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HomeMy WebLinkAbout01-03312 ~J ^" ~ .~.~ FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE RETURN OF SERVICE 1 hereby certify that 1 ~ave deposited in the U.S. Mails at Harrisburg, Pennsylvania on 0-1/-01 , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with u.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Shawn M. Bowers 1122 Fernwood Avenue Camp Bill, PA 17011 Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 Stephanie Hollen 1122 Fernwood Avenue Camp Bill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 By PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 , ~-, --,'.'/., ..n:.~,,,.-ri.'>'~44i;, - JOHN W. PURCELL HOWARD B. KRUG LEON P. HALLBR JOHN W. PURCELL JR. BRIAN 1. TYLER JILL M. WINEKA LAW OFFICES PURCELL, KRUG AND HALLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 JOSEPH NISSLEY (1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD (717) 533-3836 NOTICE TO: Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 Stephanie Hollen 1122 Fern~ood Avenue Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold real estate will be divested by the sale and that opportunity to protect your interest, if any, by said Sheriff's Sale. Leon P. Haller PA I Attorney for Plainti f against the said yo ave an otified of By: . ,~. ",,"'j I ~" ,~ '"''';~', ,...;-' ,-,,, _ i '~ FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 5, 2001 TIME: 10:00 o'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FERNWOOD AVENUE CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHAWN M. BOWERS ~ ,0 ,,-, ',c "" ,""'" -..i___,'_ - ~ ~- .t..- -~ :,t,; " A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO. TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This " . .,-.' 'l!i!i .-~ .- ~'-"',~- petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ,_1 "- ~;. ~~" ,'-"- -,~, "'r[~', ALL TEAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the western line of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the . western line of Fernwoo4 Avenue from Glenwood Ave~ue; thence South 30 degrees East by the western line of Fernwood Avenue, 65.00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of 'No. 86, 65.00 feet to Lot No. 106; thence North ~O degrees East, by the southern line of Lot NO. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana Villa Springs Terrace as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 c__ . , . '-",,-,...;" ,;,,0 &_'", J" , .' Re: PHFA v. Bowers Cumberland Sales 12/5/01 u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 Postmark: U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 -,. ~ ..~. ~ u. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 '/l!^4\i.iijiillW.Biff>I&!i:&'W!!;jlcli~liii!1~.:Iifu_~ftl~IMiiiil)l;,~,"'r.."'^""J","'\"";:o/Ji>l011fb;~,::;"I.;,~1@{",~.jdli_iIiiilliIlrdflJil1Llli- - 8~ '~ ,~ ~. o c:: <- --0 F'2c, mtt Z,..A) Zc- (fJ'5-:::' f5i--c <C~ ~,.,~! Zt:> >c ~ o 2: W - --- ;:"1 ' -:-:~~~ f-';:;~S ~~2~ CSf'i'l ';;' ::0 -< ".. -'." -- ~ w (X) ( .~ ! i i f,~ . ,,1 ..1 ., ,', ". "",- -~-'ll~o_ . FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FERNWOOD AVENUE CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHAWN M. BOWERS ...., . , ,. '''. 0 -.r,," -', '. . -~ - ~ . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed, Information about the Schedule of Distribution may be obtained from the Sheriff of the Cou~t of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This . . ~ j' ~' .Ii '~'i!i -~"k"" petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 , '1 ~ 0 0" -"-~,- 4-~J>J'" / I l ALL THAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the western line of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the , western line of Fernwood Avenue from Glenwood Aven~ej thence South 30 degrees East by the western line of Fernwood Avenue, 65.00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of No. 86, 65.00 feet to Lot NO. 106, thence North ~O degrees East, by the southern line of Lot No. 106, 166,76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana villa Springs Terrace as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 ~~i!imJIh'ili~h;!;;K;kJ<.k\t',~iilttle~~~","~'1iill;,;gt0~t'j"""; '~i;.;,_>',Kt~,;J:;,j{ll~,'f~~"""""';~~MIll~~I~E '""' -~." "" .~_.~ M'__^"'=''"'' "''',~".. <" iii:!IL (") C,) () c: .7'- -rl -o;:~ <.') r.nr';'~'1' r"l1 ~~) -'0 , i'OO-, ,.or", (-......:;. , r~':J "0 (;~i~ ..,.' ZC) :X ~"=:::O ..l>c: (.,) (~)m Z -.... -' t:" "7> -< '"" ~ 1 ~,,","..~, '"'" ...,~~~~""~ \ ",I' 'I \ i I,:, ;'1 !'I ii,! !,;,; !:j ,jl I,! II Ii II i,'1 .I Ii II i:i I, I,i Ii Ii ii 'i :1 II II 'i ~i ,i !i ., 'I I, II Ii --.'> ,,~ ~ , "",,,,,",,,,, -.- '"' ,--I ., "''''j . ~ SHERIFF'S RETURN - NOT FOUND Ij,SE NO: 2001-03312 P })MMONWEALTHOF PENNSYLVANIA . ':OUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS BOWERS SHAWN M ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT GRANT LISA M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , GRANT LISA M NO LONGER LIVES IN AREA Sheriff's Costs: Docketing Service Aft idavi t Surcharge NOT FOUND 6.00 .00 .00 10.00 5.00 21.00 ~~~ R. "Thomas Kline Sheriff of Cumberland County PURCELL KRUG & HALLER 06/07/2001 Sworn and subscribed to before me this .;1 fik.. day of ;l6V( A.D. ~~ 0 ~ ~51 P honotary , -- L > I i~ "n ; i'j(~'; SHERIFF'S RETURN - REGULAR kSE NO: 2001-03312 P ,f ~OMMONWEALTH OF PENNSYLVANIA: . i COUNTY OF CUMBERLAND .,,,';,y#,*w' FIRST UNION NATIONAL BANK , VS BOWERS SHAWN M ET AL CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE BOWERS SHAWN M was served upon the , 2001 DEFENDANT at 1400:00 HOURS, on the 5th day of June at 1122 FERNWOOD AVENUE CAMP HILL, PA 17011 STEPHANIE HOLLEN, GIRLFRIEND by handing to 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 18.00 8.68 .00 10.00 .00 36.68 Sworn and Subscribed to before a:- me this ;).f - day of 9-~ dlfW/ A.D. S264. {} fM"';'. ; ~ Pro notary So A?~~ R. Thomas Kline 06/07/2001 PURCELL KR.UG & HALL~ BY:~ Deputy Sheri f J J -- [ .- 'J ,-,_l ~ j , -, "'li\:r FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION ' LAW Ys. ACTION OF MORTGAGE FORECLOSURE 7'Lo 01- 3.3/J ~ T ~ SHAWN M. BOWERS AND LISA M. GRANT Defendants TillS F1RM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED '1'0 OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of 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 POPER 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 717-249-3166 A VISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P ARTICIP ACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U 01ROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 <.1 , "I " ,; . -~ < . nl'iil?'l"'~, FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE SHAWN M. BOWERS AND LISA M. GRANT, Defendants THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1 719 North Front Street Harrisburg, P A 171 02 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff . , - . , --. ,~' !2:.lL '-"-'1;~i: FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW vs. ; ACTION OF MORTGAGE FORECLOSURE 710.01.33 J2 ~ 1.<.- SHAWN M. BOWERS AND LISAM. GRANT, Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Finance Agency, with an address of 21 0 1 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, SHAWN M. BOWERS, is an adult individual, whose last mown address is 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. Defendant, LISA M. GRANT, is an adult individual, whose last mown address is 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. 3. On or about, December 30, 1998, the said Defendant executed and delivered a Promissory Note ("Note") in favor of BROAD VIEW MORTGAGE COMPANY ("Original Mortgagee") in the principal amonnt of $79,859.00, the proceeds of which were used to purchase a residential property located at 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. A copy of the said Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time ofthe execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1511, Page 362 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County in Book 599, Page 640. The Mortgage subsequently assigned to FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. 5. The land subject to the Mortgage is: 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on December 01,2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNP AID PRINCIPAL BALANCE $77,563.24 Interest at $10.77 per day From 11/01/2000 To 06/01/2001 (based on contract rate of 5.000%) $2,283.24 Accumulated Late Charges $117.90 Late Charges $17.15 From 12/01/2000 to 06/01/2001 $120.04 Escrow Deficit $88.45 Attorney's Fee at 5% of Principal Balance TOTAL $3,878.16 $84,051.03 "''''Together with interest at the per diem rate noted above after June 01, 2001 and other charges and costs to date of Sheriff s Sale. 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 that are actually incurred by Plaintiff. 8. No judgement has been entered upon said Mortgage in any jurisdiction. . "" L -, .' ..ci ~' 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No.6 of 1974 is not required in that the principal balance exceeds $50,000.00. 10. Defendant is not a member of the Anned Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. II. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 5.000% ($10.77 p costs including escrow advances incidental thereto to the date of Sh the property within described. PURCELL, KR & Leon P. Haller, E qnire Attorney for Plaintiff LD. # 15700 1719 N. Front Street Hamsburg, P A 17102 (717-234-4178) . em), together with other charges and s Sale and for foreclosure and sale of By: I ]\JOTE rpHA CASE NU. FR-441-5857746-703 DECEMBER 30, 1998 IDate} 1122 FERN\jOOD AVENUE, CAMP HILL,PA 17011 [Property Address} 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's ~uccessors and assigns. "Lender" m~s BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 and its Sllccessors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of SEVENTY -NINE THOUSAND EIGHT HUNDRED FIFTY-NINE AND NO!100***********************************Doll&s (U.S. $ 79,859.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of F 1 V E********************** ************************************************************************************ percent ( 5.000 %) per yc.ar until thefull amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on FEBRUARY 1, 1999 . Any principal and interest remaining on the fITst day of JANUARY 1, 2029 will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at BROADVIEW MORTGAGE COMPANY, 95 E. WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 or at such other place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 428.70 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, imeresL and other items in the order described in the Security Instrument. ITEM 643211 (96DS) Docld 0000000763 (Page 1 of 3 pages) 6/96 GREA llANO. To Order Call: HOO-530-93930 Fax 616.791-1131 ACCT# 935442 MULTISTA TE FHA FIXED RATE NOTE tthibl1 "A ~ , J.~,' -'--, -", ~-. ''-.r"l' (D) Allonge to this Note for Payu'en! Adjustments lf an allonge providing fer payment adjusunents is execuied by Borrower togC!;,CC with this Note, the WVCfl'''Cc d the allonge shall be incorporated into and shall amend and supplement the covenants of lilis Note as if the allom,e we.'e " "art of this Note. (Check applicable bm..) , . o Growing Equity Allonge 0 Graduated Payment Allonge o Other [specify] 5. nORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in pall, without charge or penalty, on the first day of any month. Lender shall accept prepayment all other days provided that Borrower pays interest on the amount prepaid for the remainder of the mond1 to the extent required by Lender and permitted by regulations of the Secretary. lf Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the. Security Instrument, as described ill Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR****************************** percent ( 4.000 %) of the overdue amount of each payment. (II) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights ill the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used ill this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7 . WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by fIrst class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER TillS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a l\uarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Anyone person signing this Note may be required to pay all of the amounts owed under this Note. ITEM 6432L2 (9606) Docld 0000000763 (Page 2 of 3 pages) GAEATLANOWl To Order Call: 1.800.530-93930Fa~616.79H131 ACCT# 935442 _.. ._,l. [ BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contBined in pages 1 L1.nJllgh 3 c~f t: Note. I HUU'J R.wlGt IRS, ~ rAY TO Tlit: UIWEI; u. PENNSYLVANIA HOUSING FINANCE AGENCY' 110A"'--' .. (CO~/~ Q::~7J;i Rosemary Howard Vice President ITEM 643213 (9606) Oocld 0000000763 (Seal) -Borrower (Seal) .Borrower (Seal) -Borrower ~~ A---- (Sell) ~Bonowc:r _,jSeal) -Bonowcl (Seal) -Borrowcl [Sign Original Only] (Page 3 at 3 pages) GREA llANO BiJ ToOrdarCall: 1-800-S30.9393D Fax 61S.791.1131 ACCT# 935442 .1 * " ~l.._""'Li ,o...~ i ~ \. j'\J..I.! 'I'H~'T C'.c}<.".rATN tl".<i..C t, "j;' ;\11eI1/ cU':'n:')2rl.s.nd Ct)unt:y I "7I.:t'ce:l of :J..;;;).nd Ai tuat .-. in ths '1'owTlohip of r~G'J1er P~Dn3ylvania, boundsd and describ~d c8 follows; BEGINNING at t.he point of intQrli8ct.ion of the western line of Fe:cnwood ..\v-smle and the line of edjoiner between lots numbered 106 and ~07 eon the hereinafter mentioned plan of loes, being 130.00 feet in a acuther.ly direction by the western lil1G of Fernwood Avenue from Gle~wood Avenue; the~~e South 30 desre8S East by the ."t:~t:ern line of Fernwood AV8...71Ue, 65. 00 f.e~t to Lot:: No. 108; thence South 60 degrees Wellt by the northern li:le of Lot No. 108, 166.7 Sfeet to I..at No. 86; thence North 30 degrees West by the eastern line of No. 86, 55.00 feet to Lot No. 106; thence Ncrth EO degrs6s.Eaet, by the eouthern line of Lot No. 106, 166.76 feet to the point and plaoe of BEGINNING, i All A Com; lmenl SCnedu to C ".".' . ,,0" E Yh'I~'1'1 y ,.-< ;~ .. Boa~ 1511 PAGE. 369 II< , VERIFICATION Donald J. Plunkett hereby states that he is the Assistant Executive Director for Single Family Programs of the Pennsylvania Housing finance Agency, 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, infonnation 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. Don4~~ Assistant Executive Director for Single Family Programs IHiN3YL\D\NIA H1EJN; FiJII'\N:E JIJ:E'{Y, s;RJJCIN::;!'GNT KR F.IR3I' lNKN N"IT.II:N'\L B'\NK PS 9" I I ">+l " 'IRBIEE KR TI:IE PENIIi!L\D\NIA H1EJN; FiJII'\N:E JIJ:E'{Y Date: nay 29, 2001 .~ " " j. oj -" "'"'" .. '-~-, UHf;;. K' " FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendant SHAWN M. BOWERS, for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance Interest (Per diem of $10.77 from 11/1/00 to 6/1/01) Accumulated late charges Late charges . ($17.15 per month to 6/01) Escrow Deficit 5% Attorney's Commission $77,563.24 $ 2,283.24 TOTAL $ 11 7.90 $ 120.04 $ 88.45 $ 3.878.16 $84,051.03** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. :~CE~' KRU~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERlA\BOWERS.P A\ '"", " (. " J',J.., I~, .~ ^' "_,'. "c ,-.:" ~w~ FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, NO. 2001 3312 IN MORTGAGE FORECLOSURE DEFENDANT CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on AUGUST 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Hal er A I.D. #15700 Attorney for plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 " "" J ~ ' ",' C'-'" '" '., .'-"~"." "-';k v , ...4 4." . FmST UffiONNATIDNAL BANK AS TRUSTEE FOR PENNSYL VANIA HOUSING FINANCE AGENCY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-3312 CIVIL TERM VS. SHAWN M. BOWERS AND LISA M. GRANT : CIVIL ACTION LAW : IN MORTGAGE FORECLOSURE Defendants DATE OF THIS NOTICE: AUGUST 21, 001 TO: SHAWN M. BOWERS 1122 FERNWOOD AVENUE CAMP HILL, PA 17011 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOuR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 OR 800-990-9108 PURCELL, KRUG & By LEON P. HALLER, Attorney for Plaintiff LD. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 ~!!tf~,!ii~2"!:"iiiiL;;!t~irrMif'l!i~lb"'l.l.~I,['~""-"i1.,~"",i;~",;,tiL<"}1'"_t_Ic]:'h_;~,;;";I"Jl<-l&;,~;,}~"-~~~~_IIlI~iliiBii'~ ~jl\lliN;~1il!i~ ,~. '-. '~-" "'~" . ."_",-,"_H'. ~ ~, ",~ t D ~ (") lJ c, ("' r: ~ c j ~n ft:- <:'"' 'n ~ D -o[j~ ,.." _:,j nlrT" --0 :_;~ 0 Z:r:i f ~ zc: "' (j~.J"_;. I',) ...... ~ ;:::s~,: -Ie ~ ~"....C,I f'5~ (i' )S; ~"""'l -0 -, :z: 3 ~ W 6' ;&-0 c ~ r,~5rtl --0 z ~ Ilf' ,) b =< r::- :b ~ , '0 -< R . . "~ ,<-, ^ .'-"'" ~-~- "~ ~ j ~. " Ii . :! 'i , Ii , i:j ;i !1 I " II ri Ii II d I :i i'l 1'1 ii ii ii .. ,. 4 FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You following 'captioned are hereby notified that judgment has been entered matter: on ~ I~ d...{n/ against you i'n the the above- $84,051.03 and for the sale and foreclosure of your property located at: 1122 Fernwood Avenue, Camp Hill, PA 17011 Dated: 9//J.-/oJ If' (LXo JkJ ~ PROTHONOTARY Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (71 7) 234 -4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, Pa 17011 K:\MKFIDOCS\CUMBERLA\BOWERS.N . I '.- ','-'- 1~ ~ , FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VB. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and "against Defendant SHAWN M. BOWERS, for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: unpaid principal balance Interest (Per diem of $10.77 from 11/1/00 to 6/1/01) Accumulated late charges Late charges .($17.15 per month to 6/01) Escrow Deficit 5% Attorney's Commission $77,563.24 $ 2,283.24 $ 117.90 $ 120.04 $ 88.45 $ 3,878.16 TOTAL $84,051. 03** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. 'URC~LL, mUG' "U~, By ~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\BOWERS.P _'l, ,~-- lK ; , ,-,', -~--- -,,~, - s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 3312 FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF TOTAL AMOUNT OF JUDGMENT $84,051.03 V Interest at $10.77 per diem to sale date $ 2,024.76 Late charges at $17.15 per month to sale date $ 85.75 Escrow Deficit $ 2,000.00 TOTAL $88,161.54* VS. SHAWN M. BOWERS, DEFENDANT(S) *SALE DATE: WEDS.,DEC. 5, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. ~ond PA I.D. #15700 Date: September 12, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1122 FERNWOOD AVENUE, CAMP HILL, PA 17011. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:\MKRDQCS\CUMBERLA\BQWERS.W .. , ~, ~. L ~ .1 .; :0..,:, ,'< lMilu'tii -- f ALL THAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cumberland County, pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the western line of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter . mentioned plan of lots, being 130.00 feet in a southerly direction by the western line of Fernwoo4 Avenue from Glenwood Aven~ei thence South 30 degrees East by the western line of Fernwood Avenue., 65; 00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of 'No. 86, 65.00 feet to Lot No. 106; thence North ~o degrees East, by the southern line of Lot No. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana villa springs Terrace as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 ~~JS;;!!@MM!Jl1.Jiil&..:Jejr.",,,,,,!*,~~&,\;t._-.;j;"';iillirM~~-"'!k1<i~~,,,,\f!['_~ ',h',I""f.h,_~~kii1hc1',m;!\t<,*:!iki",~~~mrd uii ~ - Tlli[j~M4t1li!li!lII~I!llin'lio!;,1II1~1lliI'illIlI -G~ ....... (:) lA..) r ~ ~~ :-t- ..oJ(, ~ ~ ~ W ~ ~..~' Y):,~'&) Vj 6 """OQ008' , ....... t...J C C/ D (: ~ & ....... If' \:) \ I I ::tJ "is -..:) ?' P -....0 C, / ~rr .., ~ ;:: , - ~ - , ~~~ , , -., " ""' ~ .~ ,."",",_", h.~" ~ _.~~_~,=.,__ ~.o~" ~ ,_, ",~_.__"<<~._, ,~_ ~~ . " ~ (") ~ "1,)(1:; EDrn Z2':L: -7j" (j"? ;~~ r:: ~.S'I ~1".., 2;:() ~C) ,,""<.::: Z =< -- c,:> V., !'1 '."::1 f'''::- ~. .~c: :~)~~ "")111 ~ ,=< w ~ '.0 ..... \ '::~:.~ ~;;; ,. " ,.,,-,- '" ., " -. - .:.~- "'.'-,~---, '~';""""""'A'~'-,: , """" FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1122 FERNWOOD AVENUE, CAMP HILL, PAl 1. Name and address of the Owner(s) or Reputed Owner(s) : Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6 . interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN ,.~ . 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: TENANTS IF ANY Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 - '-, ~ I . '~,:;'" -, '''''~;~'!l,..,~,g::,:,j every other person of whom the any interest in the property which (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 PA C.S. Section 4904 relati 0 unsworn falsification to authorities. DATE: September 12, 2001 Leon P. Halle PA I.D. #15700 Purcell, Kru & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ,b.';;;'.:..L'l.:ti1U 'Ji'N'~1i!r~:iliiiti~jjilft~~M~~_~il.~"""''',ot'-')')' i'Jl,.,,~,~j'Ji'.~i...!!}n;';,,*,~",i~~iIidOOllblol!l'&!"'~ ~, 0'=._ <"-< ,~",^,.h.~.~ . ~~._~ ~ ~ 'c,,"^ ---'--""I'~lIilil -M. ,.." .. (") C::> Cj c: $: -~,..t "'t]"T" en n""- > 1''1 _ .rr " Z"';L :Z:r 0)". 1'-"'.:, ~(~j ~'t; :~:~';c: ~.("-, i~t~ L(-< :,X ):lod '~ c.. .";;~ ~ <- .t:"" '?> =< <.0 :::0 -< . " FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF VS. SHAWN M. BOWERS AND LISA M. GRANT, DEFENDANTS .. ,.,.,'. :'-H';'il.~[[f-';'-'-' ' ~t~~rffi,i ". ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 3312 IN MORTGAGE FORECLOSURE PRAECIPE TO REMOVE DEFENDANT AND RELEASE FROM LIABILITY TO THE PROTHONOTARY; The above named defendant, LISA M. GRANT, has been released from liability and should be removed as a Defendant in the above action. By: Dated: September 12, 2001 Leon P. #15700 PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 _1 ~ STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND " } 55. Robert P Ziegler I, _____________________________________________________.________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sherifrs Deed in which ________________ SEcretary Of HOusing & Urban Dev of Washington D C ___________________________.________________________________________________________ ~ thegr.anlee 5th the same having been sold to said grantce on the _____________________n________________________ day of 01 ______________~::_______________________ A. D., ; _____, under and by virtue of a writ______________ 12th Execution . _________'-____________________________ __________ ISSued on the ___ _ __ _____ __ ___ ______ ____ __ __ _______ September 01 , day of --------t----------------- A. D., -----, out of the Court of Cornman Pleas of said County as of 01 Civil -----------------------------....--------_________ -_ -______ _____________ ___________ T enn, : '3312 First Union l'Iatl Bk tr for Penna Housing Fin Agency Number ______________, at the suit of __________________n___________________________________________ Shawn M Bowers ____________________________ ...__..._ __ against____ ...___ __ _ ____ _____ _______ ________ ____ __ ____ ____ __ _ is duly recorded in Sherifrs Deed Book No. ____~!:~____, 4Va~e m_________. IN TESTIMONY WHER.EOF, I have hereunto --tf:- d and seal oE said o({ice this _L!.m____ day -------------7) A'f.' c>t.QI!J.s2 -~-~~- - ------ . j~eeo of Deeds !lecorder 01 Deeds, Cumberlaml County, Carlisle, ~.L My Commission Expires the fIr&! Monlla. 01 jan. i!UIIP " " t!lll1t -'~'-"~", ~-~ -~~-"~~"t~ , First Union National Bank, as Trustee For Pennsylvania Housing Finance Agency VS Shawn M. Bowers In The Court of Common Pleas of Cumberland Connty, Pennsylvania Writ No. 2001-3312 Civil Term Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 7:45 o'clock P.M., E.D.S.T., he served a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the ~ithin named defendant, to wit: Shawn Bowers, by making known unto Shawn Bowers petsonally at The Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 5:05 P.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 Shawn M. Bowers, located at 1122 Fernwood Ave., Camp Hill, Pennsylvania, accordingtd 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 I. Sheriff mai.l~d a notice of the pendency of the action to one of the within named defendants to wit: Shawn M. Bowers, by regular mail to his last known address of The Cumberland County Prison, 1101 Claremont Road, Carlisle, P A 17013. This letter was mailed under the date of October 2,2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum of$I.00 to Attorney Leon P. Haller for The Secretary of Housing and Urban Development of Washington, D.C., his successors and/or assigns. It being the highest bid and best price received for the same, The Secretary of Housing and Urban Development of Washington, D.C., his successors and/or assigns of c/o Golden Feather Realty at 1600 Sacramento Inn Way, Suite 220, Sacramento, CA 95815, being the buyer in this execution paid SheriffR. Thomas Kline the sum of $843.18, it being costs. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail $30.00 16.53 15.00 15.00 30.00 10.00 .50 1.00 13.00 1.74 Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed .1- ," -'-li.. i" c21lli!t;; 15.00 20.00 297.95 300.30 25.66 25.00 26.50 $843.18 pd by atty. Sworn and subscribed to before me So ~w~ v# r~~..e;~.t: /..Ar.-<.; R. Thomas Kline, Sheriff This /'fte day Of~ 200ll( A.D. ( k' Ofl,J/,....; thonotary ~ BY {j~swA R6a1 Est e Deputy ?~ t uV AD' J ~ (" -Pt,L I. tk. 3SbC,(, tlv. ;.zool ~ , "'-" 't: / ~ FIRST UNION NATIONAL ~ANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the 'real property located at 1122 FERNWOOD AVENUE, CAMP HILL, PA. 1. Name and address of the Owner(s) or Reputed Owner(s): Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 2. Name and address of Defendant (s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW) : Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UNKNOWN 6. interest sale: Name and address of every other person who has any record in the property and whose interest may be affected by the UNKNOWN - ~~ - ~ 1< i i,-- . c'" ~; - '-;<'-,,'.1;;:;; " lliit I f 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 Domestic Relations Office . Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 PA C.S. Section 4904 relati 0 unsworn falsification to authorities. ~ Leon P. Haller PA I.D. Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 #15700 DATE: September 12, 2001 ~? ~, 1: c_ _c_ ~U-_~ ~ "lok<"~', ,. "c ~r'~~_ ( FIRST UNION NATIONAL BANK, AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. SHAWN M. BOWERS, DEFENDANT NO. 2001 3312 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FERNWOOD AVENUE CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHAWN M. BOWERS --~ ......, 1-" ,', .,_~' _,. , _ ~_",,~_.~_:~'_' \; , A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Cou~t of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. S Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This "., '", , - 4~"> ,'" - - '1" - 2 ",,;~, t petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific retu= date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 -,.'" -_.-" ;&' - ~:"'-'-)1 , ALL THAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, cumberland County, Penn~ylvania, bounded and described as follows: BEGINNING at the point of intersection of the western line of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the western line of Fernwood Avenue from Glenwood Avenue; thence South 30 degrees East by the western line of Fernwood Avenue., 65.00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of .No. 86, 65.00 feet to Lot No. 106; thence North ~O degrees East, by the southern line of Lot No. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana Villa springs Terrace as recorded in the Cumberland County Recorder's Office in plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 o , ",'j . ~ I, ~_~ . .... ,",-,-._1.J. ",",'. -~';""".''''--''~ ,.,j"."ifi: WRIT OF EXECUTION and/or ATTACHMENT , , . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-3312 CIVIL ~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due First Union National Bank as Turstee for Pennsylvania Housing Finance Agency PLAINTIFF(S) from Shawn M. Bowers. 1122 Femwood Avenue. Camp Hill. PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notijy the garnishee(s) that: (a) an aUachment has been issued: (b) the garnishee(s) is/are enjoined trom 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 of thedefendant(s) not levied upon an subject to attachment is found in thepos,session of anyone other than a named garnishee. you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. 'A~~)Due $84.051.03 ;';':::",' at $10.77 per dim to sale date Inttr~~ C2. 024.76 Adii;:<Jomm ..it~..il!O> ~id Plaintiff Paid Due Prothy $.50 $1.00 LL % OtherCosts Late Charges at $17.15 per month to Sale Date $85.75 -- Escrow Deficit $2000. $1'4 hR Date: September 12, 2001 CUrtis R. Long Prothonotary, Civil Division _ by:,.. a e/}" 0 2. ~O?./?./"V. ~ Deputy REQUESTING PARTY: Name Address: Leon P. Haller. Esg. 1719 North Front Street HarriSburg. PA 17102 '.:, , Attorney for: p.,l",j nt iff Telephone: 717-234-4178 Supreme Court 10 No. 15700 f,_o;-",_:",i,~,,,,,.',-"!~H;'i,\'f.~'15ci~H'"'~-"~"'ki;:.,"_.'_,.-~ '_,'~"J,;;,j,~,,;'1f-*,j~",i,'J'fi;jjj~-!<g~'M~~,it~kit.."I!iIl:.iWM!>_i'"1fi-tM@t~~~lOi!iJlIlI~~ ~ '-'-~-iiIlI~~~'lC~- Hi 1iW;-~' . < REAL ESTATE SALE No. L/1' On September 18, 2001, the sherifflevied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, P A, known and numbered as 1122 Femwood Ave., Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 18, 2001 By: q~~ Real Estate Deputy 0' ~I?,d , !,' -:,' \!~ y( ls -.;) \ \:\ " (,11) \'\ \1", \}S 10\ 't \ ;\11':) " I,' \. C',' ~)." . _ ( :_\i )' \ :t~~\\f; I" ~ . " S"'...lBli-~ ., , ,.I , ~~ ~1ir,"-. , . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 58?, 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 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 DaUP(in Miscellaneous Book "M", v;~m~~~:~~~;. ......................CZ.................................................................. COpy t' 19th day over 2001 A.D. Notarial Saal S ALE #47 Terry L. Russell, Notary Public Harrisburg, Dauphin County My Commission Expires June 6. NOT RY PUBLIC Member, Pennsylvenla Association of NotarlaS My commission expires June 6, 2002 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERLAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PAT,RIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 298.80 1.50 300.30 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'limCl publicatiofl costs and certifies that the same have been duly paid. By.................................................................... , % F 1:" r:::::::: EJ'iittQ:t#:,,~,-t:::~6;" ~ \y~ :',' !Ili...~.;".:-~.~i.,f..."~.;r".'.;...."..~.).f.?:..~.n.LO:.::N. t~.:,:':.:::.:.:::r.'..?~~.::.,..'.':.''':':..'.':.~.:.:,::,......:....f..,....f.:.:ieet.~...::,..'.:...~.....~.i. ,...,~Qmt ,~,I),(l plact:.,:aCBEOU'lNINtf.. ,,",'.::. ','. ,:.::.,..:.,.:. ',' :: : ',' .:: ,,:::. l~.....>...~...~r.I..:~.~.I.(.I.,.... ~:w.Q.\\:l:rs:'andli " "M::.Grai:i:t.lf::i1&if,iW.~ 1113100. .~~ttt'~ 'Wi.-.. - j, ~' ~laillij;>"" -~"> <> .. - om-:- .- -"~-~&~t_ , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Joumal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Joumal, 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 ofthe 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 ofthe aforesaid notice or advertisement, and that all allegations in the foregoing ~tatep'~'1ts as to time. \llaceand character of publication are true. .To/,Y~.,-_.- Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 ~/~~i~~~A/ NOTARJA['~. , LOlSE.~. ..PublIc C8rIIsI8 BollI. .CounIy ~c..llIlIJ,tEx\lll8l Mlltl:h 5, 2005 ! __ ~~~. ,,;,iH_j'j",.<&"""f,<:';!,jj'tlii,i>'!"'~;;b!\!l;1i_:'1'i1l_i(:j,.;d.i",lol:Mi-'1hii&~~t\c;,;~Ji'lk.""-,,l d_;'H~~:~il:b",a4l!l~~Lliji'ilIiW~lIiilillil!lllfilfllr til!l!d00i- ~~ ~, .-- ~ ~ J:~> <!; '1--'-' ;"." " '-,' "<~jilll!l'<1::c, ;fI'~_'JW'. >'< ,~ ~~~ ... 'l!'jjIllr""'N"-'t' "=,~ ~~........... - -~. mMIlJ.b.:' . .~, -~ .--'~-, REAL ES'!ATE SALE 1'10, 47 Writ No. 2001-3312 CMl First Unlon National Bank, As Trustee for Pennsylvania Housing Agency vs. Shawn M. Bowers Atty.: Leon P. Haller ALL TIfAT CERTAIN tract or par- cel of )and situate 111 the Township of Lower Allen, Cumberland County, Pennsylvania. bounded and de- sertbed nas follows: BEGiNNING at the point of in- tersection of the western line of Fernwood Avenue and the line of . adjomer between lots numbered 106 and 107 on the hereinafter men- tioned plan oflots. being 130.00 feet in a southerly direction by the west- ern line of FemwQod Avenue from Glenwood Avenue; thence South 30 degrees East by the western line of Femwood Avenue, 65.00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108. 166.75 feet to Lot No. 86: thence North 30 degrees West by the eastem hne of No. 86, 65.00 feet to Lot No. 106; thence North 60 degrees East, by the southern hne of Lot No. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Raila Villa Sprtngs Terrace as recorded in the Cumberland COWIty Recorder's Office in Plan Book 2, Page 42. HAVING THEREON ERECfED A RESlDEZITIAL DWELLING KNOWN AS 112,. FERNWOOD AVENUE, CAMP HIlL, PA 17011. BEING THE SAME PREMISES WHICH Shawn M. Bowers and Usa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROP- ERlY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251.