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Home My WebLink About01-03335 . FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, 01 -34 6.S CIVIL ACTION - LAW CRAIG A. BRUNGARD ACTION OF MORTGAGE FORECLOSURE Defendant TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTlNGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and ftling 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 jndgment 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 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 A VISa LE RAN DEMANDADO A USTED EN LA CORTE, SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSoLUTAMENTE NECESSARlo QUE USTED RESPoNDA DENTRo DE 20 DIAS DESPUES DE SER SERVIDo CON ESTA DEMANDA Y A VISa, PARA DEFENDERSE ES NECESSARIa QUE USTED, 0 SU ABoGADo, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER oBJECCIoN CONTRA LAS QUEJAS EN ESTA DEMANDA, RECUERDE: SI USTED NO REPoNDE A ESTA DEMANDA, SE PUEDE PRoSEGUIR CON EL PRoCESo SIN SU 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. paR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERo, PRoPIEDAD U oTRoS DERECHoS IMPORTANTES, LLEVE ESTA DEMANDA A UN ABoGADo IMMEDIATEAMENTE, SI NO CaNaCE 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 7 ">1''i'6~ , ry" - ~~~ ~c' FEDERAL NATIONAL MORTGAGE ASSOCIATION, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs, CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE CRAIG A. BRUNGARD, Defendant 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 ofthe 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 1719 North Front Street Harrisburg, P A 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff --"t';!"EdlJ0~ ,~ ~', "<.,'T'l"" - ,~- ., " Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW t> /- .3 33 J' C;..:.J r ~ FEDERAL NATIONAL MORTGAGE ASSOCIATION, vs. : ACTION OF MORTGAGE FORECLOSURE CRAlG A. BRUNGARD, Defendant COMPLAINT IN MORTGAGE FORECLOSURE 1, Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION, is a corporation originated under an Act of Congress and existing pursuant to the Federal National Mortgage Association Charter Act, acting through its servicing agent, Fleet Mortgage Corp., with an address of P.O. Box 1169, Milwaukee, Wisconsin 53224. 2. Defendant, CRAlG A. BRUNGARD, is an adult individual, whose last known address is 1015 CHIPPENHAM ROAD MECHANICSBURG, PENNSYLVANIA 17055. 3. On or about, Jillle 25, 1993, the said Defendant executed and delivered a Mortgage Note in the sum of $120,000.00 payable to MELLON BANK, N.A., which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the 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 COilllty and Commonwealth in Mortgage Book 1145, Page 727 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MELLON MORTGAGE COMPANY and was recorded in the aforesaid COilllty in Book 506, Page 918. The Mortgage was subsequently assigned to FLEET REAL ESTATE FUNDING CORP. and was recorded in the aforesaid County in Book 493, Page 1093. The Mortgage was subsequently assigned to FEDERAL NATIONAL MORTGAGE ASSOCIATION and recorded in the aforesaid COilllty in Mortgage Book 609, Page 1131. The Said Mortgage and Assignments are incorporated herein by reference. '~"j;""W'~ ~.., e,,'~ ,~,_ ~ , - "~~~ 5. The land subject to the Mortgage is: 1015 CHIPPENHAM ROAD, MECHANICSBURG, PENNSYLVANIA 17055 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 February 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRlNClP AL BALANCE $74,305,94 Interest at $13.48 per day From 01/01/2001 To 06/01/2001 (based on contract rate of 6.625%) $2,035.48 Accumulated Late Charges $0.00 Late Charges $52.68 From 02/01/2001 to 06/01/2001 $263.39 Escrow Credit $554.50 Attorney's Fee at 5% of Principal Balance TOTAL $3,715.30 $79,766,21 **Together with interest at the per diejIl 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. 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 original principal balance exceeds $50,000,00. '^'f""~""" ,--.~ 7"" < . _ ",~ . . . 10. Defendant is not a member of the Armed Forces ofthe United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended, 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 6,625% ($13.48 per diem), together with other charges and costs including escrow advances incidental thereto to the date of the property within described. PURCELL, Leon P. Hall , Esquire Attorney for Plaintiff LD, # 15700 1719 N. Front Street Harrisburg, P A 17102 (717-234-4178) By: "D_,_"P'"' - ","3""'"'" , 1 ,~ ,,'f ~'- ~~ ~ Fmc40373 (1696x2200x2 tiff) [42] "~r~l~.'l';~'-""''''.~''''''''-'-IT''''ii<-mtr ..,~ - ~ ~: :,. ...'..~. ~~,8-:' .'~i" I,: NOtE ...-A - -- I!EtUI~11055 ftiIlMllUtOUNINIUISKI",WltNT ""hn ~ ...t.,'.. ..,:."i v,.,. -~I;' E Yhl\)Jt 'A" " Fmc40373 (1696x2200x2 tiff) [44J ',''''', '"...,.....,.".,.,'.,.,~.:z, . '.""^'~"-"'""'-''''~'-~"''''1'''''. !', ~.. .;'i'r' '.,' !',' . ,"'(.L ....'. ""'~I!!'~~,;~ "~11ONS0I'~" ': mtBNO'J'S · . . .' . ........~ '!~,~j-,.. : i't~ dI-.........-__ M'~"").- kl\lIl.J'......-HY ~ t......n "'1100"""'" P.t+ ~~i 'd .;::~.~~....&1t~....t~___",.."",--,~"'____dr.kNowU.~,:AA~,~'.!'" '~" . . .,........illol.I$_"""'"'~.IllocWl.I.........-..,.lI;U__...l'dY..____-AfQij~<-i{.~,~~t}" ".1,j'.~ ~.Uilt""''''''-*'''''''''lkMB, .........,........................NoUHJol.......u~.~'~.-:~t~ . '_ ",...~."nlk__~__,lf:'"'tIII!f"'~~PI.u.,u..__-.l"""Ilt."-. . '. ~~<ii!j; . ~'n' (_. ~i~r~. , . .................~.......,....,..._~~fll.llfIMW-...lUC....-r~~~1 l~l , _......._...__.._.............__...'1>"........:lfi.>!'oi":m, o~l . .................................-)II*.....,.w. ~, '~llilIC<I_l'IMIt ." filj '''....i;..__~....._..__.............._....~~.~'!;1l . .....~...~_...,...DMI~~~4aW..._...~~ ~)~ .................-M__IrI...........,.................I__mll.s.....~~J. .. ~'"::, ;;,!~~-::-~V~1................1fll.....~1...1I.,.._.~t_......,'~ ..::.r~.i~ ~\'~" .......,................~............___ll......_...,_...............,.,.. ~:.~~ ~.,::' :IiI....MlIi:_..........,t-...~........___'-._..............-.-~_~~ '~i~ .......'................,.........................--.....ln~~..rI.n....~loJ ,,';&;- .........,.~.u.nwr.tJdI..~_..........."t~If......tJ~..w....l\w.-al ,.~ ....,.....~~ ' , ;.:,~.~' lrt..l.ir____iWo~~fhw.............uc-.~...........,.~trJul)l,-u...~.t,.. . :-/-' _.~Il...'"'-_"""'. "'_.', .,,~.....u..wItWIl~___....a:Jlff,~.-.~_~ '1,1, ........~IU_-'w.IW\e"'M'lIwM_........lN~.,t.IIit.,.ma.t.a...._m'-'<<"~ .-. ~ .........~IV.~~w!lhMatilAthw..u.....~..._a.--. .'~' .:~ . "..:-; ~;.. -. ~';" .......,. ;;:~r.; . ~,.QA!ID(J)~~~9:''l'Dmmt.u1OtIU. . ,1'- ;~: i;\~ ,;.~~ 1. ',,'; .,.. . ., ,.,.~~! , 1 !~~ .,~ "~I r.. .':;:~' ,.t~'A~; ... " '~:i ,f',i~ , '; '.~e,,, ., " '<, <'...-r:!~.-,~ ,.'~ ,,--, ~ Fmc40373 (1696x2800x2 tiff) [16] , , ._~.....v~__..".,.. ........,,_. ...."._. . ALL THAT CERTAIzr-'ot of l.ancl situate in Ha~~n"TownBnfp, Cumberland county. Pelulsylvania, being Lot #212, _ingswood, phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a'point on the West side of Cbippenham Road, said point aLso being a distance of One Hundred Twenty-Five feet North (L25.00') of the intersection of the North side of Dorset Drive and the West side of Chippenham Roa~ thence by the line of Lot No. 198 South Eighty-Two degrees Fifty-Three minutes Twenty-Two seconds West (5 82.53'22" W) a distance of One Hundred TweLve and One ' One-Hundredths feet (112.01') to a point at Line of Lot No_ 199, thence by same North'Twenty-Eight degrees Fifty-One minutes Thirty-Five seconds West (1'128.51'35" W) a distance of Ninety-Five and Thirty-Four One-Hundredths feet (95.34') to a point at Line of Lot No. 211, thence by ssme North Sixty-Six degrees Twenty-Eight minutes Thirty-One seconds East (N 66.28'31" E) a distance of One Hundred Forty-Two snd Ninety-Seven One-Hundredths feet (142.97') to a' point on the West side of Chippenham Road; thence by same and a 'curve to the right heving a radius of Two Hundred Fifty feet (250.00') an arc length of Seventy-One and Fifty-Eight One-Hundredths feet (71.581) to a point; thence br pame South Seven degrees Seven minutee Fifteen seconds East (5 07.07 15" E) a distance of Fifty-Eight and Thirty-Five One-Hundredths feet (58.35') to the pLace of Beginning. .. " CONTAINING 14.246.40 square' feet. and being known and numbered as 1015 Chippenham Road, Mechanicsburq, Pennsylvania. ~.... BEING the 'same premises which pamay Development Company, Inc.. >' by its deed dated May 22, 1991 and reco~ded in Cumberland County Deed Book D, Volume 35, Page 267, granted and conveyed unto Craig A.. Brungard. - ........:.....;~~~.~,.~ .,,~ '?.I)::-g'~t.>'i : '~~:;,~~11.~:~:;i.~~ftl .l't'..".::;"'l!:.,..~,~,.<;..)"" : .:'A.$"'if~' ,,:~"'-:.~ ..~.!; .}:;;.,..~:, 'I . , .< /' XljP'<' - ". < '... :.. ~.~\;~::;~~~f;;~ .,' . ... "10.;,. ..../,.... . I} , ',.'/t..-.'.".;;:;-.......- ..' ':,,': ",: (,>;'RLA;IOv~:J \, ..' ...."... .~;':,;1..;- of PennSylvanil } 55 .: )'.i~'~1 of CumOOflond ..; ~!t',.:,:~ in the offiOO for the recordJng of DNdra ....~..C ,-'.'.dll""~ r1ondCounJV"I!I'", ,,' . ";:~~\I.lr.':: __J.eLJ :';'.,:.m\'h~~ q!; S..,'F'''''<, ,"'this ~~ ;;.~ 8OnK1145 PAGE 733 Ex Vll~-t "e; ''>,'''''IV,,''''''''''' ~.~, ~ ~,__ <, ), IT f ~ r' COMPANY NAME: FlEEr M:RlG'(E crnP. l'CTIJ'G bIS'l\BER\lICIN:;!laNI' KR FEI:EH\L N'a'ICN'J. M:RlGIJ:.E A9:l:CIATICN VERIFICATION . I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. Dated M\Y 30, 2001 By KAR ORLANDO Title VICE PRESIDENT ,,,,- ,,~r,.~" , , _" 0, ~ , ~ <, "' , , .,," '" = ~,' SHERIFF'S RETURN - REGULAR CASE NO: 2001-03335 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS BRUNGARD CRAIG A CPL. MICHEAL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, tne within COMPLAINT - MORT FORE was served upon BRUNGARD CRAIG A the DEFENDANT , at 0018:37 HOURS, on the 5th day of June , 2001 at 1015 CHIPPENHAM ROAD MECHANICSBURG, PA 17055 CRAIG A. BRUNGARD by handing to a true and attested copy of COMPLAINT - MORT FORE NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Aff idavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 Sworn and Subscribed to before me this .:2?~ day of C)~, .;;.0." / A.D. CJ.r ~ t2 '/h, 'Ph "9ry- rothonotary , ;'~~~ ~. ,~" "'""l!l, So Answers: ~~..e.'~~~ R. Thomas Kline 06/06/2001 PURCE~~:;(~~ - Dep ty eriff . FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 CRAIG A. BRUNGARD 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 $13.48 from 1/1/01 to 6/1/01) Late charges ($52.68 per month to 6/01) Escrow Credit 5% Attorney's Commission $74,305.94 $ 2,035.48 $ 263.39 $ 554.50 $ 3,715.30 TOTAL $79,766.21** ** 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. PURC=, KRU=/ . By' .~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKF\DOCS\CUMBERLA\BRUN.P :,9f( _ ,1 , ,< ~ ',>', .1', '_ "~'"', , " ,.. ,,~ ,,~: > .... . FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on AUGUST 20, 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. Haller PA I.D. #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 ""*R~ -,,~ . ~"..-' .-".' -, ;,,-~" . ,,",'_ ,~"_'" '0"".-- _ . FEDERAL NATIONAL MORTGAGE f ASSOCIATION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : NO. 2001-03335 CRAIG A. BRUNGARD Defendant : CIVIL ACTION LAW : IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: August 20, 2001 TO: CRAIG A. BRUNGARD 1015 CHIPPENHAM ROAD MECHANICSBURG, PA 17055 TillS 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 YOV 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, PAl 70 I3 717-249-3166 OR 800-990-9108 By LEON p, HALL I.D, # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 --,~"'*W , " ~ , , 1'-- .-, Cl ,ny",,,"', ,~"' h "" '" " ,coY" , 'f('lIiirliillll111 !i . 'J lIiil"'liii "~,, ;. 10 (:J .(q. ~ -0 li- i 0 r ~ 0 (') c (') ~ c.v C ~'h ? ~ \;> U nl:]G~ (/) fT'I 6"- p: __ rj. '"0 .-'~'i ;g 3 ~ ~(E~ , f Cf) .{.:o. N :~3Ej ~ li' ~l:: ~:~;? 1 :.--\...,> j>""': '"0 ~~ ZI...i :t: ,;~~~ >~i :."", cSf'n =< ':::> ~ U1 -< :-;:~ , " .=L, . ""~TU:!l,mliil"j1w"~",,~!il)ll, ~~___J ~1~_~~>!'''~,"''';'}''''''1'f'' '-"~'[0f';-;P;:'-0'''''_t'j~*''Fl~if'j~:i!'!.1,,:::\!#$M~f,f~,,~~~p-l1Wj!'J'liof'i~~_~~!_""".~; f FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 ~ -/::( "Jonl the against you in I the above- $79,766.21 and for the sale and foreclosure of your property located at: 1015 Chippenham Road, Mechanicsburg, PA 17055 Dated: q !t:1../rv I I Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receiv~ this Notice pursuant to PA R.C.P. No. 236: Craig A. Brungard 1015 Chippenham Road Mechanicsburg, PA 17055 K:IMKFIDOCSICUMBERLA\BRUN.N "*"""~"""""'!'~ ~- "fl 't"-_~- .., FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 CRAIG A. BRUNGARD 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 $13.48 from 1/1/01 to 6/1/01) Late charges ($52.68 per month to 6/01) Escrow Credit 5% Attorney's Commission $74,305.94 $ 2,035.48 $ 263.39 $ 554.50 $ 3.715.30 TOTAL $79,766.21** ** 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. ~ PURCELL, KR,UUGG & & HA HALL~Z-'/ By' ~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 K:\MKFIDOCS\CUMBERLAIBRUN.P ":(;,~~ - r:'1_" - ''= -, ",~" --, '~, ' , I ~ , :r .' . !N'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2001 03335 CRAIG A. BRUNGARD, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $79,766.21 p/ Interest at $13.48 per diem to sale date $ 2,534.24 Late charges at $52.68 per month to sale date $ 316.08 Escrow Deficit $ 2,000.00 TOTAL $84,625.53* FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF VS. *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 .case. Date: September 10, 2001 Attorney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Leon PA I.D. 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 1015 CHIPPENHAM ROAD, MECHANICSBURG, PA 17055. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:\MKFlDOCS\GUMBERLA\BRUN.W \,,,~-,i<, ,_~". . .,r , ALL THAT CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #212, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of One Hundred Twenty-Five feet North (125.00') of the intersection of the North side of Dorset Drive and the West aide of Chippenham Road; thence by the line of Lot No. 198 South Eighty-Two degrees Fifty-Three minutes Twenty-Two seconds West (5 82053'22" W) a distance of One Hundred Twelve and One One-Hundredths feet (112.01') to a point at line of Lot No. 199;. thence by same North Twenty-Eight degrees Fifty-One minutes Thirty-Five seconds West (N 28051'35" W) a distance of Ninety-Five and Thirty-Four One-Hundredths feet (95.34') to a point at line of Lot No. 211; thence by same North Sixty-Six degrees Twenty-Eight minutes Thirty-One seconds East (N 66028'31" E) a distance of One Hundred Forty-Two and Ninety-Seven One-Hundredths ~eet (142.97') to a point on the-West side of Chippenham Ro~d; thence by same and a curve to the right having a radius of Two Hundred Fifty feet (250.00') an arc length of Seventy-One and Fifty-Eight One-Hundredths feet (71. 58') to a point; thence by same South Seven degrees Seven minutee Fifteen seconds East (S 07007'15" E) a distance of Fifty-Eight and Thirty-rive One-Hundredths feet (58.35') to the place of Beginning. CONTAINING 14,246.40 square feet. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1015 CHIPPENHAM ROAD, MECHANICSBURG, PA. BEING THE SAME PREMISES WHICH pamay Development Co., Inc. by deed dated 5/22/91 and recorded 5/30/91 in Deed Book D-35, page 267 granted and conveyed unto Craig A. Brungard. TO BE SOLD AS THE PROPERTY OF CRAIG A. BRUNGARD ON JUDGMENT NO. 2001 03335. ASSESSMENT: 10-16-1056-162 ';;~-J ~ ,~_ ~, "~ ~ ~, ~" " ~__ ',_ 0_'" . ,~ -,," __ '"e~" > ,__",,' "__~> ' " -, ,- ."'"",,,",-, , ""'- 0 C:J 0 ....... ~ C "'f'l () '<l. () ~ ~ s:: U) ~-j ~ .~ tl if( ~ uG'> r'1 -_,;'"T! ~ '>- -:'0 .-{l 6"- mfr' "" .';r= -'/01; ~g8 d 8 ~ d 8 S b g ~~'~~ f'V :~~~ f' -<~ ~~~; ." ....... w I I ( w,,li;,. ....... ~ -u ""0 :AJ ~1'n .... ~ ~ );., c:: --J> '(--. r z :::> ":0 t, (- ~ " " =< (11 "< i) ~ " ~ % r "- " " .~ , '"' , , I i I " i1 " " fi ii !. i1 i'~1 i>'f,~"'r""!N"0,;.,'t-,-i*"~!~\'"!ijWlMI.~m~'%~ml~f:'w.'iB\;'Wji'~'~,"'#iijjt'f~~~} ~,,=->ilij.l-~-fi;~~"!;~'F i-~! .-' "' " ; - " FEDERAL NATIONAL MORTGAGE . ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 1015 CHIPPENHAM ROAD, MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s): Craig A. Brungard 1015 Chippenham Road Mechanicsburg, PA 17055 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) : Associates Consumer Discount Company 3871 Union Deposit Road Harrisburg, PA 17110 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... Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 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 made subject to the penalties of 18 PA C.S. Section 4904 relatin 0 unsworn falsification to authorities. DATE: September 10, 2001 >F>7,:t;'re.n!!L "-- _1_"",, , -<-c" c' ~",- -", Leon P. Haller PA I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ,'_.;J_ =-. ...,.-,~t N .~,-" <~ ."'""'.~-i""m"ON ""__..A~ __ , _~"'~~, >~.,~, ,.' ..... (') C1 C) C ,', -ot13 -:/') in!''''' j." T' ~~I~~: -0 c: , , ;11 ~~~,;' j',) , , c::.' I '. ; f~) ;"'-'..-" -0 ~:::! ~C~ -:!1" ,;:::::: -n :Zci -~ ('5 ":;;'" >c": w (.5 rn Z --< => )> =< :0 (Jl -< , " ,:It!i!!ijl'!l!lh> __1'-'ilI1-~m!fI~~j~m~~.i'1Ji1i!))C'-""',~,;~-j,yo;;j!.ii":TN.!.:~,f,'(jl"'''d''''h"":i'11'BfRiin-'il_<-~0~V<i1";'''''',!;"1''''';'!"-_:I''11'"6'"i:A;.{;;':SW,'jI'!I!I\"':fi!!~~~ FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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: 1015 CHIPPENHAM ROAD MECHANICSBURG 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 03335 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property CRAIG A. BRUNGARD K:\MKF\DOCS\CUMBERLA\BRUN.NOS -~+"~ . , , .' ~ !." ", , , 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 a.nd 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 te~ (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 r-ights. 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 agalnst 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. ,~7'l!""".. ' '" , ._ _ '-" ",;>,,_, '''< ~~, - C" 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 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 ~'~r" __, . , "" , ,_;:,~~_, r' " "'""," , . ALL THAT CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #212, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of One Hundred Twenty-Five feet North (125.00') of the intersection of the North side of Dorset Drive and the West side of Chippenham Road; thence by the line of Lot No. 198 South Eighty-Two degreE>i3 Fifty-Three minutes Twenty-Two seconds West (S 82053'22" W) a distance of One Hundred Twelve ~nd One One-Hundredths feet (112.01') to a point at line of Lot No. 199; thence by same North Twenty-Eight degrees Fifty-One minutes Thirty-Five seconds West (N 28051'35" W) a distance of Ninety-Five and Thirty-Four One-Hundredths feet (95.34') to a point at line of Lot No. 211; thence by same North Sixty-Six degrees Twenty-Eight minutes Thirty-One seconds East (N 66028'31" E) a distance of One Hundred Forty-Two and Ninety-Seven One-Hundredths feet (142.97') to a point on ths.West side of Chippenham Road; thence by same and a curve to the right having a radius of Two Hundred Fifty feet (250.00') an arc length of Seventy-One and Fifty-Eight One-Hundredths feet (71.58') to a point; thence by same South Seven degrees Seven minutes Fifteen seconds East (5 07007'15" E) a distance of Fifty-Eight and Thirty-Five One-Hundredths feet (58.35') to the place of Beginning. CONTAINING 14,246.40 square feet. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1015 CHIPPENHAM ROAD, MECHANICSBURG, PA. BEING THE SAME PREMISES WHICH pamay Development Co., Inc. by deed dated 5/22/91 and recorded 5/30/91 in Deed Book D-35, page 267 granted and conveyed unto Craig A. Brungard. TO BE SOLD AS THE PROPERTY OF CRAIG A. BRUNGARD ON JUDGMENT NO. 2001 03335. ASSESSMENT: 10-16-1056-162 ;. "~. ~~-' - , ". ~.."," ,., , ,~ >" , ,~ (') ,'~ () C ,1 ~:: U) -r; ,-,- 1"'1""1 rntl"~ 'U , Z:T' ,_. Ze-' r" ~:T~ l'v '......,1 ~L, """0 '~..:.i'() .t' C _Jf. '~J6 Z 0 ):.~ C 'Y;) Grn Z .".f :< :::::> ~- :J;J 01 '-<: 0$ ,',- -~"""'. ",.i:J,,~~_&:l~~~~~fH~i;,;r;*-\jW,;':"-;;;Y--t':Hr;o*,W-ii"~'!i.,~j~~~Pfl~j>'ji~~~~~ FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. NO. 2001-3335-CIVIL CRAIG A. BRUNGARD CIVIL ACTION - LAW DEFENDANT IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY: Kindly Settle and Discontinue the above matter of record. PURCELL, KRUG & HALLER By: ~- Leon P. Haller ID #15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: November 13. 2001 ,-'J !,. [:1 " i; '-'I ;-,,; !-: " ;',; , ' i>~ 1"::1 ["j ~::;1 I'c! I";" ---" ,,',..' ,-"'-' ." ,~," I': " " '" ,,",,--ie'-',' .,J C '.~,'" .'" '-'" ^'" ~~ (') 0 0 C -'n s: ~ "'Urn Cd ~~;:TI mrr1 e_ 2:"T: .~ '.l~t~} zc; .- CIl .c, -<..L_ c'O ~C;- "0 '-,--'"Tf ~C) ::g. ~~~ "=0 ~ 01 >c -""i Z "" 3S ::< C7i -< - '~'~C:::i\'~\'ZJ:'-.'iiY' ,~ ., < ~~:lI,!;H!___, "'l,J!~-!~~~r~ ". , .,"," __,__ c{~ _mJl!M~~IM!lJ~?:; , . " Federal National Mortgage Association VS Craig A. Brungard In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3335 Civil Term R, Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney'Leon P. Haller. Sheriffs Costs: Docketing 'Surcharge 'Posting Handbills Law Library Prothonotary Share of Bills Mileage , Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 20.00 15.00 .50 1.00 25.66 18.20 15.00 15.00 2.57 13.64 363.05 175.80 $695.42 paid by attorney Sworn and subscribed to before me This .2'i~ day of ~"LP~ k.J 2001,A.D.QL'f"-'J/J JtM;'-u,~- Prothonotary -,<r,~"""...!,,, 0 _.~, , "' d_ " so~ ~ -,~~~ R. Thomas Kline, Sheriff BY (~ool filSw5:lA Re . Estat Deputy 1,')'0. UL 3~"7?6 ~, II'J-?>o 1__' FEDERAL NATIONAL MORTGAGE , ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 1015 CHIPPENHAM ROAD, MECHANICSBURG, PA 17055: 1. Name and address of the Owner(s) or Reputed Owner(s) Craig A. Brungard 1015 Chippenham Road Mechanicsburg, PA 17055 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) : Associates Consumer Discount Company 3871 Union Deposit Road Harrisburg, PA 17110 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 ,"'" 'C ,; '~.,~, ^'" . , ~-, ' -~ , UNKNOWN 7. Name and address of Plaintiff has knowledge who has may be affected by the sale: every other person of whom the any interest in the property which TENANTS rF ANY... 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 made subject to the penalties of 18 PA C.S. Section 4904 relatin 0 unsworn falsification to authorities. ~ Le<5D P. Haller PA r.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 10, 2001 -;~_~-"""'!l'1~JI"<'_~ ..... ,~ err-' ;"- ,. f"," , " FEDERAL NATIONAL MORTGAGE ASSOCIATION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF VS. CRAIG A. BRUNGARD, DEFENDANT CIVIL ACTION - LAW NO. 2001 03335 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 I 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: 1015 CHIPPENHAM ROAD MECHANICSBURG 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 03335 is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property CRAIG A. BRUNGARD K:\MKF\DOCS\CUMBERLAIBRUN.NOS ~jl., ,,' ". ,- ~ -~ \'0",0',"_.." __'' '_"_'___~'" ." A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive 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 te~ (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. 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 agalnst you. You may also flle an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you, ^li''1tl_", e_ """"n_' "'_. ~"Y', "'"'~~~_"., _""_'_, ,_ . , . 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 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 i\,,?~ ,,,<--"-;-','-'F_'''' . , p '. ALL 'IHl\T CERTAIN lot of land situate in Hampden Township, Cumberland County, Pennsylvania, being Lot #212, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55, Page 93, more particularly bounded and described' as follows, to wit: BEGINNING at a point on the West side of Chippenham Road, said point also being a distance of One Hundred Twenty-Five feet North (125.00') of the intersection of the North side of Dorset DriVe and the West side of Chippenham Road; thence by the line of Lot No. 198 South' Eighty~Two degre&s Fifty-Three minutes Twenty-Two seconds West (S 82053'22" W) a distance of One Hundred Twelve ;lnd One One-Hundredths feet (112,01') to a point at line of Lot No. 199, thence by same North Twenty-Eight degrees Fifty-One minutes Thirty-Five seconds Wsst (N 28051'35" W) a distance of Ninety-Five and Thirty-Four One-Hundredths feet (95.34' 1 to a point at line of Lot No., 211, thence by Same North Sixty-Six degrees Twenty-Eight minutes Thirty-One seconds East (N 66028'31" E) a distance of One Hundred Forty-Two and Ninety-Seven One-Hundredths.feet (142.97' 1 to a point on the.West side of Chippenham Road, thence by same and a curve to the right having a radius of Two Hundred Fifty feet (250.00') an arc length of Seventy-One and Fifty-Eight One-Hundredths feet (71.58') to a point, thence by same South Seven degrees Seven minutes Fifteen seconds East (5 07007'15" E) a distance of Fifty-Eight and Thirty-Five One-Hundredths feet (58.35') to the place of Beginning. CONTAINING 14,246.40 square feet. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1015 CHIPPENHAM ROAD, MECHANICSBURG, PAc BEING THE SAME PREMISES WHICH Pamay Development Co., Inc. by deed dated 5/22/91 and recorded 5/30/91 in Deed Book D-35, page 267 granted and conveyed unto Craig A. Brungard. TO BE SOLD AS THE PROPERTY OF CRAIG A. BRUNGA.RD ON JUDGMENT NO. 2001 03335. ASSESSMENT: 10-16-1056-162 "'\"f_p "". ~.., ,", , .~ ,- '-" '~-, , '" WRIT OFE~~CUTrON and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA} COUNTY OF CUMBERLAND) NO, 01-",,, CIVIL ~-TEBM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Federal National Mortgage Association . PLAINTIFF(S) from Craig A. Brungard, 1015 Chippenham Road, Mechanicsburg, PA 17055 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 nomy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defehdant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subjectto attachment is found inthe possession of anyone other than a named garnishee, you are directed to nomy him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $79,766.21 at $13.48 per dlem to sale date Interest $? ",4 ?4 Atty's Comm % L.L. Due Prothy $.50 $1.00 Other Costs Late charges at $52.68 per month to Sale Date $316.08 -- Escrow Deficit $2,000. Atty Paid Plaintiff Paid $108.06 Pate: September 12, 2001 Curtis R. Long Prothonotary, Civil Division ---J>y: AQ0' 0 P ~j)/?-N 6;- Deputy REQUESTING PARTY: Name Address: Leon P. Haller, Esq. 1719 North Front Street Harrisburg, PA 17102 Attorney for: Plaintiff Telephone: 717-234-4178 Supreme Court 10 No. 15700 ;<<~,,!\I',~~~~,. -~l ,-" , '~~~Il" (il ~ A1H,~~= ~ .. ~ ''"~-_ ~""~4~, ~.- ~'_~' ._~,~.~ '~.>~-"~~~ REAL ESTATE SALE No. 'YS On September 18,2001, the sh~riff1evied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, known and numbered as 1015 Chippenham Rd., Mechll1).icsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. ., c;;:a C\til c:::::iI Gi> G;;Q Date: September 18, 2001 By: L)~ SMt~ Real Estate Deputy "",\'j~ '... 1'- , ~-, '''\ ,.' ~ ('\ \J\ '.' ,,\,\~1) ".\ t.n ~\ '" \'~ II" .\\\,) \"\" ,'. .\1 .-\.~I.) \.', 3.~'\- I' ..~,_\:~\ :-'~ '___, "\ , l< 1'\':'\\' '!,;\ t - .~ , '!.'l!! ~,_~~~, _" 1111':;@-"W!W)ill'I~~~~~~~~!O-B'f'i'l'~~:-"~",:.",r,c'_"';-"'::e'~'_\';'1"'';:'' [!':'iL,_:>:,r;-;C;:_"",,'-g':i":!tWfOP"~':c'"-i;,-"'~'!,T"--;0>~--!"CC''''~'!~,;~''r.~r.''''II!~t:!!!;\j~~'' . REAL ESTATE SALE No, 4S Writ No.2001-3335 CivllTerm Federal Nat,jonal Mortgage Assoclatfon vs Craig A. Brungard . .. Ally: Leon P. Haller DESCRIPTION ALL- THA..T CERTAfN lct. of l<Inci situate in Hampden 'lbWJ1$ip, Cumberlimd County, Penn::ylvania, hdnlJ 1.<l[ #212, Kjng,~wtmd, Phase II, ....s reoordcd in, Cumberland Count~ Plan Book 55, '::?,jge, 93, . 1I111l'e particularly' 'bounded and descdbcd a~ follows, to wit: BEGI~NlNG at a point on tne West side of : Chippcnbam Road, said point IIlso bciog a ~&st.1nce of One Hundred Twenty-five feet Nortb r (t25JJO') of the [ntc~ti()n of tbe North ~tde of ::,:D_ Drive and the West side of Chippenham !:Road; tbence by \he line of Lot No. 198. South Eighty.two.4cgrees Fifly.Three minutes T'<'!:ettly- Two seconds West (8 82053'22" W).a distance of One Himdrcd Twevcl and One One-Hundredths fea (lJ2.01') to a yoinl at line of Lot No, 199; thence by smne North 'TWenty-Eight degrees Fifty- One minules Thirty-Five ~oc{Jnds We-st (N 2S~5t'3S" W) 11 distance (If,,Ninety-Rw atJo 'l11irtv-Four.Onc-Hundredws feet (9534') to .a pointailine olLntNo.2il; thence by sameNrn:Ui . Sixty-Six degrees Twemy-Eight minutes Thirty, , One seconds East (N 66""28'31"E) <! distance of One Hundred Forty-Two ,11ld Ninety-Seven One- Hundredths feet (142.97') to a point on the West side of Chippenbam Road; thence by same and a curve to the right h3"ving a radb$ ofTv.'Q Hundred Flitv fee! (25DJJI)') an arc length of Seventy-One aria'flfty-Eight One-Hundtedth5 feet (1J~SE') to a point; fhencc by same South Seven degrees Seven minutes Hfteell Bcconds East (8 01'07' 15" E) a distance of Fil1y-Eight and 'Thirty-Flve Onc- HuJdredths feet (5S35') lo Ute t11w;:e of BC-:g!nnjllg. ., CONTAINING 14,'2:46,40 square feet. f:f!WlNG thereon creded a resiclenti,a1 dwelling kJJow:.n as 1015 "Chippenhain Road, MecbanicsbtLrg,PA. BEGJN THE SAME premises whicb Pamay . DevClopment Co., Inc. by deed dated 5122191 and recorded 5JjO/9t In Deed Book D-35, page 257 gral!ted. and conveyed unto CtaigA. Brungard, 1b. BE SOLD as the property of Craig A. Brungard on Judgment NQ.1OOt 03335. ASSESSMENT,I().Ifi.IIl5(H62, ).., ......... ~ " ,. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct 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 Pennsyivania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and 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 23th and 30th day(s} of October 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'tmpany and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Daup, 'n i Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION \. COpy SALE #45 Notarial Seal Terry L, Russell, NotalY Public Harrisburg, Dauphin County My COmmission Expires June 6. 2002 NOTARY PUBLIC M mile. Pennsylvania ASSOCIation 01 Notaries a , My commission expires June 6, 2002 ;' CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 ~ Statement of Advertising Costs To THE PATRIOT-NEWS CO" Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 174,30 1.50 175.80 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.........,.....,."".,.,........,.,.,.,..",....,.,.,.......,.,.,., '. ~, ...,., " ',' ~~ ~.' .=. ", 1":11. <"-<, ,- ,-~. -~'!,--:.,-:,~,-. ,'~ , '~,!<-r ' REAL ESTATE SALE NO. 46 Writ No. 200 1-3335 Civil Federal National Mortgage Association vs. Craig A. Brungard Atly" Leon P. Haller ALL THAT CERTAIN lot of land situate in Hampden Township. Cumberland County, Pennsylvania, being Lot #212, Kingswood, Phase II, as recorded in Cumberland County Plan Book 55. Page 93. more particularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chlppenham Road. said point also being a distance of One Hundred Twenty-Five feet Nortb (125,00') of the intersection of the North side of Dorset Drive and the West side of Chippenham Road; thence by the Une of Lot No. 198 South Eighty-Two degrees Flfty- Three mfnutes lWenty- 'IWo seconds West (S 820 53' 22" W) a distance of One Hundred Twelve and One One-Hundredths feet (112.01') to a point at Une of Lot No. 199; thence by same North Twenty-Eight de- grees F'Ifty-one mtmutes ThIrty-Five seconds West (N 280 51' 35" W) a distance of Ninety-Five and Thirty-Four One-Hundredths feet (95,34') to a point at Une of Lot No, 211; thence by same North Sixty-Six degrees Twenty-Eight minutes ThIrty-One seconds East IN 660 28' 31" E) a distance of One Hundred Forty-Two and Ninety-Seven One-Hundredths feet (142.97') to a point on the West side of Chlppen- ham Road; thence by same and a curve to the right haVing a radius of Two Hundred F1fty feet (250,00') an arc length of Seventy-One and Fifty-Eight One-Hundredths feet (71.58') to a point; thence by same South Seven degrees Seven :minutes Fifteen seconds East (S or 07' 15" E) a distance of Fifty-Eight and Thirty-Five One-Hundredths feet (58,35') to the place of J;legtnnlng, CONTAINING 14.246.40 square feet. HAVING 1HEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1015 CHlPPENHAM ROAD, ME- CHANICSBURG. PA. BEING THE SAME PREMISES WHICH pamay Development Co.. Inc. by deed dated 5/22/91 and recorded 5/30/91 in Deed Book D-35. page 267 granted and con- veyed unto Craig A. Brungard, TO BE SOLD AS THE PROP- ER1Y OF CRAIG A. BRUNGARD ON JUDGMENT NO, 2001 03335. ASSESSMENT: 10-18-1056-162. '~~ ..... .' ,. ~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No, 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the 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. R~- SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 NOr. LOIS E. SNYDER, NoIaIy Public CIrIIaIe Bom. Cumberland County My Commi88lon ExpiIVS Mareh 5, 2005 -'J;!!,!yJ -.,~ ,..,.. , I ~ . "0 '~1'!l" 7 ~