HomeMy WebLinkAbout01-1746 FX
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
TIMOTHY K. TRAVITZ AND
ANITA M. TRAVITZ
(Mortgagor(s) and Real Owner(s))
Term
No. 01 - l7J.ffo
Cio~L'r~.
18 S. Second Street
Wormleysburg, PA 17043
Defendant(s)
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTIN~
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION!
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money 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 Bar Association
2 Liberty Avenue, Carlisle, PA
('000) 990-910'0
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE BAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON E8TA DEMANDA Y AV1S0.
PARA OEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONtES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE: Y REQUERlRA QUE USTED CUMPLA CON TODAS
LAS PRO"\7ISIONES DE ESTA DEMANDA. POR RAZQN DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLE"\7E ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
81 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215-238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
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1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate
Drive, PTX B-35, PIano, TX 75024-3632.
2. The name(s) and address (es) of the Defendant(s) is/are
TIMOTHY K. TRAVITZ, 18 S. Second Street, Wormleysburg, PA 17043 and
ANITA M. TRAVITZ, 18 S. Second Street, Wormleysburg, PA 17043, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On August 29, 1997, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
BROADVIEW MORTGAGE CO., which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County in Mortgage Book 1402,
Page 683. By Assignment of Mortgage dated August 29, 1997, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 559, Page 676. These documents are
matters of public record and are incorporated herein by reference
in accordance with pennsylvania Rule of Civil Procedure 1019(g).
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 October 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 9/ 1/00
through 3/31/01 at 8.000%
Per diem interest rate at $21.12
Attorney's Fee at 5%
of Principal Balance
Late Charges 10/ 1/00- 3/31/01
Monthly late charge amount at $43.64
Costs of suit and Title Search
Escrow Balance Credit
Monthly Escrow amount $146.17
$ 96,347.91
4,456.32
4,817.40
261. 84
560.00
$ 106,443.47
84.32
$ 106,359.15
7. The Attorney's Fees set forth above are in conformity
with the Mortgage documents and Pennsylvania law, and, will be
collected in the event of a third party purchaser at Sheriff's
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. The within mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $106,359.15, together with interest at the rate of
$21.12, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
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By:
GOL AFFERTY & McKEEVER
BY: 00seph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
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VERIFICATION
I, , as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on_ behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn ation to authorities.
.;t/wUJoYd:(
Date:
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Lel!a1 Descrintion:
(ALL THAT CERTAIN lot of ground situate in the Borough ofWormleysburg, Cumberland County, Pennsylv8nta,boimded
and described as Follows, to wit:
BEGI:NNING at the southwest Climer of Second Street and First Alley; thencc extending along Second Street in a southerly
direction 65 feet to property now or formerly of Sadie Zarker; thence extending along thc property now or formerly of Sadie
Zarkel' in a westerly direction, 130 feet to an alley; thence extending along said Alley in a northerly direction 65 feet to First
Alley;> thence extending along First Alley in a easterly direction 130 feet to Second Street, the place of BEGINNING. .
HAVING THEREON ERECTED a two and one-half story house known and numbered as 18. S Second Street,
Wormleysburg, Pennslyvania, and on the rear, a one story bungalow.. .
UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record or visible
upon inspection of said premises.
BEING the same premises which Richard J. Drag and Jayne M. Drag, his wife, by Deed dated June 28, 1996 and recorded
July 5, 1996 in the Cumberland County Recorder of Deeds Office in Book 142, Page 350, granted and conveyed unto Kenneth
A. Homer and Diane A. Homer, husband and wife.
The said Kenneth A. Homer and Diane A. Homer having divorced and are now single persons. The said Diane A. Homer
having resumed her maiden name and is now known as Diane A.
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SHERIFF'S RETuRN - REGULAR
. CASE NO: 2001-01746 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
TRAVITZ TIMOTHY K ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
TRAVITZ TIMOTHY K
the
DEFENDANT
, at 0015:48 HOURS, on the 28th day of March
, 2001
at 18 S SECOND ST
WORMLEYSBURG, PA 17043
by handing to
ANITA M. TRAVITZ
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
9.92
.00
10.00
.00
37.92
So Answers:
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R. Thomas Kline
03/30/2001
GOLDBECK, MCCAFFERTY,MCKEEEVER
Sworn and Subscribed to before
By:
'\:J~~. ~
Deputy Sheriff
me this /I & day of
Dr:; d-!m / _ A.D.
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SHERIFF'S RETDRN - REGULAR
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CASE NO: 2001-01746 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
TRAVITZ TIMOTHY K ET AL
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
TRAVITZ ANITA M .
the
DEFENDANT
, at 0015:48 HOURS, on the 28th day of March
, 2001
at 18 S SECOND ST
WORMLEYSBURG, PA 17043
by handing to
ANITA M. TRAVITZ
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
.00
.00
10.00
.00
16.00
So Answers:
f!'"fV'~.r~~~
R. Thomas Kline
03/30/2001
GOLDBECK, MCCAFFERTY,MCKEEVER
Sworn and Subscribed to before
By:
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Deputy Sheriff
me this // ~
day of
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(Rule of civil procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Countrywide Home Loans, Inc.
, Plaintiff
Vs.
NO. 01-1746
Timothy K. Travitz
Anita M. Travitz
, Defendants
Notice is given that a Judgment in the above captioned
matter has been entered against you on June
tk
/.;1; ,2001.
By: *,. 0 ~EPUTY
If you have any questions concerning this matter please
contact:
**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 R.ECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,
BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
philadelphia, PA 19106
(210;) 627-1322
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
7105 Corporate Drive, PTX B-35
Plano, TX 75024-3632
Vs.
Timothy K. Travitz
18 s. 2nd Street
WODnleysburg, PA 17043
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-1746
Anita M. Travitz
18 S. 2nd Street
WODn1eysburg, PA 17043
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF n"MI""3ES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
Timnthy K. Travitz and Anita M. Travitz, Defendants for failure to file an
Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is
the United States of America) from the date of service of the complain and
for foreclosure and sale of the mortgaged premises, and assess Plaintiff's
damages as follows:
As set forth in Complaint
Interest - 4/1/01 - 6/8/01
Late Charges
Escrow Debit
TOTAL
$106,359.15
$ 1,457.28
$ 130.92
$ 438.51
$108,385.86
I hereby certify that (1) the addresses of the Plaintiff and
Defendants are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, copy attached.
Goldbeck, Jr.
for plaintiff
DAMAGES ARE HEREBY ASSESSED AS
DATE: (), u .. / :L,JtJo I
INDICATED.
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PRO PROTHY .
I hereby certify that the above names are correct and that the
precise residence address of the judgment creditor is 7105 Corporate
Drive, PTX B-35, PIano, TX 75024-3632 and that the names and last
known addresses of the Defendants is:
Timothy K. Travitz, 18 S. 2nd Street, Wormleysburg, PA 17043
Anita M. Travitz, 18 S. 2nd Street, Wormleysburg, PA 17043
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TO: ANITA M. TRAVITZ
18 S. Second Street
Wormleysburg, PA 17043
COUNTRYWIDE HOME LOANS INC.
7l0S Corporate Drive
PTX B-35
plana, TX 75024-3632
Plaintiff
vs.
TIMOTHY K. TRAVITZ AND ANITA M. TRAVITZ
(Mortgagor (s))
(Record Owner(s))
18 S. Second Street
Wormleysburg, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-1746
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: ANITA M. TRAVITZ
18 S. Second Street
Wormleysburg, PA 17043
DATE OF THIS NOTICE: April 18, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ Jo()eph -A. (jotJbeck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
21.5-627-1322
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TO: TIMOTHY K. TRAVITZ
18 S. Second Street
Wormleysburg, PA 17043
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-3S
Plano, TX 75024-3632
Plaintiff
vs.
TIMOTHY K. TRAVITZ AND ANITA M. TRAVITZ
(Mortgagor (s) )
(Record Owner(s))
18 S. Second Street
WormleyGburg, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-1746
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMI?TING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: TIMOTHY K. TRAVITZ
18 S. Second Street
Wormleysburg, PA 17043
DATE OF THIS NOTICE: April 18, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JO:leph -A. (Jotdbeck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
III S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) fi27-11?2
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Countrywide Home Loans, Inc.
Vs.
No. 01-1746
Timothy K. Travitz
Anita M. Travitz
CUMBERLAND COUNTY
VERIFICATION OF NON-MILITARY SERVICE
JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that
he is attorney for the Plaintiff in the above-captioned matter,
and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that the defendants are not in the Military or
Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief
Act of Congress of 1940, as amended.
(b) that defendant Timothy K. Travitz, is over 18
years of age, and resides at 18 S. 2nd Street,Wormleysburg, PA
17043.
(c) that defendant Anita M. Travitz, is over 18 years
of age, and resides at 18 S. 2nd Street, Wormleysburg, PA 17043.
This statement is made subject to the penalties of 18
Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
June 8, 2001
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
Countrywide Home Loans, Inc.
Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
VS.
NO: 01-1746
Timothy K. Travitz
Anita M. Travitz
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Defendants
TO THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 6/8/01 to sale date
at $17.82 per diem
Total
$108,385.86
$
$
and Costs
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Jo A. oldbeck, Jr.
Suo e 500~~e Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Attorney for Plaintiff
Note: Please attach description of property.
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WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183 and RULE 2357
Countrywide Home Loans, Inc.
P1aintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
Vs.
NO: 01-1746
Timothy K. Travitz
Anita M. Travitz
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Defendants
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA
To satisfy the judgment, interest and costs in the above
matter, you are directed to levy upon and sell the following
described property (specifically described property below) :
Premises:
18 S. 2nd Street, Wormleysburg, PA 17043
(see attached legal d~scription)
Amount Due
Interest from 6/8/01 to Date
of Sale at $17.82 per diem
Total
$108,385.86
$
$
Plus Costs
as endorsed
Clerk
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ALL THAT CERTAIn lot of ground situate in the Borough ofWorm1eysburg, Cumberland County,
Pennsylvania, bounded and described as follows, to-wit:
BEGINNING at the southwest comer of Second Street and First Alley; thence extending along
Second Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence
extending along the property now or formerly of Sadie Zarker in a westerly direction, 130 feet to an
alley; thence extending along said Alley in a northerly direction 65 feet to First Alley; thence
extending along First Alley in an easterly direction 130 feet to Second Street, the place of
BEGINNING.
Having erected thereon a two and one-half story house known and numbered as 18 Second Street,
Worm1eysburg, Pennsylvania, and on the rear, a one story bungalow
Tax Parcel #47-20-1858-071
Being known as 18 S. Second Street, Wormleysburg, PA 17043
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Countrywide Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Timothy K. Travitz
Anita M. Travitz
NO. 01-1746
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
Count~ide Home Loans. Inc., Plaintiff in the above action,
by its attorney, Joseph Goldbeck, Jr., 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
18 R. 2nd Street. Worml~sburg. PA 17043.
1. Name and address of owner(s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Timothy K. Travitz
18 S. 2nd Street
Wormleysburg. PA 17043
Ani~a M. Travitz
18 S. 2nd Street
Worml~sburg. PA 17043
2. Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAMm AS ABOVE
3. Name and address of every judgment creditor whose judgment
is a record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
I.'ilQne
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
HouReho1d Realty Co~.
5105-H Jonestown Road
Colonial Commons
Harrisburg. PA 1712
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5.
Name and address of every other person who has any record
lien on the property:
Name
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
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland Coun~ DElI)t. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa Dapt. of Public Welfare
Bureau of Child Sqpport Enforcement
Health and Welfare Bldg. Room 432
P.O. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
None
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. #4904 relating to unsworn
falsification to authorities.
June 8, 2001
oldbeck, Jr.
or plaintiff
_;.^ '.1.,
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GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(2J '0) 67.7 1122
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
countrywide Home Loans, Inc.
Vs.
CUMBERLAND COUNTY
CIVIL DIVISION
NO. 01-1746
Timothy K. Travitz
Anita M. Travitz
CERTTFICATION
JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is
the attorney for the Plaintiff in the above captioned matter and
that the premises are not subject to the provisions of Act 91
because it is:
(X) an FHA Mortgage
( ) non-owner occupied
() vacant
() Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa.
C.S. ~ 4904 relating to unsworn falsification to authorities.
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?i5) 6?7-J3??
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Timothy K. Travitz
Anita M. Travitz
NO.01-1746
Defendant(s)
NOTTr.F. OF SHF.RTFF 'S SAT,F. OF RF.AT. F.STATE
TO, Anita M. Travitz
18 S. 2nd Street
Wormleysburg, PA 17043
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, 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 18 S. 2nd Street. Worml~sburg.
PA 17043. is scheduled to be sold at the Sheriff's Sale on
SAptember 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland
County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle,
PA 17013 to enforce the court judgment of S108.385.86 obtained by
co.mtrywide Home Loans. Inc. (the mortgagee) against you.
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 attorneys
Fees due. To find out how much you must pay, you may call:
(215) 627-1322
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.
."-~
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....,,,....
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 Sheriff's Sale
sold to the highest bidder.
calling (2]5) 627-132/.
is not stopped, your property will be
You may find out the price bid by
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 the Sheriff's office at (717) /.40-6390.
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 this 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 proposed schedule of distribution of the money
bid for your house will be prepared 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 posting of the Schedule of Distribution.
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?1 S) 6?7-1 ::l2?
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Timothy K. Travitz
Anita M. Travitz
NO.0l-1746
Defendant(s)
NOTH~F. OF RHF.RTFF' R RAT,F. OF RF.AT, ERTATF.
TO: Timothy K. Travitz
18 S. 2nd Street
Wor.m1eysburg, PA 17043
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, 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 18 S. 2nd Street. Wor.mleysburg.
PA 17043. is scheduled to be sold at the Sheriff's Sale on
S~tember 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland
County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle,
PA 17013 to enforce the court judgment of SI08.385.86 obtained by
Countrywide Home Loans. Inc. (the mortgagee) against you.
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 attorneys
Fees due. To find out how much you must pay, you may call:
(2151 627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open the judgment, if the judgment
was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
,
,_~ ' I,
,l, -,-
I" . ~,'--, i- '!;
,
..
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU ~Y STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RTGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale
sold to the highest bidder.
calling (/.15) 6/.7-13/./.
is not stopped, your property will be
You may find out the price bid by
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 the Sheriff's office at (717) /.40-6390
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 this 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 proposed schedule of distribution of the money
bid for your house will be prepared 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 posting of the Schedule of Distribution.
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
~illi>~k~~~~'Ji!iiJii;JliJ.Ul\W.0,~iI~~"""i; ';c"~5,,;;i '1-_';>ruJ!,ffi'''1,'''#M;rt;JJ'*fOlf~~'''~""'''~'''-~'-.~-~~''~~~- ~~~iliii.IlI!IiilIifi~' '''-''''-''-'
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph ~: Goldbeck, Jr.
Attorney 1.0.#16132
Suite 50! - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
vs.
TIMOTHY K. TRAVITZ AND
ANITA M. TRAVITZ
18 S. Second Street
Wormleysburg, PA 17043
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-1746
CERTIFICATE OF SERVICE
PURSUANT TaPa.R.C.P. 3129.2(c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
mall:~Y:
(1/lf Personal Service by the Sheriff's Office/ . ~ " (copy of
return attached) .Per J04leSNllTH eShv"~ff off,u "'" 7{/O/01.
) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) .
Certified mail by Sheriff's Office.
ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached) .
ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) premises was posted by Sheriff's Office/competent adult (copy of
return attached).
certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the
penalties provided by 18 P.S. Section 4904.
,
R Y & McKEEVER
ldbeck, Jr.
intiff
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Co~t~~de Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Timothy K. Travitz
Anita M. Travitz
NO. 01-1746
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
Count~ide Home Loans. In~., Plaintiff in the above action,
by its attorney, Joseph Goldbeck, Jr., 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
18 S. 2nd Street. Wormleysburg. PA 17043.
1. Name and address of owner(s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Timothy K. Travitz
18 S. 2nd Street
Wormleysburg. PA 17043
Anita M. Travitz
18 S. 2nd Street
Worml~sburg. PA 17043
2. Name and address of defendant(s) in the judgment:
Name
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
Address (if address cannot be reasonably
ascertained, please so indicate)
1:IQwa
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Household Real~ Co~.
5105-H Jonestown Road
Colonial Commons
Harrisburg. PA 1712
,,-
.,. <'J
-J. ,,<-' _-I~.. --..:".J~h
5. Name and address of every other person who has any record
'lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Nlmil
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
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County Dept. of
Domestic Relations
P.O. Box 320
Carlisle. FA 17013
Pa Dept. of Public Welfare
Bureau of Chi1d Sqpport Enforcement
Health and Welfare Bldg. Room 432
P.o. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Nlmil
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. #4904 relating to unsworn
falsification to authorities.
June 8, 2001
oldbeck, Jr.
or Plaintiff
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7:LIIIo If 575 :Li!"IlI lfWJS !f8:L 7
TO:TIMOTHYK. TRAVITZ
18 s. second street,-
WOrmleYSbUrg, PA 17043
.
CUMBERLAND
SENDER:
REFERENCE:
GOLDBECK MCCAFFERTY & McKEEVER.
June 8, 2001
TRAVITZ. TIMOTHY
CWD-1133
PS FQrm 3800 June 200rfJ/ 5/01 -
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
RestrIcted Delivery
Total Postage & Fees
K. 1
-"-
"
US Poslal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
7:Lf11o IfS7~ :L~ltItlo1il5' !f8i!1f
TO:ANITA M. TRAVITZ
18 s. Second street,
Wormleysburg, PA 17043
CUMBERLAND
SENDER:
REFERENCE:
GOLDBECK MCCAFFERTY & McKEEVER.
June 8, 2001
TRAVITZ.TIMOTHY K. 1
CWD-1133
PS Form 3800 June 200rfJI 5/01 -
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fee
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mall
"~ ~-
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND
} 55.
Robert P Ziegler
I, --____________________________________________________________________________Ilecorderof
Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which _n_n___n_____
__C.9.1l.Iltry.l'Lic<i!L!l<2.IJ!!L.k<2.'!!)~__l'!~_n___n_______ _nnn_n_____n___n__n______n__ is the grantee
the same having been sold to said grantee on the -----____n______________n2!:!.t____n______n__ day of
September . . 2001 . . .
_________________n___n__________nn__ A. D., ' un_' under and by vIrtue of a wnL_n_n____n_
Execution .
____________________________n_________n_______ ISSUed on the ___n__.J..J.th.n_nn________n____n_
day of ______}_~':!!'_______________ A. D.. 20~_1_n' out of the Court of Cornman Pleas of said County.as of
Civil . 2001
------------------------------..,----------------- --_______________________________ Term, . ~_____
Number ____E4.l1_____. at the suit of ____Q~I}.!:.t:.~l'~_i_<!':_!I_c:~':_!:.c:~~~__~~:nn________nn______n____
__________________ __________ _______ agabtSL__ _ J_~~~E.!:~_~_!:_~~_i_t:~_~__~:~:y_~ ~~__ ______ ______ _ is
duly recorded in Sheriff. Deed Book No. __?~_!!._n_n. Page _n':~~~n___.
IN TESTIMONY WHEIlEOF. I have hereunto
set my hand and seal of said office this ____~_~_ day
of ____u(l)~______________ A. D..J....'" ':'_L_
-~--12"-~R~!~~.:m
Recorder 01 Deeds, Cumberland County. Carlisle, M
My Commission ElCjlires the First Monday of Jan. 2001 '
~-
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Countrywide Home Loans, Inc.
VS
Timothy K. Travitz and
Anita M. Travitz
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-1746 Civil Term
Michael Barrick, Deputy Sheriff, who being du1y sworn according to law, states
on Ju1y 10,2001 at 10:16 o'clock A.M., EDST, he served a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of the
within named defendants, to wit: Timothy K. Travitz, by making known unto Timothy
Travitz, at The Lemoyne Borough Office, Market Street, Lemoyne, Cumberland County,
Pennsylvania 17043 its contents, and at the same time handing to him personally the said
true and attested copy ofthe same.
Michael Barrick, Deputy Sheriff, who being du1y sworn according to law, states
on Ju1y 10,2001 at 9:58 o'clock A.M., EDST, he served a true copy ofthe within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of the
within named defendants, to wit: Anita M. Travitz, by making known unto Anita Travitz,
at 18 South 2nd Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its
contents, and at the same time handing to her personally the said true and attested copy of
the same.
Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states
on July 10,2001 at 9:58 o'clock A.M., EDST, he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action upon the property
of Timothy K. Travitz and Anita Travitz, located at 18 South 2nd Street, Wormleysburg,
Cumberland County, Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants, to wit: Timothy K. Travitz, by regu1ar mail to his last known address of 18
South 2nd Street, Wormleysburg, PA 17043. This letter was mailed under the date of July
13,2001 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, states that he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a pendency of the action to one of the within named
defendants, to wit: Anita M. Travitz, by regu1ar mail to her last known address of 18
South 2nd Street, WormIeysburg, PA 17043. This letter was mailed under the date of Ju1y
13, 200 I and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being du1y sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County,
Pennsylvania, on September 5, 2001 at 10:00 o'clock A.M., E.D.S.T., and sold the same
for the sum of $30,000.00 to Attorney Scott A. Dietterick (for Attorney Joseph Goldbeck)
for Countrywide Home Loans, Inc.. It being highest bid and best price received for the
same, Countrywide Home Loans, Inc. of7105 Corporate Drive, PTX B 35, Piano, TX
75032, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of
$1,430.74.
,~ "-~_.
Sheriff's Costs:
Docketing $
Poundage
Posting Handbills
Advertising
Acknowledging Deed
Auctioneer
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
30.00
600.00
15.00
15.00
30.00
10.00
.50
1.00
20.80
2.41
15.00
30.00
204.95
178.92
25.66
25.00
26.50
$1,230.74 paid by attorney
10-05-01
Sworn and subscribed to before me
-.-..-"
-'-- ~..L .,J,,..~,,,,,,..<,
SOAn~ d.
~ -,...,u<t:~
This~dayof ~
Q R. Thomas Kline, Sheriff
2001, A.D. t" t2 111.0),. , r~
ro onotary By ~,S~
RS Estate Deputy
a-Jv~
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WRIT OF EX!:C?UTIO~ and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-1746 CIVIL 19
CIVIL ACTION. LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
To satisfy the debt, interest and costs due Countrywide Home Loans, Inc.
PLAINTlFF(S)
Timothy K. and Anita M. Travitz, 18 South 2nd st., Wormleysburg
17043.
from
PA
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 18 South 2nd st., Wormleysburg PA 17043. (See attaehed legal
description.)
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
i .";1 ::~ 'I;;~:,:~' .
'l{;/* .,.
," .:'.:;..
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
thereof;
(3) If property ofthe defendant(s) notlevied upon an subjectto attachment is found inthe possession of anyone other
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $108,385.86 LL
6/8/01 9/5/01 @ $17.82/diem
Interest - Due Prothy
$.50
$1. 00
Atty's Comm
Atty Paid $125.92
Plaintiff Paid
%
Other Costs
Date:
June 13, 2001
CURTIS R. LONG
Name
REQUESTING PARTY:
Joseph A. Goldbeck, Jr., Esq.
Suite 500, The Bourse HiOg.
111 s. Ing~nd@oce Mall v.",,+
Philadlephia PA 19106
Plaintiff
Prothonotary, Civil Division
by ~~i!r ~~
Deputy
Address:
Attorney for:
Telephone: (215)
Supreme Court 10 No.
627-1322
16132
~~~~~il~;i~:ti<l"';""'''''-''$)"",._"~',.,'-''-''''l"",,!j),'~'wa~ri~,,,,~~)[1jflil~~~"' "'l"-..IliIil_~~~lllliiiiiltl:
.
.
.REAL EST ATE SALE No. 53
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On J /)JI.L Iq / ;zoo I the sheriH levied upon tile Iletenllam<
interest in the real property situated in, t..f'~~ &:1~
Cumberland County, Pa.. known and numbered as: Ii A1tJLd:i :r!'&MJll:
tJ~nd more fully described on ExhIbI "A" IRed with
ttUs writ and by this reference Incorporated henJIn.
0Jl\!:o~~.t2f)O!' 1lJ: :t:;~~
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SCHEDULE OF DISTRIBUTION
SALE NO. 53
Writ No. 2001-1746 Civil Term
Countrywide Home Loans, Inc.
VS
Timothy K. Travitz and Anita M. Travitz
Filed October 5, 2001
Date of Sale:
Buyer:
Bid Price:
September 05,2001
Countrywide Home Loans, Inc.
$30,000.00
Real Debt
Interest
Attorney writ costs
$108,385.86
1,585.98
125.92
Total
$110,097.76
Distribntion
Amount Collected
Legal Search
Sheriff's Costs
$1,430.74
200.00
1,230.74
So Answers:
r'~~'<#~
R. Thomas Kline, Sheriff
-.:
,
TITLE REPORT
THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING
ITEMS, WIDCH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY
EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED.
SHERIFF SALE NO. 53
Held Wednesday, September 5, 2001
Date: September 5, 2001
TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive. Taxes for the current year
2001.
WATER RENT:
SEWER RENT
Company assumes no liability for private supply of water or sewer.
Receipts to be produced if services are lienable.
MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims.
MUNICIPAL CLAIMS
MORTGAGES: Listed Under Other Exceptions Below.
JUDGMENTS: Listed Under Other Exceptions Below.
INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to
dated , 2001, and recorded
, 2001, in Cumberland County Deed Book , Page
RECITAL: BEING the same premises which Kenneth A. Homer and Diane A. Homer by deed
dated August 15, 1997 recorded September 2, 1997 in the Office ofthe Recorder of Deeds in and
for Cumberland County in Carlisle, Pennsylvania in Deed Book 163, Page 75 granted and
conveyed to Timothy K. Travitz and Anita M. Travitz, husband and wife.
OTHER EXCEPTIONS:
1. The identity and legal competency of parties at the closing of this title should be
established to the satisfaction of the closing attorney acting for this Company.
2. Rights or claims of parties in possession, if any, other than the owner.
3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area
and encroachments which an accurate and complete survey would disclose.
4. Payment of State and local Real Estate Transfer Taxes, if required.
5. Public and private rights in the roadbed of Second Street, First Alley, and in an un-named
alley.
6. Mortgage in the amount of $99,765.00 given by Timothy K. Travitz and Anita M.
Travitz, husband and wife to Broadview Mortgage Company dated August 29, 1997
recorded September 2, 1997 in Mortgage Book 1402, Page 683. Assigned to Country
Wide Home Loans, Inc. by instrument dated August 29, 1997 recorded September 2,
1997 in Miscellaneous Record book 559, Page 676.
..
.
L~ .t-;
Complaint in Mortgage Foreclosure filed by Country Wide Home Loans, Inc. as
Plaintiff against Timothy K. Travitz and Anita M. Travitz in the Office of the
Prothonotary of Cumberland County to.file number 2001-1746. Default judgment in
the amount of $108,385.86 entered on June 13,2001.
7. Mortgage in the amount of $10,000.00 given by Timothy K. Travitz and Anita M.
Travitz, husband and wife, to Household Realty Corporation dated August 19, 1999 and
recorded August 26, 1999 in Mortgage Book 1566, Page 781.
I
!
8. Satisfactory evidence to be produced that proper notice was given to the holders of all
liens and encumbrances intended to be divested by subject Sheriff Sale.
9. Real estate taxes accruing on and after January 1,2002 not yet due and payable.
It is to be noted that no search of Domestic Relations Records has been made to
determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any
search been made for environmental liens in Federal District Court.
~.
Robert G. Frey, Agent
Note: This Title Report shall not be valid 0
until countersigned by an authorized signato
.'
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'.
REAL ESTATE SALE NO. 53
Wrtt No. 2001-1746 Civil
Countrywide Home Loans. Inc,
vs.
Timothy K. Travltz and
Anita M. Travltz
Atty.: Joseph A Goldbeck. Jr.
ALL THAT CERTAIN lot of ground
situate in the Borough ofWormleys-
burg. Cumberland County, Pennsyl-
vania. bounded and described as
follows. to-wit:
BEGINNING at the southwest
comer of Second Street and First Al-
ley: thence extending along Second
Street in a southerly direction 65
feet to property now or formerly of
Sadie Zarker; thence extending
along the property now or formerly
of Sadie Zarker in a westerly direc-
tion. 130 feet to an alley; thence
extending along sald Alley in a north-
erly direction 65 feet to First Alley:
thence extending along First Alley
.. ~in an easterly direction 130 feet to
Second Street. the place of BEGIN-
NING.
Having erected thereon a two and
one-half story house known and
numbered as 18 Second Street.
Wormleysburg. Pennsylvania. and on
the rear, a one story bungalow.
Tax Parcel #47-20-1858-07l.
Being known as 18 S. Second
Street. Wormleysburg. PA 17043.
..;.;
1
" -.
~-.
--.--{<._;
.
"
.~
.
Countrywide Home Loans, I~c.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Timothy K. Travitz
Anita M. Travitz
NO. 01-1746
Defendants
AFFIDAVIT PURSUANT TO RULE 3129.1
Count~ide Home Loans. Inc., Plaintiff in the above action,
by its attorney, Joseph Goldbeck, Jr., 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
18 S. 2nd Street. Worml~sburg. PA 17043.
1. Name and address of owner(s) or reputed owner (s):
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Timothy K. Travitz
18 S. 2nd Street
Worm1~sburg. PA 17043
Anita M. Travitz
18 S. 2nd Street
Worm1~sburg. PA 17043
2. Name and address of defendant(s) in the judgment:
Name
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
Address (if address cannot be reasonably
ascertained, please so indicate)
None
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Household Realty Co~.
5105-H Jonestown Road
Colonial Commons
Harrisburg. PA 1712
-
-
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'..
.
.
,
5.
Name and address of eyery other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
HQne
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
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County D~t. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa D~t. of Public Welfare
Bureau of Child S~ort Enforcement
Health and Welfare Bldg. Room 432
P.O. Box 2675
Harrisburg. PA 17105
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the
property that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
HQne
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. #4904 relating to unsworn
falsification to authorities.
June 8, 2001
oldbeck, Jr.
or Plaintiff
;;.;....
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GOLDBECK McCAFFERTY & McKEEVER .
By: Joseph A. Goldbeck, Jr. .
Attorney I.D. #16132
Suite 500 c The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, pA 19106
(7.1 sl 627-1:>7.7.
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff
Vs.
Timothy K. Travitz
Anita M. Travitz
NO.01-1746
Defendant(s)
NOTYC:F. OF' SHF.RTF'F" S SAT,F. OF' RF.Ar, ESTATF.
TO: Anita M. Travitz
18 S. 2nd Street
Worm1eysburg, PA 17043
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, 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 18 S. 2nd Street. Worm1eysburg.
PA 17043. is scheduled to be sold at the Sheriff's Sale on
September 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland
County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle,
PA 17013 to enforce the court judgment of S108.385.86 obtained by
Countrywide Home Loans. Inc. (the mortgagee) against you.
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 attorneys
Fees due. To find out how much you must pay, you may call:
(215) 627-1322
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.
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You may need an attor~ey ~o 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 yon HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale
sold to the highest bidder.
calling (2]5) h7.7-117.7.
is not stopped, your property will be
You may find out the price bid by
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 the Sheriff's office at 17]7) 7.40-h,90.
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 this 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 proposed schedule of distribution of the money
bid for your house will be prepared 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 posting of the Schedule of Distribution.
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
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ALL THAT CERTAIn lot of ground situate in the Borough of W ormleysburg, Cumberland County,
Pennsylvania, bounded and described as follows, to-wit:
BEGINNING at the southwest comer of Second Street and First Alley; thence extending along
Second Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence
extending along the property now or formerly of Sadie Zarker in a westerly direction, 130 feet to an
alley; thence extending along said Alley in a northerly direction 65 feet to First Alley; thence
extending along First Alley in an easterly direction 130 feet to Second Street, the place of
BEGINNING.
Having erected thereon a two and one-half story house known and numbered as 18 Second Street,
Wormleysburg, Pennsylvania, and on the rear, a one story bungalow
Tax Parcel #47-20-1858-071
Being known as 18 S. Second Street, Wormleysburg, PA 17043
REAL ESTATE SALE NO. 63
Writ No. 2001-1746 Civil
Countrywide Home Loans. Inc.
vs.
Timothy K. Travitz and
Anita M. Travitz
Atty.: Joseph A. Goldbeck. Jr.
ALL TIfAT CERTAIN lot of ground
situate in the Borough ofWormleys-
burg. Cumberland County. Pennsyl-
vania, bounded and described as
follows. to-wit:
BEGINNING at the southwest
corner of Second Street and First Al~
ley; thence extending along Second
Street in a southerly direction 65
fe.et to property now or formerly of
Sadie Zarker: thence extending
along the property now or formerly
of Sadie Zarker in a westerly direc-
tion, 130 feet to an alley: thence
extending along said Alley in a north-
erly direction 65 feet to First Alley;
thence extending along First" Alley
in an easterly direction 130 feet to
Second Street. the place of BEGIN-
NING.
Having erected thereon a two
and one-half story house known and
numbered as 18 Second Street.
Wormleysburg. Pennsylvania. and on
the rear, a one story bungalow.
Tax Parcel #47-20-1858-071.
Being known as 18 S. Second
Street. Wormleysburg. PA 17043.
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esqnire, I1ditor of the Cumberland, Law Journal, of the County
and State aforesaid, being duly sworn, acc9rding to law, deposes an,dsays that the Cumberland
Law Journal, a legal periodical published ilfL the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952,1 and designated by the local courts as the official legal
periodical for the publication of all legal mjtices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
JOlunal on the following dates,
viz:
JULY 20, 27, AUGUST 3, 2001'
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
ROge~ditor--
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
0' NO'tARJAL'
LOIS E.~~PubIIc
CallaleBorq, Cum CoIIIIr
My CamrilnloR EllpIc8a M1R:t15t 200S
<10.
THE ' PAT-RIOT 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 iaw, 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 Pennsyivania, 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 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 ail have been continuously published
ever since;
That the printed notice or publication which is secureiy attached hereto Is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 24th and 31 st day(s) of July and the 7th
day(s) of August 2001. That neither he nor said Company is Interested in the subject matter of said printed notice
or advertising, and that ail of the ailegations 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 severaily 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. MiSCrl 'neous Book oM",
Volume 14, Page 317. 1
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PU SLICA TION ...................................~/.:.....5..............................................
COpy Sworn to an !" this 21&..t yof t 2001 A.D.
S ALE #53 Notanal Soal ~
Terry L Russell, Notary Pu ~ /'1/-
REAL"'ESTATE SALE No. 53 Harrlsburg, Dauphin Cou ty
Wdt No. 2001-1746 My Commission Expires June 6. TARY PUBLIC
. Civil Term
CQ~ntrywide Home Member, Pennsylvania Association of NQtarilS My commission expires June 6, --2002
" Loans,.lne.
", ", vs
rirootl1y K. Travitz
. Anita M. Travltz
Atty: J~ph A. Goldbeck, Jr.
OESCRIPTlON
AU THAT: GERTArN rot of ground situate
in tilt:. Borough of WormlcY5oorg.
Cumberland O:lUnty. Pcmlsylvania, bounded
:in-((9.~~ibe(ras follows, to wit; . ,
BEG1NNINfY'"'at" the southwest corner of
Second 5tiect' and First Alley; thence
.extctlding ll.\tmg Second Street in a Sl:l\lIherty
direction 6"5 feet to property now or fOlTl1erly
:" .ors-ad~ 'Zarker, thence extending along the
I, propert~rrtOw:.or formerly of Sadie Zarket' in
. a. we.~teriy ':dire<::tion, 130 feet 10 an ~l1ey;
i "thence extending along 1iald Alley In a
.11brtheriy direction -65 feet 10 First ~ney;
d}(:n.::e exte.nd:ipg along First Alley .m, an,
eili;t't~rly dirc"~lO!1 13:0 Ccet to Second ~t,
tht; place of ~~INN(NG. , : ."
Hav._ln.g crcCWU.: ':- thereon a two and ~~half
, 5tOry hou!)e, .known and nllmbered 3,.';'" i 8
Second Stree.l.. Wormleysburg. PcnnsyMmia.
and on _llie .~r. '!- one-story bungalow_
Tax Parcel :"#47-2l).18Sg-07l.
Being" knoW>> as j 8 S. Second SIret-'t. !
Wonnleysburg, FA 17043. " J
CUMBERlAND COUNlY SHERIFFS OFFICE
CUMBERUlND COUNlY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT,NEWS CO., Dr.
For pubiishing the notice or publication attached
hereto on the above stated dates
Probating same Notary Fee(s)
Total
$
$
$
177.42
1.50
178.92
Publisher's Receipt for Advertising Cost
0., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
Ige receipt of the aforesaid notice and publication costs and certifies that the same have
By....................................................................