Q1rn :;z:: rT1rr z:;rl N ~g@ liic -.1':; N c');r~ ?o """ :,~;J ~~:t; :.:: I~-n ~.g ::;I:: 7(~ r..:? om :Pc: -< ~ t.,) :P \0 :Q .. ~--'~:! '. i , ~;j It I I':' ,I t:i " n !I i:1 U " ;-! f; Ii ti 1'i J'i " " u II H " u 1:1 Ii f1 u Ii II 'i Ii II :1 II '1 II I' II " ij II ,I = ~ ~ , ,.", ~II ;~...... - ~-(iI!L~1M7'~~f..oJ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1422 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY BANK OF PENNSYLVANIA Plaintiff (s) From LINDA L. EDEN, 21 GIVLER AVENUE, ENOLA, P A 17024 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $89,638.74 Interest $2,823.68 Arty's Comm % L,L. $.50 Arty Paid $114.30 Plaintiff Paid Date: JANUARY 22, 2003 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthO~ {J ~ <..!lv: q_'" Y?.A...at... r Deputy REQUESTING PARTY: Name LOillSP. VITTI, ESQillRE Address: 916 FIFTH AVENUE -!,ITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ill No. 3810 ~...- J.-~~ . '~__"'. ,_ -. ",' , '~ "' , ~~-', ~'. ~o "~,,,""-";";"""i'~.lJI.~ UNITED STATESBANKRUPl'CY COURT MIDDLE DISTRICT OF PENNSYLVANIA INRE: EDEN. LINDA L CASE NO. 01-01913JJT-l CHAPl'ER 13 Debtor(s) NOTICE TO CREDITORS AND OTHER PARTIES IN INTEREST Notice is hereby given that the Court has entered an Order dated December 20, 2002 DISMISSING the above-captioned case due to: TRUSTEE'S MOTION TO DISMISS DATE: December 20. 2002 Clerk. U.S. Bankruptcy Court 228 WALNUT STREET P.O. BOX 908 HARRISBURG. PA 17108-0908 VAN-87 055556 ., _b_''_ -- ",,-L ''''-'' ,'i",,~_' ..: """~',,,,, ',',,: " ..,-- {" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. AFFIDAVIT I, Louis P. Vitti, hereby certif'y that as representative of National City Bank of Pennsylvania am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws ofthe Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. ~@~ L P V E oms . Itti, squrre Attorney for Plaintiff SWORN to and subscribed before me this 10th day of January, 2003. NOTARIAL ilEAL LOIS A EVANGEUSTA, 'NOTARY PUBUC CITY OF PITTSBURGH, ALLEGHENY COUNTY MYOOMMlSSJON EXPIRES OCTOBER 17,2005 . '. , " - i!i~~~~~~~.~41*~.m~i -r~-- ", n .~" . ,,' ,'~ " J', r ;';'.; '/~) <_ ~-'l '',.:,;\\i~ ,. ~ '" ;,,~,' ~ -, ~ . . . ~, ' ''''''>''''''0'''.''- ' ," r l I,' l'!)- I i I,', 1-': , , I, i l. I" , I I' I;' " L I' ~' , [' l Ii', ~, r'" F i I ! g 0 0 W -n s.: ~ ,-j Ii! ."tH::n "" :~J~ "T\ l' ~g:j :z :'.tp N "',..,1'1 I zr; ':"9 ro~" 1'0 ,"'..;0 ~6 :~'o ~1 -0 '<,' q ~:D i'f ~o 3 ""0 i! '):>0 Zm I' , c td (-:.) . ~ ,:.,.) s;! I ::0 \.0 -< .1. ". ".' ~ , .'" -_,...,:"'",_J ': , ~ >.---" '-"'","'--" , .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. AFFIDAVIT PURSUANT TO RULE 3129.1 National City Bank of Pennsylvania, 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 21 Givler Avenue, Enola, PA 17025. 1. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Linda L. Eden 21 Givler Avenue Enola, P A 17025 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. I above. 3. Name and last !mown address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None .L "" ."e' - 'jj~te!, "~ 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) Commercial Credit Corporation 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) None 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) Tax Collector ofE. Pennsboro Township c/o Alicia Stine 98 South Enola Drive, Room 101 Enola, P A 17025 American Water P.O. Box 371412 Pittsburgh, PA 15250 Twp. ofE. Pennsboro Trash & Sewer 98 South Enola Drive Enola, PA 17025-2796 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, P A 17013 ~ --, ~i '" Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, PA 17013 Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 21 Givler Avenue Enola, P A 17025 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. January 10. 2003 Date ~A Louis P. Vitti, Esquire Attorney for Plaintiff SWORN TO and subscribed before me this lOth day of January, 2003. NOTARIAL SEAL LOIS A. EVANGELISTA, NOTJI\RY PUBLIC CITY OF PrrrsauRGH. ALLEGHFNY COUNTY PIN COMMISSION EXPIRES OCTOBER 17. 2005 , 1l1~~ ,~'~':"_"~~~~~Tr1fw~~iii!:k~J1~lLJ~it' . o,~: ~. ,.:....,; -"~ *' jl\!':'~:U!, ''''"1,J'\'1'''' ,~"'_'"'''' . 0 ~.: l I I l i i , t I l I I ! , [, ~ ~:i ,~, t:: \" , , I. 1< i, I.: " , tl l'j Ii (") 0 0 c.: v-" -1'1 :s: '- ~-,;:! -ow )~ ;tl~:! ~g] z ZS; N ~g~) N .,,'1 (I)-J<;-~ ~-'O '-<,.c!-" ~c " .::1-:-, r'~ --n j;; :x '--?c) 2,8 tf! om ~~ ..; c..> :iJ \D -< 'I. ': H I' . , , I,! I~ I;; :.; I" jl' I' f1 " ~'" . NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Linda L. Eden 21 Givler Avenue . Enola, P A 17025 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland COUllty, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland COUllty Courthouse on June 11, 2003 at 10:00 A.M., the following described real estate, of which Linda L. Eden are owners or reputed owners: East Pennsboro Twp, Cumberland Cty & Cmwlth ofPA. HET a dwg k1a 21 Givler Avenue, Enola, PA 17025. Parcel No. 09-13-1000-036. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Bank of Pennsylvania vs. Linda L. Eden at No. 01-1422 Civil in the amoUllt of$89,638.74. Claims against property must be filed at the Office of the Sheriffbefore above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to beheld or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights you must act promptly. , _ .'1 " " , ::.;;t YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LA WYERAT 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial ofthe issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service ofthe Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriff's Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office ofthe Sheriff. GI' r7~ ...~~ Louis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh,PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTE\MPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** , ' ~ ,l ~~"r ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. LEGAL DESCRIPTION ALL that certain piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof, dated March 25, 1966, prepared by Roy M. M. Benjamin, Registered Engineer, as follows: BEGINNING at a point on the Eastern line of Givler Avenue, said point being 99 feet in a Southerly direction from Southeastern corner of the intersection of Givler A venue and Church Street, said point being on the dividing line between Lots Nos. 13 and 12 on the hereinafter mentioned plan oflots; thence along said dividing line North 79 degrees East 150 feet to a point on the Western line of an alley; thence along the Western line of said alley South 11 degrees East 85 feet to a point; thence South 79 degrees West 150 feet to a point on the Eastern line of Givler Avenue; thence along the Eastern line of Givler Avenue North II degrees West 85 feet to a point the place of beginning, HAVING erected thereon a dwelling known as 21 Givler Avenue, Enola, PA 17025, PARCEL NO. 09-13-1000-036. BEING the same premises which Edith M. Lloyd, a widow, by deed dated 10/31/1997 and recorded on 11/18/1997 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 167, page 1115, granted and conveyed unto Linda L. Eden, a single woman. ~~~;;:;i'>'Mr''tr!\lft.;~+J:;-i~~~~t.~~j,\#!;,fl&.i,-;;~bt&iii''&lm,i~'';;j.jjd,~~~~W~'.'~. ~'..Eh.~~~' . -" -., - -, c_ __, ~.. " '~' '. '-'m ,'>l.<"~ 'e... t ! f: I I' I I 0 0 0 C W -1 ~~ L. .,-~ ""00.1 ". ~'.::,~ ~-gj :z: ';,,-- , lESi; N }1::q N ;:.O:;'-r" ~e ~<.) j8 ~ .'f.'j -.-..... 3 r.~--' ~() ca 6m ~ w ;g V' ~ ~ ,,"~--I, ~ ~" .. , ~, _ , ' -' " <>;;; -' - '-"j ,'- ;':':., ?,',,,i,~-:. ~')' , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY BANK OF PENNSYL VANIA, CIVIL DIVISION NO. 01-1422 CIVIL AFFIDAVIT OF SERVICE Plaintiff, vs. Filed on behalf of Plaintiff Counsel of record for this party: LINDA L. EDEN, single, Louis P. Vitti, Esquire PA LD. #3810 Supreme Court #0 I 072 Defendant. Louis P. Vitti & Assoc., P,C. 916 Fifth Avenue Pittsburgh,PA 15219 (412) 281-1725 \, ,,- , " <^ '~>'"' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYL VANIA, : NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. AFFIDAVIT OF SERVICE I, Audra 1. Hunger, do hereby certify that a Notice of Sale was mailed and served upon all lien holders by Certificate of Mailing for service in the above-captioned case on January 22, 2003, advising them of the Sheriff's sale of the property at 21 Givler Avenue, Enola, PA 17025, on June 11, 2003. LOUIS P. VITTI & ASSOCIATES, P.C. Bf1k~!lrt{~ SWORN to and subscribed before me this 30th day of May, 2003. NOTARIAl. SEAL LOIS A. EVANGEUSTA, NOTARY PUBUC crrv OF PITTSBURGH. AllEGHENY COUNTY MYCOMMISSION EXPIRES OCTOBER 17,2005 "'-' .~".~~.;...;..... ~' -j, :1'," ,";\ :",'~:~;T~:~F~:1J~:f' . : i ' , :';, :,:', ,: i ~ : - i ii, ! , ' ~i~L.,:~~; '~C:j:'F~~t. :J:'j'" "' ok..-J ., U,S. POSTAL SERVICE CERTIFICATE OF MAIL ., MAY BE USED FOR DOMESTIC A P~ROVIDE FOR INSURANCE pos~81~i~~NATJONAl MAIL, DOES N One piece of ordinary mail addressed to: Tenant/Occupant 21 (~+~Tl p,- AUt.:ln11t.:l ~P01., Pd 17025 PS Form 3817, January 2001 _AJ/Eden/ Ec~~~ ~_..._----------:-- .......- "-.,. U,S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAl MAil, DOES NOT PROVIDE FOR INSURANCE POSTMASTER R'~ P. VITTI & ASSOCIATES, P.C. "-( 916 FIFTH A' ENUE i'5\ PITTSBURGH, PA 15219 41 281-17 5 One piece of ordinary mail addressed to: Bureau of Compliance Attn: Susan Blough Cl<=GlLClllL" SUppuL L S=L.i.Ull J)ppr #?R1?iO Harrisburg, PA 17128-1230 PS Form 3817, January 2001 AJ/Eden/6-11-03 G Afflxfee here In stamps U .8. POSTAL SERVICE .CE'RTIFICA TE OF MAlliN or meter postage and postmark~, MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll, DOES NOT stma~rfor c~treJl>~, '/ PROVIDE FOR INSURANCE POSTMASTER . fef. ~'f.,~ ,;: / /)\. \ . . IATES. P.C'/y.. ';;-> ,,-1, ~ U\ 916 FIFTH AVENUE 1"'-/ ':~~ \ \ ~1 '~v;' 1-'111::it:SUHl2H.PA15219 (;:!:il',"\,. Ii H0""~ (412) 2el-l/~o \-:;\, ';~;'~:'';': 'w~1 "~~./j~ '~ C~~~tOf~f'C;;~~;'ptleas Cumberland Cty'<: .,... <:, '. ,l?4~~ i." Nl t~ , ~ I ::'7> !i' /11 ....co 0'1 'i C-c fO. , I " 'bl'! II ", :[1 '.-'- ,-.,....__' I ': /II.IJ '''-If:;;'~'~'1";;-:.~.J \.,. T'f "ti\';;-~~ Domestic Relations Division P.O. Box 320 Carlisle, PA 17013 P8 Form 3817, January 2001 AJ/Eden/6-11-03 ~.~"'~ t - f';- j I:~'I . --~ ~h'~ilj . iR .,;.;,;" ..,..'j;:,; I" , R" U,S, POSTAL SERVICE CER IFICATE OF MAILING ~~6J:6EU~6~ ~~~~~~T~'b~~iU~i~~NATIONAl MAIL, DOES NOT URGH, PA 15219 l41c) cljl-l f25 One piece of ordinary mail addressed to: Tax Claim Bureau of Ctnnblerand Cumberland County Courthouse One Courthouse Square 70 3 PS Form 3817, January 2001 _AJjEden/6-11-03 * Affix fee here in slamps or meter postage and MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT st mark. Inquire of PROVIDE FOR INSURANCE POSTMASTER ~ R,oli,oIfRS P. VITTI & ASSOCIATES, P.C.I,:t;~' '!~ '4/,~~., 916 FIFTH ~V~~~I~~ 1'-"1 J\\ I'\r.=;:e; fJJ/ PITTSBURGH P, 1~ (,~\\ f~~1.j (412) 281-1725 ' " ~~,t,~ "'I';""',~\'t\~,~ ~:::~:~:~lm:~d:;"~: _ DPW ",~ '. ..,. C~]~~~t:~~~l P.O. Box 8016 r;(-~~~t':t;;Mj~ :.;/ ~ '~r" Harrisburg, PA 17105 C;I ~- " I !.; I ~.'" lIt! PS Form 3817, January 2001 Jii1~ I ,0, llt~ AJ/Ed /6 11 03 (,I ~"# en - - '*':;;;:~..,.J"l: U,S. POSTAL SERVICE CERTiFICATE OF MAILING Affix fee here in stamps or meter pos MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll, DOES NOT post ma nquire rJP().., ,. PROVIDE FOR INSURANCE POSTMASTER . Postma erforcur@n" '~ R"LQUIS P. VITTI & ASS CIATE . P. 0 '^ '? h 0&." (J ~ ~I 916 FIFTH AVENUE .... f'/r' ,jAi ", ..~!'.J2ii PIII~~~~~~'_;~2~5219 '.. ({( ;~,t L~'~;~~i;:~~~J ,0'-_ .,~4Jll/;':tt "';, S_C ' USP"f!tt ~I ;,;;;, li~ I c:) ill .*.~~~:~)it 'yfh U.s. POSTAL SERVICE CERTIFICATE OF MAILING One piece of ordinary mail addressed to: Twp. of E. Pennsboro Trash & 98 South Enola Drive Enola. PA 17025-2796 PS Form'3817\ January 2001 AJ/Eden/6-11-03 ~ t I ...., , ~""" .~,,,,",~wl;,;, _ij;;!tj~ !5- l,. 'i_. I"" _ ,,,.iIJ' t.L....,'''''~~~,_ ~<.' ..)",~, -~~..-""'~,~, , , =" -" Affi, fe, '" '" ,&.pr;~f or met ostage!fld ,.>.. post InqUlt'Q1lf (j) Pcstm {orc-$~Il\ to R''';~S r VITTI &. ASSOCIATES. rco '?h ~~,~~ ~;C)~W:--i Q1R I=IFTH AVI=NIII= 10Y:-/-; "''.ljorgt:~~~~I, PITTSBURGH n 1 1 / S ' ,,/;, ';;!;~'!" ,",,: /, i1 r, "2 lJ~!.;,t~'i-'",,\, '1"(' " 412 .,281 1725 if) , ,~gl:,',~,/:''\t" '~,~' - IY/i J ' f'2~i~':.:X;;,.r'''~,!/t.. 0" p;,,, of om;"" maU ,''','',' to \'{i:jif .' ,Ef:i"7A,'~! American Water -"'"'' '11 I'i/ l' () Rrw 17141? !4f :.0 fir' l5, c::. 1/,1 Pitto:burgh, ph 15250 "', I" 11 \ ~~'I~~-;;~;~ U.S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND II':lTERNATIONAl MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMA~TER PS Form 3817, January 2001 AJ/Eden/6-11-03 U,$, POSTAL SERVICE CERTIFICATE OF MAILING Affix fee here in stamps ormeterpo~_ postm:;tr nqu/repM ( .--- postm terfurcl/-rretlV,:\, ( , ... - .: .."\1 \ \.' J / {J ~- nl r:::;-' \J> '., C o ~ -.... y, ';' cvl ,'.. \ ~"- \ -' ':2' ~, '~.. >w ' /. h:;- ~ r\, ,.l...,..;"<;,, -..A ,"'; IZC'k~ -\t1 -:? '-':" '->1_~ '" " >;, ,,-' . ~\J (1l?f;J ",~.",,' ~I ~ v' I.., -" 1-<l; ~ r t"t. C / C' 7;Dr-:;~!, ~~'I'-,I !~\ , if' "" 00'01,. ,_"" "~ ~ ". r:i v. ~ ~~: :':~.~ _~, '-~ 'c:- -';:~~''', ~~, f.?! III'" 71i' I ~I .'~ I" I:, '1.) 8' II ( ! ~ ,,/ ',' ~ 1'1 Ii I , ~~'.-';-;""_J ~ ..*"..,. MAY BE USED FOR DOMESTIC AND JNT 'RNATIONAl MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMt'lST R"'~OOIS r VITTI & 'ASSOCIATES , O'ne piece of ordinary mail addressed 10: Commercial Credit Corporation 3401 Hartzdale Drive Suite 126 CHill PA 17011 PS Form 3817,'January2001 AJ/Eden/6-11-03 &1& r - , c~ _.k-]' ~ . ;;", ' " ~, ,"~" '. . \ U.S. POSTAL SERVICE CERTIFICATE OF MAILING One piece of orainary mail aaaressed to: Affix fee here In st!'lmps or meter postage and postmark " ~~m erfor (~1TfbY~~. f{ ~ ,. . ~ U """ r') [J:;> :::.' ~I \ ;; ,c:-; .~ ,r,""-/J ~,,'t;I\\~~ ~'~'" f ~"kl""''1A'\''r;'''''''fI( ~1~ ~fi:~~~~i;:ItP~& I Ch " """,,,,",. '" ."1{J ,~~ \. : -, ,,:: ~:~:~/ gt~~i'ii;~1~1->'ft:~ Pennsboro ::rw.p.> c ...... ="" i'i,,,g .' "'{ Iii i'~~ I ~ I c:;:' h,fil ,. 1I~ il '-C 'Ii f I~ III/ *.*.~......-..J 'L' ~'f.'f't~,. Re . , . I' 916 FIFT'/'i AVENUE /s,v,-.)::..!:!!((" ~liiS8UF\~H. I-'A lO<!l.9s/,,:.liiii ,,\',~ I ".. '"")/1 ".Y (412) 281-1n5~ " 22 1)0> Tax Collector of East ('/0 Al;"" St;np 98 South Enola Drive, Eno1a PA 17025 PS Form 3817, January 2001 AJ/Eden/6-1i-03 Room 101 Reo U,S, POSTAL SERVICE C~RTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMAST R One piece of ordinary mail addressed to:: Clerk of Courts , I . ., I)' . . rr;m;n:::l.l (;lVl lV~~lnn OnP c.OllrtnOllSe Sqnare r FA 17013 PS Form 3817, January 2001 AJ/Eden/G-ll-03 " ' ,~ ',' .."c"~,,,",",~',:J!2 dliii' "- ;!:'::j'o;;' ;' ~ .i;~I['~:'i' >.j,.l;';, . '.',."-J':;--,, ~;';';i,'""r-'">";;",_,,,' ,:,,', " ',"- . ....OI......=. "'~'-"'l~--' ilii ,;~c'i;, ";"";:':~ ,'," 8~'c."',;"~~,,,~, ':..__,;; ":, "," -- ,-- ~.,;,."~'tM ~ ~ "'~ , ,'",-.t...,,;,' ~ Cl !::,; .r.-- ~~~D ;:: r (/1,1" -< :~. k'c' "rS., ~'7f '; !:,c::f".-:'j >-~~ ,.C :-J ..0,,," ,'- ~,,- -,.""""'-~, '-,~,~ ,< , "" , r;:- I ii I I' ~ . ! I I , I I j I I I I I' I I I ! i I I () -,J c'. , ':.~ ",- C'! :~7: ~c) , -~(,~ -:",~ c- ...j '!"> ::n --< .f, ~,*\.;,' - h..--"""",.~ -~ " , ,-- ~='~"''''~,,"c< \'. " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which National city Hoe Loan Serv is the grantee the sanJe having been sold to said grantee on the 11th day of June AD., 2003, under and by virtue ofa writ Execution issued on the 22nd day ofJan, AD., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number 1422, at the suit of National City Bank of Penna against Linda L Eden is dilly redorded in Sheriffs Deed Book No. 257, Page 4336, IN TESTIMONY WHEREOF, I have hereunto set my hand ~ and eal of said office this I day of Recorder of Deeds olDeed8, ~Coun\y, CIuIIste. PA My CClIM1IBIIon ElcpIno8lhe Flnil Mondily of JtIl. 2llOI _'::"7__.,';-;'< ,;'i ",'-,,:::",~.::'~~::~~}-- "~~,"'~ ~ ~- .. ~ I,... "\ ~. .~ I'lII ~ ~~ """-'~~-,' National City Bank of Pennsylvania VS Linda L. Eden In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1422 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on Febm\rry 05, 2003 at 2:35 o'clock PM, he served a tme copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within nanJed defendant, to wit: Linda L. Eden, by making known unto Linda L. Eden, personally, at 21 Givle~ Ave., Enola, Cumberland County, Pennsylvania, its contents and at the sanJe time handing to her personally the said true and correct copy of the sanJe, Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2003 at 4:22 o'clock AM., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Linda L. Eden located at 21 Givler Ave., Enola, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within nanJed defendants to wit: Linda L. Eden, by regular mail to her last known address of21 Givler Ave., Endla, P A 17025. This letter was mailed under the date of April 4, 2003 and never returned to the Sheriffs Office. R.Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, pennsylvania on June 11,2003 at 10:00 o'clock AM. He sold the sanJe for the sum of$I,OO to Attorney Louis P. Vitti for National City Home Loan Services. It being the highest bid and best price received for the sanJe, National City Home Loan Services of 150 Allegheny Center, Pittsburgh, PA 15212, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$738,76, it being costs, Sheriff's Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage $30.00 14.49 15.00 15.00 30.00 10.00 .50 1.00 20.70 --,,,,,"...,,tt"~'-~"~h_ lIi;,,-.l.I~,l~,.~~.~ " ..., Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed " .. ~~'W\ij,~--<., 15.00 20.00 242.15 235.18 25.24 25.00 , 39.50 $ 738.76 Sworn and subscribed to before me SOAn~ Q ~~-~)~~ ~ This 3# day of D _ ' ~ -e;.. q ) _ R. Thomas Kline, Sheriff 2003, AD. ~,() ~,~ J (~11, r thonotary BY od ~..JlfVU Real Estate eputy ~~ tIO 30, ,51> 1. <.k. Y I J.~-t. ~. 139';). 7 " " I_I -- " ". ,~ " IMfi: " "'4, , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. AFFIDAVIT PUlJ-SUANT TO RULE 3129.1 National City Bank of Pennsylvania, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information conceming the real property located at 21 Givler Avenue, Enola, PA 17025. 1. Name and address ofOwner(s) or R~puted Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Linda L. Eden 21 Givler Avenue Enola, P A 17025 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. I above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None "' ~" J", , 1'- ',~' -~~ ~- :d!:i~' ... ,,0;- " , 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) Commercial Credit Corporation 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) None 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of E, Pennsboro Township c/o Alicia Stine 98 South Enola Drive, Room 101 Enola, P A 17025 American Water P.O. Box 371412 Pittsburgh, PA 15250 Twp. of E. Pennsboro Trash & Sewer 98 South Enola Drive Enola, P A 17025-2796 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, P A 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 "'_.. ,~ - _"M:'," " "':0; ~, ,..; Tax Claim Bureau of Cumberland County CInnberland County Courthouse One Courthouse Square Carlisle, PA 17013 Court of Common Pleas of Cumberland COUllty Domestic Relations Division P.O. Box 320 Carlisle, P A 17013 Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 21 Givler Avenue Enola, P A 17025 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, January 10. 2003 Date ~$C Louis P. Vitti, Esquire Attorney for Plaintiff SWORN TO and subscribed before me this 10th day of January, 2003, NOTARIAL SEAL LOIS A EVANGELISTA, NOTARY PUBLIC CITY OF PITTSBURGH, ALLEGHENY COUNTY MYCOMMISSION EXPIRES OCTOBER 17, 2005 . - ~ ".~ .~~ ~~i'fo '>>, ,.... NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Linda L. Eden 21 Givler Avenue Enola, PA 17025 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of CInnberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on June 11, 2003 at 10:00 A.M., the following described real estate, of which Linda L. Eden are owners or reputed owners: East Pennsboro Twp, Cumberland Cty & Cmwlth ofPA HET a dwg k1a 21 Givler Avenue, Enola, PA 17025. Parcel No. 09-13-1000-036. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Bank of Pennsylvania vs. Linda L. Eden at No. 01-1422 Civil in the amount of$89,638. 74. Claims against property must be filed at the Office ofthe Sheriff before above sale date. Claims to proceeds must be made with the Office ofthe Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date, Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. Ithas been issued because there is ajudgment against you, It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights, If you wish to exercise your rights you must act promptly. .. . 'j,'::"'", .. ';.,<,,' ,~ YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 You may have legal rights to prevent the Sheriff's Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid retum of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriff's Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property, The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. r7~~- Louis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** ~'..."",.. ~- L.... .."... ~ ,~ ;'R :. ..- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY BANK OF PENNSYLVANIA, NO. 01-1422 CIVIL Plaintiff, vs. LINDA L. EDEN, single, Defendant. LEGAL DESCRIPTION ALL that cet;lain piece or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bOUllded and described in accordance with a survey and plan thereof, dated March 25, 1966, prepared by Roy M. M. Benjamin, Registered Engineer, as follows: BEGINNING at a point on the Eastern line of Givler Avenue, said point being 99 feet in a Southerly direction from Southeastern corner of the intersection of Givler Avenue and Church Street, said point being on the dividing line between Lots Nos. 13 and 12 on the hereinafter mentioned plan oflots; thence along said dividing line North 79 degrees East 150 feet to a point on the Westem line of an alley; thence along the Western line of said alley South II degrees East 85 feet to a point; thence South 79 degrees West 150 feet to a point on the Eastem line of Givler Avenue; thence along the Eastern line ofOivler Avenue North II degrees West 85 feet to a point the place of beginning. HAVING erected thereon a dwelling known as 21 Givler A venue, Enola, P A 17025. PARCEL NO, 09.13-1000-036, BEING the same premises which Edith M, Lloyd, a widow, by deed dated 10/31/1997 and recorded on 11/18/1997 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 167, page 1115, granted and conveyed unto Linda L. Eden, a single woman. -~'" o "~~, ~ '" , I. ~'1;,M~'i.", WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-1422 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUN"TY: To satisfy the debt, interest and costs due NATIONAL CITY BANK OF PENNSYLVANIA Plaintiff (s) From LINDA L. EDEN, 21 GIVLER AVENUE, ENOLA, P A 17024 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee( s) that: ( a) an attachment has been issued; (b) the garnishee( s) is enj oined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, AmounlDue $89,638.74 Interest $2,823.68 Atty's Comm % L.L. $.50 Atty Paid $114.30 Plaintiff Paid Date: JANUARY 22, 2003 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthO~ p ~ ___By: (J/kP Yldj'L;- Deputy REQUESTING PARTY: Name LOUISP. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ill No. 3810 iIMi~&I',il,MG~i'''&'J-d'j,-"i,';I--'i'' '" ""'-"_;;'~"':::J'2;":i!h"""''';",-!-''~~i"J\j&,;~iB''iiiil!:':i''''-~rJ.~~~~~T",~(ii!1Q.,""~~,,,~'4.f'T"" ~'~"'IiJtie"'j@" .-""_",,,__o.L;-.:.,;,0;;;",,-,,,.<,',' ",','1"'", Real Estate Sale # 04 On January 31,2003 the sherifflevied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A known and numbered as 21 Givler Ave., Eno1a, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: January 31, 2003 By:00fu{ JrricLh Real Estate Deputy }:' N~T )",,1 'I"; : ~.~j fJ ~i.~L ~ L""~"~~"lli ~ ~ c;::::3 GV ova e." ~ v , "'"";~: .'. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the COUllty and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the sanJe as was printed in the regular editions and issues of the said C1llllberland Law Journal on the following dates, viz: APRIL 25, MAY 2, 9, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. - SWORN TO AND SUBSCRIBED before me this 9 day of MAY. 2003 NOTARIA\. SEAl LOIS ea:roc:-== CaIlIslIl . Cvnl_ &'-iI5. 2005 My Comm\S8lOII.......- ........ . REAL ESTATE SALE No.4. Writ No. 2001-1422 Civil Term . National City Bank of Pennsylvania vs Linda L. Eden ,Ally: Louis P. Villi DESCRIPTION L that certain piece or parcel of land situate If East Pennsboro Township, CumberlalJd Q:u~> Pennsylvania, bounded and descrWed in ac'~' d:ir1ce with a sut'\-'cy and plan thereof, dated ~5>_ 1966, prepared by Roy M. M, !l:lnjaiillnKegisteredEngineer"asiollows; - - GINN:mG at a 'Point on the Eastern Ho.e of . er:,e,.venue, said point being 99 feet In a _. __ oiilli:e!ry direction from SQutheastern comer of .:o'f"thdntersecuon of Givler Avenue and Church ~ said pellnt being on the dividing line ~et.wcen Lots Nos. 13 and 12'00 the ~~~a~r 2m.<mtionM plan of lots; lI!ence along s3.1d di~l(ling ~Jine_Narth 79 degrees East 150 feet to a point on ~eWeslemlineofana11ey;thencealongthe ~temJjne of said alley South II degrees East :;a5Jeeuo.lL paint; tJience South ~9 ?egrees YVes! -:,1:50 Teet to a point on the Ea'item hne of Gtvler ~Yenue; thence along the Eastern line of ,Gi~ler ~~ueNotth 11 degreesWest85 feet to a pOint, ~ira- lace of BEG.INNING, = ;'IN. G erected thereat!- a dwelling known as _ ,lGivlcrAvenue, Enola, PA 17025. ~CELNO:U9.T3,lO()(}'036., . ~EING the same prell11ses which Edith M. "E. 'yd l\ widow, by deed dated lQ/31JJ997 and --Jecl on 11118/1997 in the Cumberland =- - unty, Pennsylvan;~,Recorder of Deeds Office ~=:;:; d,Book VoIlIme' 167, page 1115, granted , ..coAveyed lln[Q tiDda L Eden, a single ',--\.----'--- . i:)YPlIfah, REAL ESTATE SALE NO.4 Writ No, 2001-1422 Civil National City Bank of Pennsylvania VS, Linda L. Eden Arty,; Louis P. Vitti LEGAL DESCRlPTION ALL that certain piece or parceL of land situate in East Pennsboro . Township. Cumberland County, Pennsylvania. bounded and described in .accordance"With a survey and plan , thereof. dated March 25. 1966, pre- pared by Roy M. M, Benjamin, Regis- tered Engineer. as follows: BEGINNING ata paint an the East- ern line of Givler Avenue. said point being 99 feet in a Southerly direc- ' tion from Southeastern comer of the _ - intersection of Givler Avenue and Church Street, said point being on the dividing line between Lots Nos. ~ 13 and 12 on the hereinafter men- tloned plan-oflots: thence along said , dividing line North 79 degrees East 150 feet to a point on the Western line of an alley: thence along the Western line of said alley South 11 , degrees East 85 feet to a point: thence South 79 degrees West 150 I feet to a pOint on the Eastern line of I Givler Avenue: thence along the Eastern line of Givler Avenue North 11 degrees West 85 feet to a point the place of beginnlng, HAVING erected thereon a dwell- ing known as 21 Givler Avenue, EnoJa. PA 17025, , PARCEL NO, 09-13-1000-036, " BEING the same premises which Edith M, Lloyd. a widow, by deed dated 10/31/1997 and recorded on I 11/18/1997 in the Cumberland' COWlty, Pennsylvania.. Recorder of Deeds Office in Deed' -Book Volume 1 167. page 1115. granted and con- veyed unto Linda L. Eden. a single woman. ,', - A _. ;"'''''~",''_,'''P''''4' THE ~ THE PATRIOT NEWS SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss JOSEPH A.DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller 01 The Patriot News Co.. a corporation organized and existing under the laws of the Commonwealth of Pennsylvania. with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general pirculation, 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 22nd and 29th day(s) of April and the 6th day(s) of May 2003, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, ;and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facls aforesaid and is duly authorized and empowered to verify this statement on behalf of the Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted se\(erally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M". Volume 14, Page 317, PUBLICATION COpy SALE #4 " t .,......&~.......... Notana! Sea! '.'. T eny L. Russell, Notal)l Public City Of Hanisburg, Dauphin County Y PU BLI C My Commission Expires June 6, 2006 Member,PennsylvaniaAssociationOfNota' Y commission expires June 6. 2006 CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COU~ 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 $ 233,43 1,75 235,18 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.....,.,.,.,.,..............,.,.,.""".,.,.,.,.,.,.,.,.,.,.,.,.",