Loading...
HomeMy WebLinkAbout01-2908 FX FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 MANUFACTURERS AND TRADERS TRUST COMPANY ONE FOUNTAIN PLAZA BUFFALO, NY 14203 ATIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION TERM Plaintiff v. NO. oj - ,;J90r b;J CUMBERLAND COUNTY DALE L. CROMER TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "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 TillS DEBT WAS NOT REAFFIRMED, TillS 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 obj ections 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 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 #: 9787037 I' , "-,-"C':," ,,--~^ "--< 'I '7 ."" 1- I "' .r...... v 1. Plaintiff is MANUFACTURERS AND TRADERS TRUST COMPANY ONE FOUNTAIN PLAZA BUFFALO, NY 14203 2. The name(s) and last known addressees) of the Defendant(s) are: DALE L. CROMER TAMMYL. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/30/89 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FARMERS TRUST COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 957, Page 312. 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 4/1/00 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." "-',:~~" l -, ,"-" . ~",,' -- ,'^ "I_"~' '1' ., ,<, ,~.~...... ~~, 6. The following amounts are due on the mortgage: Principal Balance futerest 3/1/00 through 4/1/0 I (per Diem $4.36) Attorney's Fees Cumulative Late Charges 10/30/89 to 4/lJO I Cost of Suit and Title Search Subtotal $19,005.19 1,730.92 800.00 143.76 550.00 $22,229.87 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $22,229.87 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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $22,229.87, together with interest from 4/1/01 at the rate of $4.36 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 .....-,.. I" ~ . 't ,,, 1- .~ . -"-"""'~ . . ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM DATE: Ja"uary 11, 2001 FORECLOSURE TO: Dale L. Cromer 448 N. Pitt Street Carlisle, P A 17013 Tammy L. Cromer 448 N. Pitt Street Carlisle, PA 17013 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 ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. This is an official notice that the morteaee on vour home is in default and the lender intends to foreclose. Soecific information about the nature of the default is provided in the attached oaees. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM !REMAP) mav be able to help to save vour home. This Notice explains how the prol!l'am works. To see ifHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou when vou meet the Counseline Aeencv. The name. address and phone number of Consumer Credit Counseline Aeencies servine vour County are listed at the end of this Notice. Ifvou have anv Questions. vou mav call the Pennsvlvania Housine Finance Aeency toll free at 1-800-342-2397. (Persons with imoaired hearine can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE pROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA FERDlDA DEL DERECHO A REDIMAR SU HlPOTECA. etfA all ~ ""'1<"1< ,,!!l':J~'~,~ ~ ",--- ~ ....,,, l' I: - ~ . ,~ -. - , STATEMENTS OF POLICY HOMEOWNER'S NAME(S): Dale L. Cromer and Tammy L. Cromer PROPERTY ADDRESS: 448 N. Pitt Street, Carlisle, PA 17013 LOAN ACCT. NO.: 9787037 ORlGINAL LENDER: Farmers Trust Company CURRENT LENDERlSERVICER: M&T Mortgage Corp. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE. . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one ofthe consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY EOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAUL T" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMPR CREDIT COUNSELING AGENCIES-Ifvou meet with one of the consumer credit counseline aeencies listed at the end of this notice the lender mav NOT take action aeainst vou for thirty (30) davs after the date of this meetine. The names. addresses and telephone numbers of desienated consumer credit counseline aeencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICA nON FOR MORTGAGE ASSISTANCE- Your mortgage is in a default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one ofthe designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. rawJMlF IA ,,--~ "^ ," --< ~ ~" ~ " ~, -- f .-' . ,; I ,,_~ 0' ~,_ ~ _~ AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. l NOTE: IF YOU ARE CURRENTLYPROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yOU have filed bankru tc ou can still a I for Emer enc Mort a e Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to date). NATURE OF THE DEF AUL T -The MORTGAGE debt held by the above lender on your property located at: 448 N. Pitt Street, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Start/End: 4/1/00 thru 1/1/01 at $239.60 per month. Monthly Payments Plus Late Charges Accrued $2,407.98 NSF: $0.00 In'pections: $0.00 Other: $0.00 (Suspense): $0.00 Total amount to cure default $2,407.98 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use ifnot applicable): N/A !:lOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,407.98, PLUS ANY MbRTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THJRTY (30) DA Y PERIOD. Pavments must be made either bv cash. cashier's check. certified check or monev order made oavable and sent to: FEDERMAN AND PHELAN, L.L.P., One Penn Center at Subnrban Station, Snite 1400, 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103- 1814" Attentiou:Payoffs/Reinstatements Department. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not aoplicable.) N/A. IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclose UDon your morte:ae:e orooertv. IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe lender, which may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be reouired to pav attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. BHIsrr A ~"- "-I "... ~ r_ ~ n 1 r'~_' ,~~= ,-~^ ~''''_W~IIU '" "'c RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ri01t to cure the default and orevent the sale at anv time uo to one hour before the Sheriff's Sale. You mav do so bv oaving the total amount then oast due. olus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sale as soecified in writing bv the lender and bv oerfonning anv other reQuirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale ofthe mortgage property could be held would be approximately SIX (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: FEDERMAN AND PHELAN, L.L.P. One Penn Center at Suburban Station, Suite 1400 1617 John F. Kennedy Boulevard, Philadelphia, PA 19103 Tel:(215) 241-1711 Attention: Phyllis Levin, PayoffslReinstatements Dept. EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You may or_X_may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements ofthe mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. . TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. . TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) . TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED Very truly yours, Attn: Carmen Otero FEDERMAN AND PHELAN, L.L.P. Account No.: 9787037 Mailed by 1" Class mail /Certificate of Mailing and Certified Mail No: 7106457512941900 7673,7666 EXHIBIT A ',' , ~ . r~~~ [-'''l,''''= '~. PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8100) CLINTON COUNTY .; Lycoming..clinton Counties Commision for Community Action (STEP) 2\38 Lincotn Sttee, P.O. Box 1328 Williams port, PAt 7703 (570) 326-0587 FAX (570)322-2197 CCCS ofNortheasrom P A 20 I Basin Sll1:ct WiIliamsport, PAt 7703 (570) 323';;627 FAX (570) 323-<;626 COLUMBIA COUNTY 3 t W. Marke' Sll1:ct POB 1127 Wilkes-Bane, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity ofLuzeme County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-05 to or (800) 822-0359 FAX (570) 829-1665-(Catl Before Faxing) (570) 455-4994 Ha>elrowo FAX (570) 455-563 t-(Catl Before Faxing) (570) 836-t090 Twtkhannock CRAWFORD COUNTY Booker T. Washingt()n Center 1720 Holland Center Erie, PA 16503 (814) 453.5744 ~AX(8t4) 5749 lohn F. Kennedy Center, Inc. 2021 Eas' 20. Street Erie, PA 16510 (8I~) 898-0400 FAX (8t4) 898-1243 CUMBERLAND COUNTY cces of West em Pennsylvania, Inc. 2000 Linglestown Road Harrisburg., P A 17102 (717)541-1757 Urban League of Metropolitan Harrisburg N. 611I Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 15t~ Derry Street Harrisburg, PA 17104 (717)232-9757 FAX (7t7) 234-2227 PENNSYL VANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999 '0--.., F" ~- , ,'1"-,"-,-, '_,'- "'e-"" ,-' r' CCCS ofNortheastem PA 1631 South AtlIerton St, Suire 100 SIale Cnllege, PA 16801 (814)238-3668 FAX (8t4) 238-3669 1400 Abington Executive Park: Suite 1 Clarks Summit PA 184tl (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Greater Erie Community Action Committee 18 West gill Street Erie, PA t6501 (8t4) 459-t58t FAX (814) 456-0161 Shenango Vatley Urban League, lnc. 601 Indiana Avenue Farrell, PA 16121 (4t2) 981.5310 Financial Counseling Services of Franklin 31 West 3m Street -:: Waynesboro, PA t7268 (717) 762-3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 170t3 . (717) 243-38t8 FAX (711'73t-9589 Adams County Housing Authority 139-t43 Carli,te St Genysburg, P A 17325 (717) 334-t5t8 FAX 334-8326 ~rHmerr ~ ~.,o_~ ,,^ ~- --~- ALL THAT CERTAXN lot or piece of land situate in the Fifth Ward of the Borough of .caJ:'liGle, Cumberland count:.y, pennsylvan1.a, bounded and deseribed in aecordance ~ith a sur~ey ana plan thereof made by Gerrit J. Betz, Registered Surveyor, dated Sep~ember 22, 1971, as follows: BEGINNING at a point on the West side of North Pitt Street, said point being 108.6 ~eet South of the South.west gorner of Nort.h Pitt Street and "A" Streetl thence alonq the West side of North Pitt Street South 10 deqrees 30 minutes West 30 fe.t ~o a corner of premises now or formerly of Ralph McKeeJ thence along said pr~mises and passing through the center of a parti.tion wall North 79 degrees -30 minutes West 165 feet to a point on the East side of a lS foot alleYJ thence along said alley North 10 degrees 30 minutes East 30 feet to a corner of land now or formerly of Charles c. Yinqer1 thence alonq said land Sout.h 79 deqrees 30 minutes East 165 feet. to the point and place of BEGINNXNG. HAVING thereon ex-ected a 't,wo story frame dwelling house, known and numbered as 448 North Piet Street, carlisle. ' BE:tNG the same premises whi.c:b Harry R. - .Poper and Carolyn L. Peper (now known as carol~ L. Olsen) by their deed dated June 11th,. 1986 and ~ecorded ~n the Office of the Recorder of Deeds in and for cumberland County at So OK D, Vol. 32, Page 357, granted and conveyed unto Glenn E. Hockenberry, Grantor herein. PREMISIS: 448 NORTH PITT STREET "', ., '~'I' .., , ~,~~ ,.,. ," l~ "!."'_II"l_ ~.,-..-- ~~ __ . VERIFICATION DENNIS GAWRON hereby states that he is BANKING OFFICER ofMANUF ACTURERS & TRADERS MORTGAGE CORPORATION 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 tme 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 unswom falsification to authorities. DATE: 5)0/01 BANKlNadFFIcER " " -, ~ l "I' - ,~"- ~""= ~,~~"""'" ,-~'"' '''' ~ '~", - ""- " "- ~ i\ '"'' ,.., T" ." ",,,.,,,..,,, M'" ,-".,,- , r""ilil'lnler-'T ir r . ~ t ~ ~ ~ (') ~ ;:gF: z::~_, _'7,n' ,,',,'-- ('" I ~;:: r:::L' ~f .,,::- =< C_y ~: ---,::-. '":1 ---" (,:-1 DTn'WlII ~ c' '-j !lt~~4)..,,~~....,_"ii\'l~~~~~f"j~~-molll'!'if.1~I!'I~~~.''''t;_9''''~'''1'''1'""P"9"'i,,~,~"p.P'_(::~_:F'r"!,-,";!'fW,~j-~~~-jf1il-J\i''f'Mi!-!P~!illJJJ)_;WW:~j'~!*}~!WJ~ l' . ':,\~~~, , . SHERIFF'S RETURN - REGULAR CASE NO: 2001-02908 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS CROMER DALE L ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT & NOTICE CROMER DALE L the , 2001 DEFENDANT , at 0019:00 HOURS, on the 15th day of May at 448 NORTH PITT STREET CARLISLE, PA 17013 TAMMY L. CROMER (WIFE) by handing to a true and attested copy of COMPLAINT & NOTICE together with IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 Sworn and Subscribed to before me this )3.ut.. day of '1'k........ .2tnJI A.D. 0~~ R. /M~{Jj?,- i ~ rothonotary 'I So Answers: ~~~-e~! R. Thomas Kline 05/16/2001 FEDERMAN & PHELAN By: CJ~ ~. ~ Deputy Sheriff " I I 1 ,'~~'~~ 'L" '~.~~,~ _' "" ,_~ t SHERIFF'S RETURN - REGULAR . CASE NO: 2001-02908 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS CROMER DALE L ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROMER TAMMY L the DEFENDANT , at 0019:00 HOURS, on the 15th day of May , 2001 at 448 NORTH PITT STREET CARLISLE, PA 17013 by handing to TAMMY L. CROMER a true and attested copy of COMPLAINT & NOTICE together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~~t:~~ R. Thomas Kline 05/16/2001 FEDERMAN & PHELAN CJ~ ~. ~ Sworn and Subscribed to before By: me this :l ':fM-.. day of Deputy Sheriff 'AA""t .J.M'JI A.D. ~Q~ ~ rothonotary I ~ i""'-__~ . ""~"~1 I' I -~ ,~ ~-,~ ~- ..~ , ,. .. ~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MANUFACTURERS AND TRADERS TRUST COMPANY ONE FOUNTAIN PLAZA BUFFALO, NY 14203 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff : CML DMSION vs, DALE L. CROMER TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, PA 17013 : NO, 01-02908 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 DALE L. CROMER and TAMMY L. CROMER 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 Plaintiffs damages as follows: As set forth in Complaint Interest 4/1101-6/19/01 $22,229.87 $348.80 TOTAL $22,578,67 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. 1r~ ~llN1A(I__ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE:~ JLu~_ :Jt"l/ WO/ (]u,..f~) k., PRO PRO **Tms FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** r'""~"r ,.~::", ~ " '-I ~ I 1 I ! ~ ~~'-~-; , FEDERMAN AND PHELAN " Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF , . COURT OF COMMON PLEAS MANUFACTURERS AND TRADERS TRUST COMPANY CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY DALE L. CROMER TAMMY L. CROMER :NO.01-02908CIVIL Defendant TO: TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE,PA17013 DATE OF NOTICE: JUNE 6.2001 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. filE COpy IMPORTANT NOTICE You ar~ 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 <', "-.., ,.., , .< I'~.f ~, ,<, ,. ~. "., - "" ~, 1'1 . , - \ 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 MANUFACTURERS TRUST COMPANY AND TRADERS COURT OF COMMON PLEAS CIVIL DIVISION vs. DALE L. CROMER TAMMY L. CROMER CUMBERLAND COUNTY NO. 01-02908 CIVIL Defendant(s) TO: DALE L. CROMER 448 NORTH PITT STREET CARLISLE,PA17013 FILE COpy DATE OF NOTICE: JUNE 6.2001 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 ,,-'" , ",. - ,~" .~.,- 0_ "I', ~ .-__v ~._~ ' . , "; I' ,- SHERIFF'S RETURN - REGULAR CASE NO: 2001-02908 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS CROMER DALE L ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROMER DALE L the DEFENDANT , at 0019:00 HOURS, on the 15th day of May , 2001 at 448 NORTH PITT STREET CARLISLE, PA 17013 by handing to TAMMY L. CROMER (WIFE) a true and attested copy of COMPLAINT & NOTICE together with IN MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 .00 10.00 .00 31.10 ~~~! R. Thomas Kline 05/16/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: CJ~~i, ~ Deputy Sheriff me this day of A.D. Prothonotary 1''__'_~~ ~"" " ~ ~ ~ -"I" 11 ~ ,~~,~~=~.- . .- .~, '~K'KU"'"u'" N..u' SHERIFF'S RETURN - REGULAR CASE NO: 2001-02908 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS AND TRADERS TRUS VS CROMER DALE L ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROMER TAMMY L the DEFENDANT , at 0019:00 HOURS, on the 15th day of May , 2001 at 448 NORTH PITT STREET CARLISLE, PA 17013 by handing to TAMMY L, CROMER a true and attested copy of COMPLAINT & NOTICE together with MORTGAGE FORECLOSURE 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~~~e R. Thomas Kline 05/16/2001 FEDERMAN & PHELAN CJCUN~ ~ _ \LL Sworn and Subscribed to before By: day of Deputy Sheriff me this A.D. Prothonotary , !W~~~,~'" .,,' [ "' r - I' I ",> rk ~ ,~ FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 MANUFACTURERS AND TRADERS TRUST COMPANY Attorney for Plaintiff : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CML DMSION vs, : NO, 01-02908 DALE L. CROMER TAMMY L. CROMER Dl)fendant(s) .'.. , VERIFICATION OF NaN-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 lrnowledge of the following facts, to wit: .. (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant DALE L. CROMER is over 18 years of age and resides at 448 NORTH PITT STREET, CARLISLE, PA 17013. (c) that defendant TAMMY L. CROMER is over 18 years of age, and resides at 448 NORTH PITT STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ 1f~AA.-- FRANK FEDERMAN Attorney for Plaintiff ~.'c- "" '- , ^". 1'''''1 ,1 ~. 1 I _ ~ '~p=~~"~A " 1$J "" ......,. T..'~ ~ ~... """ '-' e-.~ .~.~e".>>""r~1!~,.,.nfIKI"nl~'l'ii;l"-''1f1ililn'''Trl" II "'lrn;[f'jjyy ~ .tq (') -(::) C_J t ~ c " ~ ~ ;:g ~~~~ s & -~,~ -/._', L__. r-',,) :::-:~: i ,---I r - ~ :':;~~. c:, .t C~) ~ r !;~(,; '-n -,' "' ~I~.~'-: C) ~ ~ ~ );t~ :...) ~-_); r-. f'" :-----; ",," ::> - 1- ---! :.-0 -~ -< .0 ..< r ~t~~, ,llJ~"""~~~~IU1!lL~~!It-!~"*,":;jI,"~df;1<{;"FVW<'i'~<'""c.'IW>H'"""r""r''''~!'''.-'$f"1\.\i'!~~~~I(i!~",''f~~~~'!!II~'f,iiJfill$iIfi';.' ,~-" ~~ (Rule of Civil Procedure No. 236 - Revised) MANUFACTURERS AND TRADERS TRUST COMPANY : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 01-02908 DALE L. CROMER TAMMY L. CROMER Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JUNE ':;0 , 2000. ~y L2OA. ,,~2 ~..IZ"'lCr1>EPUTY 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 **TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINEDWlLL 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 ~ .~.- . ~. ~ ""'''' FEDERMAN AND PHELAN, L.L.P. BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD. STE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 01-02908 TERM, 2001 Plaintiff Vs. DALE L. CROMER TAMMY L. CROMER Defendant{s) SUGGESTION OF RECORD CHANGE RE: PLAINTIFF I S NAME TO THE PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief the plaintiff' was erroneously listed in the complaint as: MANUFACTURERS AND TRADERS TRUST COMPANY The correct name for the Plaintiff is: MANUFACTURERS AND TRADERS TRUST COMPANY, S/I/I TO FARMERS TRUST COMPANY Kindly change the information on the docket. Date: July 12, 2001 ~"". ~ M/rl)e . '111A/fki!U ~nk Federm n, Esquire 1- Attorney for Plaintiff p,,,,,, ~'i _ . ~, , . . I-I . ,. I, PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R,C.P. 3180-3183 MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, No, 01-02908 v. DALE L. CROMER TAMMY L. CROMER Defendant( s), TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $22,578.67 Interest from 6/19/01 to 12/5/01 (per diem - $3.71) $626.99 and Costs TOTAL $23,205.66 , ESQUIRE ER at SUBURBAN STATION Note: Please attach description of property.No. "!"i.,,,,,"..,..,~,~ i' f -- "I .. . . -~ ~ I'~I~ ~- _. . ~,-~"- ~,. - ~ ' ."" on" ""~"~"""<"""lli" l"l'illnirWT'Ii'llllliliTii l[m]'" I . J . iTlfl11"'1 . ..... .\ ( '" ,.., <:> r- ,.., ~ r4' ..< 00 .... ><.;:$ Z ~ o~ 0 U 00> ~ .... .,; ~~ ~ Eo< f;l;l ~ ):l f;l;l S:oo ~~ U ~ "ti ZZ ~~ ~'E Eo< <l) .. OZ 00 .... f;l;l = <l) ~~ ~~ '" Eo< '" ><. = Eo< <l) ~=- 0"< 0.. s: .0 O~ '" >> ~~ ~~ Eo< ... " UZ .; ;~ S ><.):l ;- J~ ~~ '" 00 ~~ \) Eo<U ):l00 f;l;lEo< ~~ ~ ~~ Eo<~ :;J 01:: Po ><. = <l) ):l~ UEo< ~ rs:e \) 8~ ~ ~ ):l .... U f;l;lf;l;l ~ ~ =i:l:I ..c; Eo<~ <l) - .~ ~):l i:.. U ~~.'$t"~~!~;,~I'@~lm~II~II~~'"if'-M!il~;~mg~',~!n.',r!!Nf;";"~'"";T---''I" O-~-j;;'''''''F-''f~:q';'@'~'''R;;;.-m;'?N#H!!l]:\;jim~;l<tS'~Ill!!~V.<_ _~,li . . ; >, ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Registered Surveyor, dated September 22, 1971, as follows: BEGINNING at a point on the West side of North Pitt Street, said point being 108.6 feet South of the Southwest corner of North Pitt Street and "A" Street; thence along the West side of North Pitt Street South 10 degrees 30 minutes West 30 feet to a corner of premises now or formerly of Ralph McKee; thence along said premises and passing through the center of a partition wall North 79 degrees 30 minutes West 165 feet to a point on the East side of a 15 foot alley; thence along said alley North 10 degrees 30 minl,ltes East 30 feet to a corner of land now or formerly of Charles C. Yinger; thence along said land South 79 degrees 30 minutes East 165 feet to the point and place of beginning. HAVING thereon erected a two story frame dwelling house, known and numbered as 448 North Pitt Street, Carlisle. ,. TAX PARCEL #06-20-1798-277. TITLE TO SAID PREMISES IS VESTED IN Dale L. Cromer and Tammy L. Cromer, his wife bv Deed from Glenn E. Hockenberry, single dated 10/30/89 and recorded 10/30/89 in Record Book G: 34 Page 190. "!""_lRl "_, , 1 I ~ - Mf.f ~ QR Pp . .,.... ~ CJ'1 ~ -- Q., \::)1 ~ ~ '" -- a. . O~ ~ '["' ., -~." q.""~" , ""~-~"'"'""~""~'" ....~,.".'f'..,....~'lIIJ"i n~""_r-- iil'!.1 Fh ~ ::::::::- ~,,\J -0 ~(}JI.~ ~ 7'1 ~ .- lJI' .. ~ ~ ~ '0 0'0 ~ ~ e, c,. o ~~-~~ '71 II '. ~ '"\( () ~ . .< \0') 0 C__) C S :;;;.......,. -()C ~s n:1L: , ~ L.___ Z I ; l~-" ~~~.~ U , " 't~ .. r.'J "-'r,; >("-'" ;;~~ (~ 2;-.< =~ I;:> iP --"'C: ~;j -/ 1'0 =< ~'[J =< .,'~""""""~""~ _Jf"~~~~~"~~~~WiJ:3!~'~I'Pi'f':--'f''-''';:'''1''"'1'f;:'-;'-;~';"j~',' T-f[f{-;""}!'1;r,epJl~~~~;r,:''!1J'''--il'-Wf!'i'\'iiWi''''%W,"WW't'f4ft~OW~~ /- f MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, No. 01-02908 v. DALE L. CROMER TAMMY L. CROMER Defendant( s). August 9, 2001 TO: DALE L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBT AlNED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCf!ARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 448 NORTH PITT STREET CARLISLE, P A 17013is scheduled to be sold at the Sheriff's Sale on DECEMBER 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 MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the MARCH 6, 2002 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. 0]',. " " 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, I. 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 ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe 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 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 fired 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 ':;~-'~-- ,,-~ 1-'-'1" .~ . ~ -" I i 1 , ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the Borough of Ca'rlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Registered Surveyor, dated September 22, 1971, as follows: BEGINNING at a point on the West side of North Piu Street, said point being 108.6 feet South of the Southwest corner of North Piu Street and "A" Street; thence along the West side of North Piu Street South 10 degrees 30 minutes West 30 feet to a corner of premises now or formerly of Ralph McKee; thence along said premises and passing through the center of a partition wall North 79 degrees 30 minutes West 165 feet to a point on the East side of a 15 foot alley; thence along said alley North 10 degrees 30 minutes East 30 feet to a corner of land now or formerly of Charles C. Yinger; thence along said land South 79 degrees 30 minutes East 165 feet to the point and place of beginning. HAVING thereon erected a two story frame dwelling house, known and numbered as 448 Nprth Pitt Street, Carlisle. ' TAX PARCEL #06-20-1798-277. TITLE TO SAID PREMISES IS VESTED IN Dale L. Cromer and Tammy L. Cromer his wife bv Deed from Glenn E. Hockenberry, single dated 10/30/89 and recorded 10/30/89 in Recbrd Book G: 34 Page 190. ~~ ." ,. . -~~ ~ {r i'-..J,() i '-!'U ........ -,~ I ..<w~_~ . " ~~ <"'~'__""""'o". .0,.=" 1 ,,",',. l[rm.'"lf (') C ::?" ~~1 r::=c: ~f:- Pl~ ''''C'' ~oo :< t=.' ;r::.... c= G') "'j (F -'-,:; ,;} "-> :", "" ~:iJ -< ~l!lBJ,_. ~ "~.~lI[J~)_.~ ~,..I~,~'~~~I~i\"~7;iJf!*""'~"~""""'!'L--':'"" "-c; '-"---"-'"'''''''-''''''"'''-li'-'1'<'S'''l';''j;,.V'''''-v;<n,-'-,'' "'_~''''_N,~''';";;J:'''''1'''P''''~'I--~!' AFFIDAVIT OF SERVICE . PLAINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY No.01-02908 DEFENDANT(S) DALE L. CROMER TAMMY L. CROMER Type of Action - Notice of Sheriff's Sale SERVE DALE L. CROMER AT 448 NORTH PITT STREET CARLISLE, PA 17013 Sale Date: DECEMBER 5, 2001 Served and made known to () ~ \ e. i..... at (ft07,0'clockf,.m.,at .J/.48 SERVED Ci:.c 1M ~ ~ . Defendant, on the / ,;{ It- ~ l 811- s~. r,9-((.\i~ k- day of J,v,vs-t-, 2001, , Commonwealth of Pennsylvania, in the manner described below: ~Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place 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.!:/:Q Height ~ Weight ~OO Race We... Sex MOther I, Ck~e\JC,,--l. Vfo..-l.;;,r ,"J"iL. 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, Notary Public Sworn to and sUmEs ribed ChambelSburg Bora, Franklin County .' d My Commission Expl . 5, 2002 befor me t s . ay . . J(<L, L ..M.~b.r, :::SYIVanl S, lonot N ~ NOT SERVED of Not On the ____ tlay of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Orne!: Swcrn ta and smbscribed before me this ___~ Jay 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 [,,"",~.-- ." 0-"--1"" .~ "" . .., ~ ~ ~ -'\"" ~,~~,. "I,l!II!IiiI "~ ,.,.. - . ~" " T "" ,,,,,.' ..,,,,,,,,.. ~~rTlr''''''''lriiiFfClli'IIUI'lll[mr i ~ n- 'C 0 0 () C -n :? (.I) 'lJ53 rrl :-1', ITlm --0 'i= 2::0 ZC ~-~'l2J U) 1.' -' ~.... ~=~f~ ~;, ""C -0 j;: , ::g zC, ~~C) -=0 1:-;> Om ::Pc Z ~ ~ =< \0 -< ,r J. 1 _,~" r~""--'-~- r ~..,..~'""",,,,,, _",. _>;~~>!l'~~~F~:~J!"~:l1"P""~-;0,;:-;,\"",,;~!,;,'E'-'ln - "-'I),.,\\t':'1fC~I~t;;p-l"P:-';i!!$'''fi!~''':,!'''":"'''' """i"~ffil'l!-r''W~ltff,~~ ~,;o.l'V\ ; AFFIDAVIT OF SERVICE , PLAINTIFF MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY No,Ol-02908 DEFENDANT(S) DALE L. CROMER TAMMY L. CROMER Type of Action - Notice of Sheriff's Sale SERVE TAMMYL.CROMERAT 448 NORTH PITT STREET CARUSLE, PA 17013 Sale Date: DECEMBER 5, 2001 SERVED Served and made known to ""';:\iI.J\. VV'-i 1--, C~lM-e~, Defendant, on the /1- ft.- day of A-Vj V"'+-200J, at~, o'clock-f-.m_, atAlf 8 tJ, f?\\- Sit-, J C<O>-t<. \\b \~ ,Commonwealth of Pennsylvania, in the manner described below: Defendant personally served_ J ( I X Adult family member with whom Defendant(s) reside(s)_ Relationship is VII,} S\D3tJ I:l- Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant( s) resider s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. 011-\"\1... L. ~VI'el{t, Other: Description: Age~ HeightL Weight OlOO Race Wl.. SexA Other . I, C~\<.Cl-lc.1l.. 1--, Co ~ ~1--:~ompetent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice 'ff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Notanal Seal Stacy L. Heefner, NOlal}l Public Sworn to and SJ~bed ~haComb.rsburg 80",: Franklin County [) y mmlSSlon EXpl A 5 2002 ~ befor me tips day ember, ennsy vam ' of &-f ,2001../.. I . ; ono oa s ~ Not : '--i ~ By: CF NOT SERVED On the _'__ day of_ ,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 at Snburban Station 1617 John F. Kennedy Boulevard, Snite 1400 Philadelphia. PA 19103-1814 (215) 563-7000 Pc ." , - .1 1 I '(~ ~'" ">d_ - " -""",,' "'" """"'-'~jMil))j'Hnmni'll~lrT~lnllm}" $' i1(,) \ . () 0 0 C ."n ::g: en -ace "., -n fT1 ['1'1 'Ll r' Z:t: ",;:,r::Q Z;;:::, , ,','-..-Jo' ~:'E~ ~;~~~ yC~ -0 -j.; ""I-~ i;~('.) '7() - ~O r;? ;'):"1') >...C~ '='... Z !;:"" ;V ::::J. ";:9 t'" ~ '~~,~ ...,l]f~_~ "" ~'!'t~,lJill~Jl~~~= ~~fIt"~rlifil'lWiir:-""M;"~~,~,lr)W"1W~)R.-",:~I\;:~0'-F"'"'' ^'.'~'-'-"'f-,;,:of,~,'G~-m87"i,'l'-'f~;+i\i~'"W\'''':~;,''*''Mr,,:'''\~;"'iFV'i'lM'~~;!i~P(i: i MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION DALE L. CROMER TAMMY L. CROMER NO. 01-02908 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MANUFACTURERS AND TRADERS TRUST COMPANY, 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 448 NORTH PITT STREETCARLISLE. 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.) DALE L, CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 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 "''''l'l~" '1". , ,. I '; I' ,I ~~ '" ~_._, " -. 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.) A VCO FINANCIAL SERVICES CONSUMER DISCOUNT CO, ONE 5205 SIMPSON FERRY RD. MECHANICSBURG, PA 17055 HOUSEHOLD REALTY CORP, 25 GATEWAY DRIVE, SUITE 107 MECHANICSBURG, PA 17055 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 448 NORTH PITT STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to autho . . es. August 9. 2001 DATE :.%~ ! - '"-'.'.' -, 1--' l' II~ " ,~ , "' 'f;\ ["'1'" 1!lI!I~-~ ~,~." < , ~- -, .~,=. .~~~,~ ,._""","," 'ow r I IUllIIJr lLU nT'/"t" .' , (') C) C) C $: r! "0 CO "'" ,,, r"~' r:::: Z T ~~") f~ (J '''"'. , j'"'.j ?::: "j ::;;l ='".) ,;J ':"u -< W~" ,~~;lI.;r!JI'lI'il,~","~ ';.,,1.' ~ f[1ilJ'iI~ ~ ~ .~. )'~~~~~~~F--,;",''-',",lT-'~;~;'''''",'';;'''''f-"T'' ;,;~S!,'G'n>t}';-"'''i'''':m;\;f''~~'''~!'~'V:;lf;',~,W"!{~;'''1!'1'-'''-r;~-!l,'lp~.~~..;JJ~ 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 MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION DALE L. CROMER TAMMY L. CROMER NO, 01-02908 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. C.S. Section 4904 relating to unsworn falsification to authorities. FED ttorney for Plainti I~-",~, . "--'" I 1 I . "'-~ " ~l ~ ~ 't~~ ,~ ".",~..L~ , ..,.. -,,~."'~' .,. "'I1TlilT U-Tmn T 'IT ''11 o C 'Z ~W~ "'7 -, 'ZC ~:;~~ ~I..:.-j t~ ::< (.-'::} :"'" G? C:) .Cl"i <..r; r;-? j"-....) " ~,- .., " ~.."l'",",",,~'m!;m~~~~~~WJ~,"mrF."'WBi':1,;,K~;r;""i~01.W~'W'"c''1'-,,!','"'' ",~9;'WNt;'!'1!'!W!'&~,ft"~'n~i7,!;i1'!~'~:i'~,1(i4'~~IIflM~II1~~~ T-""'""""'.'''~'O- " 'J."~__" .. SALE DATE: DECEMBER 5.2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MANUFACTURERS AND TRADERS TRUST COMPANY No.: 01-02908 vs. DALE L. CROMER TAMMY L. CROMER 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: 448 NORTH PITT STREET. CARLISLE. P A 17013. As required byPa. R.C.P. 3l29:2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3l29.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously fillld).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. ~is~ Attorney for Plaintiff December 3, 2001 '., I,"' "! ",'r I I ~ , MANUFACTURERS AND TRADERS TRUST COMPANY C~IBERLANDCOUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION DALE L. CROMER TAMMY L. CROMER NO. 01-02908 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) MANUFACTURERS AND TRADERS TRUST COMPANY, 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 448 NORTH PITT STREETCARLISLE, PA 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.) DALE L. CROMER 448 NORTH PITT STREET CARLISLE, PA 17013 TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, PA 17013 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 l__'_~ ,. I ,'''.c "" ,] V__".., ,'"' " 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.) A VCO FINANCIAL SERVICES CONSUMER DISCOUNT CO. ONE 5205 SIMPSON FERRY RD. MECHANICSBURG, PA 17055 HOUSEHOLD REAL TY CORP. 25 GATEWAY DRIVE, SUITE 107 MECHANICSBURG, PA 17055 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 448 NORTH PITT STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verifY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. e.S. Sec. 4904 relating to unsworn falsification to autho . 'es. 1 ~{;QIjV\j AUl!'Ust 9. 200 I DATE , ESQUIRE I --"" , : '.- ~~";"i "I",' , f 'f .~ . DATE: August 9, 2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) DALE L. CROMER TAMMY L. CROMER PROPERTY: 448 NORTH PITT STREET CARLISLE, P A 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on DECEMBER 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 1-"'1 < - ,--' ':Y' ~ , 1"'1 ~,o ,. 1-1 ~~ .~ ':. ..,.... -'0 1la; CD- "Z r" ar 3 lDO" 0. III ~a '" CD ~ 0. III '1- ,.- , ,~-'" "'.... CDO gel: iil-z 0." ",3 _0" ..,Ill 00 ,,- -.., 0-' 3l1l o CD CD " "'.., CDO 16" --3 :s.w ~" lClD m_~ 3.., '0 CD o~ "'- CDZ CD'" -3 CD So C11 ~ .... """"r"'1 ~ '-' ~ N ~ ~ '" ~ o (Xl .... '" ~::!~~rC~5'~ I I I I I I I I I I C11 .... s~~ dt"lt"l t{l~~ :=z.... o....z t"'t"l> ;;g;~ i'Jd.... >l':I> t"'G"Jt'" ..,';.,'" -<>~ t"l.....< o~ C1:=; "'i'l . '" '" ~ t"l '" 0 ~ ~ .., d i'l 3: ~ i'l > l':I -< 1::1 .... iil "'I .. t"l < 0 l"l ~ ~ .., .... t"l ;l 9 o ~ '" .... o '" '" ~ .." '" o Z "i i'l ~ P ..... o :' 3: i'l t"l ~ .... t"l '" = d l':I gl .." > .... ... o '" '" '" .., .. = .. = <t o " " = 'C .. = ~ .... .... 00 :;z o ~ =: "= .... .., .., 00 .., [;.; l"J .., 'h ~ .... 00 t"' !"1 "= > .... -.J Q .... ... N ~ ..... C> C> N C> N C> .... C'l s: :;c 1i: o CD :s: ~ m 3 ?J ~ c t"l .. 3 [ij = " .. !!. - ". .. - .." .. = = ~ ..., :; .. ::I .r 1::1 .. 'C .. .. [3 .. = - .. - ~ .. ~ .. !' .." o = .. .. .... '" ... '" := .. .. :I. ~ ". = .. '!" .." > 1::1 Z .. '" ~ ~ =- sa. ;:;- 6: ~ ~ ;' ~ - CD Q' .CD ~ sa .. CiI ... CD ~ ; = ~ 3 0- ~ ~ ;; 0 Ii ::!l o t"l CD .. 6: = 0- S. CD ~ !i1 ..... '-' Z .. .. - ". := .. = .. .., .. .. '" - .. .. .. - t"l .. ~ f!!, !' ..... ... ..... o '" .." > ..... ... o ..... '-' r S' CD o>z -0.0> C/)o.3 (l) Ci CD = '" 0> 0."'= ~ 0. "O~OIl ::rO):;jm =:::iCDO ~c-"Om ctlOCD:::U -c::,-:;j~ ::,-:::1:::1)> -- 'Tl () z J>>. CD ,po;::l > )>CDroZ ::l~CJ cO~!!1J ~o.enI 0,< c: m CfCJO'"r ~OC:)> ~~a-z ....CDO) < ::l Ql(f) C. _ - 0) en!:!':. 'co CD == ::::J o CD s:~ - 0 o .., o " a; <0 CD " CD CD - - !l'; {t "~ ~ , 1I!If!!~~~ . h_ "'~ ~, ", '"0',,,,-,,, ,,-. ",--'0"0; "'0" >","- """,~""v'lI',o""v,,,,'vltljj11lon"m'lIMTI I. :rn!11'~ (') c LPt( the , r:: ,-, ;!.::,.--, :sp -:::;; ..:::.- -..' ..< . C) '::::J :'~q ,;,'"'") I en '-; C,,) ~"~~I ;::> (fl 1''- ~.o -< " .,.".jmo_ ' ~iI:.'19;-"ho,__"".~~W!lll';!fflll;~!ftl~~~!!"l"C'l~r'''-~''e<:'''<'''-''J''''''. .""~"'1':,-~,,.- ",." -")-':'::~;'2,T1'!i'p~11I'1~:,~"i~""'!1;1t".);j,~","""'k~W%1~m:~~i!i DlIIt" STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, _____________________________________________________"________________________Ilecorderof Deeds in and for said County and State do 'hereby cenify that the Sheriffs Deed in which _______h_______ Manufacturers & Traders" Trust Co ____________________________________________________________________________________ ~ thegr.ontee the same having been sold to said grantee on the ______h~E.!'________h_______h______________h_ day of _____U___________Jl!:f___________h_____ A. D., ; O~____, under and by virtue of a writ______________ Execution , 15th __u_____________________u________h____ h _____ ISSUed on the ___ h_ _____ h_h __ ____ ________ _______ August day of __________________________ A. D" Civil ---------------------------- - -..------- --- ----___ u__ ___h _________ ____ ____ ____ ___ Tenn, : 01 " -----, out of the Court of Cornman Pleas of said County as of 01 2908 Number ______________, at the suit of Manufactures and Traders Trust Co --------------------------------------------------------------. . Dale L Cromer & Tammy L Cromer ---------------- ------------ ------- agaInst. --._ - -. ______ _ ___ ____. ____ ________ ____ ___________. _ is 249 4832 duly recorded in Sherifrs Deed Book No. ____________, Page ____________. IN TESTIMONY WHEIlEOF, I have hereunto d d and seal of said office th~ _-'1______ day -------------~ ~~~~ dJ--.~~r;;". IlICIIIder of Deedt. b1IJerIam/ Caunlr. 1:1_ ~_, llJClNnm',fF &pi!eaIlleFinll,......,of_2lMP 1"-;""'l\1~~ <,-~ " " ~,! "" ", . - ':~! ~ Manufacturers and Traders Trust Company VS Dale L. Cromer and Tammy L. Cromer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2908 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 12,2001 at 9:30 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dale Cromer, by making known unto Dale Cromer personally, at 448 North Pitt Street, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Jason Vioral, Deputy Sheriff, who being dilly sworn according to law, states that on Sept. 12,2001 at 9:30 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice and pescription, in the above entitled action, upon the within named defendant, to wit: Tammy L. Cromer, by making known unto Dale Cromer, adult in charge, at 448 North Pitt Street, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Jason Vioral, Deputy Sheriff, who being dilly sworn according to law, states that on Oct. 01,2001 at 8:36 A.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dale L. Cromer and Tammy L. Cromer, located at 448 North Pitt Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency ofthe action to one of the within named defendants to wit: Dale L. Cromer, by regular mail to his last known address, 448 North Pitt Street, Carlisle, P A 17013. This letter was mailed under the date of October 2, 2001 and nev~r retumed to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the aboV'e Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendlllflts to wit: Tammy L. Cromer, by regular mail to her last known address, 448 North Pitt Street, Carlisle, PA 17013. This letter was mailed under the date of October 2, 2001 an<il never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being dilly sworn according to law, states 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 December 5,2001 at 10:00 A.M., EST. He sold the same for the sum of$1.00to Attorney Frank Federman for Manufacturers and Traders Trust Company. It being ,the highest bid and best price received for the same Manufacturers and Traders Trust CoJ:j:J.pany of One Fountain Plaza, Buffalo, NY 14203, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$703.83, it being costs. ~,~,;"""" .-r-" ,0 l " ,~ .>;"""~ -~'"~. ,'i"'3"'f'L Sheriffs Costs: Docketing Poundage Advertising Posting Bills Acknowledging Peed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed ; $30.00 13.80 15.00 15.00 30.00 10.00 .50 1.00 6.50 1.48 15.00 30.00 251.45 206.94 25.66 25.00 26.50 $703.83 Sworn and subscribed to before me This l.!L!!:.. day Of~ 2002, A.D., 9::tL- (2 n.lij~.-(~ Pr th notary ~I I~~ So _~w~: /.# .r->/6-,.~J< 1"~ R. Thomas Kline, Sheriff Byq~~ S~ Real Estate eputy ~ ~' "" 31" 4J 1,6 Ck. ao,2A..~ a..... /.20& 3 'f iil r U1 'n 111un , MANUFACTURERS AND TRADERS TRUST COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION DALE L. CROMER TAMMY L. CROMER NO, 01-02908 Defendant(s), AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) MANUFACTURERS AND TRADERS TRUST COMPANY, 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 448 NORTH PITT STREETCARLISLE, PA 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot ~ reasonably ascertained, please so indicate.) c <: -ofij n1{r: Z:.:r..'~ z~... ~~~: r:::c.: ~Q ;p;c; c z ~ DALE 1. CROMER 448 NORTH PITT STREET CARLISLE, PA 17013 TAMMY L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 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 .~ -, "'" c= G") (..lj " -,v 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 '!"~~"?,, '~-~._'- - ""', " , o -n ~y T'--:> r" -,-,IT1 '."f' ';C) ',-, .:~~~ ,<:-;::'{1 ,-,I ~ ~) ~c H~T':T-- "I"] , , , 4. Name and address of the last recorded holder or every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) A VCO FINANCIAL SERVICES CONSUMER DISCOUNT CO, ONE 5205 SIMPSON FERRY RD. MECHANICSBURG, P A 17055 HOUSEHOLD REALTY CORP. 25 GATEWAY DRIVE, SUITE 107 MECHANICSBURG, P A 17055 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 448 NORTH PITT STREET CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealtb of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 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 Wlderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to Wlsworn falsification to autho . . es. ilwv August 9. 200 I DATE , ESQUIRE / 'i'~{~ '. ~_ ,> ,> ',," ,""'" p_ ,_ . - .. CUMBERLAND COUNTY MANUFACTURERS AND TRADERS TRUST COMPANY Plaintiff, No. 01-02908 v. DALE L. CROMER TAMMY L. CROMER Defendant( s). o c s: -00.::,1 rnrn Z:T' 9 01 ?h.~, August , 20 2it. ~c'; TAMMY L. CROMER ~ g 448 NORTH PITT STREET 3. CARLISLE, P A 17013 C:J C) "^j'\ :P" c:: (i"J u - TO: DALE L. CROMER 448 NORTH PITT STREET CARLISLE, P A 17013 r.~ . -I" "~~~ ~,~ c~~ . ::r-,'. "'-r1 -"'. -c. ~;; :"2'..: ,,) I') "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECENED 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 448 NORTH PITT STREETCARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 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 MANUFACTURERS AND TRADERS TRUST COMPANY (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the MARCH 6, 2002 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: 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. I'WDl '~I ,;,"~' 'C, j."". , "" j , ~ You may need an attorney to assert yg!lf rigl;tts. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale 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 ifthe 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 fired 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 !_'".d~, ,), '__,' ,.,."), f"' 'I_I' - "~~~ ,A' "" ,,<~'" '" . ALL THAT CERTAIN lot or piece of land situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Registered Surveyor, dated September 22, 1971, as follows: BEGINNING at a point on the West side of North Pitt Street, said point being 108.6 feet South of the Southwest comer of North Pitt Street and "A" Street: thence along the West side of North Pitt Street South 10 degrees 30 minutes West 30 feet to a comer of premises now or formerly of Ralph McKee; thence along said premises and passing through the center of a partition wall North 79 degrees 30 minutes West 165 feet to a point on the East side of a 15 foot alley; thence along said alley North 10 degrees 30 minutes East 30 feet to a corner of land now or formerly of Charles C. Yinger; thence along said land South 79 degrees 30 minutes East 165 feet to the point and place of beginning. HAVING thereon erected a two story frame dwelling house, known and numbered as 448 Nprth Pitt Street, Carlisle. ' TAX PARCEL #06-20-1798-277. TITLE TO SAID PREMISES IS VESTED IN Dale 1. Cromer and Tammy 1. Cromer, his wife bv Deed from Glenn E. Hockenberry, single dated 10/30/89 and recorded 10/30/89 in Record Book G: 34 Page 190. :""~,l " "." ,> _, _" , ,', -, , ,,'.- ,~--'" "^""'" =' , . WFU:r OF EXI;QUTION and/or ATTACHMENT ",' '. ,,I ,>. - )", COMMONWEALTH OF PENNSYLVANIA) NO. nl-?qnR CIVIL 1BLCIYIL COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF ('"mh<>rl "nn COUNTY: To satisfy the debt, interest and costs due MAnufactures and. Traders Tnlst Canpany PLAINTIFF(S) from Dale L. Craner & Tarrmv L. Cremer 448 North Pitt Street, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant{s) and to sell !=i.pp 'At-t-rlrohM TpgFl" fp~roript-i()n (2) You are also directed to attach the property of the defendant{s) not levied upon in the possession of GARNISHEE(S) as follows: and to notny the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant{s) and from delivering any property of the defendant{s) or otherwise disposing thereof: (3) If property ofthe defendant(s) not levied upon an subjectlo attachment is found in the possession of anyone other than anamed garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due 22,578.68 from 6-19-01 to 12-5-01 (per diem $3.71) Interest $929.99 and COEltc Atty's Comm % Atty Paid ]1<).10 Plaintiff Paid LL .50C;: Due Prothy 1 .00 Other Costs Date: I\"g""+ 1 'i, :m01 ()1r+i~ R T,()n~ Prothonotary, Civil Division by: C1m)~/\~~ IA ~JJU>1\ ~ tr ~. REQUESTING PARTY: Name FrAnk Fedennan, Esq. Address: One Penn CeDer at Suburban Station: Suite 1400 PhilaGel~ia. p~ 1919) Attorney for: P.l "in+if'L. _...' Telephone: 215-562-7000 Supreme Court ID No. 12248 '~'-~~f' ;" "",,,' r-y""""""~,,,,,,,,,,,,,,,''''_"'~'N<' ~-""""r ., - i!!1 < "'~. ~"~W"_' _n'.' "'''~",~--" '~"_'~~""=~4"~TI~.n_' T'U~ lmC::'-li':l ~~'rT" REAL ESTATE SALE No. IY un Sept. 11, 2001 the sheriff levied UflO/l the Clefel'Klanti. i.nterest in the real property situated In Borough of Carlisle Cumberland County, Pa" known and numbered as: 448 North pitt St. Carlisle and more fully described on exhibit "A" filed with this writ and by this reference incorporated herein. !)ate: Sept. 11, 2001 By: nn~ SlVUlt ~~al Estate Deputy ~8 t;;::'il ~ ~ '3~ GViI \.Ii NV P\-I,' S H H3d ,. ,_, _,: " _n" ';' ~'l \0. Hcl 01 t 9\ ~n~ '1"" ,. " ",ql'l(\j):" ^ ,,11',' '.' ,-,o,HO '"'I.'C: '''''_r l3d .:1./i~.;:l j3\Hj,," 0'" . ."" ", _~~''''H~~_, "",.,,.."~__ _IIUI ~.~t1\Ml."ll'I'~,. ~~\lRMm}R!lIl!i'I!!~f'1"'I'~1~4"J"--'~~M-~5i!~'n1tf?:~"1/.1~)ffifr~'!!!IjJN'ffl!S'~fi'~1Ii~...".,,-=~"".~'-ij".!!"l-'~~'"'-""'_"",^""v"~"rp~ REAL ESTATE SALE NO. 14 Writ No. 2001-2908 CIvil Term Manufacturers and Traders , Trust Company F,;:::::;:::,:,:'; ,;::-'''' ' . '" :baIe"L~iOmeF' ,. "Tammy L Cromer :::': , ,::~:':F~!ik:Fel:;i,el'!11'an,' .nE$Ci\ii'TIQ\1, .',' ',. ,.-ALt.,THAT CERTAJ;N lot or piece orland :mualc ':i.li':ibe Hfth Warii,'of the Borough of (~~1.i~e.. "'CU,fi!.'Wrlanp. Coun~--t,- PennsyLvania, ~ci!-' and. '&seii:bedil,1 accordance with a survey and plan thereof ma'de by Oerrit 1. Belz, R~~tered Surveyor, dated September 22. 1971, as follows: BEGINNING at a point on the West side of North PiIL..Street, ,'sakI. point being 108,6 feet South of the Southwest corner of North Pitt Street and "A" Stii:et'; .thence along the West side of North Pitt Stien:Soutb,.\O ,d,c~~~ 30 mlnulesWeM 3.0 feet to a"camei'of premL~es now or foonerly of Ralph McKee; thence along said premises and passing through.,the c<i11ter of a partition wall North 79 tlegi-ee:l 10 minutes West 165 feet to a point on the Ea.'lt side, of a 15.foot alley; thence along said alley North 10 degrees 30 minutes East 30 leet to a comer of land nor or formerly of Charles C. Yirtger, thence_along. said land South 79 degrees 30 minutes Ea~t 16: Feet to the point and place of ,beginning. . HAVING thereon, erected a two-~tory frame dwelling house,JullT#n .and numbered as 448 North Pit! Street, Cadsle. TAX PARCEL ;1J6.20-1798.277. TITCE TO SAID P REMISES is vCil1ed in Dale L Cromer'i;d Tammy L. Cronier, his wife. by Deed from Gicnn e, Hockenberry, single, dated 101301 89 and recorded 10130/89 in Record Book G-34 P'il,190. i,,-II 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 Th e 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 23rd and 30th day(s) of October and the 6th day(s) of November 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 behaif 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 Da hin in ,iscellaneous Book "M", Volume 14, Page 317. /. ............................ ...t:.:...~l....n................................................ PUBLICATION COpy SALE #14 e this 19th da of N~ber 2001 A.D. Notarial SGal // // ~ Teny L. Russe". Notary Public /1:' /-1 'ia~ Harnsburg. Dauphin CQunty' ~ ~ , My Commission Expires June 6. 2002 NO ARY PUBLIC Member, Pennsylvanle AssocJation ot NQlertl!lly commission expires June 6, 2002 . CUMBERL^.ND 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 $ 205.44 1.50 206.94 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..n..n............... ........... ..... n.n.....n.... REAL ESTATE SALE NO. 14 \VIit No. 2001-2908 Civ1l Manufacturers and Traders Trust Company vs. Dale L. Cromer and Tammy L. Cromer Atty.: Frank Federman ALL THAT CERTAIN lot or piece of land situate in Ibe Flflb Ward of the Borough of Carlisle, Cumberland County, Pennsylvania. bounded and described in accordance with a sur- vey and plan thereof made by Gemt J. Betz, Registered Surveyor, dated September 22, 1971. as follows: BEGINNING at a pOint on the West side of North Pitt Street, said point being 108.6 feet South of the Southwest corner of North Pitt Street and "'A" Street; thence along the West side of North Pitt Street South 10 degrees 30 mlnutes West SO feet to a comer of premises now . ~ or formerly ot:RaIpIt---McKee;~the1J.ge along said premises and paSSing through the center of a partition wall North 79 degrees 30 m1nutes West 165 feet to a po1nt on the East side of a 15 foot alley; thence along said alley North 10 degrees 30 minutes East 30 feet to a comer of land now or formerly of Charles C. Yinger; thence along said land South 79 degrees 30 minutes East 165 feet to the point and place of beginn1ng. HAVING thereon erected a two story frame dwelling house, known and numbered as 448 North Pitt Street, Carlisle. TAX PARCEL #06-20-1798-277. TITLE TO SAID PREMISES 1S VESTED IN Dale L. Cromer and Tammy L. Cromer. his VJ1fe by Deed from Glenn E. Hockenberry. sIngle dated 10/30/89 and recorded 10/ 30/89 in Record Book G-34 Page 190. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : 55. 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 same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19,26,2001 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. /~;)ltA ___ Rlger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 I. ~/~'M~ .~~i!~bA/ rl iI.'OTAR,~ . I; 1~ , t'\~s r= ,::>\~,.."'--U=i:i s.~"',+""";r ~.~it,.. ,1 ~' b.Vl I:;:; "-;;"lllla.,r,;;;n~~.."''''''~r-ut.''!n.o . ,1 C:lllislo Bo.1:i. Cl'!llOO.:';i;.:l Cr.J\..nw ~ ~ My ~l1~~ri ~s ~~are.h 5,20D51