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Home My WebLink About01-2423 FX > ~.- ,I,", "" , . -", -~'. ' '" ,~ _'~'~''''-~'''*d FEDERMAN AND PHELAN, LLP By: F~KFEDERMAN,ESQU]RE IDENTIFICATION NO, 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F, KENNEDY BOULEVARD SUITE 1400 PHlLADELPHIA, PA 19103-1814 (71 'i) 'i/i1-7000 ATTORNEY FOR PLAlNTIFF COURT OF COMMON PLEAS CIVIL DMSION BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA 101 EAST MAIN STREET, LOUISVILLE, KY 40232 Plaintiff TERM NO, 0/- .J'I:U ~ r~ v. CUMBERLAND COUNTY BARRY L. STEINOUR FELICIA F, STEINOUR 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, P A 17065 Defendant( s) CTVTT. ACTTON - T.AW COMPT ,A TNT TN MORTGAGR FORRCT .OSlJRR NOTTCR **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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court, If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GOTO 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, PA 17013 (717) 249-3166 Loan #: 1592732 ",'~' , " ;<~,' ;.' ,~ - - ' "r'rt;~fj 1. Plaintiff is: BANK OF AMERICA, NA, FIKJA NATIONS BANK, NA 101 EAST MAIN STREET, LOUISVILLE, KY 40232 2, The name(s) and last known address(es) of the Defendant(s) are: BARRY L. STEINOUR FELICIA F. STEINOUR 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 who is/are the mortgagor( s) and real owner( s) of the property hereinafter described, 3. On 8/25/89 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 950, Page 560, By Assignment of Mortgage Recorded 1/27/93 the mortgage was assigned to SOURCE ONE MORTGAGE SERVICES CORPORATION which Assignment is recorded in Assignment of Mortgage Book No, 436, Page 558, By Assignment of Mortgage Recorded 9/6/95 the mortgage was assigned to NATIONSBANC MORTGAGE CORPORATION which Assignment is recorded in Assignment of Mortgage Book No, 503, Page 573, PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same, 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 11/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith, ,~J ,,"." '~ " it:'~,; 6, The following amounts are due on the mortgage: Principal Balance Interest 11.86 through 10/1100 (Per Diem $4/1 /0 I) Attorney's Fees Cumulative Late Charges 8/25/89 to 4/1/01 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $43,298,84 2,170.38 2,164,00 61.49 55fljJQ $48,244,71 0,00 2.3..2..Q& ~ ?1Q OR $48,483,79 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. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A." WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $48,483.79, together with interest from 10/1100 at the rate of $4/1/01 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, ~L~ /<;1./ FT::tnk Ferlerm::tn FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - ~'''~'~- "' "~ ~ ,..,..~ ~~ ...., ~' ~ ~"'H'-'< 'n~ 1M:! ., ."1:1. '''.'''.'i1fk Bank of America Mortgage P. O. Box 35140 Louisville, KY 40232-5140 February 26, 2001 Barry Steinour 20 Fairfield St Mt Holly Spgs PA 17065 Bank of America Mortgage 52 ACT 6.1 ACCOUNT NUMBER: ~~~~~0 MORTGAGORS: Barry SL",lnour Felicia Steinour PROPERTY ADDRESS: 20 Fairfield St Mt Holly Spgs PA 17065-1705 NOTICE OF INTENTION TO FORECLOSE MORTGAGE THE MORTGAGE HELD BY Bank of America Mortgage. (HEREINAFTER WE, US, OR OURS) ON YOUR PROPERTY LOCATED AT 20 Fairfield St, Mt Holly Spgs PA 17065, IS IN SERIOUS DEFAULT BECAUSE YOU HAVE NOT MADE MONTHLY PAYMENTS OF $592.43 FOR THE MONTHS OF 11.01.00 THROUGH 12.01.00 AND $581.73 FOR THE MONTHS OF 01.01.01 THROUGH 02.01. 01. THE TOTAL DELINQUENCY AS THIS DATE IS 2409.81 COMPUTED AS FOLLOWS: DELINQUENCY AS OF February 26, 2001 LATE CHARGES/OTHER FEES TOTAL DELINQUENCY AS OF February 26, 2001 $ 2,348.32 61. 49 2409.81 $ THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT, OR IN OTHER WORDS, BRING YOUR PAYMENTS CURRENT, AS OF THE DATE OF THIS LETTER IS $2409.81. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (30) DAYS OF THE DATE OF THIS LETTER, BY PAYING TO THE MORTGAGE COMPANY THE ABOVE AMOUNT OF $2409.81, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND LATE CHARGES WHICH MAY FALL DUE DURING THIS PERIOD. SUCH PAYMENT MUST BE MADE EITHER BY CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER, AND MAILED TO P.O. BOX 35140, LOUISVILLE, KENTUCKY 40232, OR MAILED TO OUR PHYSICAL ADDRESS, 101 East Main Street, Suite 400, Louisville, Kentucky 40202. IF YOU DO NOT CURE THE DEFAULT WITHIN THIRTY (30) DAYS, THE MORTGAGE COM- PANY INTENDS TO EXERCISE THE RIGHT TO ACCELERATE THE MORTGAGE PAYMENTS. THIS MEANS THAT THE AMOUNT OWING ON THE ORIGINAL MORTGAGE AMOUNT BORROWED WILL BE CONSIDERED DUE IMMEDIATELY AND YOU MAY LOSE THE CHANCE TO PAY OFF THE ORIGINAL MORTGAGE IN MONTHLY INSTALLMENTS. IF FULL PAYMENT OF THE AMOUNT OF DEFAULT IS NOT MADE WITHIN THIRTY (30) DAYS, THE MORTGAGE COMPANY ALSO INTENDS TO START A LAWSUIT TO FORECLOSE YOUR MORTGAGED PROPERTY. IF THE MORTGAGE IS FORECLOSED, YOUR MORTGAGED PROPERTY WILL BE SOLD BY THE SHERIFF TO PAY OFF THE MORTGAGE DEBT. IF YOU CURE THE DEFAULT BEFORE WE BEGIN LEGAL PROCEEDINGS AGAINST YOU, YOU WILL STILL HAVE TO PAY THE REASONABLE ATTORNEY'S FEES, ACTUALLY INCURRED, UP TO $50.00, HOWEVER, IF LEGAL PROCEEDINGS ARE STARTED AGAINST YOU, YOU DROB 045 DB3 ~,.;..A ~."I_'P\ djllllkC,'~ ~ ..~ <~~~, ~ ,>~ '....J, .iliJ ~'. 6~ '~ ~_i1i'- - ...< , ~ ~ .., -.''"'''i:;i{H Bank of America Mortgage P. O. Box 35140 Louisville, KY 40232-5140 February 26, 2001 Felicia Steinour 20 Fairfield St Mt Holly Spgs PA 17065 Bank of America Mortgage 52 ACT 6.1 ACCOUNT NUMB MORTGAGORS: 0001592732 Fel~c~ ur PROPERTY ADDRESS: 20 Fairfield St Mt Holly Spgs PA 17055-1705 NOTICE OF INTENTION TO FORECLOSE MORTGAGE THE MORTGAGE HELD BY Bank of America Mortgage. (HEREINAFTER WE, US, OR OURS) ON YOUR PROPERTY LOCATED AT 20 Fairfield St, Mt Holly Spgs PA 17065, IS IN SERIOUS DEFAULT BECAUSE YOU HAVE NOT MADE MONTHLY PAYMENTS OF $592.43 FOR THE MONTHS OF 11.01.00 THROUGH 12.01.00 AND $581.73 FOR THE MONTHS OF 01.01.01 THROUGH 02.01.01. THE TOTAL DELINQUENCY AS THIS DATE IS 2409.81 COMPUTED AS FOLLOWS: DELINQUENCY AS OF February 26, 2001 LATE CHARGES/OTHER FEES TOTAL DELINQUENCY AS OF February 25, 2001 $ 2,348.32 61.49 2409:81 $ THE TOTAL AMOUNT NOW REQUIRED TO CURE THIS DEFAULT, OR IN OTHER WORDS, BRING YOUR PAYMENTS CURRENT, AS OF THE DATE OF THIS LETTER IS $2409.81. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (30) DAYS OF THE DATE OF THIS LETTER, BY PAYING TO THE MORTGAGE COMPANY THE ABOVE AMOUNT OF $2409.81, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND LATE CHARGES WHICH MAY FALL DUE DURING THIS PERIOD. SUCH PAYMENT MUST BE MADE EITHER BY CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER, AND MAILED TO P.O. BOX 35140, LOUISVILLE, KENTUCKY 40232, OR MAILED TO OUR PHYSICAL ADDRESS, 101 East Main Street, Suite 400, Louisville, Kentucky 40202. IF YOU DO NOT CURE THE DEFAULT WITHIN THIRTY (30) DAYS, THE MORTGAGE COM- PANY INTENDS TO EXERCISE THE RIGHT TO ACCELERATE THE MORTGAGE PAYMENTS. THIS MEANS THAT THE AMOUNT OWING ON THE ORIGINAL MORTGAGE AMOUNT BORROWED WILL BE CONSIDERED DUE IMMEDIATELY AND YOU MAY LOSE THE CHANCE TO PAY OFF THE ORIGINAL MORTGAGE IN MONTHLY INSTALLMENTS. IF FULL PAYMENT OF THE AMOUNT OF DEFAULT IS NOT MADE WITHIN THIRTY (30) DAYS, THE MORTGAGE COMPANY ALSO INTENDS TO START A LAWSUIT TO FORECLOSE YOUR MORTGAGED PROPERTY. IF THE MORTGAGE IS FORECLOSED, YOUR MORTGAGED PROPERTY WILL BE SOLD BY THE SHERIFF TO PAY OFF THE MORTGAGE DEBT. IF YOU CURE THE DEFAULT BEFORE WE BEGIN LEGAL PROCEEDINGS AGAINST YOU, YOU WILL STILL HAVE TO PAY THE REASONABLE ATTORNEY'S FEES, ACTUALLY INCURRED, UP TO $50.00. HOWEVER, IF LEGAL PROCEEDINGS ARE STARTED AGAINST YOU, YOU DR193 010 DB3 'x ~t" ".""" ~ . , _'~~_ '-'.....>1_ ~""'.~,~!tiMI,g;li<WIiclll~ "'<Il~' .""'''\'!i_'''''-", ~t}lo9 . WILL HAVE TO PAY THE REASONABLE ATTORNEY'S FEES, VEN IF THEY ARE OVER $50.00. ANY ATTORNEY'S FEES WILL BE ADDED TO WHATEVER YOU OWE THE MORT~ GAGE COMPANY WHICH MAY ALSO INCLUDE REASONABLE COSTS. IF YOU CURE THE DEFAULT WITHIN THE (30) DAY PERIOD, YOU WILL NOT BE REQUIRED TO PAY ATTORNEY FEES. YOU HAVE THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDINGS THE NONEXIST~ ENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. THE MORTGAGE COMPANY MAY ALSO SUE YOU PERSONALLY FOR THE UNPAID PRINCIPAL BALANCE AND ALL OTHER SUMS DUE UNDER THE MORTGAGE. IF YOU HAVE NOT CURED THE DEFAULT WITHIN THE THIRTY (30) DAY PERIOD AND FORECLOSURE PROCEEDINGS HAVE BEGUN, YOU HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME UP TO ONE HOUR BEFORE THE SHERIFF'S FORECLOSURE SALE. YOU MAY DO SO BY PAYING THE TOTAL AMOUNT OF THE UNPAID MONTHLY PAYMENTS PLUS ANY LATE OR OTHER CHARGES THEN DUE, AS WELL AS THE REASONABLE ATTORNEY FEES AND COSTS CONNECTED WITH THE FORECLOSURE SALE (AND PERFORM ANY OTHER REQUIREMENTS UNDER THE MORTGAGE). IT IS ESTIMATED THAT THE EARLIEST DATE THAT SUCH A SHERIFF'S SALE COULD BE HELD APPROXIMATELY FIVE (5) TO SIX (6) MONTHS FROM THE DATE OF THIS NOTICE. A NOTICE OF THE DATE OF THE SHERIFF'S SALE WILL BE SENT TO YOU BEFORE THE SALE. OF COURSE, THE AMOUNT NEEDED TO CURE THE DEFAULT WILL INCREASE THE LONGER YOU WAIT. YOU MAY FIND OUT AT ANY TIME EXACTLY WHAT THE REQUIRED PAYMENT WILL BE BY CALLING THE MORTGAGE COMPANY AT THE FOLLOWING TOLL FREE NUMBER, 1-888~91S-6262 PAYMENT COUNSELING DEPT. THIS PAYMENT MU BE IN CASH, CASHIER'S CHECK, CERTIFIED CHECK OR MONEY ORDER AND MADE PAYABLE TO THE MORTGAGE COMPANY AT THE ADDRESS STATED ABOVE. YOU SHOULD REALIZE THAT A SHERIFF'S SALE WILL END YOUR OWNERSHIP OF THE MORTGAGED PROPERTY AND YOUR RIGHT TO REMAIN IN IT. IF YOU CONTINUE TO LIVE IN THE PROPERTY AFTER THE SHERIFF'S SALE, A LAWSUIT COULD BE STARTED TO EVICT YOU. YOU HAVE ADDITIONAL RIGHTS TO HELP PROTECT YOUR INTEREST IN THE PROPERTY. YOU HAVE THE RIGHT TO SElLLTHE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND' COSTS ARE PAID PRIOR TO OR AT THE SALE; AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BE- HALF. IF YOU CURE THE DEFAULT, THE MORTGAGE WILL BE RESTORED TO THE SAME POSI- TION AS IF NO DEFAULT HAD OCCURRED. HOWEVER, YOU ARE NOT ENTITLED TO THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR. VERY TRULY YOURS, Malinda Lamb Collections Department CERTIFIED MAIL-RETURN RECEIPT REQUEST RETURN RECEIPT NO. 7000 0600 0023 9162 6466 cc: VA/FHA/PMI No. DR040 028 DB3 ...,1. ALL that certain tract of ~and with the improvements thereon erected situate at the intersection of the southwestern side of Fairfield Street ~th the northwestern side of Ce~ter Street, Borough of Mt. Holly Springs, Cumberland County, Pennsylvania. being also known as part of Lot No. ~ on a plan of lots by Phillip A. and Edith A. Warner, recorded in Cumberland County Plan Book 4, Page 23. and being more fu~ly bounded and described in accordance with a plan of survey by stephen G. Fisher, Registered S~rveyor~ dated October 25. 19~5. and bearing draw~ng No. 78A182, as foll.ows: BEGINNING at a stake set at the intersection of the southwestern side of Fairfield street (35.00 feet wide right-of-way) with the northwestern side of Center Street (35.00 feet wide right-of-way) thence extending from said beg~nning stake and along the northwestern side of Center ,Street, South 34 degrees 49 minutes West, 156.50 feet to a railroad spike set on the north~astern side ofa 20.00 feet wide al~ey; thence extending a~ongeosame, North 4S d~grees 02 minutes West. 10S.6S feet to a stake set at corner of land now or formerly of Lester A. Sheaffer; thence extend~ng along same. North 3~ degrees ~g minutes Eastt 137...88 feet to an iron pin set-ori the southwestern, side or Fairfield street. aforesaid, thence extend~ng a~ong line" of sarne~ South 55 degr~es 11 minutes East, 104.00 feet to the first mentioned stake and place of BEGINNING. ' BEING the same premises which Ricky L. Cramer and Cheryl A. Cramer, his wife, by their deed dated July 27, 1988 and recorded in the Office of the Recorder of Deeds ~n and for Cumberland County in Deed Book "M", Vol. 33, Page 49 granted and conveyed unto Chr~stopher c. Shughart and Wendy Lee Richardson, the Grantors herein. PREMISES ON: -2cr-FAIRFIELD STREET;-KOUNT HOLLY_SPRINGS, Pll. 17065 ;,-,'~~ -1,- - d VERIFICATION B. SCOTT ARNOLD hereby states that he is V,P, of BANK OF AMERICA (KY) 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, DATE: f IfJojO I ~<~~ B. SCOTT ARNOLD VICE PRESIDENT ',,-. 'o't,-,,~ ~--"' ;j(' ~l~i~~~!lIl~1.l&1!%lblii:j,.;.~;;M,,~~";j{;~~&;%''Jll!l~''>ffiI~ili'''''-~:i')'"'"';-';")""'d":'fj,,,,,w<.;l':!'1:mb~d"Js-~~~~~~~~L ~fi '-. --- '" Uu "- ~ ~ -c:. t?~ -<: -.() -" ~""= ~ -,,~- (") c: ~:,:~ -0- mm 2::0 :zc ~~ js ~. _,_~~, ,.__""-C,<<'_''''',,,_,_., ~ ~._"'''_~, r__,.~.~, ~~~, tll.il "'-:1 i I C> o .,., ' :::i n:~~ ~6-ffl ;~ ;1,Y. t:)'~ :::.".n otTl 35 -< "'" -u ::0 N <.rJ -0 % ..... ~ (X) e ~ F '" '" -1:.. -c :'\ 0-\ P lI; g~ r r F' "'..J -~ -- ~~ ~6s.J.. - ~" --" , :_'liiIil~~;' t .. ,:j; ~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-02423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK. OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L, KELL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR FELICIA F the DEFENDANT , at 1757:00 HOURS, on the 27th day of April 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F, STEINOUR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: :r'"~~ R, Thomas Kline 04/30/2001 FRANK FEDERMAN me this of By: ~~. 'L~ Deputy Sheriff Sworn and Subscribed to before ~- ~~"~'-~--I "T ---:'.;~1,i r"-- ...1 '" SHERIFF'S RETURN - REGULAR CASE NO: 2001-02423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L, KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR BARRY L the DEFENDANT , at 1757:00 HOURS, on the 27th day of April 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F, STEINOUR WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.72 .00 10.00 .00 31.72 .~~ lilL~ R, Thomas Kline 04/30/2001 FRANK FEDERMAN Sworn and Subscribed to before me this ~ day of By: \:Jo.w-n 1. ~ Deputy Sheriff A,D, .. .'~ ~ ~~ ~. .o\J' ',] I , '~ --.;.;, - " '-,-, '~~1l'1~,:;.' " FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No, 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff BANK OF AMERICA, NA, F/KJA NATIONS BANK, NA 101 EAST MAIN STREET LOUISVILLE, KY 40232 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CIVIL DMSION vs. BARRY L. STEINOUR FELICIA F. STEINOUR 20FAUUnELDSTREET MOUNT HOLLY SPRINGS, P A 17065 : NO. 2001-2423 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff and against BARRY L. STEINOUR and FELICIA F. STEINOUR, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 10/1/00-5/30/01 $48,483.79 $2,870.12 TOTAL $51,353.91 I hereby certify that (I) 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 DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: fYl~y I , ~I (51A-};--;' ) {2. , PRO PROT "THIS FIRM IS A DEBT COLLEcrOR ATfEMPrING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY AND TInS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATfEMPr TO COLLEcr A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, .. -== ~~""""",--"".,,,,,,,,, ~ ~,~ ,""'- -, .' FEDERMAN AND PHELAN 'F~ank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs, CUMBERLAND COUNTY BARRY L. STEINOUR FELICIA F. STEINOUR :NO.2001-2423 Defendant TO: FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS,PA17065 DATE OF NOTICE: MAY 18,2001 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 ~-LU~ -- .- <'~ - '.....' ,-, ,-- ...,. -- ,.......' .-" ..... ..- .- ~"""'"". .... _. ..- ',~.' '.' ...' ";;'" , .. - -""..... ........ - ,'.... ~.' "''iMI~ "'....." ". .-. ..- ...... --...- -"""","'. ,- ....... "'.-, - ::a: ' ....... -'_.. .-- --. .- '-, ,....' b'" ,-,. - ._. .--...' ._. ..~,~-""""".~ ~, . ,~ '. " 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 BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA COURT OF COMMON PLEAS CIVIL DIVISION vs, BARRY L, STEINOUR FELICIA F. STEINOUR CUMBERLAND COUNTY NO. 2001-2423 Defendant(s) TO: BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS,PA17065 DATE OF NOTICE: MAY 18.2001 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 l~wyer 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 ,'~.... ~~*lhl'\, -. ...." ..... .... - ""*-~ J -- "1If''' "....' '~- '- --- ........ ....... .- .. '-M- -.. 'W" ...........'0 - ..... -....- -. -. ~-~I~t~ - ...... .: ...... ~"""'" ._, -' - M'" .'.. ""- .- ........... 4"_' ..........' - - ,- -- - ""--' ..,..,....,. ~_. - "'- .~' ~- SHERIFF'S RETURN - REGULAR CASE NO: 2001-02423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR FELICIA F the DEFENDANT , at 1757:00 HOURS, on the 27th day of April 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F, STEINOUR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6,00 ,00 ,00 10.00 .00 16.00 So Answers: :r"~-i~~ R. Thomas Kline 04/30/2001 FRANK FEDERMAN me this day of By: ~"'Yl {. iLJl Deputy Sheriff Sworn and Subscribed to before A,D, Prothonotary - " ~ - '->", , - "-'< ." ,~"~, ~ --'~--' ""'--~, SHERIFF'S RETURN - REGULAR . CASE NO: 2001-02423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L, KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR BARRY L the DEFENDANT , at 1757:00 HOURS, on the 27th day of April , 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F. STEINOUR WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service ,Affidavit Surcharge So Answers: 18,00 3,72 ,00 10,00 ,00 31.72 .~~~/~ R, Thomas Kline 04/30/2001 FRANK FEDERMAN Sworn and Subscribed to before By: DCM)SI) ~. \L~_Jz Deputy Sheriff me this day of A,D, Prothonotary , , ~ , d!i!litiHii~!:" FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No, 12248 One Penn Center at Snbnrban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563.7000 Attorney for Plaintiff BANK OF AMERICA, NA, FIKIA NATIONS BANK, NA : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2001-2423 BARRY L. STEINOUR FELICIA F. STEINOUR Defendant(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 ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant BARRY L. STEINOURis over 18 years of age and resides at 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS,PA 17065. (c) that defendant FELICIA F. STEINOURis over 18 years of age, and resides at 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, P A 17065. This statement is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, F~~ Attorney for Plaintiff - - , ,~.', b'~ " --,'"""",,- - "~~".~-;; . (Rule of Civil Procedure No. 236 - Revised) BANK OF AMERICA, NA, FIKIA NATIONS BANK, NA : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2001-2423 BARRY L. STEINOUR FELICIA F. STEINOUR Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JUNE I ' 200., ' -J3:t a.p.-.. p ,P 7Jh/1;"D /DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY. ** -IJ ~~&J;iI'l>.."",iIil]H,,,",~W&',fu"il1i:~~~~'[\jW,t-MJi:'iW;;;'!b,,,~:,,~,,,j,,j~'''''',L<L',,ilig,..t,l:\Hmcit"~lll.ti~~~tii!iii~" '1~""''''fu<~' "~--~'i"1"~'''--'~''''='''iE'i. - . '(1) <:;) 0 c: -0 t ~ ~ r t- ::::I ~ ;C <= r1,::D Z r g .S;; t --1fn :bo L. ()...l.... - ",,0 -~t~T-' 8' ~ "'U :J: -rl ........ r :x Q5 ~ W 5>~ N (sin ., ~ ~ 1..) ~ ~ N ~ ---.) 0'> -< VJ ~ () '--Z:t ,.., D R ~ ~M,~= ,,~ _ ,_, , ~'__',~,*""o',",=",""C_"",', ,..' __"~__P,'~__,,, -, "~ ,',,'n " __ ~,,_, ~? __ "'," ,~, .~ c ,~,=_. , . - . . -- . ~ - ^ ",,'.n' " .. ~ '~--.:~"',", '---, , ~",- -, " '~JBW~~: , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA Plaintiff, CUMBERLAND COUNTY v. No. 2001-2423 BARRY L. STEINOUR FELICIA F. STEINOUR Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $51,353.91 Interest from 5/30/01 to 9/5/01 (per diem - $8.44) $827.29and Costs TOTAL $52,181.20 ~1Jp, RANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property,No, ~~~'~..i'H(l',5i"''''J''~'iM:'f,WM~,;t,,+-_~W'''MM>~l''''~;''''tr-'-;;'-<!'"'~';'{''''"'.'''1~,,'';'''''hjt#:iiN{,~,,'Ii;J;;!fl!~;,~&ljl<ll!$f;'.ilil ,,<- ~ ~- - ~u:II.\m",," ~',- ,'..... - ~ ~~~. II , 1'1 ',I J I I , I , " I I I , . 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ALL that certain tract ot' land with the improvements ~hereon erecteds1tuate at the intersection of the southwestern side of Fairfield Street W'ith t.he northwestern side of Center Street;, BorOUQh of Me. Holly Springs, Cumberland County, Pennsylvania, being also k~own as part of Lot No. 3 On a plan of lots by Ph1lli~ A. and Edith A. Warner, recorded 1n Cumberland County Plan Book -'. .page 23, and being more fully bounded and described in accordance with a plan of survey by Stephen G. Fisher, Registered Surveyor, da~ed October 25. 1978, and bearing drawing No. 78A182, as t'ollows: - BEGINNING at a stake set at the intersection of the'southwestern side of Fairfield Street (35.00 fe~t ~ide ~ight-of-way) witht"e northwestern side of CenterS~re~t. (3S.00 feet wide right-of-way); thence extending from said be'g.inning stake and along the ' northwes;tern side of Center ,Street, South 3-' degrees 4:.9 minutes West, 156.50 feet to a railroad spike set On the north~Astern side of a 20.00 feet wide alley; thence extending along same, North 45 d~grees 02 minutes West. 10~.65 feet to a stake set 'at COrner of land now or formerly of Lester A. Sheaffer; thence extending along sam..., North 34 degrees 49'minutes East, 137.88 feet to an iron pin set on the southwestern 'side, of Fairfield Street. aforesaid, thence extending along line' or same, South 55 degrees 11 minutes East, 104.00 feet to the first mentioned stake and place of BEGINNING. . BEING the same premises which Ricky L. Cramer and Cheryl A. Cramer, his wife, by their deed dated July 27, 1988 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book "M", Vol. 33, Page 49 granted and conveyed unto Christopher C. Shughart and Wendy Lee Richardson, the Grantors herein. PREMISES ON: 20 FAIRFIELD STREET, HaUNT HOLLY SPRINGS, PA 17065 BEING Tax ParcellI23-3l-2l87-48, TITLE TO SAID PREMISES IS VESTED IN Barry L. Steinour and Felicia F. Steinour, his wife'-' . by Deed from Christoper C, Shughart and Wendy Lee Richardson dated 8/25/89, recorded 8/28/89, in Deed Book D-34, Page 212, ':'~~'l~j'I~Fr """"_"",~! ~""~.,. .. "",),j;c'fkj'Jli, ~!ffl~Mi.,~i!>1V~~~~~-''';;la'''~ . "'~=<""'"'~"Ji(r~ ^~rr'~;rl:I'i@iIMiI~ ""Eft! ~ },..1 " .... ~ 'l.Q ~ ::::: ~ ..() ~ ...... 6-> ...... 0 0 0 k! -0 f'- ..... ~ C "'"t1 , . s: ~ ..... ..:t d 0 B ~ ~ '- .,--; 1 0 "c.c C '~f-:J 2 () fJ c ?-' n~rn :z :;~ 2,:0 () 0 ~~ I I CO .-,Lj I 4. ~~C) I ;<:C :>0- ---:-"'1 "- ~ ?'-P ~r PC'") :::g: ~R ..... .... "- 2:0 Om 10 "g , " .... )>C 'f? f " " .... ... ~ f'- C5 ~ ::0 .... "- " (j~ .II;" -< '-t " " ......:) ~ ... .... ""' -- '6~ ,,,""""""--~ "..."","'~"'" t'k.",<_' J ~;" J.J..~"f'\',"'_"'.. ~~ . ",,' ,~,~ '","., -J',","~"~" ^,. ,""".. ',,",""\0' ~~'"'''' ,'y,,- ~'. ,.~ "', ;.""'.. - . ~, - ~ ' - , ..' ;,-"', ~i"i- ""' ~'- -." - ~,,-~,_, "O'""'i " '. BANK OF AMERICA, NA, FIKIA NATIONS BANK, NA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS BARRY L. STEINOUR FELICIA F. STEINOUR CIVIL DIVISION NO. 2001-2423 Defendant( s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No.1) BANK OF AMERICA. NA. F/K/A NATIONS BANK. NA, 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 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS. PA 17065 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, P A 17065 FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 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 ";,,,rl" .... ~, ~ ..- -",'-", ',,",,-,~ '.- ,.~~~~ .. . 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.) UNION FEDERAL SAVINGS BANK 1631 SOUTH ATHERTON STREET STATE COLLEGE, PA 16804-0179 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/Occnpant 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, P A 17065 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 infonnation and belief, I understand that false statements herein are made subject to the ::.'::,n. CS ~4904re-'ro 1;::;t?;;};~ , DATE FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff M,~f!J~~o!iII!J..i';!dlU:ilh~;l"",-~ki'll~8~~('j-,:.&Jli.lf",,'Ij<;<(<j "",g,_._;~H,,!<ij,:i-JiW$f'o.:'g~.%;li'i,g'~-MMUtl-~~"""-~""'if~~'i1JI,~ "'~''''''''';;''-1i,:,~,-" "11' 0 <=> 0 C -n .".. -oED '-- .-, c: ~r: -n mrn :z Z:r.i rnpi:-: ZC I :n~ <:n",C: Q) -'-'1' ~., 0 ;<0 -,,0 ~O :>>e X"{, ::!i:' ,;~'') ::J )>0 ~O C co 6rn ~ :;;! +"' ~ ~ ,,~" _.~ ,~ " y~, ... 0' 'I .. " . ~ ~: ",,,,,,' ~ - 'I .....~~, ~, 1.,,1. _c' ,"- W'-'" 1fr~"r.!fY~ FEDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, NA, F/K1A NATIONS BANK, NA Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION BARRY L. STEINOUR FELICIA F. STEINOUR NO, 2001-2423 Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C,S. Section 4904 relating to unsworn falsification to authorities. y~ Attorney for Plaintiff ~_~4i~jl8~M$i:>l11j'f;1""~'~,1"'lj;r-~J!!!,.t~rf~~-":'\!'J.if;l"~~m'.~,-;,,..:.",%",~;~""",>,i.,"~""h--l1'~f!if~~:!;~:;iM",!~i!.\$l,!tl\;~~W'~-"~"'"-'-- '~L 'h (') 0 0 c :s:: 'T1 L 52cc c:: .-/ fn Z ~~21 :zfl I ' r- :Qi'n (t);J> CO --<,,~Q -< 2:~ C).L kG :I> "iU ~o 3: "~C=R ~.10 );:0 V? om c: ~ -oj .;:- j5 -<; ~~ ,^ ~""~,,,,,,~,,, .'- . ,~ !1-i ~-~- - - ~" .. , . . . "-, '.". , '""."U1J'lJilm; , BANK OF AMERICA, NA, FfKJA NATIONS BANK, NA Plaintiff, CUMBERLAND COUNTY v. No. 2001-2423 BARRY L. STEINOUR FELICIA F. STEINOUR -.. Defendant(s). June 4, 2001 TO: BARRY L. STEINOUR FELICIA F, STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, P A 17065 .- ""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 CONSlRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY,"" Yonrhouse (real estate) at 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS, PA 17065is 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 BANK OF AMERICA. NA. FIKJA NATIONS BANK. NA (the mortgagee) against you, If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this 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,' ", ,-""-'~. '~:""'~~ii\41~i-; '" , You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice on page two on how to obtain an attorney,) yOU 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 wil}O<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 fmd out ifthis has happened, you may call (717) 240-6390, .- 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer, At that time, the buyer may bring legal proceedings to evict you, 6, You maybe 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 'ie'__'" '-""'""""'-.I.m_ . 't.....' - ~ ' ~~c. , '~ ~,~ ....."!lr~W' ,. --~ ALL that certain tract of land with the improvements~thereon erected situate at the intersection of th~ southwestern side oe Fairfield Street .W'ith the northwestern side of Center Street, 13orou'gh o~ Me. Holly Springs, Cumberland County, Pennsylvania. being also known as part o~ Lot No. :3 on a plan of' lots by Phillip A. and Edith A. Warner. recorded in Cumberland County Plan Book ~, Page 23. and being mOre fully bounded and described in accordance with a plan of survey by Stephen G. Fisher. Reg~stered Surveyor. dated October 25, 1978, and bearing drawing No. 78A182, as ~ollows: - BEGINNtNG at a stake set at the intersection of the southwestern side of Fairfield Street (35.00 feet wide right-of-way) with the northw~stern side of Center Street (3S.00 feet wide right-of-way); thenCe extending from said beg;inn.ing stake and along the 1"l.0rthwElstern side of Center ,Street, South 34 degrees ~9 minutes West. 156.50 feet to a railroad spike set on the north~astern side of a 20.00 feet wide alley; thence extending along same. North 4S d~grees 02 minutes West. 105.65 feet to a stake set at corner or land now or formerly or Leste~ A. Sheaffer; thence extending along sam~, North 34 degrees 49'minutes East, 137.88 feet to an iron pin set on the southwestern 'side of Fairfield Street, aforesaid, thence ext~nding along line' of same, South 5S deg~ees 11 minutes East, 104.00 feet to the first mentioned stake and place of BEGINNING. . BEINa the same premises which Ricky L~ Cramer and Cheryl A. Cramer, his wife, by their deed dated July 27, 1988 and recorded 1n the Office of the Recorder Of Deeds in and for Cumberland County in Deed BookUM", Vol. 33, Page 49 granted and conveyed unto Christopher C. Shughart and Wendy Lee Richardson, the Grantors herein. PREMISES ON: 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 BEING Tax Parcel if 23-31-2187-48. . TITLE TO SAID PREMISES IS VESTED IN Barry L. Steinour and Felicia F, Steinour, his wife'-' , by Deed from Christoper C, Shughart and Wendy Lee Richardson dated 8/25/89, recorded 8/28/89, in Deed Book D-34, Page 212. Jil<!i~~-ri,f#1\iR~j,icl?,P.6;(k;'\';U)i0$.."";!."iil\E~-t,~w:-,,,M~6,,,'.",,di' "'""''',,'','bhd'''''''JO;h~l*ji!i~~,,,,-' -llillll'dll1 'lIId~~~~lIili'il, '^' ,0 ',"": '-"'';''''''''__'''''''''''''~ ,., "",,.,,~S_"""""C """," _", ~,', t -<'"<;<~-'- , '0" ,',' "_"~~ ,_ ,,",0,-. ,~'" ,_, , ,~ '''',~' '" ' 'l~ ,DliitliH1HliIIiHJ ' - " , (") <=> 0 c: -0 ;;;:: L... ....., -or;,) c: ;:!~i,;g m,J'> z Z::V ",]f-n zr' I en ,sc co '00 ~L. ~~~) ",=0 ~ ~~~~ )>c Z' -:0.. )>0 'P. om c: -I Z ~ =< .&:" ~' ,';.e.. ~' . ,~olJ~~ _ ~ . ''':~;'~h , < '_";L' ~,,,!;t --,--", ~_~,~_ AFFIDAVIT OF SERVICE PLAINTIFF BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA CUMBERLAND COUNTY No.2001-2423 DEFENDANT(S) BARRY L. STEINOUR FELICIA F. STEINOUR Type of Action -,Notice of Sheriff's Sale SERVE l,IEliICIA F. STEINOUR AT 20 FAmF1'ELD STREET IVIOUNT IJOLL Y SPRINGS, P A 17065 Sale Date: SEPTEMBER 5, 2001 SERVED Served and made known to re lie ,;) r. 5 d-.,.:, l" 0 V ({, Defendant, on the /8 fi, day of ~1V " 200..1 at 1:0lJ ,o'clock_fm.,at 0Zo Fa.'''fi~L d.. '5'..(-'1 Mf.. 8~/{r S'(K',IV.55,commonwealth of Pennsylvania, in the manner described below: -LDefel)dant personally served, Adult family inember with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Man~ger/Clerk of place oflodging in which Defendant(s) reside(s), Agent or person in charge of Defendant( s)' s office or usual place of business, an officer of said Defendant(s)'s company, Other: .,.- ( (f IpS Description: Age;JL Height..ik..: Weight -Ll.Q Race W\", Sex L Other I, ~ ;?~etJc'--l. Ca~ 1::1 ,~ a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct coPy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above, Notarial Seal Stacy L. Heefner, Nota'Y Public Sworn to and su~s ribed ChamllelSburg BOlO, Fran~in County b ~ hi da My Commission Expl u ,5, 2002 e.ore ~e t s y ~ota~: M~'J.. I ,^, l ~ember, P;;~YIVanla l) 0 U I w::JjUJU NOT SERVED On the __-'--_ day of 4~ , 200~ at o'clock _,ill., 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 Peuu Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, P A 19103-1814 (215) 563-7000 ir~~.1himl:ftM;!1r"'~,:';rl"ii,'(t',";;,\('-~1:!i.l'Z';[Mm:a"ilj]~.lIl'l1i''0J'',"~i;h~*"""":,tlt,,,,~';;,;;'l'il,;\'i)S18"'i<i:l'~'iiK~,;;-;.'ici.,,,,,,,,,,,,,0>,1illi~."li -""""IIiitM-~~ ~::m@~lll' ii.m' i~ iJ c";,,,...... .. ... "."lMJ (j C ~. tiIiI.:JJ. s'::= \'-,.. 0.,'- :2.; en ...../ ..- w;; ",',1 , 'I' ,', " ", eJ,;;'. . " "- ,-.,"~liti~, AFFIDAVIT OF SERVICE . PLAINTIFF BANK OF AMERICA, NA, FIK! A NATIONS BANK, NA CUMBERLAND COUNTY No.2001-2423 DEFENDANT(S) BARRY L. STEINOUR FELICIA F, STEINOUR Type of Action - Notice of Sheriff's Sale SERVE.BARRY L. STEINOUR AT 20 FAIRFIEI..DS'OU:ET MOUNT HOLl-Y SPRINGS, PA 17065 Sale Date: SEPTEMBER 5, 2001 SERVED Served and made known to (j;;J(l..f{1 L, S' .J-"" tJ 0 U f.- at fr'., o'clockf,m., at ~O F;;>it:.fT...ld, 5<1:-, J of Pennsylvania, in the manner described below: , Defendant, on the / I) f!-. J.I+, rf.(~y ~r; }J:J5 day of ~J.J"L , 200.l, , Commonwealth )( Defendant personally served, _ Adult family member with whom Defendant(s) residers), Relationship is W, fe.. Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place ofIodging in which Defendant( s) resider s), Agent or person in charge of Defendant(s)'s office or usual place of business, an officer of said Defendant(s)'s company, ,f~\i.cio- S.kINOU,z Other: - , I' Ih J C Description: Age:3 b Height..2JL Weight ~ Race ~ Sex j- Other I, cla'iCe.t"C<L L. C:a~~ ' ~" a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of .Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. S Notarial Seal Sworn to and S~bS 'bed Cha=~ Heefner, fa My urg 80 . F in County before e this day Commls8lon lug, 5, 2 ,2~: d" LM"M~mber. ~;~V. · U1 ~uuu NOT SERVED On the _ da): of , 200~ at o'clock _,m" Defendant NOT FOUND because: Mov~d Unknown _ No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esqnire - J.D. No. 12248 One Penn Center Suburban Station, Snite 1400 Philadelphia, PA 19103 (215) 563-7000 . ~ Lt, _, ~ ,,~~,~~"~~>=, .,~ ~~" r"",:;;;;illqffi~illbo:.~W~it'~ "'~ lEllI li!'~< 'Jili.i!mil ....'>l!I 'i\iil!j ........, <~" _. 'r """ _, """'~*""~',' " ,A"" , ,~ '-,," ~. jl ~-""" ,,&c '. ""~, -'~"...... '-...~ ',--- .0'" ~~\ _, '~ ri - .< r"-:: "~ ) ..-'i ~.:'. 1:; ,,-, ' , '"l".-'tt>_t, " Bank of America, NA, f/kJa Nations Bank, NA VS In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2001-2423 Civil Term Barry L. Steinonr and Felicia F, Steinonr R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman, Sheriff's Costs: Docketing Snrcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30,00 30,00 15.00 ,50 1.00 25,66 3,90 15,00 15,00 2,29 15,85 381.65 272.28 $808.13 paid by attorney 8/31/01 Sworn and subscribed to before me This _ day of So Answers: rJRr~',.~~~ R. Thomas Kline, Sheriff BY~~~~ Real Es te Deputy 2001, A.D, Prothonotary I. ~ 53l?3cr U(. /' ~JI,,).:1~ ;(~"",- ",~~-L ,~~.~ -, ; ,,~ I , -- "'" ~~~~'~-k:l~ :L . BANK OF AMERICA, NA, FIK/A NATIONS BANK, NA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS BARRY L. STEINOUR FELICIA F. STEINOUR CIViL DIVISION NO. 2001-2423 Defendant(s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) BANK OF AMERICA. NA. F/KIA NATIONS BANK. NA, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date thePraecipe for the Writ of Execution was filed the following information concerning the real property located at 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS, PA 17065 1. Narne and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate,) BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 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 ..~ . . J... _ - ~.....~. ,'I" " e ~.-'[,; " 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,) UNION FEDERAL SAVINGS BANK 1631 SOUTH ATHER'];ON STREET STATE COLLEGE, PA 16804-0179 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 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 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 :::'::," p, CS ~4~rel'ting~'*::itil:;;~ , DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~ l illl ,'''''~ >-~ '-),:( .r f<<"- " .. ,. BANK OF AMERICA, NA, FfKJA NATIONS BANK, NA Plaintiff, CUMBERLAND COUNTY v. No. 2001-2423 BARRY L. STEINOUR FELICIA F. STEINOUR -" Defendant( s). June 4,2001 TO: BARRY L. STEINOUR FELICIA F, STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, P A 17065 - "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECf A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY," Your house (real estate) at 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS, PA 17065is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by BANK OF AMERICA, NA, F/K/A NATIONS BANK. NA (the mortgagee) against you, If the Sheriffs sale is postponed, the property will be relisted for the DECEMBER 5,2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment 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, ~"~<'.'-,,,-- ..,.;; < ~ " ~~~ !.~ .,' - '. - ~~"'~"""""-'<'"""~f.:, . , 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 propertywiU"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 fmd 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 arnount 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 '..--- ~,~ ; " i f _ < _ ' , ^"" ~ ,~ )-';-. ",' ""->.iliiJl:; - , --~ ALL th~t certain tract of 2~nd with the improvements~thereon erected ~ituate at the intersection o~ thQ southwe~tern side of F~irfi.J.dStre...t .W'1th the n.orthwestern side of Center St:reet:. Borough of Mt. Holly Springs. Cumberland County, Pennsylvania. being ,also known as part of Lot No. :3 on a plan of' lots by Philli'p A. and Edith A. Warner. recorded in Cumberland Count:y Plan Book 4, p~ge 2:3. and being more fully bounded and described in ~ccordance with a pl~n of survey by Stephen G. Fisher, Registered Surveyor., dated October 25. 1978, and beari.ng drawing No. 7SA1 82. as follows: - BEGINNING at a stake set at the intersection of the southwestern side o~ Fairfield Street: (35.00 feet wide right-of-way) with the nort:hw~~tern side of Center Street (35.00 feet wide right-of-way); t:hence, extending from said beg;i.nning stake and along the northwestern si,de of Center .Street. South 34 degrees 49 minutes West. 1.6.50 feet to a railroad spike set on the north~~stern side of a 20.00 feet wide alley; thence ext:ending along same, North 45 d~grees 02 minutes West. 105.65 ~eet to a stake set at corner or land now or ~ormerly of Leste~ A. Sheaffer; thence extending along sam~, North 34 degrees 49'minut:es East, 137.88 feet: to an iron pin set: on t:he southwestern 'side of Fairfield Street. aforesaid, thence ex~ending along line' of same, South 55 degrees 11 minu~es East, 104.00 feet to the first mentioned staKe and place of BE:GINNING. ' BE:ING the same premises which Ricky L. Cramer and Cheryl A. Cramer. his wife, by their deed dated July 27, 1968 and recordec in the Office of the Recorder of Deeds in and for Cumcerland County in Deed Book' "M", Vol. 33, Page 49 granted a."1d conveyec unt:o Christ:opher C. Shughart and Wendy Lee Richardson, the Orant.or"S herein. PREMISES ON: 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 BEING Tax Parcel II 23-31-2187-48. .rITLE TO SAID PREMISES IS VESTED IN Barry L. Steinour and Felicia F, Steinour, his wife'-' , by Deed from Christoper C, Shughart and Wendy Lee Richardson dated 8/25/89, recorded 8/28/89, in Deed Book D-34, Page 212, -,--, ~-~- , ___ _"L " ~ ""~' '5 .,'.... WRIT OF EXECUTION and/or ATTACHMENT i\ "'J ,1,"'~ COMMONWEALTH OF PENNS'fL VANIA) COUNTY OF CUMBERLAND) NO, 01-2423 CIVIL 1?fX TERM CIVIL ACTION - LAW TO THE SHERIFF OF CllmbE>xland COUNTY: To satisfy the debf. inferest and costs due Bank of America, NA, F/K/A Nations Bank, NA PLAINTIFF(S) from Ban:y L. Steinour and Felicia F. Steinour, 20 Fairfield Street, Mount Holly Springs, PA 17065 DEFENDANT(S) (1) You are directed fo levy upon the property of fhe defendanf(s) and to sell See Legal Description (2) You are also direcfed to attach fhe property of the defendant(s) not levied upon in the possession of , ,;,"',,\, GARNiSHEE(S) as follows: and to notily the garnishee(~)'that: (a) ~~ ~t;achment has been issued; (b)~he garnishee(s) is/ar~ enjoined Irom paying any debt to or for the account of the defendant(s) and from delivering ~ny ~ropertr,pJ, the del~nSllj:~$~) ,%J!ltherwise disposing thereof; <;,." . " "(;, ';:,,1 I;!" ,,'11',", "', I ,," (3) If property 01 the defendant(s) not levied upon an subject to allachrpent is 10uf1C/ ,in the poss~l?sion 01 anyone other than a named garnishee, you are directed to notify him/t'lerthat he/she has been ad'ded as agarnisheeand is enjoined as above stated, Amount Due $51,353.91 L.L. from 5/30/01 to 9/5/01 Interest (pw.: tHem - $R AA) $R?7.2'l i'lnil CORtS Due Prothy Atty's Comm % Other Costs 5.50 $1.00 Atty Paid Plaintiff Paid $119.72 Date: June 8, 2001 Curtis R. Long Prothonotary, Civil Division ~~ D/l- It P - 71;/J/UJC f ~ Deputy REQUESTING PARTY: Name Address: Frank Fedennan, Esq. One Penn Center at Sll""rhi'ln Station, Suite 1400 Philadelphia, PA 19103 Attorney lor: Plaintiff Telephone: 215 563-7000 Supreme Court 10 No, 12248 'J!!lf.~~:l&~~mt<~~iMdMH"'M",':i-!il!;~i""+~:;;)jiL'":F',"(~~e:';;;t,,~,L;;'."';'',-^,;,1;j;d),t,~'"hi-'(",";'\oill.'i,;i'ili~\i!lI~==""" 'Uk! - --'1;jll'l\liiii:J#.ll<iM~-. '~~'<'h_ ~'-""""~'T~~'"'~=[I1J'f>""""'"" ~ . ' REAL ESTATE SALE N~ ~5 ~ ~ on dwu.../3J ;;)001 the sheriff levied upon the aetenaao!, Interest In the real property situated in fY7ol.vrt 1/oLi;-J~ 'EJ;J6)il~ 6umbeI1and County, Pa.. known and nUmberedas:dD r-~)eLl;ttM (f}riJJd.. ~ ~1Iy described onExhlbtt "A" Wed . this writ and by this I'8fer8hce Incorporated hendn. -.: J~ 13,"001 Br: Zf;:J;lf:;t -': Cd' ~ "'\ cl .1, " \~. \.,:J 1\"'Ii 1\ 'I" ";,' \ ", "" 'I. 'I ^:,\' \ '~\ ' , 1\ \i\l\ \~. ~d st: t, , 0 , ;\jl~n,~ " , ". 1,:11} ^lr.i\\"~ ---~\l J0)~ ;\:1\<\3\\" ;I.. ~~. ""_~,.~. # "'~,__~,_ ~_. J~,fu_~'~" "~ ,"'",",'_"..",,' _,.,,,' -,'" ,.., - - . '"., ,~ " ~-" -< ,8 j, ,-,. .~ j'- - ,-_ t IJ'_,',: '"'1_1:,__,' ~cl _ , ,- nil PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough 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 sarne 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true, R~EditO: SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 ~~~~)L. ~iJd~ Notarv . NOTARIAl SEAl . LOIS E. SNYDER, NoIary PuIlIIc Carli$leBoro, Cumberland CoW1ly My CommiaaIori ExpiI8S MlIdI~' 2005 iilll!~~i~~~!J;I,;"tB~""~;;;;:.,...,,,~~i;t.,J~:!l-lii0:'lU""'lfAti;'I!~,'I~~-1!;!d;;""t;;~>d~~Iiil&i;jH$ill,1!:1HliI' ~:i! --'"""~I'Mi~~- '~~~'1f' REAL ESTATE SALE NO. 25 Writ No, 2001-2423 Civil Bank of America, NA. F /K/ A Nations Bank. NA vs, Barry L. Steinour and Felicia F. Steinor Atty,: Frank Federman ALL that certain tract of land with the improvements thereon erected situate at ,the intersection of the southwestern side of Fairfield Street with the northwestern side of Cen- ter Street. Borough of Mt. Holly Springs, Cumberland County, Penn- sylvania. being also known as part of Lot No.3 on a plan of lots by Phil- lip A and Edith A Warner, recorded in Cumberland County Plan Book 4. Page 23. and being more fully bounded and described in accor- dance with a plan of swvey by Ste- phen G. Fisher. Registered Sur- veyor, dated October 25. 1978, and bearing drawing No, 78AI82, as fol- lows: BEGINNING at a stake set at the intersection of the southwestern side of Fairfield Street (35.00 feet wide right -of-way) with the northwestem side of Center Street (35.00 feet wide right-of-way); thence extend- ing from said beginning stake and along the northwestern side of Cen- ter Street. South 34 degrees 49 minutes West. 1-56.50 feet to a rail- road spike set on the northeastern side Qf a 20.00 feet wide alley~ thence extending along same, North 45 de- grees 02 minutes West. 106.65 feet to a stake set at corner of land now or formerly of Lester A Sheaffer: thence extending along same, North 34 degrees 49 minutes East. 137- .88 feet to an iron pin set on the southwestern side of Fairfield Street. aforesaid, thence extending along line of same, South 65 degrees 11 minutes East. 104.00 feet to the first mentioned stake and place of BEGlNINING, BEING the same premises which Ricky L. Cramer and Cheryl A. Cra- mer. his wife, by their deed dated July 27, 1983 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 'M", Vol. 33, Page 49 granted and conveyed unto Christopher C. Shughart and Wendy Lee Richard- son, the Grantors herein. PREMISES ON: 20 FAIRFIELD S1REET, MOUNT HOLLY SPRINGS, PA 17065, BEING Tax Parcel #23-31-2187- 48, TITLE TO SAID PREMISES IS VES1ED IN Barry L, Steinour and Felicia F, Steinour, his wife by Deed from Christoper C. Shughart and Wendy Lee Richardson dated 8/25/ 89. recorded 8/28/89. in Deed Book D-34, Page 212, ,_ ~~N..,'..~ ",~ ""'''''', "~., ,~" "', , ---'-<"'~' "'-~ ^" '-'iiulit::lti " ", ~ ~:; : :,'~j ,~ , fI'("' jJ '"-'. .' .'..'.H.' "" ~ . , i"i' , , ~ J" '&If,;'''''i~.!ijjll~ It, ~'" , -~ ~ "",' ",;;.,,- ~I I I I , , THE THE PATRIOT NEWS SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 The Patriot-News and The Sundav Patriot-News newspapers of general circuiation, 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 andlor Sundayl Metro editions which appeared on the 24th and 31 st day(s} of July and the 7th day( s) of August 200 1, That neither he nor said Company is interested in the subject mailer of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in M.,isillaneous Book "M", Volume 14, Page 317, L PUBLICATION .".,.."....,.."..........,..'..',. .://..:,.1.....,.....,..".........,.. ..,..,....,......", COpy Sworn hi 21st day Augu S ALE 1125 Notarial Sool TIny L. Russoll, NotalY Public Ham'l>>Jlg, 00"""" County My Cainmlsslon ExpillSJunU, NO RY PUBLIC Member, pennsylvania Associa\lQn II N411~ commission expires June 6, 2002 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 $ 270,78 1.50 272,28 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid, By.....,.....,..............,...............................,........, ,-",<'" ~"- ---"'-/""- n ,REALesTATE SALE No, 2S Writ No, 2001-2423 ClvilTerm .. Bank of America. NA. ... FIK/ A Nat~ns Sank, NA V6 BalT'J~L-Steinour felicIa f. Steinouc A\ty:Frank Federman DESCRIPTION --,----ALL that ccrt:lJn tract lOr' larlu \\llh the ;.;.;::mrpro\,~nt~th<:r<.:on .::rt:ctl.'d M[UJlc ;1l.1h..:: -----mt'C~troIl\inhc ~outh...~t.::m 'ilde ul FJJrfldJ SlIcet 'o\'lIh, ~ nooh.....::~~m srJc of C,,:nLa S[r~x:t Burougll 1)( Mt. Holl~ Srnng~, Cumlx;rJiJ,IlG ,CUM!)'.. 2cn~}'h'al)la, ~\llg ahll known as p3rt of Lot No.3 on a plan n( ~,t~ b, Phillip A. and !:Jim A. W:uncI. monied In Qimbcrl:md. County Plan Book 4, Page ~J, and beutg m~ fully bound.:d and Uc'~nbcd m ~ WIth a plan OrSUnC}' b~ Sk11hl'n G. . r:.clV.:r. R.::ght.::tCd,SUl'\'cyOI:. dated ().;tobl:r 25. lnS. afI!1 bean.ng drawmg No. 7lSA I ~2, as rQTIUv,~: BtGIN;-;-iNG 3\ ;U.ta\..-.: ~l ;II. me. mlcl'SI.:..:tu1ll of tll.o.: ~Olllh\\'L~[(rn ~hk of blludJ $1.rect \35.00 (cd v.-iJA: righL.oi'\~JY) v.ith lhe nDrtlw,c:,.\cm silk of urn.:r \'.t~d Q5.00 Jl:.-'ct 1.\ Ilk nght-uf. _ ~_ lh\:ncc ",...[cOOing from ~Id tk:glllmng ~__' and :11(111& th~ !Ionlw.c"-tcm ~ldl: of Ccntct Sr.r<.'t~..soolh 3-\ u.:gr~ ~'-:l HllilutC$. WC~l. ~ - fl.'el ll.uuailroad SpJ.\ic ~\,.'-\ \)fl \~ \Nnh.~.,:ro~ ii,' l,(;n;:O.~ f,\.'\?t ....~.IJ.ko ij',lll?); tbl."ll~c C~,' ',- , 0,' )<2. North .t5 I,kgnx~ 02 rrunutC:~ 5 r<,.~t to a MJl;.c: !>t:l ~ comer of land now or ~~.A.~""'noins ~ ~ ~ 34 d.:gr~).w mU;lUh;, bbl, ;:;;l.U,M.w-~' in ~~ thesoutb.....t'w:rn lrti!:l.--_ cresa' tn.:t\l.:C -. l:. mg.' on.g me Of\ainc. 500tll 55 lkgre.;:' 1 t minutei [;a~l> 104.00 ,_feel tv tin; first itltTitlonCQ!,take;md pla..:c of BEGtN~ING. ~G dlc ~mc prcmiser. wnkh Rid..~' L Cc.mcr.and Cheryl A. Cramer. hi:. wife, b) theIr =-clWf dit&.CJufy :'7, 'F.l1;'8aiiJ -recorded In ii:ie 0\110.: (If th~ RccOl"dcr of Det.'lll> In ami for CUlTl.bcrhmd C~u~,:dll.Pfx-d E~k lMi, vol- 33. ~ragc- 4~ gr:m\~d-andCOn\c~cd unto Chri'>lophl.-'/" C. Shughart and v.:cn\l)' ~..: Ridurdwtl, tht; Gf311torsh..'rcin. - PRE~nSCS ON:'20"Fairfidd Slre..:t, f>,lounl HoB)' Springs, PA l7065. BEI~Ta'\ Parcel #~Yll.ltg7-Jl':. 'HIlI. 1"0 S,\lD PRltMIS-ES i.., \..:~t(:J 10 BJI1)' 1-= c1nour <lnd f:dicit t:. Slcil)l.'llit, i\l~ \\ ll..;, b)' 1AA'd from Chnsiflp\0 -r.-Shtlg-h.lrt ar...i \~~lIdy ~ Rkhall.borl J.tl.t,oJ bJ15!S9, T<."CUf11.-d '6i2l)i~9. ~ DCcilBwk n-->f. Pijc~j:!. I I L -- " J.', L_"J,_>,' ~' - ,,, '~k-- ,", ,- '-,i,: ~"c", ",-,"~, " --t~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA 101 EAST MAIN STREET LOUISVILLE, KY 40232 No,: 2001-2423 vs, BARRY L. STEINOUR FELICIA F, STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, P A 17065 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY Kindly mark the judgment that was entered in the above captioned matter on MAY 31,2001 vacated upon payment of your costs only. ~AlVIl !flt~ Frank Federman, Esquire ' Attorney for Plaintiff August 31, 2001 i~~~;li;~",W;@;j".;r,;'fifrkij,.tt~~iliMi!ll.;;;iI:t4;;:';!f8i%';<!"':':k",'""~j""lC',:':1~""",',f"-""';~'l(L...!i-l&~fili\iIiWIi~~iW~-~~='-~'"I:Yr =W'~<W!liW' j ll"h:f"I"~ ES"~ 'lUiWllJ 0 0 '-----' C. -':;'1 ~ V> ~Q:l f'11 ;g~ g) --0 m:; I 0' '~)b ~6 :.--d,\ --0 ~!'~ll '< :% 0-- ~O ~O .c-rn -0 t.f? 9. J>>C ~ I',) 55 - '< ~