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HomeMy WebLinkAbout01-1813 FX .~, ~~. -,- 'I J, ,.."L__L ~ _....""'_A~;;~" . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION , F/KIA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 TERM Plaintiff v. NO. tJl- J1/3 &;J CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE ..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 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 pag~s, 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 properly or other rights important to you, YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #, 0008445934 "L 'II ,," <<, "J__,~" 1. Plaintiff is CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2. The name(s) and last known addressees) of the Defendant(s) are: JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 4/19/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1315, Page 411. By Assignment of Mortgage recorded 4/24/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 518, Page 597, 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 811/00 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." I~, 1-1',1 "',- ",,,,i .c:.,.",; 6, The following amounts are due on the mortgage: Principal Balance Interest 7/1/00 through 3/1/01 (Per Diem $16,82) Attorney's Fees Cumulative Late Charges 4/19/96 to 3/1/01 Cost of Suit and Title Search Subtotal $81,884.65 4,104.08 4,000.00 388.96 550.00 $90,927.69 Escrow Credit Deficit Subtotal 66.82 0.00 ($ 66.82) TOTAL $90,860,87 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. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $90,860.87, together with interest from 3/1/01 at the rate of$16,82 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale ofthe mortgaged property. }~~--- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ 1'~ ~-, -~' ',. ^ " , ~l . II, ' "-, '~l''1ill-t-' 03/15/01 l'HU 16:35 FAX 215" 4508 FFDElUWlaPHELAN 1iI00z FEDERMAN AND PHELAN, L.L.P. One Penn Center at-Suburban Station 1617 John F, Kennedy Boulevard Sui(e 1400 Philadelphia, PA 19103-1814 215-563-7000 Fax: 215.563-5534 Representing Lenders ill Pennsylvania and New Jer$cy February 12, 2001 Joseph T. Jordan 120 Palm Club Circle Brunswick, GA 31525 Olivia K. Jordan 120 Palm Club Circle BrllIlSwick, GA 31525 Re: Premises: 11 Paradise Drive-Carlisle, PA 17013 Loan No.: 0008445934 NOTIC!: 01' IN'l'ENTION' TO I'OlUlCLOSE We represent CendaneXortgageCorporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HERBIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU RAVE 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY.' You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, including late and other charges is $5,628.59 for the months of 8/1/00 through 2/1/01. ~our failure to pay the delinquent amount, plus any additional monthly payment and late and other charges (including any accrued interest} that MaY corne due within the next thirty (30) days, ..,ill result in the acceleration of all sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be instituted. eXHIBIT A ~~' " " .. " II "~, ; --,~.-., "'"1'~"'O" 03/15/01 THU 16: 36 FAX 215' 4508 FE1>ERJW!&PHELAN 1ZI003. To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIFIED CHECK OR MONBY oaoaR and received in our offices at CKNDANT MORTGAGB CORPORATION, 6000 Atrium Way, Mount Laurel, NJ 08054, Attention: Collections Department, in or before thirty (30) days from the date of this letter. Please call (800) 257-0460 for the exact amount required. You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may call our office to discuss these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder. You have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense to acceleration and foreclosure. Very truly yours, FEr:~~) By: Frank Federman FF:ll cc: Cendant Mortgage Corporation Attn:Collections Department Loan No.: 0008445934 eXHIBIT A -~ 1,-.1_ J', -, "~"'~ ' " -~ J', '..::,...flLL THOSE. CERTAIN lots of ground with the improvements thereon erected situate in . ~dareselC TownshIp, Cumberland County, Pennsylvania, bounded and described in accordance .\;'1th,a Lot ;Pla~ for Barry Roush prepared by Larry B. Neidlinger. Professional Land Surveyor. a copy gf w!uch IS attached hereto, as follows: . "', BEGINNING at an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at corner,:of Lot No. 149 as shown on the Dale Fetrow Revised Plan of Lots recorded in the hereinl\fter menrioned Recorder's Office in Plan Book No.3, Page 103; thence by said Lot No, t49 South 86 degrees 15 minutes East a distance of 172.85 feet to an iron pin; thence South 3 degrees 45 minutes West a distance of 100 feet to an existing iron pin at comer of Lot No. 146 as shown on the above mentioned Dale Fetrow Revised Plan of Lots; thence by said Lot No. 146 North 86 degrees 15 minutes West a distance of 172.85 feet to. an iron pin in the northern right- ef-way line of 50 feet wide Paradise Road; thence by said northern right-of-way line of Paradise }toad North 3 degrees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. HA VING thereon erected a single family dwelling house with mailing address of 11 Paradise Road. Carlisle, Pennsylvania. . BEING Lots No. 147 and 148 on the aforementioned Dale Fetrow Revised Plan of Lots, which Plan is recorded in the hereinafter mentioned Recorder.s Office in Plan Book No.3. Page 103, BEING the same premises which Edith J. Myers, Executrix under the Last Will and Testament of Tressie A. Corman by Deed dated September 16, 1983 and Recorded September 16, 1983 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle. Pennsylvania in Deed Book "J". Volume 30, Page 465, granted and conveyed to Barry L. Roush and Linda C. Roush, husband and wife, the grantors herein. BEING also as to Lot 147. the same premises which Arthur E. Clepper and Cannaline Clepper, his wife, by Deed dated July 3, 1948, and recorded July 3, 1948 in the the above- mentioned Recorder's Office in Deed Book "V.., Volume 13, Page 414, granted and conveyed to Luther L, Clepper, and Mary Lou Clepper, his wife. It being also as to Lot 147, the same premises which the Tal( Claim Bureau of Cumberland County by Deed dated March 6, 1964, and recorded March 9, 1964 in the above-mentioned Recorder.s Office in Deed Book "D", Volume 21, Page 55, granted and conveyed as the property of Luther Clepper, to Vernon M. Shirk and Tressie A, Shirk, husband and wife. The said Luther L. Clepper, by Quit-Claim Deed dated May 9, 1991 and recorded May 14, 1991 in the aforesaid Recorder.s Office in Deed Book "C", Volume 35 , Page 633. conveyed any interest which he may have had in the above-described property by virtue of any irregularities in the said sale and conveyance of the Tax Claim Bureau, to Barry L. Roush and Linda C. Roush, the Grantors herein. . And being further as to Lot 147, the same premises which by Order of Court recorded August 26, 1991 in Deed Book "H", Volume 35. Page 5 permanently enjoined and restrained the said Mary Lou Clepper, her heirs and assigns, from asserting any claim or interest in or to the said real property adverse to that of Barry L. Roush and Linda C. Roush, the Grantors herein. SUBJECT HOWEVER. to the restrictions as they appear on the Dale Fetrow Revised Plan of Lots recorded as aforesaid, VERIFICATION MARK IffiNKLE hereby states that he is V.P, ofCENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take 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. 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. J.;Jtu DATE: 3)23/01 " "'.'f;-:..., '.- ",'-.. ',,'. '<io '. '~U~;R,i-~:tf~~I&iM;,",---~L'0",i..;,,,.,..,M't,,',,;r-,:'~l!i,U.':.l,,~<,,",,.!,'m',;, ""_iJ,-,,,,,,,,,,,,'I,~,,,,;-,"',"J,:".',6j;~,i---i!li!~'fi~\ii'l1l~llfit~;~!il~ij"",,!.'f.""."uac',,'~~" ,~,"- l~ ~ " Iv ~ 0!. ~ CJ ~ ~ ~ ~/l.. "" j,;",J:y.crr "D.L'~ rk:,lL~,!!>JtiK <.r,'o',,",.~i)! ',:~bt ~,(l,_.."",,,~U U~L_,..",,,m1L,JH,,, ", ~~,,'~ ~ ~ ~ fJ ~' ~\~ ~ \\ ~~ ,. ~-.. '. o ~::; ~~:~! ~~~' en ), ~[3 c:.'::~ c-' :f;~ -{ -< ~T= _IMll'.' " \b ~- ",~j "--, :I: >:#> ---,.j :"'.) ()J N ',-) :.:;~;! :5:J -< N ,"".........< -' j', . --I ,I~ " ',-' ~ ,'" ~'i SHERIFF'S RETURN - NOT FOUND ,. I . CASE NO: 2001-01813 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS JORDAN JOSEPH T ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JORDAN JOSEPH T but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE FORECLOSURE , NOT FOUND , as to the within named DEFENDANT , JORDAN JOSEPH T DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEF FORWARDING, RETURN NOT FOUND AS PER JASON RICCO 4/9/01 Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 3.10 5.00 10.00 .00 36.10 S7Z~ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 04/09/2001 Sworn and subscribed to before me ,) cj "::' day of ~ this .,2.&v>1 A.D, ~~ G. )vdo,., # Prot 0 otary I "," " "'"\"'>" '-'- SHERIFF'S RETURN - NOT FOUND ". " CASE NO: 2001-01813 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS JORDAN JOSEPH T ET AL R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JORDAN OLIVIA K but was unable to locate Her in his bailiwick, He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , JORDAN OLIVIA K DEFT, NO LONGER RESIDES AT ADDRESS STATED, LEFT NO RETURN NOT FOUND AS PER JASON RICCO, 4/9/01 Sheriff's Costs: Docketing Not Found Return Affidavit Surcharge 6.00 5.00 .00 10.00 .00 21.00 S~ / ~ R. 'Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 04/09/2001 Sworn and subscribed to before me this .2'1'::: day of ~ .2fJ-o ( A.D. prg::fn~tEy J1",p;,.. ,~ "\ ~.. ~" ~_. , - .', -' "'- ^ < '" ~ '~,', -^ ,~, ~~"~ I I "'," > FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER A T SUBURBAN STATION SUITE 1400 PHILADELPH[A, PA 19103-1814 (2[5) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIV[L DIVISION CENDANT MORTGAGE CORPORATION , F/KlA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 TERM Plaintiff NO. (}/~ )~13 i;J v. CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT A;>ID 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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTE:vJPT 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 LA WYER AT ONCE, IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. We hereby certify the within to be a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOClA TION 2 LIBERTY AVENUE CARLISLE, PAl 7013 (717) 249-3166 Ll),Ul If UOOX-l-45LJ34 ., . L Plaintiff is CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: JOSEPH T. JORDAN OLIVIA K, JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/19/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1315, Page 41 L By Assignment of Mortgage recorded 4/24/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 518, Page 597. 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 8/lIOO 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." >l ,...J .11 ,.. '"~, " , '. , . 6, The following amounts are due on the mortgage: Principal Balance Interest 7/1/00 through 311101 (Per Diem $16,82) Attorney's Fees Cumulative Late Charges 4/l9196 to 311101 Cost of Suit and Title Search Subtotal $81,884.65 4,104.08 4,000.00 388,96 550.00 $90,927,69 Escrow Credit Deficit Subtotal 66,82 0.00 ($ 66.82) TOTAL $90,860.87 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 Sheriffs 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. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s), WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $90,860,87, together with interest from 3/l/0 1 at the rate of $16.82 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale ofthe mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff TRUE COpy fROM RECORD In Testimony whereof, I here IJnto set my hand and the seal of said Court al Carlisle, Pa, This ..~"..," ~ay oL7.11.~., ~I ..............~~...j<,~ W Prothonotar;"" . ... I. ," . i:l..lCJ '--i_. ^ ,03/1'5/01 TUU 18: 35 FAX 215" 4508 FFDERlIANa.PBELAN i100z FEDERMAN AND PHELAN, L.L.P. One Penn Center at-Suburban Station 1617 JohnF. Kennedy Boulevard Suite 1400 Philadelphia. PA 19103-1814 215-563-7000 Fax: 215-563-5534 Representing Lenders in Pennsylvania and New Jersey February 12, 2001 Joseph T. Jordan 120 Palm Club Circle Brunswick, GA 31525 Olivia t{,Jordan 120 Palm Club Circle Brunswick, GA 31525 Re: Premises: 11 Paradise Drive-Carlisle, FA 17013 Loan No.: 0008445934 NOTIC!: OJ' INTENT:ION '1'0 FORBCLOSE We represent Cendane Mortgage Corporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI, ECTOR 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 k~ SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A. DEBT I BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof, If. you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, including late and other charges is $5,628.59 for the months of 8/1/00 through 2/1/01. Your failure to pay the delinquent amount, plus any additional monthly payrr,~.t and late and other charges (including any accrued interest} that may come due within the next thirty (30) days, ...ill rest:le in the acceleration of all sums due under your Mortgage, After acceleration OCC'..lI"S, a foreclosure a.ction or any other remedy permitted by your mortgage may be instituted. EXHIBIT A ,,' " ,," "" . ~"""""" 4 OJ/lS/0l THO 18:J8 FAX 215' 4508 FE1:lERJWI&PHELAN 1iI00J To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIFIED CHBCX OR MONBY ORDER and received in our offices at CENDANT MORTGAGB CORPORATION, 6000 Atrium Way, Mount Laurel, NJ 08054, Attention: Co11ectione Department, in or before thirty (30) days from the date of this letter. Please call (800) 257-0460 for the exact amount required. You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may call our office to discuss these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder. You have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense to acceleration and foreclosure. Very truly yours, FEr;:~ ~~) By: Frank Federman FF:ll cc: Cendant Mortgage Corporation Attn:Collections Department Loan No.: 0008445934 EXHIBIT A - "~ 1 I, i.~ ~Ijo", . '...:....11LL THOSE. CERTAIN lots of ground with the improvementS thereon erected situate in ,~ddlese?C TownshIp, Cumberland County, Pennsylvania. bounded and described in accordance "'Jth. a Lot ?lal} for Barry Roush prepared by Larry B. Neidlinger, Professional Land Surveyor, a copy gf winch IS attached herelo. as follows: - - - ": BEGINNING at an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at comer,:of Lor No. 149 as shown on the Dale Fetrow Revised Plan of Lots recorded in the herein,!fter mentioned Recorder's Office in Plan Book No.3. Page 103; thence by said Lot No. ~49 South 86 degrees 15 minutes East a distance of 172.85 feet to an iron pin; thence South 3 degrees 45 minutes West a distance of 100 feet to an existing iron pin al comer of LOI No. 146 as shown on the above mentioned Dale Fetrow Revised Plan of Lots; thence by said Lot No. 146 North 86 degrees 15 minutes WeSI a distance of 172.85 feet 10 an iron pin in the northern right- of-way line of 50 feet wide Paradise Road; thence by said northern right-of-way line of Paradise Road North 3 degrees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. HA. VING thereon erected a single family dwelling house with mailing address of 11 Paradise Road. Carlisle, Pennsylvania. . BEING Lots No. 147 and 148 on the aforementioned Dale Fetrow Revised Plan of Lots, which Plan is recorded in the hereinafter mentioned Recorder's Office in Plan Book No, 3, Page 103, BEING the same premises which Edith ], Myers, Execurrix under the Last Will and Testament of Tressie A. Corman by Deed dated September 16, 1983 and Recorded September 16, 1983 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book "J", Volume 3D, Page 465, granted nnd conveyed to Barry L. Roush and Linda C. Roush, husband and wife. the grantors herein, BEING also as to Lot 147, the same premises which Arthur E. Clepper and Carma!ine Clepper, his wife, by Deed dated July 3. 1948. and recorded July 3, 1948 in the the above- mentioned Recorder's Office in Deed Book "V". Volume 13. Page 414, granted and conveyed to Luther L. Clepper, and Mary Lou Clepper, his wife, It being also as to Lot 147. the same premises which the Tax Claim Bureau of Cumberland County by Deed dated March 6, 1964, and recorded March 9 1964 in the above-mentioned Recorder.s Office in Deed Book "D", Volume 21, Page 55, granied and conveyed as the property of Luther Clepper, to Vernon M. Shirk and Tressie A. Shirk, husband and wife. The said Luther L. Clepper, by Quit-Claim Deed dated May 9, 1991 and recorded May 14, 1991 in the aforesaid Recorder's Office in Deed Book "C', Volume 35 , Page 633, conveyed any interest which he may have had in the above-described property by virtue of any irregularities in the said sale and conveyance of the Tax Claim Bureau, to Barry L, Roush ,:nd Linda C. Roush, the Grantors herein. .And being further as to Lot 147, the same premises whlch by Order of Court recorded August 26. 1991 in Deed Book "H", Volume 35, Page 5 permanently enjoined and restrained the said Mary Lou Clepper, her heirs and assigns, from asserting any claim or interest in or to the said real property adverse to that of Barry L. Roush and Linda C. Roush, rhe Grantors herein, SUBJECT HOWEVER, to the restrictions as they appear on the Dale Fetrow Revised Plan of Lots recorded as aforesaid. I..-J' ~ ~ b~~: VERIFICATION MARK HUNKLE hereby states that he is V,P. ofCENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take 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. 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. ~w DATE: 3/23/0 ~ " ~~~," ~Iilli~".i,r;jW1.~'!ik@K4;:""'A'.',d.,k""'i~",I~'\;jj;I:H1M!-5*,'"'<AW"k'-'-"f.' .LJIIIJIJll,[ ~ ~ ps ~ ~' L I 111.:1 Y!IUn! ; '" >,- \" ~"~,, >'-<~,--", ~~ ~ ~ ,<~..,'," c' .,-,'!,,,__-,, , "",,~~,-,~ ,,,.-!iiiliillSll~ ~']iltlli_iil;j(ii ~ ".'~" w~' " 1\1' pf',\"ill't' ~~:1"1'~ 'I'~?' ~ N::; d , '" ' :', .!~ j'''- In, Wi TO' l. -",L,' l' 8Z H auw ", '0" Ij! .h""I"~''''''" ,,'!T. .....1 q::f'4hh't' ,.:,;'~".i ,,~, '''':',7,.M:'~ "",I/lIQ ,:tl~1fI: l,r.',J4.n!lla3 ",'" JI,':l ""','7j ~..Ji ...' ~"'.'\l~j9 '"" ',", ,,~ " ~~ ... ". "" '-', if: , wi -~"~ ,.I'J ~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 ONE PENN CENTER AT SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103-18]4 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 A TRlUM WAY MOUNT LAUREL, NJ 08054 TERM Plaintiff NO. OJ- /1/3 ~ v, CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "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 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 HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, w.e hereby certify the WIthin to be a true arid correct copy of the original fi/Old of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3 166 Loan '* 0008445934 ,', ,,",, ~ '''''-'1i;; , . ,,',I J . -"'" . '"" ~~~; 1. Plaintiff is CENDANT MORTGAGE CORPORATION, F/K1A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2, The name(s) and last known address(es) of the Defendant(s) are: JOSEPH T, JORDAN OLIVIA K, JORDAN ]20 PALM CLUB CIRCLE BRUNSWICK, GA 31525 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3, On 4/19/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 1315, Page 411. By Assignment of Mortgage recorded 4/24/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 518, Page 597, 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 8/1/00 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." 1,- -J. II ,_.J ,~_.,,--~, , _ ~ ~"'-' <. 6. The following amounts are due on the mortgage:. Principal Balance Interest 7/1/00 through 3/1101 (Per Diem $16.82) Attorney's Fees Cumulative Late Charges 4/19/96 to 3/1/01 Cost of Suit and Title Search Subtotal $81,884.65 4,104.08 4,000.00 388.96 550.00 $90,927.69 Escrow Credit Deficit Subtotal 66.82 0.00 ($ 66.82) TOTAL $90,860.87 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 Sheriffs 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. . This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $90,860.87, together with interest from 3/1/01 at the rate of$16.82 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 TRUE C;')PV FR0'A RECORD In Testimony whereo.f, I h:T8 unto set my hand and the seal of said Court at Carlisle, Pa. This ....'i??f{...... day of.g~..., aP.q;?/ . r/ J r .............~......~~=...~ ." . " bJ..< '. "',< 03/15/01 THtI 16: 3S FAX US" 4508 FFDERlIAN.PBELAN iJOO% FEDERMAN AND PHELAN, L.L.P. One Penn Center at-Suburban Station 1617 JohnP. Kennedy Boulevard Suile 1400 Philadelphia, PA 19103-1814 215-563-7000 Fax: 215-563-5534 Representing Lenders ill Pennsylvania and New Jersey February 12, 2001 Joseph T, J arctan 120 Palm Club Circ10 Brunswick, GA 31525 Olivia K. Jordan 120 Palm C1~b Circle Brunswick, GA 31525 Re: Premises: 11 Paradise Drive-Carlisle. PA 17013 Loan No.: 0008445934 NOTICE 01' rNTENTION TO FORECLOSE We represent Cendane Hortgag.Co~oration, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI,ECTOR ATTEMt'TING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNgSS 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 k~ SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, including late and other charges is $5.628.59 for the months of 8/1/00 through 2/1/01. Your failure to pay the delinquent amount. plus any additional monthly paYffier~t and late and other charges (including any accrued interest) that may come due wi thin the next thirty (30) days, will resc:1. e in 'the acceleration of all sums due under your Mortgage. After acceleration OCC'..lrs, a foreclosure action or any otr.er remedy permitted by your mortgage may be instituted. EXHIBIT A ~ 'J ~ ,I". '1,.,1 ~'~" - "'>- 03/1~/01 TBlI 16:36 FAX 21S' 4S08 FEIlEJUWl.PBELAN Ii 003 To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIFIED CHECK OR MONBY ORDBR and received in our offices at CKNDANT MORTGAGB CORPORATION. 6000 Atrium Way. Ho~nt La~r.l. NJ 08054. Attention. Collections Department, in or before thirty (30) days from the date of this letter. Please call (800) 257-0460 for the exact amount required. You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may call our office to discuss these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder. You have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense to acceleration and foreclosure. Very truly yours, FE~~~~) By: Frank Federman FF:ll cc: Cendant Mortgage Corporation Attn:Collections Department Loan No.: 0006445934 EXHIB'T A ,^ J I ~J ,^ '>~w', ~t l~', IF ....:,...!lLL TlIOSE. CERTAIN lots of ground with the improvements thereon erected situate in .~ddlese" TownshIp, Cumberland County, Pennsylvania, bounded and described in accordance ':'1th a Lot !,la~ for Bany Roush prepared by Larry B. Neidlinger, Professional Land Surveyor, a copy <;f wluch IS attached hereto, as follows: - -:::. ". BEGINNING at an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at corner,'of Lot No. 149 as shown on the Dale Fetrow Revised Plan of Lots recorded in the hereinafter mentioned Recorder's Office in Plan Book No.3, Page 103; thence by said Lot No. ~49 South 86 degrees 15 minutes East a distance of 172.85 feet to an iron pin; thence South 3 degrees 45 minutes West a distance of 100 feet to an existing iron pin at comer of Lot No. 146 as shown on the above mentioned Dale Fetrow Revised Plan of Lots: thence by said Lot No. 146 Nonh 86 degrees 15 minutes West a distance of 172.85 feet to. an iron pin in the northern right- of-way line of 50 feet wide Paradise Road; thence by said northern right-of-way line of Paradise Road North 3 degrees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. lIA VING thereon erected a single family dwelling house with mailing address of 11 Paradise Road, Carlisle, Pennsylvania. . BEING Lots No. 147 and 148 on the aforementioned Dale Fetrow Revised Plan of Lots, which Plan ;s recorded in the hereinafter mentioned Recorder's Office in Plan Book No.3. Page 103. BEING the same premises which Edith J. Myers, Executrix under the Last Will and Testament of Tressie A. Corman by Deed dated September 16, 1983 and Recorded September 16. 1983 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book "J", Volume 3D, Page 465, granted and conveyed to Barry L. Roush and Linda C. Roush, husband and wife, the grantors herein. BEING also as to Lot 147, the same premises which Anhur E. Clepper and Carma1ine Clepper, his wife, by Deed dated July 3, 1948, and recorded July 3, 1948 in the the above- mentioned Recorder's Office in Deed Book "V", Volume 13, Page 414, granted and conveyed co Luther L. Clepper, and Mary Lou Clepper, his wife. It being also as to Lot 147, the same premises which the Tax Claim Bureau of Cumberland County by Deed dated March 6, 1964, and recorded March 9, 1964 in the above-mentioned Recorder's Office in Deed Book "D", Volume 21, Page 55. granted and conveyed as the property of Luther Clepper, to Vernon M. Shirk and Tressie A, Shirk, husband and wife. The said Luther L. Clepper, by Quit-Claim Deed dated May 9, 1991 and recorded May 14, 1991 in the aforesaid Recorder's Office in Deed Book "C", Volume 35 , Page 633, conveyed any interest which he may have had in the above-described property by virtue of any irregularities in the said sale and conveyance of the Tax Claim Bureau, to Barry L. Roush and Linda C. Roush, the Grantors herein. .And being further as to Lot 147, the same premises which by Order of COUrt recorded AugUSt 26, 1991 in Deed Book "H", Volume 35. Page 5 permanen:ly enjoined and restrained the said Mary Lou Clepper, her heirs and assigns, from asserting any claim or interest in or to the said real property adverse to that of Barry L. Roush and LInda C. Roush, the Grantors herein. SUBJECT lIOl-VEVER, to the resmctions as they appear 011 the Dale Fetrow 'Revised Plan of Lots recorded as aforesaid. ~ _ I ii, VERIFICATION MARK HIINKLE hereby states that he is V.P. ofCENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take 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. 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. ~J/.u DATE: 3/23/01 ~; ,- .....~....--, /J ....~1,.,.""'^ " .', ~ . ~~'~ ;.~tJ;,~>IiW~!t~,ilt~-;4:j.~,>li'IJl1f1l'I..i;;J,,"'~~,;~'~""F~iii,-;i;;;:," ,cd,~-,_,;":,"'>_""""i,,,\_,,,;c.-",",~r,,,,,,-,,,'WJi<ii,.I,41I.llihm~I"" ~ ~ ~~""~""""'''''"~- ~! ~. ~ ~. ~. ~ ~,1I",M<_: L~V ~ IT! L- "'<<J:fj,lUJ 1 Ulfln,!8IiJLL .L__~",!-",,,.,,,<,,_,,,, " M V ! h: V A -\ ,l. ':~: ~~ ~-! 3 d >,' .' ,'1..' 10, p,j 10 ~. BlIlUW! ..uNi~(~~' c :;-~ '.! -;,~; ~'3 iiaa 4.:11111HS 3h.~ J{r :J'lL:b;:l1l "111"' "'-"'Ii;~'I'lIil'''" - "~~ ,~.. ~r ~~, .I~, -If: f.!!l ~ I J" '" .. '~Ifjjp; I ~, 1 AFFIDAVIT OF SERVICE - CUMBERLAND PLAINTIFF (FHLMC) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION NO. 01-1813-CIVIL DEFENDANT JOSEPH T. JORDAN OLIVIA K. JORDAN 55;0 0 Il-/TI'I-"'- /-I. ~... A-p* 102 1:/9 Pl'MI EbtfB eU~C1.&- BRUNSWICK, GA 31525 TYPE OF ACTION ~ Mortgage Foreclosure ~ Civil Action SERVE AT: ~ERVED ~ -- I Served and made kn'i''l''f to .~~~ l ~ J6~~ , Defendant o!.h the ---.L:L day of , . ' 2001, at 1 ~ ~u ?rlJ _~'c10Ck' t"'. M., at ~O.2.. 0 ~1:a~.4-e.- t+Q'f* ~ ~~wv~ ~ ,City in the manner described below: __ Defendanf personally served. Adult family member with whom Defendant(s) reside(s). RelaLionship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s) Agent or person in charge of Defendant's office or usual place of business. and officer of said defendant company. Other: I, , a competent adult, being duly sworn according to law, depose and state that I personally handed to a true and correct copy of the issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed B~~ore me this day Of , 20or-:- Notary: Defendant Moved NOT SERVED day of , 2001, at NOT FOUND because: Unknown No Answer Vacant ~Yl By: On the .M., o'clock Other :-- Sworn to and SUbsc~ibed Before m~ the 11 ~ day Of A-p1,(~ .. ' -;;;001. Notary: ~ ~\Ql.lQ1\C{ f'lcji''"j;;''.' ~l<,;i,::;G i~~;',"-';';'} ~"'.';'i.)t.;~- (;,>;'(~fjt'" ~ '~,r::;:;:'r;:,,;": t:'},'J~!C,\!;. ,j~I;! :, :,,\i? By: ATTORNEY OF PLAINTIFF FRANK FEDERMAN, ESQUIRE - 1.0.#12248 Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103-1799 (215)563-7000 flit f1 I, ~ .. AFFIDAVIT OF SERVICE - CUMBERLAND (FHLMC) PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION NO. 01-1813-CIVIL DEFENDANT JOSEPH T. JORDAN OLIVIA K. JORDAN TYPE OF ACTION XX Mortgage Foreclosure ~ Civil Action SERVE AT: 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 SERVED Se rved and made kn^q.w{l to ~ f /;!/::;- ;::.. ~J 6t)/~ Defendant o{J-,the ~ d~! ,,\ , 2001, 1;02>, 0.;.9 qffik' ::Ie. M., at ,!j z;c..b I? - 'V;:;:; ~ , City in t e manner descr ed below: ~e ndant personally served. ~Adult family member wi w om reside(s). Relationship is ' Adult in charge of De ndant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside Is) Agent or person in charge of Defendant's office or usual place of business. and officer of said defendant company. OthEer: I, , a competent adult, being duly sworn according to law, depose and state that I personally handed to a true and correct copy of the issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed Before me this day Of , 20~ Notary: NOT By: ucrl}..-~ OnJthe :M. , day of , 2001, at NOT FOUND because: Unknown No Answer Vacant o'clock Defendant Moved Other: Sworn to and subsc~bed Before me the 11 ~ day Of ~.d ; 2001. Notary . ~ ,brQU1J>1(d :.'ltA~f"; i'~",~I'-tk: ,\jk. 'y, ~','}"If;';:;' ~:' ';'{':f'"j--.- 'J. ',.'1,N,':;!.'-'-;'-, - ) ,,/"~_';. _~i':S ) ,;. By: ATTORNEY OF PLAINTIFF FRANK FEDERMAN, ESQUIRE - 1.0.#12248 Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103-1799 InS) 563-7000 ,.'1 } . .' .,-"-' . " . t11 X rO 4jjlkM~ii.I~1~",~,~;,~t;'''';'M':I'';'';,~\i'',ij,.'lli;,,;i@~h1j~,%;~',i,;":",';-"-.''il,",^', ".~""".",-j,'I"'o,~,,,,ki'2<fJj&.""~",&~iftU.~~~.~~~tWiIIlI.~ t ~,1i:f;,;, ");W,,,~,lJ.,L,l;;,,__,~~.,J~.~,I!:I.llJ~,,, Jj~ .-J ,,"). -',~',h""'~. ." ~.. '_ ,',,", '_""',_","'.",' ~. - .- ~ ~, ~ <g Cl ;:R it ~ zgj :::;) t;.S;; N ~~'r:: ..-J <::0 ):>: v Z,O :1: s>g ry ~ N '"~ '-;iFJ ,~B9 ~).!.. "-10 .1 '.'~i ;~--\ ~n ~O _~m ~ :0 -< o -q ..-: . ,. ,.. ~ II . "' FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, FnuA PHH MORTGAGE SERVICES C(i)RPORATION 6000 ATRUIM WAY MpUNT LAUREL, NJ 08054 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff : NO. 01-1813 vs. JOSEPH T. JORDAN OLIVIA K. JORDAN 58fW ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TQ THE PROTHONOTARY: Kindly enter judgment, in rem, in favor ofthe Plaintiff and against JOSEPH T. JORDAN and OLIVIA K JORDAN, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: , As set forth in Complaint Interest 3/1/01 TO 5/18/01 $90,860.87 $1,328.78 $92,189.65 TOTAL I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. i~-/~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff i DAMAGES ARE IlEREBY ASSESSED AS INDICATED. ~ D.,lTE: fYI'ry ,J,:J .:Jt')Ol (3.1/1-/;;;:-) I{. I PROP OT **THIS FIRM IS A DEBT COLLECTOR AlTEMYTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUl'TCY AND THIS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AlTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY, ** Ij".,,;-~ -, --. - ....... ...... - ...... ..... - -- ..-. ....... ...... ......' ,.- '--,. ....... ...... - ........." "'"', I ~, .....,.,,, .~. -, ".......' -., ..--"" .-." -. -, - ......" ...........' ........ -, .,."......^ ,,-- ~.. --- ........ "....... _. -' . ......... ... ... ::........ '......~ ~. ,~...." .~- ,", ~", ~""'" . ............"c -. "!!'t!i!'" ...-. '''--' -~,""* ..,,'" ~.- ,~..~ ~.... -'" """"'"'''''' <"""'A,W' , ~ ~ . ,. I.. L.J .0 ~, "' . ~ t JlIIiilk.; . <0 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 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. JOSEPH T. JORDAN OLIVIA K. JORDAN NO. 01-1813-CIVIL Defendant(s) TO: JOSEPH T. JORDAN 5800 ALTAMA AVENUE. #102 BRUNSWICK. GA 31525 ;~.~E COP'f DATE OF NOTICE: MAY 7, 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, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for plaintiff ""- - "'I ~. 1,1, -he, , "' '1I'1li'~1i<;t;." , . 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 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. JOSEPH T. JORDAN OLIVIA K. JORDAN NO. 01-1813-CIVIL TO: OLIVIA K. JORDAN 5800 ALTAMA AVENUE. #102 BRUNSWICK. GA 31525 Fji f C..'"ip" y. l,.;/ Defendant(s) DATE OF NOTICE: MAY 7. 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 w _ _~ ~ ~ .j, .,1'1 ,,',-- . .. j FEDERMAN and PHELAN I By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH : MORTGAGE SERVICES CORPORATION : CUMBERLAND COUNTY : Court of Commou Pleas : CIVIL DIVISION Plaintiff : NO. 01-1813 vs. JOSEPH T. JORDAN OLIVIA K JORDAN Defeudant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, 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 defendant(s) is/are not in the Military or Naval Service of the United I 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 JOSEPH T. JORDAN is over 18 years of age and resides at 5800 ALTAMA AVENUE, #102, BRUNSWICK, GA 31525. (c) that defendant OLIVIA K JORDAN is over 18 years of age, and resides at 5800 ALTAMA AVENUE, #102, BRUNSWICK, GA 31525. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~.-:/~ FRANK FEDERMAN Attorney for Plaintiff " ,~, ._. -2:. ._. ~ t _. ""',..., --. ....... -.. --. ...... .:t: ..... ....... ......... ........ -:- ....... ~..... -- ~....! :J:' ,"'io', '..~' ",' '. ...... -.. '...... ....... -. ........' ...... ..... ... -" ~ ~, ~'. ::r- - """'"...., .-- ........ ......... _. ......... ........ ...~ ~.. ~ ."",,'-' -- _____H _. ',,-" ~" -"'~!"" .'._-'l"_ -- ............. .- ,-' -'1,- 11,_ ,'" - ~ , ~q' \ (Rule of Civil Procedure No. 236 - Revised) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION Plain tiff : NO, 01-1813 vs. JOSEPH T. JORDAN OLIVIA K JORDAN Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on MAY;J:J... .2000. <..8.v 4~e.. P. 7'f2eAt%_rDEPUTY , If you have any questions concerning this matter, please contact: , FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Pellll 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 OBTAJlNED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, TillS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** :" --.. -, I ...... .j: -ioo, .~-, _. - -::.t: _. '"'' #. :~ -. -- ...-' ....... ......... .......... ............ - ........ ..." ...... -, _. .- _. ....... .~~, ....... .......... ........,. ....... " i ........, .....'..~ ~- -~.. _. ............" ~~~ """". _. _. --. ._. ,~'" .- '...... .- .-. .~ --.~ . .~,.,.'-'1; !I.;-:,'~- ~ '\.\. ~""~..... ,~ illiili~,~,I,j,..1:~$6!fu,L"~I'ii'ili;j;j?J","'W~"'>,,"''''''';"~1~)j,-'''i!;j;,:~~~j;;"1Ol'''\iI:ll1''~~~d~I~"'-" ~~iIlllii!ll""'-".'~"'''" ',' t p (::) -19.. ~ ..D fJ:- . 0 - 0 r 0 '",".' C' C j ." - <' -'" ,-" ~ ~ ~ vC :."" rnf';' ~< ..... -""-'--' 3 "",-.-,' ~ ~s..,: f',,) () i'J ~ 'I -",,' ;,-ft co .... - ~, , g; ~f~ ,::') 0 rn -'/" ~ !') (jl <fr. .1,,:,:):" ~~J llii,L}Kl[J: m'.",,~,llf!itfJL.)j.., ,:,,,~~,: .:,~ ,:U,~IUt. ;LJ~1 y ~t ,,,,_," .. ","',,_~' ._^,"" ",'~~,,,,"' . ',-' ,~. - ,,~ , . -~, -u. 'I, I L ,,' ,'-.' . 'J;, . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R,C,P. 3180-3183 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 01-1813 v. JOSEPH T. JORDAN OLIVIA K. JORDAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $92,189.65 Interest from 5/18/01 to 9/5/01 (per diem - $15.15) tOTAL $1,666.99and Costs $93,856.64 ~~ FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property.No. ^tJl'i,,-~t;;t!~Jcj>j,(;r;;.,--.!l"m~b.i<,"~[,~,0.~,J'X'!'o__;;<1. f'''o;;Wjtl~,'!;;'dy..b~-,..,,,",,j;,'-d' "'""'~L":;,,,,-j:.:"";'<L;,"'j;;,jf-l,illlii~~ilil&;!I;/~~Ift~Ii!~iI'~~.~!IlliIII ~'-"'-~'^'n"~~ ~- ~ ..... , ...;S Z Z M OZ 0 ",< 0", 0 .-< "" ~ <:;> ""I>;< E-< f;T;l"'" ~~ ~ ;;;l ...fl/1 ""'>- U ;;;lM -d ~'Jj O~ ~~ ~'E' z:!l Q) ZZ ~ f;T;l1"l !; OZ ~~Z f;T;l = ~~ Q :;g~ ~~ ... ~ O"@ '" ~ 0f;T;l0 O<l .~ Q) :;g . U,,"" O~ '" <~ .n - O~ ~~~ Q) ~ ;>, 0 ...< E-< ... ~U '" 0 .; ~~ E 0 uz .. ....s: E-<~ N ...;;;l <~O ~~ '" g ~"" ~~ a> 00 ~O~ ~"'" ~~ g. E-<U ~:;gO 1>;<0 0.... g~ 0.. E-< ~~ '" ... S O~U 0 Q) f;T;l:;g ~Q:I .... O~ :;g~ ... Q) ~'-' ~ us3 E-<~ "" on f;T;l1>;< ~~ U '" f;T;l ~ ~Q:I ~ ..t:; E-<:;g ~f>;; ~ "0 "0 Z;;;l f;T;l ~ ii: < ""u U - ,;~A'!,~ L~""A>~_))tJ..",,~~ ]).,.JCr.lt,lJ,;C,;4'" ;"", :'" ;,:',',7",) 'k', , ',""",,,;_ , .'. ., >-,"'0<,,""'.~~ . ~ ~~ '" ilIiL' ~. .I~ - . ..:,!l.LL THOSE. CERTAIN lots of ground with the improvements thereon erected situate in . . ....~ddfesex Townshlp, Cumberland County, Pennsylvania, bounded and described in accordance \VIlli, a Loc f'la~ for Barry Roush prepared by Larry B. Neidlinger, Professional Land Surveyor, a copy 9f wp.lch IS attached hereto, as follows: ' - .- ': BEGINNING at an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at comer:'of Lot No. 149 as shown on the Dale Fecrow Revised Plan of Lots recorded in the hereinufrer menrioned Recorder's Office in Plan Book No.3, Page 103; thence by said Lor No. ~49 South 86 degrees 15 minutes EaSl a distance of 172.85 feet to un iron pin; thence South 3 degree. 45 minutes West a distanCe of 100 feet to an existing iron pin at corner of Lot No. 146 as shown on the above mentioned Dale Fetrow Revised Plan of Lots; thence by said Loc No. 146 Nonh 86 degrees 15 minutes Wesr a distance of 172.85 feet to an iron pin in the northern righe- of-way line of 50 feet wide Par<1dise Road; thence by said northern right-of-way line of Paradise Roud North 3 degrees 4S minutes East a distance of 100 feet co an iron pin at the place of BEGINNING. HA VING thereon erected a single family dwel!ing house with mailing address of 1 I Parildise Road, Carlisle, Pennsylvania. . BEING Lots No. 147 and 148 on rhe aforementioned Dale Fetrow Revised Plan of LOts, which Plan is recorded in the hereinafter mentioned Recorder's Office in Plan Book No.3, Page 103. BEING the same premises which Edith J. Myers, Execurnx under the Last Will and Test:J.ITIent of Tressie A. Corman by Deed datedSeprember 16, 1983 and Reco!'ded September"j6, 1983 in the OERce of the Recorder of Deeds in. and for Cumberland County, at Carlisle, Pennsylvania in Deed Book "J", Voltlme 30, Page 465, granted and conveyed to Ba:-ry L. Roush ilnd Linda C. Roush, husband and wife, the granrorsherein. BEING also as to Lot 147, the same premises which Arth1,ll' E. Clepper and Carmaline Clepper, his wife. by Deed dated July 3, 1948, and recorded July 3, 1948 in rhe the above- menrioned Recorder's Office in Deed Book "V", Volume 13, Page 414, granted and conveyed to [..uther L. Clepper, and Mary Lou Clepper, his wife. It being aIso as to Lot 147, the same premises which the Tax Claim Bureau of Cumberland County by-Deed dated March 6, 1964, and recorded March 9,1964 in [he above-mentioned Recorder's Office in Deed Book "Du, Volume 21, Page 55. gnnced and conveyed as the propeny of Lutl:l,er Clepper, to Vernon M. Shirk and Tressie A. Shirk, husband and wife. The said Luther L. Clepper, by Quit-Claim Deed dared May 9,1991 and recorded May 14,1991 in the aforesaid Recorder's Office in Deed Book "C", Volume 35, Page 633, conveyed any interest which he may have had in the above-described property by virtue of at'y irregularities in the said sale and conveyance of the Tax Claim Bureau, ro Barr.! L. Roush and Linda C. Roush, the Grantors herein. .And being funher as to Lot 147, the same premises which by Order of Cou!'! recorded August 26, 1991 in Deed Book "H", Volume 35, Page 5 permanen:ly enjoined and resrrained the said Ma.ry Lou Cleppe:-, her heirs and assigns, fro,,", asserring any claim or ir.:erest in or to rhe said real property adverse to that of Ba.."ry L. Roush and Linda C. Roush, the Granwrs herein. SUBJECT lIO,VEVER. to ,.be rescrlc:icns as they appear on the Dale F:o:::-cw Revised Plan of Lacs re:;urdcd as aforesaid. Tax Parcel #21-22-0119-089 TITLE TO SAID PREMISES IS VESTED IN Josehp T. Jordan and Olivia K. Jordan, his wife by Deed from Barry 1. Roush and Linda C. Roush, his wife dated 8/30/91, recorded 9/4/91, in Record Book A-35, Page 408. ( ! ',~"'_~~iL~b,;,;""~i;J"Mlti,~;,},i'ko.'''-',,:J<,;"'',~,(!.",,{;;;.::!$<dr"''''~i";'''''~rl""'n''#lc,',:~i';:,,,'l~..,,' ~:'~A""",>,;<d~:~,orlli"""..""-"'~.Jlo~<M_~~,liljMlt\;hiim.f~&lI_~~~""..""I..,.,jMliIMl ",~ '''~.~. ~~"""ii:;,;oo -. ~(. . 0 0 .~ -- c: '.,J (.) ,-i ~ "" s: L.. ~ ~ "OUJ 1. A ~ ....0 ~ 9v &..J rnr;-e: c: L-,.. ~ h Z::r ;;.:;;: nl;2 8' - B 7' r-- :z:-' I :Bt~ c., (). 0 ~ 8 . c:i52c' co cI ..... 0 -<..<::~ {-:;.(~ () () 0 ~C) ...... ...... () )o'c """ Q~ :c c.v \ z ~ :r ~ )'-.. 6~ 1 I :;;:0 If? or., f'- f~ c Z ?E (I' )'- ::< w -.() ~ (J1 -< - ::; , . , , ~ , ~ ~=t -- "\ "' . Y,I2.:( ~~A,~,,,,_,:.j_,,J,_ U ,n~I]_,:JJ[,t]llL"f-:o)~;,_,~j:ikL _'Ct'_, "'C'-'""--,', ~,o"1_,,,,,_, , _"0"''''-'''0..,-,. _ ,0 ~~ " - I...:' 1...,1 " p <-" - ,,', ":;' . CENDANT MORTGAGE CORPORATION, FIKlA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOSEPH T. JORDAN OLIVIA K. JORDAN NO. 01-1813 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CENDANT MORTGAGE CORPORATION, F/K1A PHH MORTGAGE SERVICES 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 11 PARADISE DRIVE CARLISLE, P A 17013 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOSEPH T. JORDAN 5800 AL TAMA AVENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 AL T AMA AVENUE, #102 BRUNSWICK, GA 31525 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 , 1'1. -< ." . ~ ";}.i -~ 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address Camlot be reasonably ascertained, please so indicate.) MASTER FINANCIAL INC. PO BOX 1109 ORANGE, CA 92668 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address Camlot 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 Camlot be reasonably ascertained, please so indicate,) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address Camlot be reasonably ascertained, please so indicate,) Tenant/Occnpant 11 PARADISE DRIVE CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth olf 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 of 18 Pa. C,S. Sec. 4904 relating to unsworn falsification to authorities, ~~ RANK PEDE , ESQUIRE Attorney for Plaintiff Mav 25.2001 DATE II j~:ic-'&>iliL'!C<,~Ilis:l>~,l;!lfEO.."~~~Jl";,,",J.,,':bj;!',,~, ,""""..'",",~,:;-"",'<--;.o<~:: :"'""~",'~"~"",,,,,,,;;':,.1,~""'iJ,t._H6.,,,":h~...~Uili~~_lia~ ~ I" 1IJ..._ ~,,~ ~"!IJJ.l~. ,'_~ . ,,~=..y ..~- ",,-~- ,~,." ",",--,~. ,~ ~ '. _-1~)1"'~~:W;~!" ~- . 0 0 0 C -n ~~ , ~-, ".. C -cco :~-if1 f1lrTI % z:x' , .--,r" zr;::. ~~r:1 0') :~:~ I ~:Z: '::p~ [;20 ;J:>o ?Z:Q :x: ?)~ Zrn -=U 'P. S >e: z w )> :;! (Jl ~ ~ . , "','"' '" ~ " -" "'~ "1 1 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 CENDANT MORTGAGE CORPORATION, FfKlA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION JOSEPH T. JORDAN OLIVIA K. JORDAN NO. 01-1813 Defendant( s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is 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: () 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. e.S. Section 4904 relating to unsworn falsification to authorities, ~~ RANK FEDERMAN, ESQUIRE Attorney for Plaintiff ;~;.t~;lli<"(:~~",-W""",!",""'ii;'",l,":;j'o:iC:"io,~(1d"t.ti,',,,,,,,,,,, ~,j,),~C,~",- "~'c:'/,E,.'loH':';kim.b)oM~,l#;;',jMJ'hfll~l!:iI~~""~-u;,;r,;~,,,,~,~~~~JiII~1~""'"'--" -'~"" ~ () C> C 0 "us:: <:- -q tc --" mrl~ .::;:: Z-r, :<E: .:C;':;-'i! Ze I '~ C/'J4 .-, '" ~.- Co "'.:i{:j KG ",. _":'9 ~G ~ ~ ' I - ;::;-'"71 :SA '-9 ,~:d <'5 ~ orn W -, S'; c.n -< "":!r:,,,,<;$:ry:;,,,l?,~:,,.;-',_!~I,,4:lJ,~ "~~~U,W!I;~~t~]SJ-,.::!11 ~l"X) r;,;, "'" r.J,l~l":,,. I[ l.~. """" ,", -.' , n" " , ~ =,..w , -<~"- ",,1 ~ " ,~,. ,'- ... '," , i CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 01-1813 v. JOSEPH T. JORDAN OLIVIA K. JORDAN Defendant(s). May 25,2001 TO: JOSEPH T. JORDAN OLNIA K. JORDAN 5800 ALTAMAAVENUE, #102 BRUNSWICK, GA 31525 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSL Y 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 PROPE.1UY... Your house (real estate) at 11 PARADISE DRIVE CARLISLE, PA 170Bis 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 CENDANT MORTGAGE CORPORATION, F/KIA PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to 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 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, ~~ i, I J ~_ ,,, ,~ '"._~~li1v').! 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 ifthe 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 ~a . 6. You may be entitled to a share of the money which was paid for your house, A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days ofthe 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 ALA WYER 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 I r ,- ~<-~- ~.1 "", , I. ..,,1.LL THOSE. CERTAIN lots of ground with the improvemenrs chereon erecced situate in ...~dd!e5e>; TownshIp, Cumberland County, Pennsylvania, bounded and described in accordance Vo)tl1 a Lot 'pla~ for BarTY Roush prepared by Larry B. Neidlinger, Professional Land Surveyor, a copy of w)"uch ]s attached hereto, as follows: ". ~ . - ..": BEGINNING ac an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at comer,.of Lot No. 149 as shown on the Dale Fecrow Revised Plan of Lots recorded in the hereinafter menrioned R=co~er's Office in. Plan Book No, 3, Page 103; chence by said Lat No. ~49 South 86. deg-:-ees 15 nunutes East a distanCe of 172.85 feet to an iron pin; thence South 3 degrees 45 mlOutes West a distance of 100 feet to an existing iron pin at comer of Lot No. 146 as shown on the above mentioned Dale Fetrow Revised Plan of Lots; thenee by snid Lot No. 146 North 86 degrees 15 minutes West a distance of 172.85 feet co an iron pin in the northern righe- of-way line of 50 feet wide Paradise Road; thence by said northern right-of-way line of Pandise Road North 3 degrees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. HA. VING thereon erected a single family dwelling house with mailing address of 11 Paradise Road. Carlisle, Pennsylvania... " BEING Lots No. 147 and 143 on the aforementioned Dale Fetrow Revised Plan of Locs, which Plan is recorded in the hereinafter mention<::d Recorder's Office in Plan Book No.3. Page 103. BEING the same premises which Edith J. Myers, E:<:ecut:-lx under th.:: Last Will ~~d Test:J.J"nenr of Tressie A. Corman by De::d dated September 16, 1933 and Reco!'de<:! Septembe.....16. 1933 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book "r, Volume 30, Page 465, granted and conveyed to Bill"ry L. Roush ar.d Linda C. Roush, husband and wife, the grantors herein. BEING also as to Lot 147, the same premises which Arthur E. Clepper a.'1d CarmaEne Clepper. his wife, by Deed dated July 3, 1948. and record<::d July 3. 1948 in the eh.:: above- mentioned Recorder's Office in Deed Book "V". Volume 13. Page 414, granted and conveyed to [..uther L. Clepper, and Mary Lou Clepper, his wife. It being also.as to Lot 147, the sam<:: premises which the Tax Claim Bureau of Cumberland Couney by Deed dated March 6, 1964, and reeorded March 9, 1964 in the above-mentioned Recorder's Office in Deed Book "0", Volume 21, Page 55. grnnted and conveyed as ehe property of Luther Clepper. to V.::mon !'vI. Shirk and Tressie A. Shirk. husband and wife. The said Luther L. Clepper. by Quit-Claim Deed dated May 9,1991 a.-,d recorded )'by 14,1991 in rhe aforesaid R<::corder's Office in Deed Book "C", Volume 35, Page 633, conv<::yed any ineerest which he may have had in the above-described proper;y by 0.nue or ar.y irregularities in the said sale and conveyance of the Tax Claim Bureau, to BalTY L. Roush ~nd Linda C. Roush, the Grantors here:n. "And being further as to Lor 147, the same premises whIch by Order of Court recorded August 26, 1991 in Deed Book "H", Volume 35, Page 5 perrr.anen:ly enjoined and rescrained cJ:e said Ma...J' Lou Cleppe~, he,. heirs and assigns, fror:-: asserting ar.y claim or in:erest in or to the said real pro~rty adverse eo that of Ba..'T)' L. Roush an': Linda C. ROL:sh, the Granwrs herein. SUBJECT HO}VEVER. to [he resrric:ions as they appear on the Dale Fe:=ow Revised Pran of Lots re~"rdcd as aforesaid. Tax Parcel #21-22-0119-089 TITLE TO SAID PREMISES IS VESTED IN Josehp T. Jordan and Olivia K. Jordan, his wife by Deed from Barry L. Roush and Linda C. Roush, his wife dated 8/30/91, recorded 9/4/91, in Record Book A-35, Page 408. ( J :j~!lli18i\::ill!J..,,;,,~~;,~-"'I'I\.8'''-''; _<__~i",_l" ,';!~&-o"",:,;"",,',~".,,;~.,,"~,l,,,,-,,'<"'" ,,\.;;..,,;.= "~,,\,..,,,,~A.tB1..~~jlJjJ~ilIw:t~_I'ic~<,or~ ";11 'r->!IIIllJ~ilI"'~~" 11ll!lil4alll1dillt"'~ .~'~' "",; , 0 0 0 c: " s: '- :.-j ;:go:; c: HI Z '~l1-n Z;:C , Z1:;- , =gf9 Ws CO -<.!-- ~:1~ ~O :l> ~O ~ ~j~~ )>8 I.D 6rn :z -1 ~ W 35 (J1 -< :r~;:,;>,Jt'Ln.::':,""~,:,trr";';,:J";~t~,,,,,~~L~1~,\lc ~4!J~l'~R ,~, ~~ M;i", . 1', ,,_ ~ ,,0 ",=i,~" '?"_",__ >. < ~ - "~, I. L ~- '" ,"" <--,~ =. "', '0" . i AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY No.OI-1813 DEFENDANT(S) JOSEPH T. JORDAN OLIVIA K. JORDAN Type of Action - Notice of Sheriff's Sale SERVE JOSEPH T. JORDAN AT 5800 AL T AMA AVENUE, #102 BRUNSWICK, GA 31525 Sale Date: SEPTEMBER 5, 2001 SERVED ~ Serve~ and made known to -=r 02? ~"-P h ~ Did ~ , Defendant, On the --!b- day of -.:J l{ "'-= , 200j, at 1 ,~, o'clock -\'m., at ~ '260 -A-l~ ~ A:Vt; * Itl? , Commonwealth \SW~ of l'<!EB'yl-na, in the manner described below: Defendant personally served, , \ ^ V Adult family member with whom Defendant(s) reside(s). Relationship is l'l\ <!lfl..(:) ~(Cl!~ Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging 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 k Height 6 f Weight j.' yo 1,s;1-n('('f'fjJ;.J,,'n::...Yl , a competent adult, a true and correct copy of the Notice of Sheriffs Sale' the address indica@!. above. Race ~ Sex A Other Swom to and subscribed befo!'e "Ii: thjs JL<.- day of -J~~-, 20U. Notary: H<llllj Pu.bNc, Glynn County, Georgia .lofy Colllflljs$lon Elq,;re. Mav 9. 2005, On the day of ccording to law, depose and state that I personally handed herein, issued in the captioned case on the date and at BY:~ de ~~~ NOT SERVED ,200_, at o'clock_.m., 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 1400 Philadelphia, P A 19103 (215) 563-7000 ;~~~iIi.;l!tI/l'<<:i(~,,,b"';;",,,'-''''''J''.o1;;~';lll''''',1,-!h~;l"''''lt",;,,,.:,~;W',G..1Eh""~,,,'~':,"'JI1-;'~~!,~.Mjl1r,I;i;l~~i~lalDHI'~"'" !,,,,\ll, ",-,)!lH0,~d,tU ,,'"'-~; ~"lJ,D",I':;.U.J ',C,~-;,;,. ,~- IUo.j ~,c~ ',' ~-<" "~' ~", , '.'iIl>., "'-- .,(."""'0/0,......,. , ~._ ,~ 'M' ~ ,W ~ -~~~" ~.~~,~.~ -'.~--- "'''''' - ,,-. - --:-.~.. '~ ~;, o -v~ ['1:-11':' Z-~:' -;;,. - OJ -< ~ J.::;..I-:'" 5~~~ 5 -.( ~. ~,J.. ~ ~ ;; r...: r;: ':.n (;.J''I- ; --:,., J! '~- ,"~ ". "'"'" - -"-- "j;.,',C' " AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, FfKI A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY No,OI-1813 DEFENDANT(S) JOSEPH T. JORDAN OLIVIA K. JORDAN Type of Action - Notice of Sheriff s Sale Sale Date: SEPTEMBER 5, 2001 SERVE OLIVIA K. JORDAN AT 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 SERVED Served and made known to C:::A It,) ~.A- k ~.j' cJ)/YI , Defendant, on the If, at Jtsb ,o'clock 1m., at SB6c A/I~04- ~ 4- /~ day of ......... J",A- ,20QL, , Commonwealth of Pennsylvania, in the manner described below: ,Defendant personally served. ~ ,./' Adult family member with whom Defendant(s) reside(s), Relationship is /lIc,A.t2J \ok: .5"~ 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 ofbusilless. an officer of said Defendant(s)'s company. Other: ~ ~7! I tl/" Heig weighV~ Race L Sex mOther Description: I, 7l.S ~, a competent adult, bein a true and correct copy of the Notice of Sheriffs Sale in the the address jndicatedabove. cording to law, depose and state that I personally handed herein, issued in the captioned case on the date and at Swom to and subscribed befoJ'i:: methis ~ day of ,,\jt \F: , 200_~. Notary: Warlry~. Cl/)!nn Counly.1le .- IIy COIIImiIB/an ExDil\l$lIav 9. 2~ On the day of BY:~~~ NOT SERVED ,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 - J.D. No. 12248 One Penn Center at Sub~rban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 -"'itl) I ,i.' ~." '"","" "''''' i'!hjll~-~ "'~!~~i1!1;R48aj:~):&,f;~:'l.,,,ci,~,;liEi!!iil:1i~'<!oli1'~''''''','','''e,<d,';',&llih!'~~"'4~1W:."..,;;ml!,U-';:;~~~~.IlllliU_llij 'Y."""'->" fr t! q/ c.. u:) V6rcPCM... '!~h, ec"V~.~~.l."Co ,{.""" .f~li{I~,IJjI!;jJD:r:,,,.';,-.,!IUJJl!Jl;, ,,~,.., ,""'" ".,,,, '.--- ,~,"" '""~-- ~6~ J ~/ ,,-- ,,~~ ~ () c: <" ~~: -:" ~:- ~C~. ~~ _,1 -< . '-"-< ~ '" -~ii " c:--_> "- .~:::: , i"-":' ~." " ':A (jl M .~. '" ' ...... ,"'"'.~, ~" 't.. ., v SALE DATE: SEPTEMBER 5, 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE CORPORATION No.: 01-1813 vs. 60SEPH T. JORDAN OLIVIA K. JORDAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 11 PARADISE DRIVE. CARLISLE. PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required byPa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. August 14,2001 5. .. CENDAi'iT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOSEPH T. JORDAi'i OLIVIA K. JORDAN NO. 01-1813 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTG~GE SERVICES 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 11 PARADISE DRlVECARLISLE, P A 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOSEPH T. JORDAN 5800 AL T AMA A VENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 AL T AMA AVENUE, #102 BRUNSWICK, GA 31525 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 ... 4. Name and address ofthe last recorded holder of every mortgage ofrecord: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) MASTER FINANCIAL INC. PO BOX 1109 ORANGE, CA 92668 5. Name and address of every other person who has any record lien on the property: N ALV1E 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 plaintiff has 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 11 PARADISE DRIVE CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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. ~~ RANK FEDE , ESQUIRE Attorney for Plaintiff Mav 25.2001 DATE J~ ~ ., ~, ... DATE: May 25,2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) JOSEPH T. JORDAN OLIVIA K JORDAN PROPERTY: 11 PARADISE DRIVE CARLISLE, P A 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m, in Cumberland County Courthouse. South Hanover Street. Carlisle. P A. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule, LH .. :9.0' @!!l: ~ z c:~ i'l", ~~ "'0 '< - (Jl m ~ a. i ~ ;lJ.... ,,0 00; " - ~-~ 0.3 "'0- -" ,h @ sa. O~ ~2 2 ~ ;lJ"1l "g 0_ ~'3 s.w ~ ~ ""iii' m.~ 3"1l "" 0':' ';1;z " '" -3 " Q, ~ CJ1 J "" ~ o ~ -I> ~ N ~ ~ 1 ~I~=~I {iV.... 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" ~ .. ~ [ ~ o. 50 ~ fa ~ Q - (j '" " 5- 3 "1l =' 0 ~ !a- S' 0 = :11 Q. 2 Q 6: " a. = iii -J l;1 - w Z Q ., - =' = " " ~ .. ., '" - ;; :l .. o 0:1 Q >< N ~ ..., '" = " ., ., ,,' =' " ., '!" .. > (j " ~ ~ F .. > - ..., '" - w - ..., - '" '" ~j Q6:~ cnC.3 co .. co :::J = m c."''' ~ C. ~'O'" '"OCJ')::sm :::r~",o =-.1 m ~c....-o:AI '" 0 '" $: -0-:1"5",,"- :::r" ~ -'."Oz OJ, "')> 'lJ^3.z )>g:~o -'"::JQ)-o ~~-:c 0,< g'm c,uccO"'r ~OC)> COCi:Tz -'"mOl -1><" Ql(fJ a. _ - OJ (fJ=- .-",0 CD ;:;:::::::i o~ ~~ o "1l o ~ 0; 'li ." m m r"~ ".,' STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler ~ -------------------------------_______________________________________________Ilecorderof Deeds in and for said County and State do 'hereby cenify that the Sheriffs Deed in which ________n_u___ Federal Home Loan Mtg Corp . ------------------------------------------------____________________________________ ~ the gr.antee the same having been sold to said grantee on the ______2.!'l!.______________u__u___n________u__ day of September ' . 01 . . . __________________u_____u__________u_ A. D., ' u___, under and hy vtnue of a wnt______n______ 8th Execution . ____________________________________u__________ISSUed on the ____________n_____n_______u_______ day of ________!~':~_____________ A. D.,Ol u___, o~t of the Court of Cornman Pleas of said County as of Civil 01 _____________________ ____h___..' _____ __ u _ __ _ __ u ____ ___u_________ _u_________ __ _ Term, : . 1813 . Cendant Mtg Corp fka PHH Mtg Serv Corp Number ______________, at the SUit of __n____________u__u________________________u_u___u__u___ . Joseph T Jordan & Olivia K ------__________ ----________ ___ __ __ agalnst_ ___ _ ___ __ _____ ___ _______ __________ ______ ___________ is 248 2576 duly EUOrded in Sheriff. Deed Book No. ______u____, Page _____u_____. IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office this -.2:f--- day of ____J~-'L_________________ A. D., ~__ Ilecorder of Deeds . . '""UI~,;;' Cendant Mortgage Corporation, f/k/a PHH Mortgage Services Corporation VS Joseph T. Jordan and Olivia K. Jordan In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1813 Civil Term R. Thomas Kline, Sheriff, who being duIy sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Joseph T. Jordan, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only, to his last known address of 5800 AltamaAvenue, #102, Brunswick, GA 31525. This letter was mailed under the date of June 29, 2001. On JuIy 23, 2001, the unopened letter was returned to the Sheriff's Office with reason checked "unclaimed." R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Olivia K. Jordan, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only, to her last known address of 5800 Altama Avenue, # 1 02, Brunswick, GA 31525. This letter was mailed under the date of June 29, 2001. On July 23, 2001, the unopened letter was returned to the Sheriffs Office with reason checked "unclaimed," Dawn 1. Kell, Deputy Sheriff, who being duIy sworn according to law, states on July 2, 2001 at 8:50 o'clock A.M., EDST, she posted a true copy of the above Real Estate Writ, Notice, Poster and Description on the property of Joseph T. Jordan and Olivia K. Jordan, located at 11 Paradise Drive, Carlisle, PA 17013, according to law. R. Thomas Kline, Sheriff, who being duIy sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Joseph T. Jordan, by reguIar mail to his last known address of 5800 AItama Ave., #102, Brunswick, GA 31525. This letter was mailed under the date of JuIy 24,2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duIy sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following marmer: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Olivia K. Jordan, by regular mail to her last known address of 5800 AItama Ave., #102, Brunswick, GA 31525. This letter was mailed under the date of JuIy 24,2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 5, 2001 at 10:00 A.M., E.D.S.T., and sold the same for the sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage Corporation. It being highest bid and best price received for the same, Federal Home ""...... "~ -., -, I..J ',-', ".hiJjIilliJ.n~b Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna, VA 22183-5000, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $1 ,283 .67, it being costs. 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 Sheriffs Deed 30.00 25.17 15.00 15.00 30.00 10.00 .50 1.00 3.25 14.30 15.00 30.00 586.25 431.04 25.66 25.00 26.2Q $1283.67 Sworn and subscribed to before me This ~ day of f]).w:.t-- 2001, AoD.1rr-- 0.. "n< ,I'd,. i ~ r thonotary So..~?' r'~~Jl'-.J~ ~-t1 R. Thomas Kline, Sheriff BY~~Swcl Real Estate Deputy ~ oV~ :!io' ~,6D ->~; cle-"" ~./J7;;;;:JJ., i '''~ . 1, ~~ c:~r.:'~.. , . ~~ - oL^ "J_,I . "' , iliIlIYf. ,,' j '~ fj)tifg~ " . CENDANT MORTGAGE CORl'ORATION, FfKlA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOSEPH T. JORDAN OLIVIA K. JORDAN NO. 01-1813 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES 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 11 PARADISE DRIVE CARLISLE, P A 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannol be reasonably ascertained, please so indicate.) ~,.,. , JOSEPH T. JORDAN 5800 AL T AMA AVENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 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 J L," ~ un ,~, ^--"'~t, . J 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.) MASTER FINANCIAL INC, PO BOX 1109 ORANGE, CA 92668 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 plaintiff has 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 11 PARADISE DRIVE CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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 Qf18 Pa, e.s. Sec. 4904 relating to unsworn falsification to authorities. Mav25,2001 ~... ~ :1-~ DATE~~~, ESQUIRE Attorney for Plaintiff - ,h =, .'.. 1Ii~1IIi1illjrw: ,. f CENDANT MORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 01-1813 v. JOSEPH T. JORDAN OLIVIA K. JORDAN Defendant(s). May 25,2001 TO: JOSEPH T. JORDAN OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 -'THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON 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 A ITEMl'T TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST l'ROl'E,RTY." Your house (real estate) at 11 PARADISE DRJ[VECARLISLE, PA 17013is 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, PA 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. 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 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. - ..,J-...l ""-~;ii' ,. 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. (Seenotice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the 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 of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 IliLl.]i'...... _ _.~ , '~ " ".l.,,"" ~.~ , , . ...,,4.LL THOSE, CERTAIN lots of ground with the improvemenrs thereon erected. situate in ....~.ddk$ex TownshIp, Cumberland County, Pennsylvania, bounded and described in accordance ~,il a Lot :<>la~ for Barry Roush prepared by Larry B. Neidlinger, Profession:l..! Land Surveyor a copy gf wjuch IS attached hereto, as follows: .' ' - ,- . BEGINNING at an iron pin in the northern right-of-way line of 50 fcer wide Paradise Road at c,?mer:'of Lot. No. 149 as sh,own on the Dale Fca-ow Revised Plan of Lots recorded in the h:rclnafter rr;,enrroncd R~o~er s Office in. Plan Book No.3, Page 103; thence by said Lot No. 1...9 South 8b deg-:-ees 15 mmutes East a dIstanCe of 172.85 feet to an iron pin; thence South 3 degrees 45 minutes West": distance of 100 feet to.an existing iron pin at comer of Loe No. 146 as shown on the abov~ m:nuoned Dale Fetrow ReVIsed Plan of Lots; thence by s;:tid Loe No. 146 Nor:h 8~ degrees 1.':> nuz:utes We~t a distance of 172.85/eet to an ir?" pin in the northern righe- of-way lme of 50 feet wlde Pand:se Road; thence by sald nonhern nght-of-way line of Pan.dise Road Nor:h 3 degrees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. HA. VING ehereon erected a single bmily dwelling house wieh mailing address of 11 Paradise Road, Carlisle, Pennsylvania. . BEING Lots No. 147 and 148 on the :uorementiooed Dale Fell'ow Revised Plan of Lots, wr.ich Plan is recorded io the hereinafter mentioned Recorder's Office in Plan Book No.3. Page 103. BEING the same premises which Edith J. :lvfyers, Execunix under the Last Will 'l,nd Test.:ur.enc of Tressie A. Corman by Deed dated September 16, 1983 and Recorded. September"16, 1933 in the Office of the Recorder of Deeds io and for Cumberland County, at Carlisle, Pennsylvania io Deed Book "1", Volume 30, Page 465, granted. and conveyed to Barry L. Roush ar,d Lind:l C. Roush, husband and wife, the grantors herein. BEING also as to Lot 147, the same premises which Arthur E. Clepper a.'1d CannaEne Cleppu, his wife, by Deed dated July 3, 1948, and recorded July 3, 1948 in the the above- mentioned Recorder's Office in Deed Book "V", Volume 13, Page 414, granred and conveyed to Luther L. Clepper, and Mary Lou Clepper, his wife. It being also as to Lot 147, the same premises which the Tax Claim Bureau of Cumberland County by Deed dated March 6, 1964, and reeorded March 9, 1964 in the above-mentioned Recorder's Office in Deed Book "0", Volume 21, Pag::: 55. grnnted and conveyed as the propeny of Luther Clepper, to Vemon Nt Shirk and Tr:::ssie A. Shirk, husband and wife. The said Luther L. Clepper. by Quit-Claim Deed dated May 9, 1991 a...:d recorced :\-by 14, 1991 in the afon:said Recorder'S Office in Deed Book "C", Volume 35 , Page 633, conveyed any inrerest which he rn:lY have had in the above-described property by virtue of any irregul:0.ties in the said sale and conveyance of the Tax Claim Bureau, to Barry L. Roush and Linda C, Roush, the Grantors herein. 'And l::eing further as to Lot 147, the same premises which by Order of Court re:::orded AugUSt 26, 1991 in Deed Book "H". Volume 35, Page 5 perrnaner::iy enjoined and res:::-ained the said Ma...J' Lou Clepper, he:- heirs a:1d assigns, hor:: asserring an;! claim or in:e:est in or to the said real prope"y adverse to that of Ba.rry L. ROLlsh ar',d Linda C. Roush, the GralHors herein. SUBJECT HO"VEVER.. to doe rest:i.c:ions as they appear on the Dale F::::row R".,rjscd P:"n or Lots re~,)rdcd as aforesaid. Tax Parcel #21-22-0119-089 TITLE TO SAID PREMISES IS VESTED IN Josehp T. Jordan and Olivia K. Jordan, his wife by Deed from Barry 1. Roush and Linda C. Roush, his wife dated 8/30/91, recorded 9/4/91, in Record Book A-35, Page 408. ( ! - '_'--". ,I 1,,1 I, , " "~' -- .', ,'0' ,,d ,~, , . WRIT OF EXECUTION and/or ATTACHMENT .';'. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO, 01-1813 CIVIL ~ TERM CIVIL ACTION - LAW - TO THE SHERIFF OF OJrnberland COUNTY: To satisfy the debt, interest and costs due PHH Mortqaqe Services Corporation Joseph T. Jordan and Olivia K. Jordan, Cendant Mortgage Corporation, F/K/A from PLAINTIFF(S) 5800 Altarna Avenue, #102, Brunswick, GA31525 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to a~ach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to nomy 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 cifthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $92, 189 . 65 fram 5/18/01 to 9/5/01 Interest par diem $15'" 51 ,hhh qq i'lnn Atty's Comm % Atty Paid S 129. 10 Plaintiff Paid L.L. $.50 $1.00 CnstsDue Prothy Other Costs Date: ,June 8. 2001 Curtis R. Long Prothonotary, Civil Division '- by dv,.-,p_ f? 7t;()}/!A~~ Deputy REQUESTING PARTY: Name Address: Frank Federman, Esq. One Penn Center at Suburban Station, Suite 1400 PA 19103 Philadelphia, Plaintiff Attorney for: Telephone: Supreme Court 10 No. 215-563-7000 12248 ""~"''''''"''''~,''h,:":"'Lh'''iJ."";'',,b""'''o,,,,,~,"j''.~'';''~:"~'~''''A ~ <H> c::::::I ~ I!:!!::a ~ "'-^",-";,,,,,,,,""~"":';"~.>!1"',,""'~;;b,_:..il;,,,"&>1ioo,IM.1Il;I!;~ili!lYd1i>>M.!~'-,,~~.~iAW.,~,:MI1ilillO,"&Uili;/il~,"_<di""..,.;Jt-".' ,~i< . , REAL ESTATE SALE No. ,;2 (, J l..l..iI.R. /3, 'J.M I the 3nerifllevied upon the aeienoanu In!'i''''!'' "\~"'~'" ,,':I!~ted in t1~'I--r;;~ ,;urnnertano Coumy"o. ., KnrW'i 'HId numbered as: II p~ Oil . Co.J>>~.f) and more full\, described on Exhibit "A" filed with this writ and by this reference incorporated herein. ''It,,-#,^,,, /3, :>00/ By:~ f~ ~ \ \,\ '"11 d, .' c. r't '.\- ,\" 'ri ~\ \ . ". ,\ \; \'\'~'. , .1\ \\\I~ '\ \\\ t ' 11\, \\0,.\,\\\0" IV ,- ,~6v ,,,, ", . \" \l: '},':I\ ~~l<~~SV,\l . 66\\\- "{l,-;t&)~''':',~1'-jL , ,o"j'."~"",p", '11"',""'1" , '-.:<" ~"~:-,.",~jl ;,~ -,,', ""', ',"",'o""_,~,?,' ~'", c ,~ '" '~'''-'','',", . ~~. .- REAL EST>\'I'E SALE NO. 26 Writ No. 2001-1813 Civil Cendant Mortgage Corporation. F /K/ A PHH Mortgage Services Corporation vs. Joseph T, Jordan and Olivia K. Jordan Atty.: Frank Federman ALL THOSE CERTAIN lots of grormd with the improvements there- on erected situate in lWddlesex Town- ship, Cumberland County, Pennsyl- vania. bormded and described in accordance with a Lot Plan for Barry Roush prepared by Larry B. Neid- linger. Professional Land Surveyor. a copy of which is attached hereto, as follows: BEGINNING at an iron pin in the northern right-of-way line of 50 feet wide Paradise Road at comer of Lot No. 149 as shown on the Dale Fet- row Revised Plan of Lots recorded in the hereinafter mentioned Record- eTS Ofllce in Plan Book No.3, Page 103; thence by said Lot No. 149 South 86 degrees 15 minutes East a distance of 172.85 feet to an iron pin; thence South 3 degrees 45 min- utes West a distance of 100 feet to an existing iron pin at corner of Lot No. 146 as shown on the above men- tioned Dale Fetrow Revised Plan of Lots; thence by said Lot No. 146 North 86 degrees 15 minutes West a distance of 172.85 feet to an iron pin in the northern right-of-way line of 50 feet wide Paradise Road; thence by said nm"them right-of-way line of Paradise Road North 3 de- grees 45 minutes East a distance of 100 feet to an iron pin at the place of BEGINNING. HAVING thereon erected a single family dwelling house with mal1lng address of 11 Paradise Road. Carlisle. Pennsylvania. BEING Lots No. 147 and 148 on the aforementioned Dale Fetrow Revised Plan of Lots. which Plan is recorded in the hereinafter men- tioned Recorder's Office in Plan Book No.3. Page 103, BEING the same premises which Edith J. Myers. Executrix nnder the Last Will and Testament of Tressie A. Corman by Deed dated Septem- ber 16, 1983 and Recorded Sep- tember 16, 1983 in the Office of the Recorder of Deeds in and for Cumberland County. at Carlisle. Pennsylvania in Deed Book "J". Vol- ume 30. Page 465, granted and con- veyed to Barry L. Roush and Unda C. Roush, husband and wife, the grantors herein. >" -. """" BEING also as to Lot 147. the same premises which Arthur E. Clepper and Carmaline Clepper. his wife. by Deed dated July 3, 1948. and recorded July 3, 1948 in the above-mentioned Recorder's Office in Deed Book "V". Volume 13, Page 414, granted and conveyed to Lu- ther L. Clepper. and Maty Lou Clep- per, his wife. It being also as to Lot 147. the same premises which the Tax Claim Bureau of Cumberland County by Deed dated March 6. 1964. and recorded March 9. 1964 in the above-mentioned Recorder's Office in Deed Book MD", Volume 21. Page 55, granted and conveyed as the property of Luther Clepper, to Vernon M. Shirk and Tressie A Shirk. husband and wife. The said Luther L. Clepper. by Quit -Claim Deed dat- ed May 9, 1991 and recorded May 14. 1991 in the aforesaid Recorder's Office in Deed Book "C". Volume 35. Page 633, conveyed any interest which he may have had in the above- described property by virtue of any irregularities in the said sale and conveyance of the Tax: Claim Bu- reau, to Barry L. Roush and Linda C. Roush, the Grantors herein. And beingfurlher as to Lot 147. the same premises which by Order of Court recorded August 26. 1991 in Deed Book MH", Volume 35, Page 5 per- manently enjoined and restrained the said Ma1y Lou Clepper. her heirs and assigns, from asserting any claim or interest in or to the said real property adverse to that of Bany L. Roush and Linda C. Roush. the Grantors herein. SUBJECT HOWEVER. to the re- strictions as they appear on the Dale Fetrow Revised Plan of Lots record- ed as aforesaid. Tax Parcel #21-22-0119-089. TITLE TO SAID PREMISES IS VESTED IN Josehp T. Jordan and Olivia K. Jordan. his wife by Deed from Barry L. Roush and Unda C. Roush. his wife dated 8/30/91. recorded 9/4/91. In Record Book A-35, Page 408. .[ 1liI]11iI.~ - hi -,",":':"-'~-~ ~~ "'" _,I I" LJ i' " '"" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. MorgenthaI, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VlZ: JULY 20, 27, AUGUST 3, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~-- Rog M. Morgenthal, Edltor SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 ~~ L v!T~-V Notary ~ , NOTARIAi.'Wd., LOIS E. SNYDER, Nolary PublIc CarlisleBoro, CumbertaniI County My ConimiasIon Expna Man:II ~2005 REAL ESTATE SALE No. 26 VI.fiNo.2001.1813 . . ClvilTerm Cendant Mortgage " Corporation, F/KlA PHH Mortgage Services Corp. vs . Joseptl T. Jordan' Olivia K. Jordan Atty: FrankJe<:Ierman OESCP,PTiON . AU. TIl.OSE CERTArt'nrn~ of ground wi~b the lffi\lrtl\~ment'> thereon d'ectl'rl ~ilu<lfC In ~1lddlt'-. ~e~ Township, Cumbt'rland' COUIl!~, Pcnns\h-ani<1. . bounded and dcscrib~. l\1 ..K'Cordancc with a Lot Pl,ao fqr Bal11: Rou~h pn'llJTt-:d by Lm)' B. l'<cldhng~r, i1'olcSS1~na\ Land Sum:~(}r, d l;Opy of whl.:h 1:- attacllcd hcTt'lo,asfollo\\<;: ' HEGINKINO at an Iron pin In ~hc no;mcm ng\)'I- of-\l.,j\J line of 50 feci wide Paradl~ Road at , com~ of Lot No., 1~9 a,s shown Oil th~ D:~e , FNrO'i' Revisco Plan of ,1;)\\\ le..:l'tt\:kd, II'! i~. hereinafter mc'ntionctI RecO{'l:kr's Of,!cc 10 .Pl~n Book No.3. Page 103: IherlC~ 1?1, silld l!,J,1 No., 149 5<llJlh 86 ~grees \5 mmul~s-ea;;.t a.Q.l~tance nf 17J.XS feet to an, 'm:m p'm; 'thcr1ce South 3 degrees ,45 ~iml!c~ West.a distance of 100 f~ct ~~ an Cl\isl11li! !TIm, pm at come~ of Lot No. 1..\6 or.. r,TIll\\'n on the ~e menllrmcd Dale fetroW R-evised Plan o( l.Qts~ thence by 5;lld ~ No. 146 Nmth !Sri d~'grees 15 mi~llI~S Wtist a (hs~C of \11.&S \~et \(I au iran pin i~ the TKlrth.cm n!!ht~ {If.w:lY line of 50 k~t ",,!ue P:lradl~ .~~d~ thcnC~ by said northern nghl-of.~a~ hnt of 'Pu>,\.dii;e RlJ>id North .1 degrees ..\5 Immllt'S Ea~t ~. &;tanCC of 100 ICel. to an irOn pin at chI.' placc,ol " BEGINNING. '." ~ 'I HA.VING thereon ~'rectcd a smrJe iil?,1 Y dwdling hoo:-'c Mth mailing a.ldrcss ol: 11 Paradise Road, Carli"lI.', Pcnn<,-yl\'uma. BElNG ~ No. \47 and \48 m {h~ aforcmcntlOI1c.d Oak Fetrow Rs,."':Hsed ?~an I), I,~)ts.; which Plan l'i n;cOt'ded 1n the h\.'";111~ftcr mcltianoo ReCorder's Offi'ce hi Plan BooK: No.3, ~geJill--,-.,_ B'E[N,G the same pi1:-riil'sis v.llidil',diihJ: Myers:--- EitCcu.tnx under the L1S( will ilod T!:;'starr.ent of Tr~ssic A. Corm,lIt by Oee4 dated Scjx~inbcr J(,; '.19x3 and Recorded September 16" 1~83 m t~ Office of. Ilk:: Re\.."(lrdcr of Tkcds 1tl aad for Cumber/and Count)', at Ca'rli~le-, Pcllnsyhama In deed BoOk "J". Volume JO.. Page .\05;' gralltt'd Jnd conve~~d to BaITI; 1... ROll~1l and 'Uilcia C. Roush, husband JIId wife. the grantf'!f\ hc'r~m, EfE.1NG aho as io to! J47. the .'klme prerillses \l{~ich Arthur h. Cleppcr 3Ild CarmaJi!lc Ckppcr. hl~ Wire', by Dcetl daled, July J. 1948. and ri."C\ii'dL'd July 3. J948 ill.jhe above.rrienIIOtlt.'d Re-tordcr's Olliee III Ot.>e4 Book "V.... 'vUJume ' \3.. Pagc~\.\.. ,granleU amlC'fl-lW\.j'\:d {()Lutner C C1cpper,'.und Mary ,Lou, CJcp~r, his'v.;ife, it bt'ing aIM> as 10 f-.ot J4;, toc S3me.'premtSl:s ...;hkh the 1'.1:1;. Oaim BIlre:l.u. '\If Cumbi:~land COuntv bv Deed dated March 5, ;J%..\, and rtton:iCd March 9; 1%4 in tnl: aboVe-.mclltlonCd R<;.crm:ler's Otticc in IA-ed Book iDi, Volume 21. flagc 55. granted and conveyed as lht: property of Luther Clepper, te) vernon M. Shirk and Trc~~c ,\, Shirk. hu<J:1and'and wit<:, Thc'~d Luther L Ck:Jltkr.'h~' QUll-dainl ~ dated M<ty'9, I1Ql .Ill.] recorded May 1.\.. 1<}9[ In the afore:;aid Recorder's Oltke- in Deed Book "C', vOiume 35. PJ.f!e (,33. cOn\'cyC{! any inferest wl1ich' be may , h.J.VL" had ill thl' abQrc-d~.,;erib~'d property by _ vtrtue of any irrcguJarilit:!> in the said :-all' :lnd c!1TI\'e:yancc I)f the, Tax Claim Bureau. 10 BarT)' L. R(lu~h and Linda C f{ou!>h. the GrJ.lltors herem, .Ant! bdtlg tiJrtber .as to'Lot 1.\.7, the same llrcmhes whIch by Ord~r of Court recorded ~'UI:'USl 20. l'?9.l In Du:u BoOk iRi, Vol,ume 35. P-aE~' j permanently erijoi~ed :ind n:~!r:llncd the .~aiJ Mary Lou Clt;pper; her hem, and <.l~"lglt,>, fl'?m aSM.'fling any .dairo~ 1r mlcrC'il jn or 10 lne f'ard, real projX'rty' ad~er.;t. [0 tn.1t of Barry L R,,)]Jsh and Lmda C. Roush~ Ihe Grantor; Tit::rtin. SUBJECT HO'Y.'F.VER" ii] tne tbtrkllrm~ a$ {[1ey appt:ar on the l)Jlc Fetrow Rl.'Vised Plan Qf Lots re-corded i.l~ af()re~,J!d. Tux PijtcY#2.1-22.{}\ 19--(W,'l. TITLE TO SAID PREMISE.."i IS \'cited In Joseph 1. Jordan :md Olivia K. Jordan, hL~ wife., bv Deed (rvm Barry L. Roush and Linda ('~ RQ(l:~h, hi~ ....;xc, dated 8f3Q!<}t", t~\J\"d.-..j,.(iW9\, u(R~'(}rd ,&x.ki\~J5. Page 4118. 'Ji..'........'......... "':, I., '--I'. , , " ~ '~' , ' ,- ''''''1'.;tiM:lilb., 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 ~ 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 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 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 tor the Recording of Deeds in and for said County of Dauphin in Mis7aneous Book "M", V;I~::I~:~:~;' .....................................~..,......................,......................,.... COpy Sworn to and subscribed before e t is 21st da f Au 001 A.D. SALE#26 No\8lll181l1l T'"y..AYIIMD~~. ~nty H,"'IOIIIlI, --., My .coinmlt8lon E>cPIm J,,", t, 2001 P SVNanla AsSociatiCln at NollMJacommission expires June 6,2002 Menlb6(, eM " CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 429.54 1.50 431.04 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 ot the aforesaid notice and publication costs and certifies that the same have been duly paid. By....................................................................