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HomeMy WebLinkAbout01-1490 FX ""'W. ~ , ~ ~~-~.~ - =,,~,~- ,--- ,j, ..~~, ."",-".J"" FEDERMAN AND PHBLAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248, ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE FREDERICK, MD 21703 TERM Plaintiff NO.O/- /'fctQ C?;u,l'~ CUMBERLAND COUNTY v, ROBERT B. FORSYTHE, A/KJA RB. FORSYTHE RITA M, FORSYTHE 5203 WINDSOR BOULEVARD MECHANICSBURG, PA 17055 Defendant( s) CIV![L ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 6838603878 - m " ,J , "'.,. .~~ ~ "<,+ 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRNE FREDERICK, MD 21703 2. The name(s) and last known address (es) of the Defendant(s) are: ROBERT B. FORSYTHE, NKJA R.B. FORSYTHE RITA M. FORSYTHE 5203 WINDSOR BOULEY ARD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 6/6/86 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to SEARS MORTGAGE CORPORATION, F/KIA ALLSTATE ENTERPRISES MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 817, Page 944. By Assignment of Mortgage dated 5/13/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 635, Page 382. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith, A copy of such notice is attached as Exhibit "A," " ~h~-<' . .' ",ut\l,j~i 6. The following amounts are due on the mortgage: Principal Balance Interest 9/1/00 through 2/1/01 (Per Diem $13.03) Attorney's Fees Cumulative Late Charges 6/6/86 to 2/1/01 Cost of Suit and Title Search Subtotal $44,671.62 2,006,62 2,233,00 98.80 550.00 $49,560.04 Escrow Credit Deficit Subtotal 106.38 0.00 ($ 106.38) TOTAL $49,453,66 7, The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged, 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000,00. 9, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P,S, ~1680A03c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $49,453.66, together with interest from 2/1/01 at the rate of$13,03 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property, }-~~~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -"l - " '~ -~, ' ~ ,,,j . 1ST ..NAlJONWID... 'E " lMlD'm^"'" . ~~~ ~ ~ p.e, Box 9481 Gaithersburg, MD2OB98.9481 January 11. .2001 Certificate of Mail ~ R B Forsythe 5203 Windsor Blvd Mechanicsburg PA 17055-3529 RE: Loan No. ~838603878 ,Dear Mortgagor: / Act 91 Notice Take Action to Save Your This is an offldom&FtIQWeEQr,~19:iyr&me is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSIS.TANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains how the program works. To see ~f HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DA~E OF THIS NbTIC!. Take this notice with you when you meet with the counseling agency. The name, address, and phone number. of the Consumer Credit Counseling Aqencies .serving your County are listed at the end of this Notice. If yOU have any questions. YOU may call the Pennsylvania HOUSing Finance Aqency toll-free at 1-800-342-2397. (Persons with impaired hearinq can call (717)780-1869.l . This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia. pues afecta su derecho a continuar viviendo en su casa. 8i no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agertcia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF300-003/C24 5280 Corporate Drive, Frederick. MD 21703 EXHIBIT A . , ~; , L" " ._~E P.Q, Box 94Bl Gaithersburg, Me 2Q~B.9481 January 11, 2001 Certified Mail Return Receipt Requested Rita M Forsythe 5203 Windso~ Blvd Mechanicsbu~g PA 17055-3529 ./ RE: Loan No. 6838603878 Dear Mortgaqor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortqage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when YOU meet with the counseling aqency. The name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If YOU have anv questions, YOU may call the Pennsylvania Housing Finance Agency tOll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If yOU have any questions, representatives ,at the Consumer Credit counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/C24 5280 Corporate Drive. Frederick, MD 21703 EXHIBIT A . ,',--,.1 >' , -'-' January 11, 2001 Loan No. 6838603878 Page 2 PA Act 91 Homeowner's Name: R B Forsythe Property Address: 5203 Windsor Blvd Mechanicsburg PA 17055 Loan Account No.: 6838603878 Original Lender: Current Lender/Servicer: First Nationwide Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN. SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.. * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR. MORTGAGE PAYMENTS, AND I * IF YOU MEET OTHER ELIGIBILI~Y REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSDiG FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled .to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end .of this Notice. THIS MEETING MUST OCCUR WITHI~HE NEXT (301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY. MORTGAGE ASSISTE, YOU MUST BaING YOUR MOR'1'SAGSTO DATE. THE PARit' OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTOAGI D.F:t..UloT," EXPLAINS HOW TO BRING YOUR MORTtD.GE UP TO DATE.. DF303-001/C24 EXHIBiT A , ~_ '>I c, " ru..."h. J'"", :;.,_ ~ ~,,- 'M- '. January 11, 2001 Loan No. 6838603878 Page 3 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of the designated consumer credit counseling agencies for county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelY of your intentions. APPLICATIONS FOR MORTGAGE ASSISTANCE - ~our mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. ~our application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIM! PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds 'for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DF303-001/C24 EXHIBIT A ;j, January ii, 2001 Loan No. 6838603878 Page 4 PA Act 91 Finance Agency has sixty (60) days to make a decision after it receives your aPPlication. During t~at time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARI: CURRENTLY PROTBCi:TiED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS IS .FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED :As AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CUkE YOUR MORTGAGE DEFAULT (Bring it UP to date) NATURE OF THE DEFAULT - The MORTGA~E. debt held by the above lender on your property located at: 5203 Windsor Blvd Mechanicsburg PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MAD! YOUR MONTHLY MORTGAGE PA~S for the following months and the following amounts aie now past due: 1 Months at $619.55 =J/ , 619.55// 1 Months at $643.30 :I ;I 643.30- / 2 Months at $622.12 ~ 1.244.24~ Late Charges 59.28 Bad Check Fees . 00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees 14.00 Less Suspense Balance .00 TOTAL AMOUNT DUE ,580.37 AS OF THIS DATE HOW TO CURE THE DEFAULT - You may cur~ the default within THIRTY (30) DAYS of the date of this no ce BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 580.37 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME D URING ~HE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certified check, or money order made paYable and sent to: I First Nationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF304-001/C24 EXHIBIT A , ~. ... ^,-, ,- -- ~ ,,~ , Jh January II, 2001 Loan No. 6838603878 Page 5 PA Act 91 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riahts to accelerate the mortaaae debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attor- neys to start legal action to foreclose upon your morta.aed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees incurred by the lender even if they exceed $50.00. Any attorney's fees will be added .to the amount you owe the lender, which may also include other reasonable costs. If yOU cure the default within the THIRTY (30) DAY period, yOU will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DF304-001/C24 EXHIBIT A . - "" ' t''o - ,--.;.;.=.-', JanUary 11, 2001 Loan No. 6838603878 Page 6 PA Act 91 RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cured the d~fault within the THIRTY (30) 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 Sale. You may do so bY paving the total amount then past due, plus any late or other charges then due, reasonable attornev's fees and cost connected with the foreclosure sale and other cost connected with the Sheriff's Sale as specified in writing bv the lender and bv performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately 6 months from the date of this Notice. A notice of the actual 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 or action will be by contacting the lender. HOW TO CONTACT THE LENDER: First Nationwide Mortaaae Corporation 5280. Corporate Drive Frederick, NO 21703 Department 252 1-800-888-U33 EFFECT OF THE SHERIFF'S SALE - You should realize that the Sheriff's Sale will end your ownerShip of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO 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. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. DF305-001/C24 EXHiBIT A - .i j ~~IIi.tod. ~~..'> "".""I.~,.~_~,,,-, PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P,O, Box 1328 WilIiamspon, p A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS ofNonheastern P A 1631 South Atherton St, Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 CCCS ofNonheastern P A 20 I Basin Street Williamspon, P A 17703 (570) 323-6627 FAX (570) 323-6626 31 W. Market Street POB 1127 Wilkes. Barre, P A 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUMBIA COUNTY 1400 Abington Executive Park Suite I Clarks Summit, P A 18411 (570) 587-9163 or (800) 922-9537 FA-X (570) 587-9134-9135 Commission on Economics Opportunity ofLuzeme County 163 Amber Lane Wilkes-Barre, P A 18702 (570) 826-<J51O or (800) 822-<J359 FAX (570) 829-1665-(CalIBefore Faxing) (570) 455-4994 HazeItown FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhalmock Booker T. Washington Center 1720 Holland Center Erie, P A 16503 (814) 453-5744 FAX (814) 5749 CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-<J161 John F. Kennedy Center, Inc. 2021 East 20lh Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League,Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 31ll Street Waynesboro, PA 17268 (717) 762-3285 eees of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburl!, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N, 6" Slreet Harrisburl!, PA 17101 (717)234-5925 FAX(717)234-9459 YWCA of Carlisle 30 I "0" Street Carlisle, PA 17013 . (717)243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17104 (717)232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle Sl Gettysburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN. VOL. 29, NO. 23, JUNE 5, 1999 EXHiBIT A ~.~_~"=i..=,.~,,,,"~, _~ ".~ , 1,. ,'" k......... ~, SCHEDULE A 'Oq-~l-\ \~~l ALL that certain Lot NO.2, Glck K On Plan No.1, Windsor Park, Lower Allen 'l'ownship, Cumberland County, Pennsylvania, as partly shown on the Plan dated January 31, 1959 as revised March 27, 1959, by D. P. Raffensperger, R.S., and recorded in Plan Book 17, Page 90, more particularly descril:ed as follows, to 'wit: BEGINNING at a point on the westerly aide of Windsor Boulevard, said point being 105 feet south of the southwest intersection of Windsor Boulevard and Wesley Drive as shown on the said revised Plan; thence South 45 de9'rees 22 minutes West along the westerly side of Windsor Boulevard, a distance of 73.05 feet; thence by same on a curve to the right with a radius of 130.64 feet, a distance of 3.35 feet to Lot No.3; thence North 44 degrees 38 minutes West along the division line between Lots Nos. 2 and 3 a distance of 119.96 feet to a point; thence North 45 degrees 22 minutes East a distance of 76.4 feet to a point; thence South 44 degrees 38 Ddnutes East along the division line between Lots Nos. 1 and 2 a distance of 120 feet to a 'point in the western line of Windsor Boulevard, the place of BEGINNING. HAVING thereon erected a dwelling house known and numbered as 5203 Windsor Boulevard. BEING the same ~~~'s s which Edward M. Atkinson and Pearl L. Atkinson, his wife by Deed dated ~~<&~ 1986 and intended to be herewith recorded in the office of the 'Recorder of eds in and for Cimlberland County, Pennsylvania granted and conveyed unto Robert B. Forsythe and Rita M. Forsythe, his wife, the Mortgagors herein. , - BOOK 817 PAGE ~,1.s ~~'" "~ . b~ .', -- .,"," - VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unsworn falsification to authorities, ~r~ DATE: JI/z./ OJ I I '" , "'""''lll'"A.< ',~~~~;i!""IH:iiiif-.B<!'H~~",..iI,1'iulill.di>fjio---,;jf*-,a"l''!.:i'''''''''', c"""d,l'DI'~"',";\;;i!:ii',,'r!l!( ,.~ ~.L".J,'k,... ,',~- ~iillili_ii1~1iiIll~L, .'~'.' --. 6<t 0 0 0 ~ -f,g C ---n ~ &S; s: ::!l: ..,.1 € -o('J) ;::-~.. -,.:; ,~ [f1fI:' "'.,;;? H~i~ B Z,J.t ~1~ 0 fr ~?; .1='- ~' ~ -<:-,. '- D ~CJ -0 R.,l I ""r::;' c: -',-.. ~~~i:~ ~ I Z ,.~ ~ -..-( '..:? ;~'irn ] ')::) t/j Pc -I ~ [1 ~ ""' 5J , I' 1 .0 -< t:' ~ ~(f Z1'1-":"~~!,;I".R".'fJ_,,,,, _,=. ~ .~~.'~ ,~,"_~,"''''''~'.~ < .~ "" ,_~~, ,,~_,~_,_J_ , ~bo;"""",~,,,,-",,,",,~...,",,'""' ,~~~ , , , oM> j~ 1ft!. l SHERIFF'S RETURN - REGULAR CASE NO: 2001-01490 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS FORSYTHE ROBERT B ET AL 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 FORSYTHE RITA M the DEFENDANT , at 0013:58 HOURS, on the 22nd day of March 2001 at POE: CAMP HILL ANIMAL HOSPITAL 3804 MARKET ST CAMP HILL, PA 17013 by handing to RITA FORSYTHE a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 9.30 .00 10.00 .00 25,30 So Answers: ~~~ ~~~~~e R. Thomas Kline 03/26/2001 FEDERMAN & PHELAN Sworn and Subscribed to before me this ..2.R ~ day of By: ~l /-;'''' If;? /' -"fA.:..- /1/ ~ .-Deputy ~eriff .. ~-'..J ~I A.D. q.'F- O.1l1,eJ,."~ ,~ Prothonotary t. ~ '~~' L c,,J. - ~ 'l'~'" ~t~' " SHERIFF'S RETURN - REGULAR CASE NO: 2001-01490 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS FORSYTHE ROBERT B ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FORSYTHE ROBERT B A/K/A FORSYTHE R B the DEFENDANT at 0010:07 HOURS, on the 23rd day of March , 2001 at 400 E SIMPSON ST MECHANICSBURG, PA 17055 by handing to ROBERT B. FORSYTHE a true and attested copy of COMPLAINT - MORT FORE together with NOTI CE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.20 .00 10.00 .00 34.20 ~~nvt:#-,' R. Thomas Kline Sworn and Subscribed to before 03/26/2001 FEDERMAN & PHELAN ---- By: me this ::1<1 ~ day of ~~ ~i A.D. :;r~ 0 n,'#/h ',A1riZ7 P 0 honotary '" ~, "~. b.,~ i..... - ~ '.<11I1 I . ...- -'~;: . " ... , . FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION COURT OF COMMON PLEAS PLAINTIFF vs. CUMBERLAND COUNTY No. 01-1490-CIVIL ROBERT B. FORSYTHE A/K/A R.B. FORSYTHE RITA M. FORSYTHE DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. ~~~ I-tkvw'-WnJ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: March 29, 2001 ~~' .'. -~~' ,=- J; R-537 .-. _',,",,",w i[[~,~j, MAR-14-01 14:24 2155p37588 03/14/01. WED 1,4:02 FAX 2155637588 .. '" P.02 FEDERMAN & PHELAN Job-166 ~ . Ii!I 002 '... .. ROBERT B. FORSYTHE, A/K/A R.B. FORSYTHE #6838603878 VlmTFTCATTON , -~ hereby states that helshe is of mortgage servicing agent for Plaintiff in this matter, that helshe is authorized to take this Verification, and that the statements made ill the foregoing Civil Action in Mortgage Foreclosure are true .and correct to the best of his/her knowledge, information and belief. The undersigned .... .. understands that this statement is made subject to the penalties of 18 Pa, C.S, Sec. 4904 relating to unsworn falsification to authorities, EFT VICE PRESIDENT .' ~-.. DATE: 01/19/2001 ...' .. ~ . ' - "- I ; - .;';'- -~, ~""" _i,'; I (J~ t FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 FIRST NATIONWIDE MORTGAGE CORPORATION 5280 CORPORATE DRIVE FREDERICK, MD 21703 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DIVISION vs. : NO. 01-1490-CML ROBERT B. FORSYTHE, A/K/A R.B. FORSYTHE 400 EAST SIMPSON STREET MECHANICSBURG, PA 17055 RITA M. FORSYTHE 3804 MARKET STREET CAMP HILL, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against ROBERT B. FORSYTHE. A/K/A R.B. FORSYTHE and RITA M. FORSYTHE, Defendant(s), for failure to file an Answer to Plaintift's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintift's damages as follows: As set forth in Complaint Interest 2/1/01 TO 4/24/01 $49,453.66 $1.081.49 TOTAL $50,535.15 I hereby certify that (I) the addresses of the Plaintiffand Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached, '1AiJ;1iJ -::JdtA /Y~ FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: flr'; P .J.'l, .2 (}-{J / ROTHY "TillS FIRM IS A DEBT COLLECIOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATI OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUYfCY AND TillS DEBT WAS NOT REAFFIRMED, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECI A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, .. , ;;:iliO!ll;iil1lij!;~i"'..-i-", ~m~M!lJ:i!&J! "'d_~iil!il~ ~,~;ii!iiljlt ,'- ,~.k,.f~l ihiF,!("",,;L >ifu'ht.:,;~.-,%~:,. ""'liii"'" VJNVA7;\SNNBd JJ.NnoO GNV?I1::Jswno 62 :ZI Hd $2 YdV fa IU"'ll)~'J,i('II'n', """ I\ov ,'-<c..' ',~~t/CJ.Q ~;'tt!. "'i1'~"j!C ""_, "'I,,), " I-,J..J !I~ ~....,.!, ~. '-J I..; LJ!L~~~ w~ .,-~,'._-=;-"..'~ "__ .0.." ,,~~<,_c,~, ~_ ~~ ,;n liIIlI{u' - ill t " " ,,,J.~1-I4""~"'~ .."_-'-"U~" l . FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE CORPORATION MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY ROBERT B. FORSYTHE, A/K/A R.B. FORSYTHE RITA M. FORSYTHE NO. 01-1490-CIVIL Defendant(s) FILE COpy TO: ROBERT B. FORSYTHE, A/KIA R.B. FORSYTHE 400 EAST SIMPSON STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: APRIL 13.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LlBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff W-~ .,' ~--"""""~~J._,.J.-~"",'"'-' ~ 1__ + l . 1:4[" _/'I f FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY ROBERT B, FORSYTHE, A/K/A R.B. FORSYTHE RITA M. FORSYTHE NO, 01-1490-CIVIL Defendant TO: RITA M. FORSYTHE 3804 MARKET STREET CAMP HILL, PA 17013 rlt r CO'PYr '_ I,,' ^--" . DATE OF NOTICE: APRIL 13.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff , '"~ lw _'.. >-','h__ . '<':t: " f FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One PelUl Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 01-1490-CIVIL ROBERT B. FORSymE, AlK/A R.B. FORSYTHE RITA M. FORSYTHE Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUlRE, hereby verifies that he is attomey for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant ROBERT B. FORSYTHE, AIK/ A R.B. FORSYTHE is over 18 years of age and resides at 400 EAST SIMPSON STREET, MECHANICSBURG, P A 17055. (c) that defendant RITA M. FORSYTHE is over 18 years of age, and resides at 425 GARDEN DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falsification to authorities, :tAJJnJ1 ~ /d//)/YU'W'G FRANK FEDERMAN Attorney for Plaintiff . , . ~ ~ "' ~", J.j~( '" j (Rule of Civil Procedure No. 236 - Revised) FIRST NATIONWIDE MORTGAGE CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 01-1490-CIVIL ROBERT B. FORSYTHE, A/KJA R.B. FORSYTHE RITA M. FORSYTHE Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on APRIL J s' . 2000. By f},UU 0 /twh~ f DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attomey for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TIllS IS NOT AND SHOULD NOT BE CONSTRUED to BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT 0F A LIEN AGAINST PROPERTY. ** ~~lIHfltifmM~imflj!liW~ijiw,t~~'<?tl!:"jJj"li"'f~,_~,';d.~,ro"",.;,,ji;;ifi',"{r~;-;;--,,;.,,;;;~j."1rrir\i'Wr~i'i' ""_IO;iil!awG,-iin~" 18Ifi II ~" ~ . . (") 0 0 ~ -n ". .,,-~ S2SJ "'0 T XI ;''''1~~ ~.~ N -"~liT\ U. -C'y (-;) ,-0 ~O '-l~_ -0 -,- ", ~O :x i"~23 ''''p >8 ~ (Sf! ~ ~. N ?6 '.0 -< If ~ t J? .. ~ ~ -f ~, , 7-' i.A.. , 0 fro . t '- ......, '- "" ~ - I;'- 0() 'E ~ ,'- rlllm .=",b_ ___. _~, ~.. .,<c ~, "~,, ,__~'" __,. ,I 0" "0 , 0," J ~ "'. ~ ~ > ~' ,--, '.' O~".__ ',1 ., PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, v. No.Ol-1490-CIVIL ROBERT B. FORSYTHE, AIKI A R.B. FORSYTHE RITA M. FORSYTHE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $50.535.15 / Interest from 4/25/01 TO 9/5/01 (per diem - $8.31) $1.105.23 and Costs TOTAL $5l,640.38 'W1~ FRAJ{KFEDE~,ESQU]RE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attomey for Plaintiff Note: Please attach description of property.No. ,,,j~~e:it~!!il.~~~~~~'W1Ni~t.$[<!bj'!H~~i"'"\'''',",;h'';'''J";;H,;~';;.'rlMicifrkilltmlMII~~" ~-,'" ^ II'''' -';"~~1'11i1' 1-'" l-, ~, ~ ,--~.- ti!i-, , ,0 E-< "'"'" "'"~... == ~ E-<E-<'" ><00< ~E-<~ o~~ I'<< "" ... . == ~ ~ <-.r~ "'" E-<o 1'<<:$ == ;~U E-< Z OZ >< 00< gJ 0 E-<:::: t5 ... <> E-< ","0 "'"~ 0 >:l . ~ ~ ~ I'<< ""00 ="'" U "'"","E-<< .,,; ~Z ~'F ====CI.l~ <ll Zz ~ ~== "'" = ~~Zc5 ~ ci 0"," OZ <E-< '" '" ~~ ~8 ~~ I'<< 0 ~~~~ <ll .~ oC:: ..0 ~ . >, o~ ","E-< <~ <ll Oo~=:l ,::> E-< .. .. ,::> S~ on .0 ;~ I'<<I'<<~CI.l S <::> UZ . ...u N I'<<>:l ~O ... ","I'<< ~~ =:l .00... '" == . E-<=:lE-<~ >-< g <ll 00 Z~ E-<~ ~~ ~~~== g. E-<U 80 ><< ot: [:il<","u p.. [--< ~~ ~E-< <ll >:lZ E-<u I'<< 0 o~o"," >-< < 0; "'"6 <ll 0< Z ~<~~ ..c: uE2 I'<< ~ ~ E-< ... 0; "'""'" ~ = U '" ~ <ll ===:l ~ .i:j ~ E-<~ S <ll ~ "'" .~ Z>:l ~ fI" ...u =:l ~ 0 ....,-'" .~'~, C :y; -ol~ -". CfJFi" ,~ :fe -< c'. , i"~, C/) ,. C> ~~L, ,~ . ,.! i <,c. -" , ~::::; '" .,. '+1 5C) ::;;: ,'-~ -.,-;:c; ;;3.;'(:1 ~s (:jf f'; ""- I" s;! =<! D :n -< t ~ " '," ,,=, ~~ .. "~ ~ --" - "'--. .~ lBi"',,,,j , \ ALL THAT CERTAIN Lot Not 2, Block Kon Plan No.1, Windsor Park, Lower Allen Township, Cumberland County, Pennsylvania, as partly shown on the Plan dated January 31, 1959 as revised March 27,1959, by D, P. Raffensperger, R.S., and recorded in Plan Book 17, Page 90, more panicularly described as follows, to wit: BEGINNING at a point on the Westerly side of Windsor Boulevard, said point being !O5 feet south of the Southwest intersection of Windsor Boulevard and Wesley Drive as shown on the said revised Plan; thence South 45 degrees 22 minutes West along the Westerly side of Windsor Boulevard, a distance of 73.05 feet; thence by same on a curve to the right with a radius of 130,64 feet, a distance of 3.35 fee to Lot No.3; thence North 44 degrees 38 minutes West along the division line between Lots Nos, 2 and 3 a distance of 76.4 feet to a point; thence South 44 degrees 38 minutes East along the division line between Lots No. 1 and 2 a distance of 120 feet to a point in the Western line of Windsor Boulevard, the place of BEGINNING. HAYING thereon erected a dwelling house known and numbered as 5203 Windsor Boulevard. TAX PARCEL NUMBER: 13-23-0559-004 Being known as: 5203 WINDSOR BOULEY ARD, MECHANICSBURG,P A 17055 TITLE TO SAID PREMISES IS VESTED IN R b . by Deed from Edward M Atkinson and . 0 ert P. Fo!sythe and Rita M. Forsythe, his wife 6/9/86 m' D d B k Y Y, I Pearl L. Atkmson, hIS WIfe dated 6/6/86 and recorded ee 00' . 0 ume 31 Page 105. 1~~1f!!-" _ _i!I!iMitl~>4~ _ __ 'WID~I!-iI~illiit'ti~w.~>bl"',\,,'\, 0+: - _. 0-' ~ <>' vJ -.0 .,-l ~ .,~, ^' O~ ""1i",,~U,;-,,i-;'fd,~,r;,"biM,Ia,;,'.e"" .I. '~ ............'.~'~~'~ ,.~-~- 'd!Jjl[":;-I"'-" I,' '.I!lliUr:BI -, " 8 ~ \u \" - ,G. c---.. cl J ~ ......... ~J ~ OJ ~-"'" ~ .,..s) ~ ~ ?'\~- ~ t:;' CI< . "'" d I::> I o C ?' vi?!', nt f'i;; Z"" Z(:' 0'),1':,' -<.2C: r;:Cj =i;Ci ~Cl .J- C- ~ o o "n .- ..... ~ ....., ;:,' , --l'i "-~.;\~ ,~...oi;6 -r-ri ;;"~l'l ~:~; (") 25 fTi ');! :0 -< ,:;) '" ::s: ," o ,. '\ i I I I , I , I I I I el '$#" ~'~'~"".''"''''~~Ir.r... ,_VV," I" , " , ...."', li'1?'!!k'!:;', " " t FIRST NATIONWIDE MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS ROBERT B. FORSYTHE, AlKJA R.B. FORSYTHE RITA M. FORSYTHE CIVIL DIVISION NO.Ol-1490-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, I) FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attomey, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 5203 WINDSOR BOULEVARD, MECHANICSBURG, P A 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT B. FORSYTHE, AlK/A R.B. FORSYTHE 400 EAST SIMPSON STREET MECHANICSBURG, PA 17055 RITA M. FORSYTHE 425 GARDEN DRIVE MECHANICSBURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~I~~_'''''''~ ~~ ~ .. w~o ,~~~, , ~. - ,- 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5, Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiffhas knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 5203 WINDSOR BOULEVARD MECHANICSBURG, P A 17055 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. W~ FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff Mav L 2001 DATE ,~ilJ;Il!ijl~_I!-\j*~i!il'm.m'~fli~~~J!Ji'lJill)ti~.d";,,,ml':ii"'IYO' "Je~;;;'."~"'-"'-"""'!"/fi,ffii~Joi'?iIi ,~~I' 'e ~'lilll:.ti"""~'~~I!iliJ~i;!~.~itlJ<d ""'"C"""'~" ",~,_~,,',_~-'.~_"~~,< ,"~~_ ~'~",' ," , " '''~ ~ L c. ~" (') C -otfl mer; Z':c' ZC (/' l.-~ "<:2:: s::::C; ~,E:; :PC: Z :::: C) ..". -".. ",. -< '~ .'.. n ':::--f'! <::> 'Tl i= ~ ':~'~~ '\,j- ~~X~, 'J.;:" ::D -< -0 ~"'l~ - N C) ! 1"-- .~ ' "~ I , '_'1,',1" ' ~'" ~~'-'- "~' . "" 1l!iil<l-; FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION ROBERT B. FORSYTHE, AJKJ A R.B. FORSYTHE RITA M. FORSYTHE NO.0I-1490-CIVIL Defendant(s). C~RTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the preIhises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant ( X ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities, ~~ FRANK FED RMAN, ESQUIRE Attomey for Plaintiff .ill -iSi"O-"~_~iiiiliiI!!IiliIhilll~jj,j;~~lIOO~ill!ll~!!i:ll''r..JJ"''<>~,'"I'.m&1 !dG,;;"m:,;j~*i_ "- "--~'toIL"'=~ f...'~~IiHhlillll'WIi'~illilltil ~,.;..,."~I '- ~ ,,^ ",~ ,~ M.="="__"~ ~," ~,~, M__O, ~, "-,~ fIIIti< (') 0 () c: Tl $'~ ::J:: -00,) :J:i'-"lI mn'! -< Z::L Ze; 0 CfJ___ -<L l<':::; -0 d:';C~' :r: L_C'" C~ ;PC-':: 2': N :...;; =< ~, C) -< -- . ~,.,~' ~ . ';"'t;. . , FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v, No.Ol-1490-CIVIL ROBERT B. FORSYTHE, AlKlA R.B. FORSYTHE RITA M. FORSYTHE Defendant(s). May 4,2001 TO: ROBERT B.FORSYTHE, AIKIA R.B. FORSYTHE 400 EAST SIMPSON STREET MECHANICSBURG, P A 17055 RITA M. FORSYTHE 3804 MARKET STREET CAMP HILL, PA 17013 **POE** "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 5203 WINDSOR BOULEVARD. MECHANICSBURG. PA 17055, is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 5. 2001 at 10:00 a.m, in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by FIRST NATIONWIDE MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5. 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment wljS improperly entered. You may also ask the Court to postpone the sale for good cause. I 3, You may also be able to stoplthe sale through other legal proceedings. .5IJ" I ~ " L " ~ llilllllJl< '0', ~......'. -,<' " lIill.:L~i t , You may need an attorney to assert your rights. The sooner you contact one, the more chance , you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To find out if this has happened, you may call (717) 240-6390. 4. If the. amount due from the. Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 _o,~ ~ ~,l.. ~~ ~ ',. , ALL THAT CERTAIN Lot Not 2, Block K on Plan No, 1, Windsor Park, Lower Allen Township, Cumberland County, Pennsylvania, as panly shown on the Plan dated January 31. 1959 as revised March 27,1959, by'D, p, Raffensperger, R.S., and recorded in Plan Book 17, Page 90. more particularly described as follows, to wit: BEGINNING at a point on the Westerly side of Windsor Boulevard, said point being !O5 feet south of the Southwest intersection of Windsor Boulevard and Wesley Drive as shown on the said revised PI3Il; thence South 45 degrees 22 minutes West along the Westerly side of Windsor Boulevard, a distance of 73,05 feet; thence by same on a curve to the right with a radius of 130,64 feet, a distance of 3,35 fee to Lot No.3; thence North 44 degrees 38 minutes West along the division line between Lots Nos. 2 and 3 a distance of 76.4 feet to a point; thence South 44 degrees 38 minutes East along the division line between Lots No. 1 and 2 a distance of 120 feet to a point in the Western line of Windsor Boulevard, the place of BEGINNING, HA YING thereon erected a dwelling house known and numbered as 5203 Windsor Boulevard. TAX PARCEL NUMBER: 13-23-0559-004 Being known as: 5203 WINDSOR BOULEVARD, MECHA1"ITCSBURG, P A 17055 ~;T5;J7ro;'\~~::~S~~~~S~~E~ IN Robert P. Fo~sythe and Rita M, Forsythe, his wife 6/9/86m . De~d B k Y y' 1 ear! L. Atkinson, hIS WIfe dated 6/6/86 and recorded ~ 00 , 0 ume 31 Page !O:I. . '." "0 (") a, C) C Tt s: ...;;.. -Ow ",. -lj mp, -< ,- Z:JJ "I: '71- "!,"'( t:] ~~~ <=) ..C> r:~c; " ~j~~ < );-..,., ~ ~O ~~j'-I >c Z '" =<! :n <::l -< ',-- ~.i _', , c d ~ , "j~ .f AFFIDAVIT OF SERVICE PLAINTIFF FIRST NATIONWIDE MORTGAGE CORPORATION No.01-1490-CIVIL DEFtNDANT(S) ROBERT B. FORSYTHE, AlK/A R.B. FORSYTHE, RITA M. FORSYTHE Type of Action - Notice of Sheriff's Sale SERVE ROBERT]J. FORSYTHE, AlK/A R.B. FORSYTHE AT 400 EAST SIMPSON STREET MECHANICSBURG, PA 17055 Sale Date: SEPTEMBER 5, 2001 SERVED servedandmadeknQwnto~B- (i:,~syf-I...J... ,Defendant, on the (L../fh. dayof d~ ,2004, at /0:'::'-70 ,0'c!ocktL,m.,at ^lOa ~. 5IrnjJ$oY) :;+/ -12Ur;/'~frJH5 bCr'':j/6..., ,Commonwealth ofPenusylvania, in the manner described below: ~Defendant personally served, Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s), Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: AgeUty (p S- Height 5'l('LS' ;!l"'Weight illLl.c Race .IAL.- Sex ~ther !, ; " , r a competent adult, being duly sworn according to law, depose and state that! personally handed a true and correct copy of the No ce of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above, Sworn to and SU.bSCribe~d before me this llJ;:L d (J I. n r-" of '1711~ ,200L l'1II/V _ Notary: By: NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Swom to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 'o~ _: _ i " I ~ l_ ~,_: ='",1. , ) {') 0 ~ ~ ~ " c... .'-', ~fiJ c::: ~l:~, Z fq~~--: r -,:;fTl gst; CT'I ;i;7y ~2: :-?c> ~D " ..,."~,~ (~fJ ?fo ::ll: -;;>-.... ') :i>8 S' o,m ~ 0 ?i! -..J -< -!l!<<"'-->="- ,C."~"~_~, ~~ =~. ~, ......J.~'~...MiM,.', t AFFIDAVIT OF SERVICE PLAINTIFF FIRST NATIONWIDE MORTGAGE CORPORATION No.01-1490-CIVIL DEFENDANT(S) ROBERT B. FORSYTHE, A/K/A R.B. FORSYTHE, RITA M. FORSYTHE Type of Action - Notice of Sheriff's Sale SERVE RITA M. FORSYTHE AT 3804 MARKETSTREET;CAMI' HILL, PA 17013 **POE** Sale Date: SEPTEMBER 5, 2001 SERVED Served and made known to Rik -{2or5(<(I1u.-. ,Defendant, on the 11fA dayof 1JIl~ ,200-1, adO: 10 . o'clockl1.tn., at 38b! tiki< t-ef S:--.f J f!& rnf ;,t. /0 fJe. r? 6 1'3 . Commonwealth of Pennsylvania, in the manner described below: if..--- Defendant personally served, Adult family member with whom Defendant(s) reside(s), Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant( s) 's office or usual place of business. an officer of said Defendant(s)'s company, Other: Description: Age dol (r r. ~ Height fi.!:l5'!'W eight t1J.:l (,0 RacevJ,"~ VSex J2~:Jther [,~tlln~ ifJ P R" Pkrf.t ( , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy ofthe1Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subs~J~ed befor me this ~ day of . ,200t Notary: t~~BY: NOT~R!tlh On the day of , 200~ at o'clock _.tn., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite t400 Philadelphia, PA 19103 (215) 563-7000 - . !:l1~ __~.jiltimllfi:II'&Q.iIIil.~l!;\~!fu;,:{j~~&~"~!dh.~i;';j,""~1-'",1\,'<H;il!:",'lII~J>'.." J ILl '~ ~ ~.'".'~,- ~~ - <, ,~~_.~~ .iiUltli'u""'" 'I "_ilWlilllllllb.i&Hl:iLJ~"'~IW"~ 1 0 0 0 ~ ., '- --'J "'l:lCC c: ,- ~93 :;z ;'~:1=.J ~c: I i~~ """ en ~/.. 0 ~ -0 ~5?Q ZO ::>::: ''7'(,; >8 ra om ~ 0 ~ -.I -< .. ,,,,,-,~,~,-..,~~ .. First Nationwide Mortgage Corporation VS Robert Forsythe and Rita M, Forsythe c In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-1490 Civil Term ". "' E!.!!>'!I'_ R, Thomas Kline, Sheriff, who being dilly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriffs 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 30.00 15.00 .50 1.00 25.66 21.41 15.00 15.00 1.36 4.35 63.75 $ 223.03 paid by attomey 8/31/01 Sworn and subscribed to before me This /6'5:' day of ~ 2001, A.D. ~ a. ?lu//;"j~ Prothonotary So Answers' rfi?:.~-t:~~ R. Thomas Kline, Sheriff BY ~~h J;vufA R I Estate Deputy { \,?:' en.. 3,>8'3'1 ~_ 11(, JoJ' ,,~*""'"'..,"~._.~,. - .-< , , '" - '" ].lIAl~i> f!' ". ! . , FlRST NATIONWIDE MORTGAGE. CORPORATION CUMBERLAND COUNTY Plaintiff, v, COURT OF COMMON PLEAS ROBERT B. FORSYTHE, A1K/A R.B. FORSYTHE RITA M. FORSYTHE CML DIVISION NO,Ol-1490-CIVIL Defendant( s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 5203 WINDSOR BOULEVARD, MECHANICSBURG. PA 17055. 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ROBERT B. FORSYTHE, AJKJA R.B. FORSYTHE 400 EAST SIMPSON STREET MECHANICSBURG, PA 17055 RITA M. FORSYTHE 425 GARDEN DRIVE MECHANlCSBURG, PA 17055 2. Name and address of Defendant( s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) None 'lli!.'~--","" , , - " '> ',,--, "~' - - ,f., , ~ :" ~ , 4, Name and address ofthe last record~d holder of every mortgage of record: NAME LASt KNOWN ADDRESS (If address cannot be reasopably ascertained, please so indicate.) :' None 5. Name and address of every other pekon who has any record lien on the property: Ii " NAME LASt KNOWN ADDRESS (If address cannot be reasopably ascertained, please so indicate.) None 6. Name and address of every other pe*on who has any record interest in the property and whose interest may be affected by the sale: I , NAME LAS1 KNOWN ADDRESS (If address cannot be reasojlably ascertained, please so indicate.) 'I None 7. Name and address of every other per~on whom the plaintiffhas knowledge who has any interest in the property, which may be affect4d by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 5203 WINDSOR BOULEVARD MECHANlCSBURG, PA 17055 Domestic Relations of Cuml:1erlaJd County I 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. W 'Mvu-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Mav 1. 2001 DATE .', . 'il . . FIRST NATIONWIDE MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v, No.Ol-1490-CIVIL ROBERT B. FORSYTHE, AlKlA R.B, FORSYTHE RITA M. FORSYTHE Defendant(s). May 4, 2001 TO: ROBERT B. FORSYTHE, NKlA R.B. FORSYTHE 400 EAST SIl\1PSON STREET MECHANICSBURG, PA 17055 RITA M. FORSYTHE 3804 MARKET STREET CAMP HILL, PA 17013 "''''POE'''''' "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY," Your house (real estate) at 5203 WINDSOR BOULEVARD, MECHANICS BURG, P A 17055, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a,m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by FIRST NATIONWIDE MORTGAGE CORPORATION (the mortgagee) against you, If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale. . NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The salewill be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable att,?mey's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3, You may also be able to stop the sale through other legal proceedings. u, ~ ~. .. " ~ ~",- ^ '"' '. ~~,){lh< . You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOEST AKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, Y ou may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, . 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390, 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the mo'ney bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7, You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 '~ ~ ^" ,~ ~~ lI.U8r"~If'WF~' , . ALL THAT CERTAIN Lot Not 2. Block Kon Plan No,!, Windsor Park. Lower Allen Township, Cumberland County, Pennsylvania, as panly shown on the Plan dated January 31, 1959 as revised March 27, 1959, by D, p, Raffensperger, R.S., and recorded in Plan Book 17, Page 90. more panicularly described as follows, to wit: BEGINNING at a point on the Westerly side of Windsor Boulevard, said point being 105 feet south of the Southwest intersection of Windsor Boulevard and Wesley Drive as shown on the said revised Plan; thence SOuth 45 degrees 22 minutes West along the Westerly side of Windsor Boulevard, a distance of 73. OS feet; thence by same on a curve to the right with a radius of 130,64 feet, a distance of 3.35 fee to Lot No.3; thence North 44 degrees 38 minutes West along the division line between Lots Nos. 2 and 3 a distance of 76.4 feet to a point; thence South 44 degrees 38 minutes East along the division line between Lots No. 1 and 2 a distance of 120 feet to a poim in the Western line of Windsor Boulevard. the place of BEGINNING, HA VING thereon erected a dwelling house known and numbered as 5203 Windsor Boulevard, TAX PARCEL NUMBER: 13-23-0559-004 Being known as: 5203 WINDSOR BOULEVARD, MECHAL'fICSBURG, P A 17055 TITLE T? SAID PREMISES IS VESTED IN Robert P Forsythe and Rita M. Forsythe, his wife by Deed tram Edward M. AtkInson and Pearl L Atkinson, his wife dated 6/6/86 and d d 6/9/86 III Deed Book Y. Volume 31 Page 105, recor e ~~~ ........,...... " ~ "~'" "~"''',4_!.l-f",'h " WRIT OFE*ECUTION and/or ATTACHMENT , .t:"i CIVIL 19 . CIVIL ACTION - LAW 01-1490 COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND} NO. TO THE SHERIFF OF CUMBERLAND COUNTY To satisfy the debt, interest and costs due _.-.I"~.:..s!_ Nationwide Mortgage Corporation PLAINTIFF(S) R. B. Forsythe, 400 E. Simpson St., Mechanicsburg PA Forsythe, 425 Garden Dr., Mechanicsburg PA 17055. from Robert B. a/k/a 17055 and Rita M. DEFENDANT(S) Real estate located (1) You are directed to levy upon the property of the defendant(s) and to sell __ at_5203 Windsor Blvd., Mechanicsburg PA (See attached legal ~~s(,ription. ) (2) You are also directed to attach the property of the defendant(s) not liwiedupon in the possession ot GARNISHEE(S) as follows: and to notify 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 thereat; (3) If propertyof thedefendant(s) not levied upon an subject to attachmentisf6und inthe possession of anyone other than a named garnishee, YOlj are directedlo notify him/herthat he/she has been added as agarnishee and is enjoined as above stated Amount Due $50,535.15 LL 1$8.31 per dlem) -- Interest 4/25/01 to 9/5/01 $1,105.23 Due Prothy $.50 $1.00 Other Costs Atty's Comm Atty Paid Plaintiff Paid % 131. 50 Date May 10, 2001 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY by --6~ tJ-/7~- Deputy Frank Federman, Esq. One Penn Center @ Suburban Statlon Address ::Juitc 1400 Philadelphia PA 19103 Attorney for: Plaintiff (215) 563-7000 Name Telephone: Supreme Court ID No, 12248 ~".-" "~J'j 1Iil~~~!~ - "w.a.I~I*#w;~"'S')-!i'.,";~"''''<H'.8:,l;;,;jl,''1<lil'-2a,ffl.!i.Jt~j-]jl j;jjj lit...."'" H 'iilflw.IiJ!.~~~~~- ~ I' REAL EST ATE SALE No; I~ r ~ ~ I::::;:::i ~ On 1f.~ 11/, ;JOO J the snerift levied upon the oetelllii.l,. . Interest In the real property situated in ~DL/Jt.-1. (] gOo n/tSU...l;tdup . Cumberlland County, Pa., known and numbered as: 5,)()3 UUJUU)(J(~ rt{uhonlG/JbwJ~and more fully described on exhibit "A" filed with this writ and by this reference Incorporated herein. _~I~,;loD' By: R;,~~ '\\.~o , c, "'.. ~ ""\ I" '- > ~ ~ \ "'~~ c \>.\" .. \ \ \.\'f, \ <:;,\\ <(, . '\V ,\\ \\6. \,j"'\' >,Il ,\}\ \. " ~~; 3':'1 ";l , ... , ',)v ",\\J'-' "1\\'~ ;~\\-;"s ~,~~~.~ "yl. --~-~_ '~O____~_,_~_,...._~_ REAL ESTATE S)\LE No. 15 Writ No. 2001-1490 i--,- __" _ ClvilTert'n I'lrsili.liOnwi~ Mortgage ~-.CC ,Coljloratl<ln 1':". Fe''''''.. .. ~. .. ~ODei!B.FCll'.Ythe;" . ~".~A!l<JA.. R,a. . FO.'.rsrsythe . -------=-=---_c _-, - 'ACta M. Forsythe ~...~,' ~; Frank Federman " . . . DESCRIPTION - [~~AT c&i~ioh'l~. 2, Block K on ~'fW:'1, WfnllWiPark, Lower Allcn TO\vn.\hip, :- Cumberland County. PcrlO~ylvania. as partly '~wn on the Plan dated January 31, 1959 a~_ ==1$:':11-,,1:;,11 March 27, 1959. by D. P. R:lfft'n~pcl]~'f, 'It--S-.; and r,,'Corded in Plan Book 17, P..l!l(; 90. ~~:Irticu[arly described a~ follow~ to wIt ~ EGINNL'l'G a( a point on tbe Wl.'~e-r)y l>ide of - oub'ard. silid -point bdng' 105 ft.'1.'! xl1vresri1\(crscction C>fWinJ."-lr an :-'Wcslcv'Drivc; 3,5 ~hown on thl.: ~:lli.! an;lhetkc~!1i45 degrees 22 mintlt..'i ~est al'ong'-fue ."WMrly SlOe ,of Win&or ~BQt'ifc-riUU: a distance of n05 foct; thence bY -9amc on, a curve- \0 the right with a radiu,; of ~'@-fcel~a dist:.mcc of :).35 f~et to Lot No.3; " thence Ndrth 4:4 degrees 38 minlltes \\bt along , .-., Vision~iin<: betwccn Lots Nos. 2 nnd 3 a ofi6:4 fect'tQ. a point; thlincc South 44 38 'ri;lnilleS Ea~1 along the d;\"ision !irw --.---'--- w';.-en Lots No.1 and Z,a distance ofI20f~e( III ,,~~'ot in t1lc Wc~tem line ofWinowr Boulevard. ~_(h~place ofBEOINNING. ': HAVING thereon erected a, dwelling house: '7' kno\-vn and numbered as 5203 Windsor BOulevard, ' :CrAX PARCEL NUMBER: !3.23.1l559.OIH. : BEING KNOWN as: 5203 Windsor Boulevard. Mechartlcsbur,g. PA 17055. ~.o TO SAID PREMISES ~ ""ted in Robert -i'"ITtOrSythcoaM Rita M. Forsythe. ilis wile, by rJ;l1:ed from Edward M. AtliJl.~l) and Pearl L. ~'tt.inwif. hIS Wife. dated 6161'l,6 and tcconkd 6/ J:~~~~~~"~_~~~_~_~~~_~05. ~ ~ J. ".",,1'-' ~'-";a.-"","""",."",,,_ , , THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its 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 IJla Patriot-News and The Sundav 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 day{s) of July 2001, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Mirlaneous Book "M", V;I;;~I~:~~~~' ..................................11......... COpy S ~WII e e me i S ALE #15 TenyL._,NoWy Harrisllufg. DeupIIIn My Co/nIllII&lOn E....... JunO', !Vania "._'"t'"". ~ NARY PUBLIC Memll&r, Pennsy --, My commission expires June 6, 2002 '- CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURlHOUSE 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 $ 62.25 1.50 63.75 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....................................................................